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Home My WebLink About2017-025 Gas Well InspectionsDate: April 21, 2017 INFORMAL STAFF REPORT TO MAYOR AND CITY COUNCIL SUBJECT: Report No. 2017-025 The Department of Development Services Gas Well Inspections Division Business Efficiency Assessment. BACKGROUND: The Gas Well Inspections (GWI) Division is presented with a unique opportunity to assess its level of service. Since the adoption of the most recent gas well ordinance in August 2015, the GWI Division has realized attrition resulting in 3 vacant positions. This has enabled the reassessment of the skill sets needed to implement the ordinance. The current structure of the division is reflected in Figure 1 below. Fi�ure 1: Current Division Structure Director of Development Services GWI Administrator 2 GWI Inspectors (vacant) II II Gas Well Coordinator (vacant) The implementation and associated impacts of the ordinance were not realized until the latter part of 2015 and as a result the division's business model is being revaluated in anticipation of increased gas well production and to streamline the implementation of the ordinance by placing specific functions in the appropriate arena. Gas Well Inspection Division's Function There are 3 components to the current gas well ordinance which are outlined below; l. Zoning districts and associated limitations 2. Subdivision platting 3. Gas well drilling and production As result, the GWI Division fulfils 2 distinct and different functions necessary to achieve the regulation of gas well development; 1. Relationship to surface development (land use compatibility) 2. Operations Date: April 21, 2017 Report No. 2017-025 The infancy stage of gas well development is the spatial assessment of the gas well site as it relates to surface development. It is through the permitting and project review process that the site locations are reviewed and compatibility with the surrounding land uses is established by requiring specific setbacks based on the nature of the uses, ensuring access routes to the site do not compromise existing infrastructure, mitigate nuisance such as noise, notification disclosures, and environmental protection. This function requires the expertise of a land use planning professional. The operations function is initiated upon the approval of the gas well site plans/plats and continues through the lifecycle of the site/well. This inspections arm of the division is unique and requires an experienced professional in the gas well industry to be able to effectively enforce and discern gas well drilling and production regulations described in the ordinance. Responsibilities include; evaluating for compliance with state, federal and local regulations, site inspections, monitoring operations, environmental and erosion controls measures, nuisance prevention, security measures, integrity of equipment, proper equipment usage, general housekeeping, review of required testing and surveys, site visits relating to notices of activity and responding to public complaints and emergencies. In addition to bi-annual inspections, there are six initial inspections conducted that align with the different stages of the gas well development lifecycle which are; l. Predrilling 2. Drilling 3. Completion 4. Flowback 5. First sales 6. Plug & Abandonment. It is important to note that each stage of development poses unique operations that present higher risks to safety, health, and the environment. Recommendation In order to enable a comprehensive and thorough method of implementation of the two primary functions of the gas well ordinance it is recommended the GWI Division become more weighted in the operations arena and the land use compatibility function align with the Planning Division. It is further recommended that the Gas Well Administrator position be reclassified and tailored to Gas Well Inspector Supervisor. This position will manage the operations function of the Gas Well Inspections Division described above. This approach provides the operations function to align with industry standards and utilize necessary experience, knowledge and expertise associated with the Division's expected roles and responsibilities. The City has 226 single well sites that can support additional gas well drilling, In addition, most of the multi well sites can also support additional wells. With minimal modifications, these sites will provide opportunities for the gas well operators to pursue in-field development at lower costs and lower risks with infrastructure in place. It is predicted gas well development will become more active in the near future, and it will be necessary for the Gas Well Inspections Division to fill the vacant Inspector positions. The proposed functions are illustrated in Figure 2 below. Date: April 21, 2017 Fi�ure 2: Pro�osed Gas Well Division Structure Director of Development Services Planning Division Gas Well Land Use Planning Supervisor GWI Operations Division GWI Inspector Supervisor Report No. 2017-025 Gas Well Inspector x2 Future Predicted Activitv Over the course of the past two years drilling, completion, re-completion and workovers have been at their lowest levels of activity. This could be attributed to the decline in natural gas pricing. In the past, workover activities typically increase as depressed gas prices begin to improve. This has been a precursor and a leading indicator of future drilling activity improvement. Recently gas prices appear to be modestly rebounding and as a result workover activity has also increased. For example, from Apri12016 to October 2016, there were a total of 11 workovers and from November 2016 to present, there has been a total of 31 workovers. Exhibits Exhibit 1— Summary of Gas Well Inspections Role Exhibit 2— Gas Well Inspection Form Exhibit 3— Gas Well Inspection Form — ETJ Exhibit 4— Gas Well Development Plat Checklist Exhibit 5— Gas Well Development Site Plan Date: April 21, 2017 FAQs 1. How many gas wells are located within the City of Denton? 294 2. How many gas wells are located within the City's ETJ? 207 3. How many gas well plats are located within the City of Denton? 100 4. How many gas well plats are located within the City's ETJ? 65 Report No. 2017-025 5. How many gas well production sites have been created as a result of the current ordinance? 4 ➢ GWSP16-0005 — Eagleridge, Scout Unit located at 2013 N. Masch Branch Road. This is a new site and no wells drilling on the site ➢ GWSP16-0007 — Eagleridge, Tetra Pak located at 3003 Airport Road. This is an existing site that was replatted to accommodate the Tetra Pak addition ➢ GWSP17-0001 — Eagleridge, Guyer 1 located at 7491 S. Teasley Lane. This is an existing site and was replatted to accommodate Guyer High School expansion. ➢ GWSP17-0002 — Eagleridge, Guyer 2located at 7501 S. Teasley Lane. This is an existing site and was replatted to accommodate the Guyer High School expansion. 6. How many workovers by operator? Refer to Figure 3 Below Figure 3: W orkover Activity Workover Activity - 1 Year Reported in 6 month increments O erator 4/16-10/16 11/16-4/17 Total Eagleridge 10 20 30 Devon 1 2 3 Endeavor 0 4 4 Enervest 0 4 4 Trinit 0 1 1 Total 5 11 31 42 STAFF CONTACT: Munal Mauladad Director of Development Services 940-349-8313 MunaLMauladad(cr�,cityofdenton.com __.=- --� -- - ------ `� v � �ITY w��p�, ��,T..,�r,�� ,.. , ,��, ' �;�,��,�� Oi' 215 W HICKORY STREET ■ DENTON, TEXAS ■ 76201 ■ 940.349.8451 ■ FAX 940.340.7707 DEVELOPMENT SERV/CES Apri121, 2017 SUBJECT: Role of Gas Well Division's operation arm The role of the Gas Well Division's operation arm is to; Inspection new and existing gas well sites: a. There are six initial inspections made at the following phases of gas well development: i. Pre-drilling: Inspecting for compliance with the site plan ii. Drilling: Inspecting for compliance with Fire codes, site plan layouts and nuisance mitigation b �� iii. Completion activities: Inspecting for compliance with nuisance mitigation, sound level reports, and site layout iv. Flowback Inspecting for compliance with nuisance mitigation, flaring, dust and odor, traffic, light and sound v. First sales: Inspecting for compliance with site layout for the production operations of the wells, and the gas well equipment vi. Plugging: Inspecting for compliance associated with restoration and RRC filed reports Annual inspections are conducted two times a year for all sites within the City and its ETJ. Within the ETJ, gas well inspections are limited to inspecting only to ensure that the number of wells drilled does not exceed what was platted and to ensure required signage is in place. Inspectors also respond to Notices of Activities reported by the operator. Activities that require reporting to the City are; i. Site preparation ii. Drilling iii. Completion iv. Recompletion v. Rework/Workover vi. Setting surface casing vii. General maintenance 2. Responding to public inquiries and complaints. The Division seeks to ensure responses are provided in a timely manner and collaborates with other City departments and regulatory agencies as necessary to resolve issues at gas well sites. The Gas Well Inspection Division is responsible for not only assessing compliance with the City's gas well ordinance, but also with state and federal law. The following matrix outlines the various regulatory bodies that influence gas well drilling and production activities in Texas. Levei Re ulator Bod Sco e of Infiuence Environmental • National environmental regulations such as the Clean Air Act place limits Protection Agency on emissions and discharges from industrial operations, including oil and (EPA) gas. • Other regulations ensure the protection of the nation's water supply and Federal regulate the manufacture and distribution of chemicals used and produced b industrial o erations, includin oil and as develo ment. Occupational • OSHA Regulates worker and site safety, including personnel training, Safety and Health chemical labeling, required personal protective equipment, and other Administration measures to limit worker exposure to operational and chemical hazards. (OSHA) Railroad • The RRC is responsible for regulating almost all aspects of oil and gas Commission development in Texas, including processes from well drilling to well (RRC) plugging. • RRC maintains records of operating companies as well as their mineral leases, wells, and production levels. • RRC regional offices conduct periodic inspections of well sites and can State issue violations for improper equipment operation. Texas • TCEQ's primary concern is the limitation of air emissions. Commission on . TCEQ reviews air emission calculations for pad sites and issues permits Environmental for the m�imum amount of allowable emissions of regulated pollutants. Quality (TCEQ) Texas Department • The Department of Health is primarily concerned with limiting workers' of Health and exposure to naturally occurring radioactive material (NORM), which can Human Services be presenting in piping and storage tanks on pad sites. Gas Well • GWI reviews and issues Gas Well Site Plans and permits. Inspections . GWI reviews subdivision plats and other development projects for Division (GWI) compliance with setbacks and other provisions of the ordinance. • GWI conductions initial and bi-annual inspections of all gas well pad sites within the City and its ETJ. Watershed • The Watershed Protection department review Gas Well Site Plans to Protection ensure storm water protection and erosion control is provided. • The department conducts initial site inspections to ensure erosion control measures are installed properly. Municipal Fire Department • The Fire Department issues permits for gas wells and storage tanks. • The Fire Department conducts inspections of pad sites to ensure tanks are in good operating condition, secondary containment measures are functional, and lightning protection is in place. • The International Fire Code establishes minimum setbacks between production equipment (i.e. wellheads and flammable liquid containers) and buildings. • The Fire Department reviews Gas Well Site Plans to ensure setbacks are met and site access is adequate. Police Department • The Police respond to citizen concerns regarding safety and noise violations at pad sites. , �,��w!�K� x.�� u �. 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Phone No Good Need Resolved RRC & Api No Good Need Resolved No Smoking Good Need Resolved Reflective/Lighting Good Need Resolved Facility Equipment Wellhead Paint Good Need Resolved Wellhead Leaks Good Need Resolved Tank Battery Paint Good Need Resolved Tank Battery Leaks Good Need Resolved Equip Height Good Need Resolved Layout pe� Site Plan Good Need Resolved ,,,,,,,,,,,General Location Fencing Entry Gate Locked Site Surface Stains Trash/Debris Weeds/Brush Oders/Fumes/Dust Site Lighting Landscaping Good Good Good Good Good Good Good Good Good Need Need Need Need Need Need Need Need Need Resolved Resolved Resolved Resolved Resolved Resolved Resolved Resolved Resolved Miscellaneous Electric Lines Safe Good Need Resolved Pipeline Markers Good Need Resolved No Wells Approved Db Level @ Inspection Erosion Control Referred Fire Dept. ��F i re ��L a n e ��A c c e s s ��Ta n k ��I n t e ��r i t ��F o la m ��L i n e s �� Referred 9 y Referred Referred Auto Safety Valve Referred Containment Integrity Referred Lightning Arresting Referred Tank Level Activated Referred Drip Pots @ Disconnects Referred Pit Fencing Referred Accessible ESD Referred Storage Tank Labels Referred Pit Liner Integrity Referred Inspection Comments �,��!�� x.�� u �. C'DG` ✓.�I�III" I�"DI�I�DI�I�.' �t�c�zrc� Juri ��ic,tics0l a-:,�� rt� rv�� Il��u.��.� � � � � � , � � � � � � ��I�I ��If`��If la�r::sg�c��;tc�� I�y Inspection Type 2017 Annual Inspection Cycle Inspection Date Re-Inspection Date Close Date la�r::sg�c��;tiaa�r �t�t�a::s g-:,l�t/;�it� ��zalialc� g-,�rmit IV�z g-,l�a1 IV�z, I....�� IV�me ;�t�tC Ic� Fi�ai IV�z. ;� uc� C�,,)�t� C),i, �ta;j,c,t, UU�ll�U��U��U�ll �U-U��V� V�U�� Signs General Location Operator Name Good Need Resolved Site Address Good Need Resolved Well Name Good Need Resolved 24hr. Phone No Good Need Resolved RRC / Api No Good Need Resolved Layout pe� Site Plan Good Need Resolved No Wells Approved Erosion Control Referred Gas Well Development Plat GAS WELL INSPECTIONS DIVISION PLANNING & DEVELOPMENT DEPARTMENT ��r�� City Hall West: 221 North Elm Street � Denton, Texas 76201 � �,ai � (940� 349-8372 � ��v��vc�v.citvofdenton.com/gaswellinspections �� GAS WELL DEVELOPMENT PLAT CHECKLIST REQUIREMENTS SPECIFIC TO A GAS WELL DEVELOPMENT PLAT Any person proposing or amending a Drilling and Production Site on a tract of land located in Division I of the City's Extraterritorial lurisdiction (ETl) shall prepare and submit a completed Gas Well Development Application along with a Gas Well Development Plat Checklist form. The following must be included in each application package submitted to the City for review. 1. Gas Well Development Application; 2. Completed Gas Well Development Plat checklist; 3. Appropriate application fee(s); and 4. Exhibits A through D below* *Each Exhibit shall be submitted or uploaded as a separate sheet. Include the word 'Exhibit' and the corresponding letter in the prefix of the document title, e.g., Exhibit A— Cover Page and Project Info. Checkif Provided ❑ Exhibit A: Cover page that includes a vicinity map of the Drilling and Production Site; a Sheet Index that identifies the number of Exhibits with titles for each (exhibit titles shall begin with the word `Exhibit' and include the respective letter); the Drilling and Production Site Name (aka: Project Title); the date of preparation; the preparer's, Operator's, and property owner's names; City project number; and a signature block for both the Gas Well Administrator and the City Secretary. Add a note to the Cover Page stating the reason for amendment, if applicable. ❑ Exhibit B: A mapping exhibit with an accurate legal description of the Drilling and Production Site that was prepared and certified by a Registered Professional Land Surveyor of the State of Texas. Provide closure sheet of bearings and distances used in legal description. The exhibit shall include exact location, dimension, and description of all existing public, proposed, or private easements, and public right-of-way within the lease area, intersecting or contiguous with its boundary, or forming such boundary. Describe and locate all permanent survey monuments, pins, and control points and tie and reference the survey corners to the Texas State Plane Coordinate System North Central Zone 1983-1999 datum. Provide proposed pipeline route—note that a separate application may be necessary if the proposed route encroaches onto any public easement, right-of-way or land owned by the City of Denton. ❑ Exhibit C: A drawing of the Drilling and Production Site showing clear site boundary lines and the layout of the site. Include a 1,000-foot buffer circle around the boundary of the Drilling and Production Site for reference. ❑ Exhibit D: Access and Transportation Plan identifying the points of access and routes to be followed on the road network supporting gas well development on the Drilling and Production Site over time. I REVIEWED THE CHECKLIST AND ALL SUBMITTALS FOR COMPLETENESS AND ACCURACY. Signature Date GAS WELL INSPECTIONS DIVISION DEVELOPMENT SERVICES DEPARTMENT ��r�� City Hall West: 221 North Elm Street � Denton, Texas 76201 � �,ai � (940� 349-8372 � ��v��vc�v.citvofdenton.com/gaswellinspections �� GAS WELL DEVELOPMENT SITE PLAN CHECKLIST REQUIREMENTS SPECIFIC TO A GAS WELL DEVELOPMENT SITE PLAN Any person proposing or amending a Drilling and Production Site on a tract of land located within the City of Denton shall prepare and submit a completed Gas Well Development Application along with a Gas Well Development Site Plan Checklist form. The Site Plan may be contingent on approval of a corresponding Specific Use Permit (SUP) or Watershed Protection Permit (WPP), if required for the site. The following must be included in each application package submitted to the City for review. 1. Gas Well Development Application; 2. Completed Gas Well Development Site Plan checklist; 3. Appropriate application fee(s); 4. Exhibits A through J below*; and 5. Proof of required Insurance and Surety. *Each Exhibit shall be submitted or uploaded as a separate sheet. Include the word 'Exhibit' and the corresponding letter in the prefix of the document title, e.g., Exhibit A— Cover Page and Project Info. Check box Provided ❑ Exhibit A: Cover page that includes a vicinity map of the Drilling and Production Site; a Sheet Index that identifies the number of Exhibits with titles for each (exhibit titles shall begin with the word `Exhibit' and include the respective letter); the Drilling and Production Site Name (aka: Project Title); the date of preparation; the preparer's, Operator's, and property owner's names; City project number; and a signature block for both the Gas Well Administrator and the City Secretary. Add a note to the Cover Page stating the reason for amendment, if applicable. ❑ Exhibit B: A mapping exhibit with an accurate legal description of the Drilling and Production Site that was prepared and certified by a Registered Professional Land Surveyor of the State of Texas. Provide closure sheet of bearings and distances used in legal description. The exhibit shall include exact location, dimension, and description of all existing public, proposed, or private easements, and public right-of-way within the lease area, intersecting or contiguous with its boundary, or forming such boundary. Describe and locate all permanent survey monuments, pins, and control points and tie and reference the survey corners to the Texas State Plane Coordinate System North Central Zone 1983-1999 datum. Provide proposed pipeline route—note that a separate application may be necessary if the proposed route encroaches onto any public easement, right-of-way or land owned by the City of Denton. ❑ Exhibit C: A map showing the distance from the boundaries of the Drilling and Production Site from all Protected Uses and Residential Subdivisions. The measurement shall be computed in accordance with DDC Section 35.5.10.2.D. If the separation distance(s) from Protected Uses and Residential Subdivisions do not meet the setback requirements of DDC Section 35. 5. 10. 2, the application also must include a copy of the waivers approved pursuant to DDC Section 35.5.10.6.A, or the approval of a setback variance approved by the Board of Adjustment pursuant to DDC Section 35.5.10.6.B. If the Operator seeks to qualify the proposed Drilling and Production Site for an administrative waiver pursuant to DDC Section 35. 5. 10. 6. C, the information therein required shall be submitted with the application for site plan approval. ❑ Exhibit D: A site plan of the Drilling and Production Site, capable of being recorded, showing clear site boundary lines and the location of all on—site improvements and equipment, including: tanks, pipelines, compressors, separators, and other appurtenances in relation to the boundaries of the site. GAS WELL INSPECTIONS DIVISION DEVELOPMENT SERVICES DEPARTMENT ��r�� City Hall West: 221 North Elm Street � Denton, Texas 76201 � �,ai � (940� 349-8372 � ��v��vc�v.citvofdenton.com/gaswellinspections �� GAS WELL DEVELOPMENT SITE PLAN CHECKLIST ❑ Exhibit E: Erosion and Sediment Control Plan. Exhibit must include contact information; a physical site description including: land uses, general vegetation and surface water in near proximity; topography/contour lines both pre- and post-construction; hydrologic analysis including: stormwater directional flow, outfalls, water well related structures and water sources; receiving waters; soils; project narrative with general timeline; well pad site plan including: fueling areas, waste disposal containers, hazardous materials storage, and product and condensate storage tanks ; soil stabilization and erosion control measures including: list of selected stormwater measures, site map of selected stormwater measures locations and final stabilization plans; solid waste management plan, septic/portolet location; and maintenance plan for stormwater controls including schedule and transfer of ownership provision. See Gas Well Erosion and Sediment Control Plan Guidance Document for details. ❑ Exhibit F: An Access and Transportation Plan identifying the points of access and routes to be followed on the road network supporting gas well development on the Drilling and Production Site over time, and the internal circulation plan for the property containing the proposed site, including provisions to protect vehicle access to Neighborhood Streets. The Plan shall contain specifications for construction of the access road(s) and on -site fire lanes that meet the standards for emergency access set forth in DDC Section 35.22.2.E. A map showing transportation route and road for equipment, supplies, chemicals, or waste products used or produced by the gas well operation shall be included. The map shall illustrate the length of all public roads that will be used for site ingress and egress. Note that site access via a Neighborhood Street, as defined in the DDC, is not permitted. The water source proposed for both the drilling and fracturing stages shall be identified in the Plan, together with a designation whether the water is to be hauled or piped to the site. ❑ Exhibit G: Landscape Plan. The project review planner will determine if a buffer is required based on the adjacent land use(s). If Planner determines buffer is required, then a landscape plan must be submitted in accordance with the City of Denton's Landscape Plan Checklist. Not every Drilling and Production Site requires a landscape plan. ❑ Exhibit H: A Tree Inventory and a Preservation Plan and Mitigation Plan pursuant to DDC Section 35.13.7. ❑ Exhibit I: A Noise Management Plan, prepared in accordance with DDC Section 35.22.2.F.2. ❑ Exhibit J: Proof of issuance of Notice of Activities pursuant to DDC Section 35.22.7. I REVIEWED THE CHECKLIST AND ALL SUBMITTALS FOR COMPLETENESS AND ACCURACY. Signature Date