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2021.10.26_Vendor_Inspection_Padsite00147.PDF V MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS DATE November 23, 2021 PROJECT 21125 ReportPadsite Inspection ATTN City of Denton Padsite No. 147(Robson Ranch 100) 215 East McKinney Street Operator: Bedrock 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. ■ 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 0 0 0 Separators 2 1 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 41 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. ■ 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 2022. 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. ReAnneth 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 November 23, 2021 PROJECT 21125 PADSITE INSPECTION REPORT Padsite No. 147— Robson Ranch 100 PREPARED FOR City of Denton 215 East McKinney Street Denton,Texas 76201 PREPARED BY REVIEWED BY Zachar ondr GIT e eth S.kramm, PhD, PG, HMM PROJECT MANAGER SENIOR PROGRAM MANAGER 5100 THOMPSON TERRACE,COLLEYVILLE,TEXAS 76034 1 IF 682.223.1593 r 682.223.1322 0 2021 MODERN GEOSCIENCES.ALL RIGHTS RESERVED. www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Robson Ranch 100(#147) Operator: Bedrock Inspection Date:10126121 Inspectors: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: Minor corrosion noted as potential future action item. ® ❑ ❑ 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; AST noted as temporary. ❑ ❑ ® 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; AST noted as temporary. ❑ ❑ ® 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; AST noted as temporary. ❑ ❑ ® Item 17:Tank battery has appropriate hazardous material signage. Comments: Not applicable—tank battery not present; AST noted as temporary. ❑ ❑ ® 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 21125 1 NOVEMBER 23,20211 PAGE 1 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Robson Ranch 100(#147) Operator: Bedrock Inspection Date:10126121 Inspectors:ZT, SB MODERN G E O S C I E N C E S TRUSTED ENVIRONMENTAL ADVISORS Constituent: • At Equipment: 10,000 ppmv 1 50 µR/hr 2 Equipment: OGI Camera Radiation Meter Resolution: 3,000-10,000 ppmv 1 µR/hr Constituent: Methane tVOCs H,S NORMNoise Fenceline: 500 ppmv 3 0.1 ppmv a 0.08 ppmv 5 20 µR/hr a 35 µg/m3 ' 150 µg/m3 $ 65 dBA 9 Equipment: DPIR Meter PID H2S 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 TCEQ Air 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) PM2.5. Further monitoring will be needed to confirm if a continuous average (24-hr, 3yr) exceedance is indicated. Elevated PM2.5 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 PM10. 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 21125 1 NOVEMBER 23,20211 PAGE 2 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Robson Ranch 100(#147) Operator: Bedrock Inspection Date:10126121 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 (IiR/hr; max): Date Reported': Date Addressed': Well A None <15 NA NA Well B None <15 NA NA General Notes: Minor corrosion noted on wells. 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 - SEPARATORS Location ID: Leaks (OGI): NORM (IiR/hr; max): Date Reported': Date Addressed': Separator Actuator <15 10/27/21 11/22/21 Separator B None <15 NA NA General Notes: Minor corrosion noted on separators. 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) Location ID: Leaks (OG I): NORM ([iR/hr; max): Date Reported': Date Addressed Former AST A None <15 NA NA Temporary AST B None <15 NA NA Temporary AST C None <15 NA NA General Notes: AST B and C were noted as temporary. Minor corrosion noted on temporary AST piping. 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- COMPRESSORS OR ANCILLARY EQUIPMENT Location ID: Leaks (OGI): NORM (ltR/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 21125 1 NOVEMBER 23,20211 PAGE 3 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Robson Ranch 100(#147) Operator: Bedrock Inspection Date:10126121 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): NW Avg. Wind Speed (mph): 6.3 Bar. Pressure ("Hg): 28.99 • Avg.Temp (°F): 81.4 Humidity (%): 62.3 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 PM2.5>35 µg/m3? ❑ ® ❑ 8.14 lag/m3 8.15 µg/ms 2 PM10> 150 µg/m3? ❑ ® ❑ 22.06 µg/m3 18.11 µg/m3 Perimeter Result: 53.7 dBA(File#: 598) 3 Perimeter Noise Monitoring>65 dBA? ❑ ® ❑ Comments: None Primary Source(s): off-site construction activities 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 21125 1 NOVEMBER 23,20211 PAGE 4 www.MODERNGEOSCIENCES.com MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS DATA GRAPHS PROJECT 21125 www.MODERNGEOSCIENCES.com 8��U��N� �%�nn�d°U�N��°�� .�~,~,��.° .°�~,��.�.�~,�� TRUSTED ENVIRONMENTAL ADVISORS Particulate MatteK - Upwind un zs zn to �s —0�- pxx1n(zs0 --e*-- Pxx2.5(35) ai � u ~ s o o z 4 o x zo Fig. R1: Particu|atePWatter-Upwind Results(1O Minute Sampling) Particulate Matter - Downwind »n zs un tao zs � —0�-� pw10(150) —+*—' pxxzs(as) zo 0 »+--'�»--�W.---.mm...........* -- ........... �...........n........... +---.;�---.� ' / -- . -------- - u z 4 s o zn Fig. R2: Particulate Matter-Downwind Results(10 Minute Sampling) The above particulate monitoring data provides summary of both upwind and downwind observations during Modern's monitoring activities. Please see the attached figures for sampling locations. pnoJccrzzzzs www.xxoosnmGsosocmccs.o,m MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS Noise Monitoring Results - Padsite Fenceline Sound(A/sec) ■■■■ Criteria Result(TWA-LAeq) 85 80 75 70 65 ======================================================= on lu 60 a 55 m16 50 45 40 35 1 16 31 46 61 Time(seconds) Fig. R3: Noise Monitoring Results(1-5 Minute Sampling)—File No. 598 Noise Monitoring Results - Padsite Fenceline 25 70.0 20 60.0 15 m -a v 50.0 10 0 t 5 CL 40.0 0 0 00 0 O ° 0 0 ° o o ° ° o o ° ° ° o 0 0 o 0 E 0 a 30.0 -5 m � 0 20.0 -10 � v -15 a 10.0 20 0.0 -25 N N W A tJl W 0 0 F-` F-` N N W A In M M F-` F-` F-` N N W A (li Ol 00 F-` F-` F-` N N M O to f+ O O W O O N Ol O to N O O W O N W O N M O Ln N N N Ln N N N N O In 0 0 0 cn O coo N H = N N L, ry ry ry N ry N ry N N ry N ry � N H � � N N � H H S S S 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. 598 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). PROJECT 21125 www.MODERNGEOSCIENCES.com MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS PHOTOGRAPHIC DOCUMENTATION PROJECT 20002 www.MODERNGEOSCIENCES.com V PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS t. Aim ' S J"f .yam. No. 1 Leak observed at an actuator on No. 2 Leak observed at an actuator on Separator A. Separator A in High Sensitivity Mode. No. 3 View of wells. No.4 Additional view of wells. .................. K No. 5 View of separators and ASTs. No. 6 View of ancillary. PROJECT 21125 www.MODERNGEOSCIENCES.com MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS FIGURES PROJECT 21125 www.MODERNGEOSCIENCES.com •Aerial Source:Microsoft Corporation G andlits data suppliers BedfOC -- Well ID RRC ID Padsite Location A 253147 s_ B 253784 a Dent El ♦ w ♦� .� �'' I Basemap Source'.ESRI �♦ ILB �� +�A .! e en : ♦ . A . �� ♦' B 0 Well 04♦ ��B Separator •♦ 0 Temporary AST �♦ �� ♦� !` 0 Former AST ♦ _ �� ♦ ' r ♦� ♦ Ancillary Equipment • ♦,. Upwind Air Sampling Point �} ♦,� ®1 m Downwind Air Sampling Point Fenceline Screening Alignment Pt Sound Sampling Point Wind Direction(to) r- -r Observation Path ED Padsite Denton County Parcels PROJECT NO. 21125 FIGURE 0 50 100 150 soo DRAWN: 11.17.21 PADSITE MAP This figure was prepared using data from a variety of sources. DRAWN BY: CS/LG No warranty is made as to the accuracy or completeness of data CHECKED BY: KT provided through third parties. All data contained herein is Robson Ranch 100 Padsite(No. 147) 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: 11223 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® 147_M_Ener_RR100_Padsite_211117.mxd