2022.04.04_Vendor_Inspection_Padsite0066.PDF MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
DATE May 31, 2022
PROJECT 22075
ReportPadsite Inspection
ATTN City of Denton Padsite No. 066(Mayday-UNT)
215 East McKinney Street Operator: EagleRidge
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 AST A. According to the Operator representative, all
corrosion observations were addressed as of May 5, 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
Equipment Number Leaks* Unlabeled NORM** Labeled NORM**
Wells 2 1 0 0
Separators*** 3 1 0 0
ASTs 3 3 0 0
Other 1 3 1 1 101 0
*OGI leaks identified exclude operational low bleed components(<6 scf/hr)
**NORM exceeding 50 µR/hr
***Separator C—piping only
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
■ Fenceline Inspection Results: Our inspection efforts for this padsite included an evaluation of air
quality at representative upwind and downwind points at the padsite boundary. Our approach
utilized a variety of equipment to screen for potential impacts that could affect air quality off of
the padsite or suggest additional monitoring may be warranted. Please refer to the report for
additional detail on our findings.
Fenceline inspection did not identify air quality concerns above program screening goals.
■ 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
4
41
f6 3
°C 2
O
Z
Y
f6 1
G1
J
0
2018 2019 2020 2021 2022
tLeak Rate (NORM Rate
5100 THOMPSON TERRACE,COLLEYVILLE,TEXAS 76034 1 F 682.223.1593 I P 682.223.1322
www.MODERNGEOSCIENCES.com
4(--!Sl
MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
■ 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 2023.
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.
Re4nneth
y submitte ,
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 I F 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. 066—Mayday-UNT
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 1 E 682.223.1593 r 682.223.1322
0 2022 MODERN GEOSCIENCES.ALL RIGHTS RESERVED.
www.MODERNGEOSCIENCES.com
PADSITE INSPECTION REPORT
Padsite Name:Mayday-UNT(#066) Operator: EagleRidge
Inspection Date:04104122 ►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: None
❑ ❑ ® 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: None
❑ ❑ ❑ 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: None
❑ ❑ ❑ Item 17:Tank battery has appropriate hazardous material signage.
Comments: None
❑ ❑ ® 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:Mayday-UNT(#066) Operator: EagleRidge
Inspection Date:04104122 ►nspectors:ZT, SB MODERN G E O S C I E N C E S
TRUSTED ENVIRONMENTAL ADVISORS
• 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
•nstituent: Methane tvOCS H2S NORM
Fenceline: 500 ppmv 3 0.1 ppmv 4 0.08 ppmv 5 20 µR/hr 6
Equipment: DPIR Meter PID H2S Meter Radiation Meter
Resolution: 1 ppmv 0.001 ppmv 0.003 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.
3-Represent half of the American Conference of Governmental Industrial Hygienists(ACGIH)8-hour threshold limit value(TLV)of 1,000 ppmv
(0.1%by volume)set for potential cardiac sensitization and central nervous system depression.
4-Consistent fenceline concentrations of 0.1 ppmv could indicate a potential off-site air quality exceedance of applicable TCEQAir Monitoring
Comparison Values (AMCVs) or Effect Screening Levels (ESLs). Further sampling will be needed to confirm the individual compounds
present and direct regulatory comparison.
5-Indicative of possible 30 TAC§112.31(30-min avg.)exceedance of 0.08 ppmv. Further sampling will be needed to confirm the 30-minute
average and allow direct regulatory comparison.
6-EPA average background criteria established under Document No.402-R-08-005;April 2008. Reported background ranged from 10 µR/hr
to 85 µR/hr. Elevated fenceline observations may require further screening to confirm attenuated levels near sensitive receptors.
PROJECT 22075 1 MAY 31,20221 PAGE 2
www.MODERNGEOSCIENCES.com
PADSITE INSPECTION REPORT
Padsite Name:Mayday-UNT(#066) Operator: EagleRidge
Inspection Date:04104122 Inspectors:ZT, SB MODERN G E O S C I E N C E S
TRUSTED ENVIRONMENTAL ADVISORS
NEAR EQUIPMENT INSPECTION RESULTS:
INSPECTIC JLTS -UN
Location ID: Leaks (OGI): NORM (�tRffir; max): Date Reported': Date Addressed':
Well A 7 Plunger 5 04/06/22 05/05/22
Well B I None <15 NA NA
General Notes: No other concerns noted.
1—Reported to operator,•'—If reported to Modern by operator/City,• *NORM exceeding 50 µR/hr not labeled
INSPECTION RESULTS— SEPARATORS
Location ID: Leaks (OGI): NORM (lLR/hr; max): Date Reported': Date Addressed':
Separator A DV Controller 20 04/06/22 05/05/22
Separator B None 30 NA NA
Former Separator C None <15 NA NA
General Notes: Minor corrosion noted on separators. No other concerns noted.
1—Reported to operator,•'—If reported to Modern by operator/City,• *NORM exceeding 50 µR/hr not labeled
INSPECTION RESULTS —TANK BATTERY ASTS
Location ID: Leaks (OGI): NORM (pR/hr; max): Date Reported': Date Addressed':
AST A Thief Hatch <15 04/06/22 05/05/22
AST B Thief Hatch <15 04/06/22 05/05/22
AST C Thief Hatch <15 04/06/22 05/05/22
General Notes: Bare pipe/corrosion noted on AST A. According to the Operator representative, all corrosion
observations were addressed as of May 5, 2022,thus the corrosion observations are no longer considered Action
Items. Future verification suggested. 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— COMPRESSORS OR ANCILLARY EQUIPMENT
Location ID: Leaks (OGI): NORM (IiRffir; max): Date Reported': Date Addressed':
Temporary Pneumatic Liquid Level <15 04/06/22 05/05/22
Compressor A Controller
Ancillary A None <15 NA NA
Ancillary B None <15 NA NA
General Notes:Temporary Compressor A may require paint if converted to permanent. No other concerns noted.
1—Reported to operator,•z—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
AWWIN
PADSITE INSPECTION REPORT
Padsite Name:Mayday-UNT(#066) Operator: EagleRidge
Inspection Date:04104122 Inspectors:ZT, SB MODERN G E O S C I E N C E S
TRUSTED ENVIRONMENTAL ADVISORS
FENCELINE INSPECTION RESULTS:
- -• . •• Avg. Wind Direction (to): N Avg. Wind Speed (mph):4.0 Bar. Pressure ("Hg): 29.03
9. Avg.Temp (°F): 76.0 Humidity(%): 56.6 Precipitation: N/A
Fenceline Screening Criteria: Yes No N/A Upwind Observations: Downwind Observations:
1 PID > 100 ppbv(0.1 ppmv)? ❑ ® ❑ <1 ppbv <1 ppbv
1 Radiation >20 µR/hr? ❑ ® ❑ <15 µR/hr <15 µR/hr
1 H2S>80 ppbv(0.08 ppmv)? ❑ ® ❑ <5 ppbv <5 ppbv
1 Methane >500 ppmv? ❑ ® ❑ <5 ppmv <5 ppmv
Other perimeter/fenceline observations suggestive of releases or concerns: None
Comments: None
Notes:
1- Represents the maximum discrete sampling result recorded by Modern across fenceline screening alignment.
General Inspection Program Notes:
1- Modern confirmed operation of all field equipment in accordance with manufacture specifications and Modern's standard operating procedures
prior to field inspection efforts. This included the use of zero and prepared calibration samples.
2- Modern's services were performed in a manner consistent with a level of care and skill ordinarily exercised by other members of our profession
practicing in the same locality,under similar conditions and at the time the services were performed. The scope of services performed was in
accordance with the scope of work agreed with by our client,as set forth in our proposal and related authorization agreement(s).
3- Laws,regulations and professional standards applicable to Modern's services are continually evolving. Techniques are,by necessity,often new
and relatively untried. Different professionals may reasonably adopt different approaches to similar problems. As such, our services are
intended to provide our client with a source of professional advice, opinions and recommendations based on a limited number of field
observations and tests,collected and performed in accordance with the generally accepted practice that exists at the time,and may depend on,
and be qualified by, information gathered previously by others and provided to Modern by our Client. Modern does not warrant the work of
third parties supplying information used in the report.
4- The monitoring results collected as part of these services represent field conditions at the time of inspection or monitoring only. Samples or
monitoring data collected at other times may reveal different results that are representative of site conditions during other periods of time. The
use of monitoring efforts is not intended to replace laboratory methodology,but rather provide data indicative of when additional efforts may
be warranted. Modern's air sampling is consistent with current regulatory guidance and/or manufacturer specification. For a higher level of
certainty,our monitoring methods can be expanded over longer periods of time and/or supplemented by use of a state-accredited laboratory
when evaluation of specific COCs is desired or further verification is needed.
PROJECT 220751 MAY 31,20221 PAGE 4
www.MODERNGEOSCIENCES.com
v
MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
PHOTOGRAPHIC
DOCUMENTATION
PROJECT 22075
www.MODERNGEOSCIENCES.com
PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
• _ yam -, .
Y,
L
No. 1 Leak observed at a plunger on Well A. No. 2 Leak observed at a plunger on Well A in
High Sensitivity Mode.
r7,
No. 3 Leak observed at a DV controller on No.4 Leak observed at a DV controller on
Separator A. Separator A in High Sensitivity Mode.
LL
.6a, l`
No. 5 Leak observed at a thief hatch on AST A. No. 6 Leak observed at a thief hatch on AST A
in High Sensitivity Mode.
PROJECT 22075
www.MODERNGEOSCIENCES.com
V
PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
No. 7 Leak observed at a thief hatch on AST B. No.8 Leak observed at a thief hatch on AST B
in High Sensitivity Mode.
:i
3
No.9 Leak observed at a thief hatch on AST C. No. 10 Leak observed at a thief hatch on AST C
in High Sensitivity Mode.
4.
No. 11 Leak observed at a pneumatic liquid No. 12 Leak observed at a pneumatic liquid
level controller on Temporary level controller on Temporary
Compressor A. Compressor Ain High Sensitivity Mode.
PROJECT 22075
www.MODERNGEOSCIENCES.com
V
PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
is—`-
0
I'
No. 13 View of wells. No. 14 Additional view of wells.
No. 15 View of separators. No. 16 View of ASTs.
I �
No. 17 View of Ancillary A. No. 18 View of Temporary Compressor A.
PROJECT 22075
www.MODERNGEOSCIENCES.com
v
MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
FIGURES
PROJECT 22075
www.MODERNGEOSCIENCES.com
Aerial Source:Microsoft Corporation m and its data suppliers
Parcel:Denton County Appraisal District - Ea le Ride Padsite Location
Well ID RRC ID i __ _____
A 216209
B 229906 - y,
N
r Dent
Basemap Source:ESRI
r Legend:
Well
. - - - - - -m - - - - - - - - - - - - - - - - - - - - - - - Separator
. 11 +"' Former Separator
r ,A. ;B� A r r r r r AST
j Ancillary Equipment
Compressor
,� � � + � � .�� ■ ' "� r . . � -�� " ~ � ��y' �� Foam Lines
10 ® Upwind Air Sampling Point
Downwind Air Sampling Point
Fenceline Screening Alignment
. + Wind Direction (to)
- r--r
- - Observation Path
QPadsite
Denton County Parcels
PROJECT NO. 22075 FIGURE
0 45 90 135 180 06.06.22 PADSITE MAP
Feet DRAWN:
DRAWN BY: CS/LM
This figure was prepared using data from a variety of sources.
No warranty is made as to the accuracy or completeness of data CHECKED BY: KT
provided through third parties. All data contained herein is Mayday-UNT Padsite(No.66)
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: 1201 S Bonnie Brae Street
legal survey or construction design document. If denoted, wind Denton,Texas
direction represents dominant wind direction observed during field activities. TRUSTED ENVIRONMENTAL ADVISORS® 066 M_ER_MD_Padsite_220606—c!