The URL can be used to link to this page

2024.04.16_Vendor_Inspection_Padsite047 MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS Padsite Inspection Re port DATE May 15, 2024 Padsite No. 047(Vaughn 1H) PROJECT 24003 Operator: EagleRidge Location: ®City of Denton ❑ Denton ETJ ATTN City Of Denton TRAKiT ID: 1109-0356 215 East McKinney Street API: 12132624 Denton,Texas 76201 Insp. Date: 04/16/24 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 other than noted below: • Overgrown vegetation noted along access road. According to the Operator representative, all vegetation observations were addressed as of May 14, 2024, thus the vegetation observations are no longer considered Action Items. Future verification suggested. • Ordinance Item B.3.a signage not present. • Additional signage not present— mailing address, emergency number (911), City's Gas Well Division telephone number,and TCEQ's Regional Office telephone number. • No smoking signage not present. According to the Operator representative, all no smoking signage observations were addressed as of May 14, 2024,thus the no smoking signage 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. 5100 THOMPSON TERRACE,COLLEYVILLE,TEXAS 76034 1 F 682.223.1593 1 P 682.223.1322 www.MODERNGEOSCIENCES.com MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS Near Equipment Inspection Summary: Equipment Number Leaks* Unlabeled NORM** Labeled NORM** Wells 1 0 0 0 Separators 1 0 0 0 ASTs 2 0 0 0 Other 1 3 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. ■ 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 other than noted below: • Ordinance Item B.3.a signage not present. • Additional signage not present— mailing address, emergency number (911), City's Gas Well Division telephone number,and TCEQ's Regional Office telephone number. ■ 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 5100 THOMPSON TERRACE,COLLEYVILLE,TEXAS 76034 1 F 682.223.1593 1 P 682.223.1322 www.MODERNGEOSCIENCES.com <S1 MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS The Leak Rate and NORM Rate for this padsite over time are presented below: Leak and NORM Rate 4 a 3 � 2 O z '�q Y 1 c� a J 0 2018 2019 2020 2021 2022 2023 2024 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 2025. 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 F 682.223.1593 I P 682.223.1322 www.MODERNGEOSCIENCES.com <S MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS DATE May 15, 2024 PROJECT 24003 PADSITE INSPECTION REPORT Padsite No. 047—Vaughn 1H 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 2024 MODERN GEOSCIENCES.ALL RIGHTS RESERVED. www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name: Vaughn 1H(#047) Operator: EagleRidge Inspection Date:04116124 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: None 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:Signage not present(detailed in field inspection results summary). 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:Additional signage not present(detailed in field inspection results summary). ❑ ❑ ❑ Item B.3.c: "DANGER NO SMOKING ALLOWED"signage present. Comments: No smoking signage not present(detailed in field inspection results summary). ❑ ❑ ❑ 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: Overgrown vegetation noted (detailed in near-equipment summary). 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 24003 1 MAY 15,2024 1 PAGE 1 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name: Vaughn 1H(#047) Operator: EagleRidge ►nspection Date:04116124 ►nspectors:ZT, SB MODERN G E O S C I E N C E 5 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 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. PROJECT 24003 1 MAY 15,2024 1 PAGE 2 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name: Vaughn 1H(#047) Operator: EagleRidge Inspection Date:04116124 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 (ltR/hr; max): Date Reported': Date Addressed': 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': AST A None <15 NA NA AST B 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 INSPtG I IUN KESULTS — UUN. mNUILLAKY t Location ID: Leaks (OG I): NORM (jiR/hr; max): Date Reported': Date Addressed 2 Compressor A None <15 NA NA Ancillary A None <15 NA NA Ancillary B None <15 NA NA General Notes: Overgrown vegetation noted along access road. According to the Operator representative, all vegetation observations were addressed as of May 14, 2024, thus the vegetation 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 PROJECT 240031 MAY 15,2024 1 PAGE 3 www.MODERNGEOSCIENCES.com v MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS PHOTOGRAPHIC DOCUMENTATION www.MODERNGEOSCIENCES.com PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS 40 No. 1 View of Well A. No. 2 Additional view of Well A. ( 4 W as I"� ✓ - �� No. 3 View of Separator A. No.4 View of ASTs. M No. 5 View of ancillary. No. 6 View of Compressor A. www.MODERNGEOSCIENCES.com v MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS FIGURES www.MODERNGEOSCIENCES.com Operator-Eagleridge Padsite Location Well A-API No. 12132624 q � • Denton B--p Source:ESRI Legend QWell Separator t ; O AST Compressor i A i Ancillary Equipment t, �rO' IB A t;if B i ® Foam Lines i observation Path Padsite 0 25 50 PROJECT NO. 24003 F I C,U P E_ M Feet DRAWN: 04 22 24 PADSITE MAP This figure was prepared using data from a variety of sources DRAWN BY SB : No warranty is made as to the accuracy or completeness of data CHECKED BY ZT provided through third parties. All data contained herein is MODERN G E O S C I E N C E S Vaughn 1 H(Padsite No.47) subject to change without notice.This figure is not intended far use as a FILE fJAME 3502 Jim ChriStal Road legal survey or construction design document If denoted, wind Denton,Texas direction represents dominant wind direction observed during field activities TRUSTED ENVIRONMENTAL ADVISORS Denton Padsites mxd