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2024.10.02_Vendor_Inspection_Padsite068 <Tsl MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS Padsite Inspection Report DATE November 28, 2024 Padsite No. 068(Hudson-Breen) PROJECT 24003 Operator: EagleRidge Location: ®City of Denton ❑ Denton ETJ ATTN City of Denton TRAKiT ID: 1108-0647, 1108-0303 215 East McKinney Street API: 12132701,12131800 Denton,Texas 76201 Insp. Date: 10/02/24 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: • Bare pipe/corrosion noted on AST A. According to the Operator representative, all corrosion observations were addressed as of October 28, 2024, thus the corrosion observations are no longer considered Action Items. Future verification suggested. • Overgrown vegetation noted around Well A and B and along access road. According to the Operator representative,all overgrown vegetation observations were addressed as of October 28, 2024, thus the overgrown vegetation observations are no longer considered Action Items. Future verification suggested. • No fencing present around Separator C,Compressor A,and Ancillary C.According to the Operator representative, all fencing observations were addressed as of October 28, 2024, thus the fencing observations are no longer considered Action Items. Future verification suggested. • Ordinance Item B.3.a signage not present. • Padsite entrance signage needs replaced. ■ 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 2 0 0 0 Separators 3 0 0 0 ASTs 3 2 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. • Padsite entrance signage needs replaced. ■ 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 3 v 41 °C 2 OOF O z Y 1 f6 G1 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 second 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 November 28, 2024 PROJECT 24003 PADSITE INSPECTION REPORT Padsite No. 068—Hudson-Breen 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 ©2024 MODERN GEOSCIENCES.ALL RIGHTS RESERVED. www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Hudson-Breen (#068) Operator: EagleRidge Inspection Date:10102124 Inspectors:ZT, SP MODERN G E O S C I E N C E S 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 13.1: Light reflective sign at entrance gate present. Comments: Padsite entrance signage needs replaced. Item B.2.a/b: Appropriate fencing, buffering, landscaping, and/or screening present ® ❑ ❑ within 300ft of all equipment (as applicable). Comments: Fencing not present (detailed in near-equipment summary). Item 13.3.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. Item 13.3.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: Padsite entrance signage needs replaced. ❑ ❑ ❑ Item 13.3.c: "DANGER NO SMOKING ALLOWED"signage present. Comments: None ® ❑ ❑ Item 13.4:All equipment painted with no bare pipe, rust, blisters, or stains present. Comments: Bare pipe/corrosion noted (detailed in near-equipment summary). ® ❑ ❑ 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 13.9: 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,2024. PROJECT 24003 1 NOVEMBER 28,2024 1 PAGE 1 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Hudson-Breen (#068) Operator: EagleRidge Inspection Date:10102124 ►nspectors:ZT, SP MODERN G E O S C I E N C E S TRUSTED ENVIRONMENTAL ADVISORS IVEAK r-uUIPME, • 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 •nstituent: Methane tvOCS H2S NORM Fenceline: 500 ppmv 3 0.1 ppmv 4 0.08 ppmv' 20 µR/hr 6 Equipment: DPIR Meter PID H2S Meter Radiation Meter Resolution: 1 ppmv 0.001 ppmv 0.003 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 FIR 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. PROJECT 24003 1 NOVEMBER 28,2024 1 PAGE 2 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Hudson-Breen (#068) Operator: EagleRidge Inspection Date:10102124 Inspectors:ZT, SP MODERN G E O S C I E N C E S TRUSTED ENVIRONMENTAL ADVISORS NEAR EQUIPMENT INSPECTION RESULTS: INSPECTIC JILTS -UN Location ID: Leaks (OGI): NORM (�tRffir; max): Date Reported': Date Addressed': Well A None <15 NA NA Well B None <15 NA NA General Notes: Overgrown vegetation noted around Well A and B and along access road. According to the Operator representative,all overgrown vegetation observations were addressed as of October 28, 2024,thus the overgrown vegetation 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 INSrtI;I IUN L Location ID: Leaks (OGI): NORM ([iR/hr; max): Date Reported': Date Addressed': Separator A None 20 NA NA Separator B None <15 NA NA Separator C None <15 NA NA General Notes: No fencing present around Separator C. According to the Operator representative, all fencing observations were addressed as of October 28, 2024, thus the fencing 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 1\JIV Ixr-61-ILTS — 1 mime Lim l 1 CR t I AV 1 J Location ID: Leaks (OGI): NORM (ltR/hr; max): Date Reported': Date Addressed 2: AST A Thief Hatch and Enardo Valve <15 10/04/24 10/28/24 AST B None <15 NA NA AST C None <15 NA NA General Notes: Bare pipe/corrosion noted on AST A. According to the Operator representative, all corrosion observations were addressed as of October 28, 2024, thus the corrosion 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 INSPECTION RESUL-TS— COMPRESSORS OR ANCILLARY EQUIPMENT Location ID: Leaks (OGI): NORM (jiRffir; max): Date Reported': Date Addressed': Compressor A None <15 NA NA Ancillary A None <15 NA NA Ancillary B None <15 NA NA Ancillary C None <15 NA NA General Notes: No fencing present around Compressor A and Ancillary C. According to the Operator representative, all fencing observations were addressed as of October 28, 2024, thus the fencing 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 PROJECT 240031 NOVEMBER 28,2024 1 PAGE 3 www.MODERNGEOSCIENCES.com AWWIN PADSITE INSPECTION REPORT Padsite Name:Hudson-Breen (#068) Operator: EogleRidge Inspection Date:10102124 Inspectors:ZT, SP MODERN G E O S C I E N C E S TRUSTED ENVIRONMENTAL ADVISORS FENCELINE INSPECTION RESULTS: - -• . •• Avg. Wind Direction (to): N Avg. Wind Speed (mph): 1.1 Bar. Pressure ("Hg): 29.45 9. Avg.Temp (DF): 86.4 Humidity(%): 49.5 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 Other perimeter/fenceline observations suggestive of releases or concerns: None Comments: None Notes: 1- Represents the maximum discrete sampling result recorded by Modern across fenceline screening alignment. 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 24003 1 NOVEMBER 28,2024 1 PAGE 4 www.MODERNGEOSCIENCES.com v MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS PHOTOGRAPHIC DOCUMENTATION www.MODERNGEOSCIENCES.com V PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS #4YR3'i LCE No. 1 Leaks observed at a thief hatch and No. 2 Leaks observed at a thief hatch and enardo valve on AST A. enardo valve on AST A in High Sensitivity Mode. a M1' x sn -1 WFF No. 3 View of wells. No.4 View of separators. 1 ,.ram a•- h � � Y No. 5 View of ASTs. No. 6 View of Compressor A. www.MODERNGEOSCIENCES.com v MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS FIGURES www.MODERNGEOSCIENCES.com Operator-Eagleridge Padsite Location WellA-API No. 12132701 ' Well B-API No. 12131800 C� Denton ❑ : Corinth �............... m ................. . _ Basemap Source:ESRI r-- t _ --t t Legend Well Milk El p!T Separator OAST OCompressor Ancillary Equipment OFoam Lines r Upwind Air Sampling Point mDownwind Air Sampling Point j % •••110- Fenceline Screening Alignment C j A C Wind Direction(to) It A , %`; B % r_ _I Observation Path A i A ' O Padsite B r t f�C` PROJECT NO. 24003 FIGURE o ss so Feet DRAWN: 11.05.24 PADSITE MAP _ � ` r This figure was prepared using data from a variety of sources. DRAWN BY: SP No warranty is made as to the accuracy or completeness of data CHECKED BY: ZT provided through third parties. All data contained herein is Hudson-Breen Pad(Padsite No.68) subject to change without notice.This figure is not intended for use as a FILE NAME: 1887 Westcourt Road MODERN G E O S C I E N C E S 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