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2022.08.05_MGS_2022 - First Half
MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS DATE May 31, 2022 PROJECT 22075 ReportPadsite Inspection ATTN City of Denton Padsite No. 093 (Biltmore North 1) 215 East McKinney Street Operator: BKV Denton,Texas 76201 Location: ®City of Denton ❑ Denton ETJ Priority: ❑ High ❑ Moderate ® Low Modern Geosciences, LLC (Modern) is pleased to provide the attached Padsite Inspection Report documenting the results of our recent inspection and monitoring events at the above-referenced padsite. A general summary of findings is presented below with detailed results provided in the attached report. ■ Field Inspection Results: As part of the field inspection efforts, Modern evaluated the padsite concerning general ordinance or operational requirements set forth by the City. No operational or ordinance compliance issues were noted by Modern during our inspection efforts other than noted below: • Bare pipe/corrosion noted on Separators A through C. According to Operator representatives,all corrosion observations were addressed as of May 20,2022,thus the corrosion observations are no longer considered Action Items. Future verification suggested. ■ Near-Equipment Inspection Results: Our inspection efforts at this padsite included near- equipment monitoring using optical gas imaging(OGI)to identify leaks of methane and/or volatile organic compounds (VOCs) and radiation meters to identify equipment exhibiting naturally- occurring radioactive material (NORM)above applicable regulatory criteria. The accumulation of scale within equipment can cause elevated NORM levels requiring proper signage and equipment management. A summary of near-equipment findings is presented below with further detail in the attached report. Near Equipment Inspection Summary: Equipment Number Leaks* Unlabeled NORM** Labeled NORM** Wells 3 0 0 0 Separators 3 1 0 0 ASTs 0 0 0 0 Other 1 2 1 0 101 0 *OGI leaks identified exclude operational low bleed components(<6 scf/hr) **NORM exceeding 50 µR/hr All near-equipment inspection concerns (e.g., leaks) were communicated to the operators with a two-week period to address each. If the concerns were not addressed, these are included in the Action Items listed below. If items were addressed, this will be documented in the report. 5100 THOMPSON TERRACE,COLLEYVILLE TEXAS 76034 1 F 682.223.1593 1 P 682.223.1322 www.MODERNGEOSCIENCES.com �S, MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS ■ Action Items: If items are identified during our inspection that remain unresolved or require future confirmation, these will be listed as individual action items for the operator until the City has confirmed further action is not required. There are no outstanding Action Items as of the date of this report. ■ Inspection Data Trends (Leak and NORM Rate): Modern performed a review of inspection data across five(5) North Texas municipalities that use similar inspection methods and data acquisition to develop benchmarks concerning padsite and/or operator performance. This included inspection of over 2,600 wells and 8,000 pieces of supporting equipment. Implementation of these inspection programs resulted in an estimated 56%decrease in leaks. Using these data sets, Modern prepared the following benchmarks for general reference purposes concerning the Leak Rate (number of leaks divided by the number of wells) and NORM Rate (amount of equipment with NORM >50 µR/hr divided by number of wells). While each padsite is unique and will have operational and equipment differences, when normalized to a "per well" basis for tracking it provides a useful benchmark. Performance Leak Rate NORM Rate Good <0.5 <0.4 Moderate >_0.5 to<1.5 >_0.4 to<1.2 Poor >1.5 >1.2 The Leak Rate and NORM Rate for this padsite over time are presented below: Leak and NORM Rate 0.4 a r 0.3 0 0.2 z Y � 0.1 a J 0 2018 2019 2020 2021 2022 —4- Leak Rate NORM Rate ■ Next Inspection Event: The City of Denton completes periodic inspections at all padsites throughout the year. In addition to this, the City has asked Modern to perform supplemental inspections with high-resolution equipment based on proximity to sensitive property uses. Based on the current prioritization,this padsite is scheduled to be inspected again by Modern in the first half of 2024. 5100 THOMPSON TERRACE,COLLEYVILLE TEXAS 76034 1 F 682.223.1593 1 P 682.223.1322 www.MODERNGEOSCIENCES.com 4(--!Sl MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS CLOSING We appreciate the opportunity to provide our services to you. Should you require additional information or have any questions regarding this report, please contact the undersigned at 682.223.1322. Respect lly submitte , nneth .Tramm, PhD, G, CHMM Senior Program Manager MODERN GEOSCIENCES Texas Registered Geoscience Firm 50411 Texas Registered Engineering Firm F-16201 5100 THOMPSON TERRACE,COLLEYVILLE TEXAS 76034 1 E 682.223.1593 I P 682.223.1322 www.MODERNGEOSCIENCES.com <S MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS DATE May 31, 2022 PROJECT 22075 PADSITE INSPECTION REPORT Padsite No. 093— Biltmore North 1 PREPARED FOR City of Denton 215 East McKinney Street Denton,Texas 76201 PREPARED BY REVIEWED BY Zacha ondr GIT e eth S.kramm, PhD, PG, HMM PROJECT MANAGER SENIOR PROGRAM MANAGER 5100 THOMPSON TERRACE,COLLEYVILLE TEXAS 76034 F 682.223.1593 1 P 682.223.1322 0 2022 MODERN GEOSCIENCES.ALL RIGHTS RESERVED. www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Biltmore North 1 (#093) Operator: BKV ►nspection Date:03125122 ►nspectors:ZT, SB MODERN G E O S C I E N C E S TRUSTED ENVIRONMENTAL ADVISORS FIELD INSPECTION RESULTS: Pass Fail N/A General Inspection Checklist Items Item 1:Appropriate signage present at padsite entrance including operator name,site ® ❑ ❑ address,well names, 24 hr phone number, and no smoking. Comments: None Item 2: Appropriate signage present at padsite entrance and/or equipment including ® ❑ ❑ RRC/API numbers. Comments: None ® ❑ ❑ Item 3: Fencing present surrounding padsite and/or equipment. Comments: None ® ❑ ❑ Item 4: Site secured. Gates locked to control unauthorized access. Comments: None ® ❑ ❑ Item 5: Surface topography prevents areas with significant water collection. Comments: None ® ❑ ❑ Item 6:Surface free of stains or other signs of significant spills/releases. Comments: None ® ❑ ❑ Item 7: Padsite free of trash/waste debris. Comments: None ❑ ❑ ® Item 8: Lighting not directed toward adjacent property/roads (as applicable). Comments: None ® ❑ ❑ Item 9:All equipment painted with no bare pipe present. Comments: Bare pipe/corrosion noted (detailed in near-equipment summary). ❑ ❑ ❑ Item 10: Landscaping appears well maintained (as applicable). Comments: None ❑ ❑ ® Item 11: Lightning arrestors present at ASTs and in good condition (as applicable). Comments: Not applicable—tank battery not present. ❑ ❑ ® Item 12: Pipeline markers present at roads (as applicable). Comments: None Item 13: Tank battery and secondary containment appear to have integrity with no ❑ ❑ ® significant corrosion. Comments: Not applicable—tank battery not present. ❑ ❑ ® Item 14: Remote compressed air foam line (fire suppression) present. Comments: None ❑ ❑ ❑ Item 15:Access road accommodates 20' wide emergency vehicle requirements. Comments: None Item 16: Water/oil transfer points within secondary containment or have drip control ❑ ❑ ® accessory to minimize spillage during waste transfer. Comments: Not applicable—tank battery not present. ❑ ❑ ® Item 17:Tank battery has appropriate hazardous material signage. Comments: Not applicable—tank battery not present. ❑ ❑ ® Item 18: Ponded water(Pit) has fencing and access controls. Comments: Not applicable—ponded water not present. ® ❑ ❑ Item 19: Other Audio, Visual, or Olfactory concerns noted during the inspection. Comments: None PROJECT 22075 1 MAY 31,20221 PAGE 1 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Biltmore North 1 (#093) Operator: BKV ►nspection Date:03125122 ►nspectors:ZT, SB MODERN G E O S C I E N C E S TRUSTED ENVIRONMENTAL ADVISORS Constituent: Methane NORM At Equipment: 10,000 ppmv 1 50 µR/hr 2 Equipment: OGI Camera Radiation Meter Resolution: 3,000-10,000 ppmv 1 µR/hr Notes: 1-Utilizes the Interstate Natural Gas Association of America(INGAA) recommended leak definition within their December 4,2015 response to EPA Docket No. EPA-HQ-OAR-2010-0505 — "Oil and Natural Gas Sector: Emission Standards for New and Modified Sources," dated September 18,2015 (80 FIR 56593). Also represents 20%of the Lower Explosive Limit. A lower leak definition and additional inspection and reporting may be required at facilities subject to 40 CFR §60 Subpart OOOOa. Documented continuous low-bleed components (<6 scf/hr)and intermittent emissions from properly functioning pneumatic devices are not considered leaks for the purposes of this inspection. 2-The Texas Railroad Commission (RRC) regulates NORM under 16 TAC §4 (Environmental Protection, Subchapter F, Oil and Gas NORM). Subchapter F establishes the requirements for oil and gas NORM waste disposal for the purpose of protecting public health and the environment.NORM-contaminated equipment is defined in Subchapter F as"equipment that,at any accessible point,exhibits a minimum radiation exposure level greater than 50 µR/hr including background radiation level." When identified,the equipment suspected of being NORM-containing will be communicated to the City and operator(s)to allow further inspection and where appropriate compliance with RRC signage and management requirements. PROJECT 22075 1 MAY 31,20221 PAGE 2 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Biltmore North 1 (#093) Operator: BKV Inspection Date:03125122 Inspectors:ZT, SB MODERN G E O S C I E N C E S TRUSTED ENVIRONMENTAL ADVISORS NEAR EQUIPMENT INSPECTION RESULTS: Location ID: Leaks (OGI): NORM (IAR/hr; max): Date Reported': Date Addressed': Well A None <15 NA NA Well B None <15 NA NA Well C None <15 NA NA General Notes: No other concerns noted. 1-Reported to operator,•z—If reported to Modern by operator/City,•*NORM exceeding 50 µR/hr not labeled INSPECTION RESULTS - SEPARATORS Location ID: Leaks (OGI): NORM (IiR/hr; max): Date Reported': Date Addressed': Separator A None <15 NA NA Separator B None <15 NA NA Separator C Kim ray Valve <15 03/25/22 04/20/22 General Notes: Bare pipe/corrosion noted on Separators A through C.According to Operator representatives, all corrosion observations were addressed as of May 20, 2022, thus the corrosion observations are no longer considered Action Items. Future verification suggested. No other concerns noted. 1—Reported to operator;2—If reported to Modern by operator/City;*NORM exceeding 50 µR/hr not labeled INSPECTION RESULTS-TANK BATTERY (ASTS) N/A INSPECTION RESULTS - COMPRESSORS OR ANCILLARY EQUIPMENT Location ID: Leaks (OGI): NORM (lLR/hr; max): Date Reported': Date Addressed': Ancillary A None <15 NA NA Ancillary B None <15 NA NA General Notes: No other concerns noted. 1—Reported to operator;2—If reported to Modern by operator/City;*NORM exceeding 50 µR/hr not labeled PROJECT 22075 1 MAY 31,2022 1 PAGE 3 www.MODERNGEOSCIENCES.com v MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS PHOTOGRAPHIC DOCUMENTATION PROJECT 22075 www.MODERNGEOSCIENCES.com PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS EW No. 1 Leak observed at a kimray valve on No. 2 Leak observed at a kimray valve on Separator C. Separator C in High Sensitivity Mode. q t No. 3 View of wells. No.4 View of separators. _ I t 7i�__ A P No. 5 Additional view of separators. No. 6 View of Ancillary B. PROJECT 22075 www.MODERNGEOSCIENCES.com v MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS FIGURES PROJECT 22075 www.MODERNGEOSCIENCES.com Aerial Source:Microsoft Corporation©and its data suppliers Devon Well ID RRC ID Padsite Location A 192126 .O B 267501 C 267498 El Denton �' El a �. ❑B 0 � Basemap Source:ESRI 7��t Legend: A Well Separator Ancillary Equipment r- -r - -:Observation Path 0 a Padsite � A � 31 PROJECT NO. 22075 FIGURE 0 25 50 75 goo Feet DRAWN: 06.16.22 PADSITE MAP � ' This figure was prepared using data from a variety of sources. DRAWN BY: CS/LM No warranty is made as to the accuracy or completeness of data CHECKED BY: KT provided through third parties. All data contained herein is Biltmore North 1 Padsite(No.93) subject to change without notice.This figure is not intended for use as a MODERN G E O S C I E N C E S FILE NAME: 11482 H Lively Road legal survey or construction design document. If denoted, wind Denton,Texas direction represents dominant wind direction observed during field activities. TRUSTED ENVIRONMENTAL ADVISORS® 93_L_Dev_BN1_Padsite_220616.mxd