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2019-086 Particulate Matter MonitoringDate: April 26, 2019  Report No. 2019-086       INFORMAL STAFF REPORT TO MAYOR AND CITY COUNCIL SUBJECT: Provide information about particulate matter (PM) monitoring results for gas wells Payne #1 and #2. EXECUTIVE SUMMARY: During the April 16 Council public hearing for the Windsor Drive Apartments specific use permit (S18-0008i) the monitoring results for particulate matter 10 microns and 2.5 microns (PM10 and PM2.5) for gas wells Payne #1 and #2 obtained on July 20, 2018 were brought up by Mr. Ed Soph as evidence of PM emissions generated by the nearby gas wells that, in his opinion, would affect future residents of the proposed development. City staff have researched the PM monitoring history upwind and downwind for those two wells as well as the regional conditions for PM in the air during July 2018. The memo from Modern Geoscience explaining the monitoring results and the context in which those results should be interpreted that was emailed to the Council last Monday contained a typo on the graphic displayed on page 2. A corrected memo is attached. BACKGROUND: Denton gas well monitoring program is designed with the goal of obtaining accurate, representative, and defensible monitoring data of the gas wells activity in the city, and it gives monitoring priority to those well sites closer to protected (or sensitive) land uses. “High” priority wells are those that are less than 300 feet from sensitive uses, “Moderate” priority sites are those that are greater than 300 to 1000 feet, and “Low” priority are those that are greater than 1,000 feet. Well sites Payne #1 and #2 are classified as High priority and are monitored twice every year by Modern Geoscience contractor and twice by the city gas well inspector. Air quality parameters are measured at the fenceline boundary of the well sites, upwind (ambient air coming into the well site) and downwind (ambient air leaving the site) with the idea that differences between the monitoring readings would indicate potential pollutant contributions by the well sites. Standard monitoring and sampling protocols supported by TCEQ, EPA, and the gas well industry are used. The attached memo from Modern Geoscience provides some general information of what PM is and how is measured, the monitoring history of well sites Payne #1 and #2, the most recent results for the April 2019 inspections, and clarifications for Mr. Soph statements. Please let me know if I can provide any additional information. CONCLUSION: This IRS has been provided for informational purposes. ATTACHMENT(S): April 18, 2019 Modern Geoscience Memorandum Date: April 26, 2019  Report No. 2019-086       STAFF CONTACT: Deborah Viera Assistant Director of Environmental Services 940.349.7162 Deborah.Viera@cityofdenton.com PROJECT 19003 | APRIL 18, 2019 | PAGE 1 WWW.MODERNGEOSCIENCES.COM DATE April 18, 2019 PROJECT 19003 ATTN Ms. Deborah Viera, AICP, CFM Assistant Director Environmental Services City of Denton 901A Texas Street Denton, Texas SUBJECT Technical Memorandum – Clarification Concerning Particulate Matter Data Padsite Nos. 13 and 14 (Payne 1 and 2 Padsites) Denton, Denton County, Texas Dear Ms. Viera: Modern Geosciences, LLC (Modern) is pleased to provide this Technical Memorandum to the City of Denton (City) providing responses to concerns expressed during the April 16, 2019 City Council meeting and consideration of a Specific Use Permit (SUP) for a mixed-use development near the above-referenced padsites. Since the concerns centered on a discussion of particulate matter, Modern has included a brief discussion of particulate matter prior to providing responses to the specific concerns raised. BACKGROUND ON PARTICULATE MATTER Particulate Matter (PM) can come in many sizes and shapes and can be made up of hundreds of different chemicals/minerals. Some are emitted directly from a source, such as construction sites, unpaved roads, fields, smokestacks or fires; however, most particles form in the atmosphere as a result of complex reactions of chemicals such as sulfur dioxide and nitrogen oxides, which are common pollutants emitted from power plants, industrial businesses and automobiles. PM will contain microscopic solids and/or liquid droplets that are so small that they can be inhaled and potentially cause health problems. According to the United States Environmental Protection Agency (EPA), particles less than 10 micrometers (microns) in diameter (PM10) pose the greatest risk. Fine particles smaller than 2.5 microns (PM2.5) are of particular concern as this fraction can travel far distances and remain in the air for days or weeks and are more readily absorbed into the body. Additionally, PM2.5 is the most common cause of reduced visibility (haze) in urban areas. A size comparison of PM particles is provided below. PROJECT 19003 | APRIL 18, 2019 | PAGE 2 WWW.MODERNGEOSCIENCES.COM Particulate Matter Size Reference (EPA 2014) RESPONSE TO COMMENTS The discussion of concerns during the recent council meeting included the use of data collected by Modern as part of our ongoing padsite inspection program in support of the City. Specific comments noted in the meeting by a resident and direct responses to each are included below for informational and clarification purposes.  Comment No. 1: The resident presented to council a “total” Particulate Matter (PM) result of 157 µg/m3 using data from two of Modern’s July 2018 Padsite Inspection reports for Padsite Nos. 13 and 14 (Payne Nos. 1 and 2). Response: This approach is incorrect in two different ways. The first is that adding two readings from two different sites would be equivalent to taking the temperature at two different properties and adding them. For example, it may be 80°F at my home and 88°F at my office, but the combined temperatures of 168°F does not represent an expected temperature at either location. The second misunderstanding is that PM10 can be added to PM2.5. In this case, PM10 is by definition already inclusive of PM2.5 since this measurement is a summation of ALL particulate 10 microns or less. PROJECT 19003 | APRIL 18, 2019 | PAGE 3 WWW.MODERNGEOSCIENCES.COM  Comment No. 2: The resident presented to council a World Health Organization (WHO) 24-Hour Mean comparison for PM2.5 and PM10 of 25 µg/m3 and 50 µg/m3. Response: While the initial screening employed by Modern during our inspections is the observation of any significant increase above an expected background level or upwind sample, there is a National Ambient Air Quality Standard (NAAQS) for PM2.5 (35 µg/m3) and PM10 (150 µg/m3) established by the EPA utilized for our reporting effort. These criteria are presented in our reports with a description of how the NAAQS is applied and how Modern utilizes PM as an indicator for other potential concerns. As our data represents a short 10 to 20-minute snapshot in time, it is important to also note that much more extensive monitoring is required to directly compare against a 24-hour mean. This is also further described in Modern’s reports. While the resident is correct to note the individual PM2.5 and PM10 results observed were slightly elevated from typical ambient levels during the July 2018 monitoring, to attach the generation of the PM to the padsites in question is not supported by the data since the background levels across the entire region were elevated (discussion below) and the upwind and downwind monitoring (discussion below) performed by Modern are nearly identical.  Comment No. 3 The resident continued, noting “these are only two wells out of the 315 located within the city limits. What are the cumulative effects of the particulate matter emissions of all those other wells on our air and on our health? How will the particulate matter from Payne Well No. 1 and 2 affect the health of the residents living in the proposed apartments?” Response: Modern agrees with the resident’s concern for how PM can affect the health of our community. To the resident’s point, this is why this parameter is one of many we evaluate during our padsite inspections. However, in this case, we need to dive a little deeper into the data to understand why the PM results in question are background in nature and not related to padsite operations at the time of our inspection. Evaluating Upwind and Downwind: As part of the City’s inspection program, Modern always includes an evaluation of both upwind (conditions coming to a site) and downwind (conditions leaving a site) to aid our understanding of potential contribution from a given padsite. Below are the up and downwind summaries for both padsites from the event referenced. PADSITE NO. 13 (PAYNE NO. 2): FROM MODERN’S JULY 2018 PADSITE INSPECTION REPORT Fenceline Screening Criteria: Yes No N/A Upwind Observations: Downwind Observations: PID > 100 ppbv (0.1 ppmv)? <1 ppbv <1 ppbv Radiation > 20 µR/hr? <15 µR/hr <15 µR/hr H2S > 80 ppbv (0.08 ppmv)? <5 ppbv <5 ppbv Methane > 500 ppmv? <5 ppmv <5 ppmv PM2.5 > 35 µg/m3? 23.27 µg/m3 22.81 µg/m3 PM10 > 150 µg/m3? 63.61 µg/m3 64.45 µg/m3 PROJECT 19003 | APRIL 18, 2019 | PAGE 4 WWW.MODERNGEOSCIENCES.COM The differences between upwind and downwind conditions for PM2.5 and PM10 are -2% and 1.3%, respectively and not suggestive of significant contribution from the padsite during the time of our inspection. PADSITE NO. 14 (PAYNE NO. 1): FROM MODERN’S JULY 2018 PADSITE INSPECTION REPORT Fenceline Screening Criteria: Yes No N/A Upwind Observations: Downwind Observations: PID > 100 ppbv (0.1 ppmv)? <1 ppbv <1 ppbv Radiation > 20 µR/hr? <15 µR/hr <15 µR/hr H2S > 80 ppbv (0.08 ppmv)? <5 ppbv <5 ppbv Methane > 500 ppmv? <5 ppmv <5 ppmv PM2.5 > 35 µg/m3? 21.17 µg/m3 21.56 µg/m3 PM10 > 150 µg/m3? 47.47 µg/m3 47.77 µg/m3 The differences between upwind and downwind conditions for PM2.5 and PM10 are 1.8% and 0.6%, respectively and not suggestive of significant contribution from the padsite during the time of our inspection. Understanding Background Conditions: Anytime you are evaluating air quality data, it is important to understand the ambient conditions expected for a given area. In this case, there is a regional reference that can be utilized in the Texas Commission on Environmental Quality (TCEQ) Continuous Ambient Monitoring Station (CAMS) No. 56, located at the Denton Airport approximately two (2) miles southwest of the padsites in question. While CAMS No. 56 does not collect PM10 data, it does collect hourly PM2.5 data. During the month of July in 2018, PM2.5 ranged up to an hourly average of 39.1 µg/m3. Unfortunately, the TCEQ’s data set does not include July 20th specifically, but a look at the available data sets confirm this part of the year encountered several days where elevated PM appears to have been occurring due to conditions unrelated to the padsite. An additional reference that could be utilized is CAMS No. 60 at Dallas/Hinton which is roughly 34 miles southeast of the padsites in question and also collects hourly PM2.5 data. It should be noted this CAMS is within a city that does not have oil or gas wells. CAMS No. 60 encountered a maximum PM2.5 of 50.4 µg/m3 in July 2018 and on July 20, 2018 had a maximum of 34.4 µg/m3 and 24-hour average of 18.5 µg/m3. Based on the available background data, the observed PM data appears consistent with a regional range of values seen across Denton and Dallas in July 2018. Continued Inspection: As noted within our padsite inspection reports, we understand our data represents only the period of time we are given access to the padsites. However, Denton has incorporated different inspection requirements within its program based on the padsite’s proximity to sensitive receptors like the nearby residential area. In this case, Modern’s inspection of Padsite No. 14 (Payne No. 1) in 2017 led to its priority being elevated from Moderate to High which brings with it additional fenceline monitoring parameters and a higher frequency of inspection (twice annually). One way to address the concerns raised by the resident is to continue a risk-based PROJECT 19003 | APRIL 18, 2019 | PAGE 5 WWW.MODERNGEOSCIENCES.COM inspection program that ensures the City receives the necessary data needed to make informed decisions. As a result, on the continued inspection program, Modern can add some additional information concerning PM monitoring results at these padsites from other events. Below are the fenceline data from Modern’s first 2018 inspection event and from our forthcoming April 2019 reports for reference. PADSITE NO. 13 (PAYNE NO. 2): FROM MODERN’S FEBRUARY 2018 PADSITE INSPECTION REPORT Fenceline Screening Criteria: Yes No N/A Upwind Observations: Downwind Observations: PID > 100 ppbv (0.1 ppmv)? <1 ppbv <1 ppbv Radiation > 20 µR/hr? <15 µR/hr <15 µR/hr H2S > 80 ppbv (0.08 ppmv)? <5 ppbv <5 ppbv Methane > 500 ppmv? <5 ppmv <5 ppmv PM2.5 > 35 µg/m3? 3.22 µg/m3 3.57 µg/m3 PM10 > 150 µg/m3? 13.7 µg/m3 16.5 µg/m3 PADSITE NO. 13 (PAYNE NO. 2): FROM MODERN’S FORTHCOMING APRIL 2019 PADSITE INSPECTION REPORT Fenceline Screening Criteria: Yes No N/A Upwind Observations: Downwind Observations: PID > 100 ppbv (0.1 ppmv)? <1 ppbv <1 ppbv Radiation > 20 µR/hr? <15 µR/hr <15 µR/hr H2S > 80 ppbv (0.08 ppmv)? <5 ppbv <5 ppbv Methane > 500 ppmv? <5 ppmv <5 ppmv PM2.5 > 35 µg/m3? 6.51 µg/m3 6.54 µg/m3 PM10 > 150 µg/m3? 21.31 µg/m3 19.54 µg/m3 PADSITE NO. 14 (PAYNE NO. 1): FROM MODERN’S FEBRUARY 2018 PADSITE INSPECTION REPORT Fenceline Screening Criteria: Yes No N/A Upwind Observations: Downwind Observations: PID > 100 ppbv (0.1 ppmv)? <1 ppbv <1 ppbv Radiation > 20 µR/hr? <15 µR/hr <15 µR/hr H2S > 80 ppbv (0.08 ppmv)? <5 ppbv <5 ppbv Methane > 500 ppmv? <5 ppmv <5 ppmv As a Moderate padsite, PM was not initially evaluated. PADSITE NO. 14 (PAYNE NO. 1): FROM MODERN’S FORTHCOMING APRIL 2019 PADSITE INSPECTION REPORT Fenceline Screening Criteria: Yes No N/A Upwind Observations: Downwind Observations: PID > 100 ppbv (0.1 ppmv)? <1 ppbv <1 ppbv Radiation > 20 µR/hr? <15 µR/hr <15 µR/hr H2S > 80 ppbv (0.08 ppmv)? <5 ppbv <5 ppbv Methane > 500 ppmv? <5 ppmv <5 ppmv PM2.5 > 35 µg/m3? 6.38 µg/m3 6.39 µg/m3 PM10 > 150 µg/m3? 22.09 µg/m3 21.32 µg/m3 PROJECT 19003 | APRIL 18, 2019 | PAGE 6 WWW.MODERNGEOSCIENCES.COM As recorded in the fenceline data above, the fenceline monitoring recorded during preceding and following inspections did not encounter elevated readings or conditions suggestive significant impact to off-site properties was occurring. Modern did observe elevated ambient PM levels during the July 2018 event, but this was demonstrated to be associated with a regional event and not padsite operations. However, it is important to note that leaks from separators and aboveground storage tanks were identified by Modern during our inspection efforts. Following communication of these action items, each was reportedly addressed by the operator. It is Modern’s opinion that the optimum approach to minimizing the potential that an oil or gas padsite impact a neighboring property is to have a comprehensive inspection program that effectively identifies leaking equipment and/or fenceline concerns early and communicates these to an operator in a manner that results in corrective action. Better data leads to better decisions. CLOSING We appreciate the opportunity to assist the City in a discussion of air quality. If we can help in any other manner or participate in future meetings, please let us know. Should you have comments or questions concerning this letter, please contact the undersigned at your convenience. Respectfully submitted, Kenneth S. Tramm, PhD, PG, CHMM SENIOR PROJECT MANAGER MODERN GEOSCIENCES TEXAS REGISTERED GEOSCIENCE FIRM 50411 TEXAS REGISTERED ENGINEERING FIRM F-16201 TCEQ RCAS NO. 0000167