2024.04.16_Vendor_Inspection_Padsite062 <Tsl
MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
Padsite Inspection Report
DATE May 15, 2024 Padsite No. 062(Rayzor West 5)
PROJECT 24003 Operator: EagleRidge
Location: ®City of Denton ❑ Denton ETJ
ATTN City of Denton TRAKiT ID: 1110-0217,1110-0290,1110-0291,1208-
0358, 1208-0384,1208-0385
215 East McKinney Street 12134215, 12134216, 12134217, 12134301,
Denton,Texas 76201 API. 12134299,12134300
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 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:
• Water noted in well cellar of Well F.The presence of water in well cellars can accelerate
the corrosion process and deterioration of equipment. According to the Operator
representative,the water was removed as of May 14,2024,thus the water observations
are no longer considered Action Items. Future verification suggested.
• Ordinance Item B.3.a signage not present.
• Additional signage not present — mailing address, City's Gas Well Division telephone
number, and TCEQ's Regional Office telephone number.
■ 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 Inspection Summary:
Equipment Number Leaks* Unlabeled NORM** Labeled NORM**
Wells 6 0 0 0
Separators 7 1 0 0
ASTs 2 1 0 0
Other 1 3 1 0 1 0 0
*OGI leaks identified exclude operational low bleed components(<_6 scf/hr)
**NORM exceeding 50 µR/hr
5100 THOMPSON TERRACE,COLLEYVILLE,TEXAS 76034 1 F 682.223.1593 I P 682.223.1322
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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.
■ 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, 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
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MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
The Leak Rate and NORM Rate for this padsite over time are presented below:
Leak and NORM Rate
2
I= 1.5
0 1
Z
Y
� 0.5
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, GCHMM
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
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MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
DATE
May 15, 2024
PROJECT
24003
PADSITE INSPECTION
REPORT
Padsite No. 062—Rayzor West 5
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.
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PADSITE INSPECTION REPORT
Padsite Name:Rayzor West 5(#062) 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: None
❑ ❑ ❑ 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: Water noted in well cellars (detailed in near-equipment summary).
® ❑ ❑ 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
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PADSITE INSPECTION REPORT
Padsite Name:Rayzor West 5(#062) Operator: EagleRidge
Inspection 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
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PADSITE INSPECTION REPORT
Padsite Name:Rayzor West 5(#062) 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:
INSPECTION RESULTS -UN
Location ID: Leaks (OGI): NORM (�tRffir; max): Date Reported': Date Addressed':
Well A None <15 NA NA
Well B None <15 NA NA
Well C None <15 NA NA
Well D None <15 NA NA
Well E None <15 NA NA
Well F None <15 NA NA
General Notes: Water noted in well cellar of Well F. The presence of water in well cellars can accelerate the
corrosion process and deterioration of equipment. According to the Operator representative, the water was
removed as of May 14, 2024, thus the water observations are no longer considered Action Items. Future
verification suggested. 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 ([tR/hr; max): Date Reported': Date Addressed':
Separator A None <15 NA NA
Separator B None <15 NA NA
Separator C None <15 NA NA
Separator D None 25 NA NA
Separator E DV Controller <15 04/18/24 05/14/24
Separator F None <15 NA NA
Separator G 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
INSPECTION RESULTS—TANK BATTERY ASTS
Location ID: Leaks (OGI): NORM ([iR/hr; max): Date Reported': Date Addressed':
Former AST A NA NA NA NA
Former AST B NA NA NA NA
Former AST C NA NA NA NA
Former AST D NA NA NA NA
AST E Thief Hatch <15 04/18/24 05/14/24
AST F 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
PROJECT 240031 MAY 15,2024 1 PAGE 3
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PADSITE INSPECTION REPORT
Padsite Name:Rayzor West 5(#062) 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 (CONT.):
Location ID: Leaks (OGI): NORM (PR/hr; max): Date Reported': Date Addressed':
Compressor A None <15 NA NA
Ancillary A None <15 NA NA
Ancillary B 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 24003 1 MAY 15,2024 1 PAGE 4
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PHOTOGRAPHIC
DOCUMENTATION
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V
PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES
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' n
IF
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No. 1 Leak observed at a DV controller on No. 2 Leak observed at a DV controller on
Separator E. Separator E in High Sensitivity Mode.
I.
No. 3 Leak observed at a thief hatch on AST F. No.4 Leak observed at a thief hatch on AST F
in High Sensitivity Mode.
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L .f ��.�' n-�L u �!L'e:r 4.• �:be�k'$}.k x..t�`«e� n *'rev.:
No. 5 View of wells. No. 6 Additional view of wells.
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PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES
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i L
No. 7 View of separators. No.8 Additional view of separators.
r
No.9 View of ASTs. No. 10 Additional view of separators and ASTs.
1 t j
.a..., '•....v"ih .elm. ..�£.^ .p'.'.L:,j.cam,�..�_
No. 11 View of Compressor A. No. 12 Additional view of Compressor A.
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FIGURES
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Operator-Ea9lerid9e Padsite Location
Well A-API No. 12134300
Well B-API No. 12134299 Q
Well C-API No. 12134301
9M ik y+� Well D-API No. 12134217
Well E-API No. 12134216
Well F-API No. 12134215 "
B �►, Denton �
16
r ❑mac` •p
0 Out of Use
AST Storage Area
I Bz--p Source:ESRI
o
i 0 i Legend
1 1
1 C I Q Well
1' 1
D
Separator
F I O AST
1
1 1 1 F I O Former AST
1 j
OCompressor
1 1
E �,' G i Ancillary Equipment
I 1 I
1
Aj % q i ® Foam Lines
1
Observation Path
QPadsite
Out o� flUse
AST Storage Area
I I
I 1
PROJECT NO. 24003 F I r-,I_I P E_
0 25 50
�Feet 99 DRAWN; 04 24 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 Rayzor West 5 Pad(Padsite No.62)
subject to change without notice.This figure is not intended for use as a FILE IJANIE 3503 Jim Christal Road
MODERN G E O S C I E N
legal survey or construction design document If denoted, wind Denton,Texas
direction represents dominant wind direction observed during field activities TRUSTED ENVIRONMENTAL ADVISORSC E S Denton Padsites mxd