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2023.04.19_Vendor_Inspection_Padsite041 MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS DATE May 31, 2023 Padsite Inspection Report Padsite No. 041(Smith-Yorlum 4H) PROJECT 23002 Operator: EagleRidge Location: ®City of Denton ❑ Denton ETJ ATTN City Of Denton TRAKiT ID: 1109-0281 215 East McKinney Street API: 12131643 Denton,Texas 76201 Insp. Date: 4/19/23 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 and/or operational requirements set forth by the City. No operational or ordinance compliance issues were noted by Modern during our inspection efforts. ■ 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 1 0 0 0 Separators 1 0 0 0 ASTs 2 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 ■ 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 5 r f° 4 C c 3 O 2 Z Y ca 1 v J 0 - - -1 2022-2 2023-1 Leak 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 second 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. Respect Ily 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 I F 682.223.1593 I P 682.223.1322 www.MODERNGEOSCIENCES.com <S MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS DATE May 31, 2023 PROJECT 23002 PADSITE INSPECTION REPORT Padsite No. 041—Smith-Yorlum 4H 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 2023 MODERN GEOSCIENCES.ALL RIGHTS RESERVED. www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Smith-Yorlum 4H(#041) Operator: EogleRidge Inspection Date:04119123 Inspectors:ZT, SB MODERN G E O S C I E N C E 5 TRUSTED ENVIRONMENTAL ADVISORS FIELD INSPECTION RESULTS: InspectionPass Fail N/A General No. 000• ® ❑ ❑ Item A.4: No refining processes present (dehydrator and separator exempt). Comments: None ® ❑ ❑ Item A.5: No chemical, refuse, or wastewater discharge present. Comments: None ❑ ❑ ❑ Item B.1: Light reflective sign at entrance gate present. Comments: Not applicable for this inspection period. Item B.2.a/b: Appropriate fencing, buffering, landscaping, and/or screening present ® ❑ ❑ within 300ft of all equipment (as applicable). Comments: None Item B.3.a:"THIS IS A GAS WELL DRILLING AND PRODCUTION SITE.THIS SITE MAY BE THE SUBJECT ❑ ❑ ® OF FURTHER DRILLING AND PRODUCTION AND/OR HYDRAULIC FRACTURING' signage present. Comments: Not applicable for this inspection period. Item B.3.b: Additional signage present (well identification number, operator name, ❑ ❑ ® telephone number, and mailing address, Site address, emergency number [911], City's Gas Well Division telephone number, and TCEQ's Regional Office telephone number). Comments: Not applicable for this inspection period. ❑ ❑ ® Item B.3.c: "DANGER NO SMOKING ALLOWED"signage present. Comments: Not applicable for this inspection period. ❑ ❑ ❑ Item B.4:All equipment painted with no bare pipe, rust, blisters, or stains present. Comments: None ❑ ❑ ❑ Item B.6: Compressor located at least 24ft from outer boundary of Site (as applicable). Comments: None ❑ ❑ ❑ Item B.8: No rubbish or debris constituting a fire hazard present. Comments: None Item B.9: Site and access road free of debris, pools of water/liquid, contaminated soil, ❑ ❑ ❑ weeds, brush,trash, or other waste material. Comments: None Item E.7:Site equipped with a lightning protection system and tank battery equipped with ❑ ❑ ❑ a lightning arrestor system (as applicable). Comments: None ® ❑ ❑ Item E.8: Site equipped with a remote foam line (as applicable). Comments: None Item E.12: All-weather surface emergency access road at least 20 ft in width present or ® ❑ ❑ as approved by the Fire Marshall. Comments: None Item E.14: Appropriate secondary containment or oil absorbing materials present (as ® ❑ ❑ applicable). Comments: None ® ❑ ❑ Item F.1: Site and structures not dilapidated, unsightly, or unsafe. Comments: None ® ❑ ❑ Item F.3: Lighting not directed toward adjacent property/roads (as applicable). Comments: None Note:The above items represent key compliance requirements of Ordinance No.DCA19-0009e dated January 28th,2023. PROJECT 23002 1 MAY 31,2023 1 PAGE 1 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Smith-Yorlum 4H(#041) Operator: EagleRidge Inspection Date:04119123 ►nspectors:ZT, SB MODERN G E O S C I E N C E 5 TRUSTED ENVIRONMENTAL ADVISORS • NORM At Equipment: 10,000 ppmv i 50 µR/hr z Equipment: OGI Camera Radiation Meter Resolution: 3,000-10,000 ppmv 1 µR/hr Constituent: Methane tVOCs H2S NORM Fenceline: 500 ppmv 3 0.1 ppmv 4 0.08 ppmv' 20 µR/hr 6 35 µg/m3 (7) 150 µg/m3 I81 65 dBA 9 Equipment: DPIR Meter PID HZS Meter Radiation Particulate Particulate Sound Meter Meter Meter Meter Resolution: 1 ppmv 0.001 ppmv 0.003 ppmv 1 µR/hr 1 µg/m3 1 µg/m3 1 dBA 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 FR 56593). Within their response to the EPA, the INGAA noted the following, "the INGAA recommends a leak definition concentration of 10,000 ppm.This is consistent with the range of thresholds in current regulations,also consistent with the OGI performance objectives in §60.5397a(c)(7)(i)(B), and consistent with the Subpart W leak definition." This methane concentration also represents 20% of the Lower Explosive Limit and is consistent with 40 CFR §60.18(g)(6) (i) ("any emissions imaged by the optical gas instrument"].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. The term"leak"is used within this inspection effort to define potential fugitive emissions that appear to be continuous in nature and suggestive equipment and/or components are not functioning properly. 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. 7-National Ambient Air Quality Standard (NAAQS) for Particulate Matter (PM) PMz.s. Further monitoring will be needed to confirm if a continuous average(24-hr,3yr)exceedance is indicated. Elevated PMz.s can also be indicative of elevated semi-volatile organic compounds or other emission products may be present. Individual COC monitoring required for comparison with AMCVs or ESLs. 8-NAAQS for PM1o. Further monitoring will be needed to confirm if a continuous average(24-hr,3yr)exceedance is indicated. 9-A-weighted Leq criteria consistent with the Federal Interagency Committee on Urban Noise (FICUN) "Guidelines for Considering Noise in Land-Use Planning and Control"maximum level for"acceptable"uses. Other permit-specific criteria may be applicable. Modern's sound sampling event represents only a short event at the boundary nearest an enclosed structure. Further attenuation may be present if the sampling point is adjusted. Completed using a Class 1 microphone with 3-octave bands allowing further detail if needed. Further monitoring will be needed to confirm if average sound conditions exceed applicable criteria. PROJECT 23002 1 MAY 31,2023 1 PAGE 2 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Smith-Yorlum 4H(#041) Operator: EagleRidge Inspection Date:04119123 Inspectors:ZT, SB MODERN G E O S C I E N C E S TRUSTED ENVIRONMENTAL ADVISORS NEAR EQUIPMENT INSPECTION RESULTS: INSPECTIC JLTS -11N Location ID: Leaks (OGI): NORM (�tRffir; max): Date Reported': Date Addressed 2 Well A 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 (pR/hr; max): Date Reported': Date Addressed': Separator A 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—TANK BATTERY ASTS Location ID: Leaks (OGI): NORM ([iR/hr; max): Date Reported': Date Addressed 2: AST A None <15 NA NA AST 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 INS. r-SULTS — uuN. r%NGILLAKY t Location ID: Leaks (OGI): NORM (jiR/hr; max): Date Reported': Date Addressed Compressor A None <15 NA NA Ancillary A 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 PROJECT 23002 1 MAY 31,2023 1 PAGE 3 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Smith-Yorlum 4H(#041) Operator: EogleRidge Inspection Date:04119123 Inspectors:ZT, SB MODERN G E O S C I E N C E 5 TRUSTED ENVIRONMENTAL ADVISORS FENCELINE INSPECTION RESULTS: - -• • •• Avg. Wind Direction (to): N Avg. Wind Speed (mph): 13.7 Bar. Pressure ("Hg): 29.12 9• Avg.Temp (°F): 82.5 Humidity(%): 58.6 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 2 PMz.s >35 µg/m3? ❑ ® ❑ 17.08 µg/m3 16.63 µg/m3 2 PMlo> 150 µg/m3? ❑ ® ❑ 60.41 µg/m3 70.36 µg/m3 Perimeter Result: 63.2 dBA(File#: 012) 3 Perimeter Noise Monitoring>65 dBA? ❑ ❑ ❑ Comments: None Primary Source(s): Compressor A Alternate Result: N/A dBA(File#: N/A) 3,4 Alternate Noise Monitoring>65 dBA? ❑ ❑ ❑ Comments: N/A Primary Source(s): N/A Other perimeter/fenceline observations suggestive of releases or concerns: None Comments: In addition to direct screening of the above sound level, Modern calculated pure tone levels consistent with ordinance requirements. Based on this evaluation, ordinance thresholds were not exceeded.A depiction of pure tone comparisons is included in the attached graph(s). Notes: 1- Represents the maximum discrete sampling result recorded by Modern across fenceline screening alignment. 2- Represents the approximately 10-minute average result recorded by Modern. Sample point selected by field professional as a conservative representation of fenceline conditions at the time of sampling. 3- Represents the approximately 1 to 5-minute average result recorded by Modern. Sample point selected by field professional as a conservative representation of fenceline conditions at the time of sampling. When available,site-specific ambient levels are presented(default is 65 dBA). 4- Perimeter monitoring occurred at the padsite fenceline closest to an apparent occupied structure. If an exceedance of our screening criteria is noted at this point,a secondary(alternate)monitoring event is conducted approximately 100 feet from perimeter toward the nearest occupied structure to allow an understanding of site-specific attenuation. Further monitoring may be needed to evaluate tonal compositions and longer time-weighted averages. 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 23002 1 MAY 31,2023 1 PAGE 4 www.MODERNGEOSCIENCES.com v MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS DATA GRAPHS www.MODERNGEOSCIENCES.com ��������NN ��������U�NN�°�� .�~,~,��.° `.�~,�~,.�.°~,�� mUMa ENVIRONMEWAL ADVISORS Particulate MatteK - Upwind yo uo 70 so so pxx10(1*0) _, —X pxx2s(35) s so zo _/' x+---'w� X............*---'m---'**---'y............m............ zo ------------ o o z 4 o 8 zo _ Fig. R1: Particulate Matter-Upwind Results(10 Minute Sampling) Particulate Matter - Downwind zoo *» oo 70 � ao sn pwl10(150) 40 —X pxx2s(35) uo .----------- ----- ;w---'W.--''m...........+»...........*............*-' X zn ----------- -------- n n 2 4 s e 10 - Fig. R2: Particulate yWatter-Dovvnvvind Results(10 Minute Sampling) The above particulate monitoring data provides summary nfboth upwind and downwind observations during Modern's monitoring activities. Please see the attached figures for sampling locations. www.xxoosnmGcosc|cmccs.o,m V MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS Noise Monitoring Results - Padsite Fenceline -- Sound(A/sec) ___= Criteria Result(TWA-LAeq) 85 80 75 70 h ^ t 65 on N 60 �..►�\r\I \I\r�rr err ��'�r^... 55 m ° 50 45 40 35 1 16 31 46 61 Time(seconds) Fig. R3: Noise Monitoring Results(1-5 Minute Sampling)—File No.012 Noise Monitoring Results - Padsite Fenceline 25 70.0 20 60.0 15 m v 50.0 10 0 0 v40.0 0 0 ° ° ° ° ° 00 ° 0 ° ° 00 ° ° o pO ° 0 E o 0 0 0 ° o 30.0 -5 v m c 20.0 -10 F° -15 10.0 -20 0.0 -25 N N W A un P W N T O In F+ O O W O O N Ol O In F+ O O W O O N Ol O 2 2 2 1/3 Octave Band ❑Sound(dBA/octave) o Contiguous 1/3 Octave Tone Comparison(dBA) Fig. R4: Noise Monitoring Results(1-5 Minute Sampling)—File No.012 The above noise monitoring data provides a summary of Modern's sampling event. The general design criteria of 65 dBA is presented for comparison purposes only (time-weighted average; Leq). Please see the attached figures for sampling location(s). www.MODERNGEOSCIENCES.com v MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS PHOTOGRAPHIC DOCUMENTATION www.MODERNGEOSCIENCES.com PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS I Nil. jj I No. 1 View of Well A. No. 2 Additional view of Well A. '46 - aa.. No. 3 View of Separator A. No.4 View of ASTs. tow �y a � A No. 5 Additional view of Separator A and No. 6 View of Compressor A. ASTs. www.MODERNGEOSCIENCES.com v MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS FIGURE www.MODERNGEOSCIENCES.com 79 Atrial Source:Microsoft Corporation©and its data suppliers Parccl.Denton County ralsal District I Eagle Ride Padsite Location Well ID RRC ID A 194278 N.f Deritti El Basemap Source:ESRI . .s . . ,< . . .� . .mr .� . . . . . . Leaend: f Q Well r00 El1 Separator A 10000 O AST OCompressor © Ancillary Equipment t Foam Lines % © Upwind Air Sampling Point . i O� A Downwind Air Sampling Point ■ ■Fenceline Screening Alignment � A g 0 Sound Sampling Point I ■ ■ ■ ■ ■ ■ ■ ■ ■-M_AL© ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ Wind Direction(to) Observation Path Denton County Parcel Padsite PROJECT NO. 23002 FIGURE 0 35 70 105 140 ® 05.01.23 PADSITE MAP Fe et This figure was prepared using data from a variety of sources. 1. DRAWN BY: CS/LM/LG No warranty is made as to the accuracy or completeness of data CHECKED BY: ZT provided through third parties. All data contained herein is Smith-Yorlum 4H Padsite(No.41) 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: 754 N Masch Branch Road legal survey or construction design document. If denoted, wind Denton,Texas direction represents dominant wind direction observed during field activities. TRUSTED ENVIRONMENTAL ADVISORS° 041_H_ER_SY4H_Padsite_230501.mxd