padsite inspection summary report - denton, texas...a succinct reporting format that provide sa...

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DATE January 2019

PROJECT 17153

PADSITE INSPECTION SUMMARY REPORT

FINAL 2018

PREPARED FOR City of Denton

215 East McKinney Street Denton, Texas 76201

PREPARED BY

______________________________________________

Zachary Tondre, MS, GIT PROJECT SCIENTIST

REVIEWED BY ______________________________________________

Kenneth S. Tramm, PhD, PG, CHMM SENIOR PROGRAM MANAGER

PROJECT 17153 | JANUARY 2019 | PAGE 2 WWW.MODERNGEOSCIENCES.COM

TABLE OF CONTENTS

1. INTRODUCTION ......................................................................................................................................... 5

1.1. Project Background ................................................................................................................................. 5

1.2. Program Design ....................................................................................................................................... 5

2. INSPECTION APPROACH ............................................................................................................................. 7

2.1. Ordinance and City Inspection Items ...................................................................................................... 7

2.2. Near-Equipment Inspection .................................................................................................................... 7

2.3. Fencline Monitoring ................................................................................................................................ 9

2.4. Contingency Sampling ........................................................................................................................... 10

2.5. Pre and Post-Inspection Activities ........................................................................................................ 12

3. INFRASTRUCTURE SUMMARY ...................................................................................................................13

3.1. City of Denton Padsites (Total in City Limits) ........................................................................................ 13

3.2. First Half 2018 (High, Moderate, and Selected Low Priority) ............................................................... 14

3.3. Second Half 2018 (High Prioirty) ........................................................................................................... 15

4. INSPECTION RESULTS ................................................................................................................................17

4.1. Identified Action Items ......................................................................................................................... 17

4.1.1. First Half 2018 ....................................................................................................................................... 17

4.1.2. Second Half 2018 .................................................................................................................................. 19

4.2. Addressed Action Items ........................................................................................................................ 21

4.2.1. First Half 2018 ....................................................................................................................................... 21

4.2.2. Second Half 2018 .................................................................................................................................. 23

4.3. Outstanding Action Items ..................................................................................................................... 25

4.3.1. First Half 2018 ....................................................................................................................................... 26

4.3.2. Second Half 2018 .................................................................................................................................. 28

5. ACTION ITEM RESULTS (DETAIL) ................................................................................................................31

5.1. First Half 2018 Summary ....................................................................................................................... 31

5.2. Second Half 2018 Summary .................................................................................................................. 32

5.3. Leaks (Methane) ................................................................................................................................... 33

5.3.1. First Half 2018 ....................................................................................................................................... 33

5.3.2. Second Half 2018 .................................................................................................................................. 34

5.4. NORM .................................................................................................................................................... 36


5.4.1. Total NORM Exceedances ..................................................................................................................... 36

5.4.1.1. First Half 2018 ....................................................................................................................................... 36

5.4.1.2. Second Half 2018 .................................................................................................................................. 38

5.4.2. Unlabeled NORM Exceedances ............................................................................................................. 39

5.4.2.1. First Half 2018 ....................................................................................................................................... 39

5.4.2.2. Second Half 2018 .................................................................................................................................. 40

5.5. Fenceline Monitoring ............................................................................................................................ 41

5.5.1. First Half 2018 ....................................................................................................................................... 41

5.5.2. Second Half 2018 .................................................................................................................................. 42

5.6. Compliance Monitoring ........................................................................................................................ 43

5.6.1. First Half 2018 ....................................................................................................................................... 43

5.6.2. Second Half 2018 ................................................................................................................................. 44

6. INSPECTION RESULTS (COMPREHENSIVE COMPARATIVE ANALYSIS) ..........................................................45

6.1. Leaks per Well (All Data) ....................................................................................................................... 45

6.2. NORM per Well (All Data) ..................................................................................................................... 46

6.2.1. Total NORM per Well ............................................................................................................................ 46

6.2.2. Unlabeled NORM per Well .................................................................................................................... 46

6.3. Action Items per Well (All Data) ........................................................................................................... 47

6.3.1. Identified Action Items per Well ........................................................................................................... 47

6.3.2. Addressed Action Items per Well ......................................................................................................... 48

6.3.3. Outstanding Action Items per Well....................................................................................................... 49

7. CONCLUSIONS AND RECOMMENDATIONS ................................................................................................50

7.1. Near-Equipment Inspection .................................................................................................................. 50

7.2. Fenceline Monitoring ............................................................................................................................ 50

7.3. Outstanding Action Items ..................................................................................................................... 51

7.4. Program Updates .................................................................................................................................. 53

8. IMPORTANT ACRONYMS...........................................................................................................................54

9. LIMITATIONS AND EXCEPTIONS ................................................................................................................56


TABLES

TABLE 1: PROGRAM DESIGN

TABLE 2: NEAR-EQUIPMENT CRITERIA

TABLE 3: FENCELINE CRITERIA

TABLE 4: PADSITE DATA SUMMARY

TABLE 5: FIRST HALF OF 2018 PADSITE DATA SUMMARY

TABLE 6: FIRST HALF 2018 – OUTSTANDING ACTION ITEM SUMMARY

TABLE 7: SECOND HALF 2018 – OUTSTANDING ACTION ITEM SUMMARY

FIGURES

FIGURE 1: PADSITE LOCATION MAP

FIGURE 2: PADSITE INSPECTION SUMMARY MAP


1. INTRODUCTION

Modern Geosciences (Modern) is pleased to provide this report as a summary of our inspection results for the City of Denton (City) concerning gas well padsites within the city limits during the first half of 2018.

1.1. PROJECT BACKGROUND Modern’s staff has been providing technical support and inspection services to municipalities addressing urban oil and gas concerns for over a decade. As part of these efforts, our staff has contributed to numerous ordinance revisions, gas drilling task forces, performed continuous air monitoring events, inspected hundreds of wells across Texas, and aided in the identification of hazardous site conditions that would have otherwise been left unaddressed. As part of the City’s desire to enhance its current inspection efforts, Modern was asked to provide programmatic support that would ensure enough high-resolution data was available to the community, operators, and city staff for prioritization of any repairs or corrective action needed.

1.2. PROGRAM DESIGN Our inspection program was tailored to meet the City’s project goals of: Developing a comprehensive GIS-based tracking program for each padsite inclusive of existing

infrastructure (e.g., wells, separators, compressors); Identifying leaks associated with each padsite in a manner that can be tracked and communicated

efficiently; Identifying non-compliance concerns associated with each padsite (e.g., corrosion issues, spills/releases,

unmarked equipment with excessive radiation); Collection of air monitoring data at padsite fencelines when near sensitive receptors; Contingency sampling when fenceline data suggested possible environmental impact to neighboring

areas; and A succinct reporting format that provides a clear summary of our findings, highlights outstanding action

items, and allowed integration with the City’s online access to the reports. To ensure the padsites were adequately evaluated, the City prioritized inspections as low, moderate, and high based on proximity to sensitive receptors (e.g., schools, residential areas). Padsite inspection efforts include the performance of a compliance evaluation (e.g., signage, equipment maintenance, fire department access, landscaping, safety requirements) with additional leak detection efforts to better identify and communicate potential leaks and/or fugitive emission impacts to the City, operator, and community members. A summary of the program design is provided below in Table 1.


TABLE 1 – PROGRAM DESIGN

Inspection Item High Mod. Low Comment

Inspection Schedule Twice each year x <300’ from sensitive receptor

Once every year x >300’; <1,000’ from sensitive receptor

Once every 2 years x >1,000’ from sensitive receptor

Compliance Inspection Multiple item checklist x x x Verify existing ordinance requirements are being met

Near-Equipment Inspection

Leak evaluation x x x Use of Optical Gas Imaging (OGI) per Quad Oa Methodology

Naturally Occurring Radioactive Material (NORM) evaluation and signage

x x x Radiation Meter (uR/hr - RRC req.); Exceedances noted per RRC Guidance

Fenceline Inspection Meteorological data x x Wind Direction, Speed, Barometric Pressure

Total Volatile Organic Compounds (tVOCs) x x Use of PID (ppbv resolution)

Radiation x x Use of Radiation Meter (uR/hr resolution - RRC req.)

Hydrogen Sulfide (H2S) x x Use of H2S Meter (ppbv resolution - CAA req.)

Methane x x Use of DP-IR Meter (ppmv resolution)

Particulate matter (PM) x PM2.5 & PM10 (ug/m3 resolution; ~10-minute dataset)

Noise x Use of Class 1 Microphone with 3 Octave Band (Leq dBA)

Contingency Sampling/ Monitoring Support (*as needed) Real-time continuous air monitoring * * * Includes Methane, H2S, Met Data, tVOCs, PM, Ozone

H2S (30-minute sample) * * * Discrete samples per ASTM to confirm CAA exceedance

Discrete VOC sampling (~50+ compounds) * * * Discrete samples per EPA TO-17M to determine VOC of interest


2. INSPECTION APPROACH

2.1. ORDINANCE AND CITY INSPECTION ITEMS Prior to project initiation, Modern performed a review of current ordinance and city inspection requirements (e.g., signage, equipment maintenance, fire department access, landscaping, safety requirements) to be included in this inspection effort in the form of a city-approved checklist.

2.2. NEAR-EQUIPMENT INSPECTION During each inspection, Modern performed an Audio, Visual, and Olfactory (AVO) field inspection, as well as recording monitoring results with the use of optical gas imaging systems (e.g., FLIR cameras) to identify leaks and radiation meters to confirm conditions at accessible equipment. During oil and gas production, scale can collect within equipment and concentrate until radiation levels exceed applicable regulatory criteria. This is generally referred to as Technologically-Enhanced Naturally Occurring Radioactive Material (NORM). A goal of near-equipment inspection activities is to evaluate the operational condition of well heads, well connections, flanges, valves, pumps, well head fluids (i.e., corrosion inhibitors), production piping, visible system pressure gauges, separator systems, secondary containment integrity, above-ground storage tanks (i.e., thief hatch, ventilation), fluid disposal transfer points, compressor systems, chemical storage areas, and note any obvious signs of staining, spills, or releases.

View of OGI efforts during a padsite inspection event.

Example of leaking pressure control valve (e.g., Enardo) from a tank battery system.


Example of discrete NORM evaluation. Example of tagged equipment in need of repair

or replacement.

Our leak definitions are set at either positive visual observation with the OGI equipment, or if applicable, direct measurement for quantification. A summary of near-equipment criteria is provided below. 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). Also represents 20% of the Lower Explosive Limit. 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.

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.

The leak/exceedance references represent non-ambient conditions that would typically indicate a significant contribution of COC emissions from the inspected equipment. Normal intermittent operation of pneumatic equipment would not be considered a leak. If a continuous leak is identified, and operator granted permission, leaks are tagged to allow easy identification after the field event. When a leak is associated with a low-bleed device, we will request manufacturer documentation so this is recorded in the report and not reported as a leak.

TABLE 2 – NEAR EQUIPMENT CRITERIA Constituent: Methane NORM At Release: 10,000 ppmv 1 50 µR/hr 2 Equipment: OGI Camera Radiation Meter Resolution: 3,000-10,000 ppmv 1 µR/hr


The OGI system is verified in the field prior to leak detection screening using a known standard to confirm methane leak detection goals are met. In general, this includes verification at both three (3) and 10 meters if screening will be performed within these distances. Additionally, all other equipment used for near-equipment is calibrated per manufacturer specifications and verified daily prior to inspections.

2.3. FENCLINE MONITORING During the inspection events for moderate and high priority sites Modern evaluated both apparent up and downwind conditions at the padsite fenceline to allow record of site conditions in our final report. Inspection efforts include an evaluation of methane concentrations, radiation, hydrogen sulfide, and total VOCs for moderate and high priority sites. For high priority sites, noise and particulate matter monitoring is also included. Equipment is calibrated per manufacturer specifications and verified daily prior to inspections.

View of fenceline screening for hydrogen sulfide. Example of noise monitoring during fenceline screening activities.

View of particulate sampling during fenceline screening.

View of tVOC monitoring during fenceline screening activities.


A summary of fenceline monitoring criteria is provided below.

Notes: 1- Represents 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.

2- Consistent fenceline concentrations of 0.1 ppmv or more 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.

3- 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.

4- 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.

5- 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 that may be present. Individual COC monitoring required for comparison with AMCVs or ESLs.

6- NAAQS for PM10. Further monitoring will be needed to confirm if a continuous average (24-hr, 3yr) exceedance is indicated.

7- 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 period 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.

2.4. CONTINGENCY SAMPLING

In addition to the items above, Modern is able to provide contingency sampling for individual VOCs, hydrogen sulfide, and deploy real-time monitoring stations for multiple constituents when fenceline screening suggests a concern or when directed by the City. If field monitoring with discrete sampling at the fenceline identifies conditions indicative of elevated COCs, Modern will collect a time-weighted sample for evaluation of VOCs using EPA Method TO-17, hydrogen sulfide using ASTM Method D5504, and/or deploy real-time air monitors. For discrete VOC sampling, Modern uses conditioned thermal desorption tubes to collect an upwind and downwind air sample. A calibrated pump connected to the tube is used to allow collection of a representative sample. The air is sampled at a rate of 100 ml/min for up to 20 minutes. The sampling tube is affixed to a static sample point to allow collection of air from approximately five feet six inches (5.5’) above ground (breathing zone). The sampling systems (e.g., pumps, tubing, attachments) are evaluated before and after each sampling event to ensure sample integrity is maintained. Upon completion of the sampling event, the tubes are placed in

TABLE 3 – FENCELINE CRITERIA Methane tVOCs H2S NORM PM2.5 PM10 Noise Fenceline: 500 ppmv 1 0.1 ppmv 2 0.08 ppmv 3 20 µR/hr 4 35 µg/m3 (5) 150 µg/m3 (6) 65 dBA 7

Equipment: DPIR Meter PID H2S Meter Radiation Meter

Particulate Meter

Particulate Meter

Sound Meter

Resolution: 1 ppmv 0.001 ppmv 0.003 ppmv 1 µR/hr 1 µg/m3 1 µg/m3 1 dBA


a sealed inert container and placed on ice and sampling information (e.g., tube serial number, sample ID, time, flow rate) is recorded on the chain of custody. The sampling and monitoring efforts are performed in accordance with applicable elements of EPA Method TO-17. Following sample collection, the thermal desorption tubes are analyzed by Modern using a gas chromatograph/mass spectrometer (GC/MS) and thermal desorber to allow identification and quantification of individual chemicals of concern. All analyses are performed in accordance with Modern’s internal Quality Assurance Project Plan (QAPP) governing sample analysis procedure. Additionally, Modern reviews the resulting chromatograms of each sample using both the National Institute of Standards (NIST) Library and the Automated Mass Spectral De-covolution and Identification Software (AMDIS) library to further evaluate any Tentatively Identified Compounds (TICs) not within the current calibration library.

Example air sampling using TD tubes for VOC analysis

Example chromatogram with upwind (blue) and downwind (red) samples.

View of air quality monitors being calibrated prior to field deployment.

Example view real-time air quality monitoring data. H2S, Ozone, PID result shown in ppmv.


2.5. PRE AND POST-INSPECTION ACTIVITIES Modern coordinates with each operator prior to the inspection so a representative can be present to address leaks and allow re-inspection when present. Additionally, Modern communicates the results of the inspection with the operators so any corrective action completed after the inspection, within approximately two (2) weeks, can be recorded in the final report. An individual padsite inspection report was prepared for each padsite with the results of the inspection, figure with equipment inspected (unique identifiers), photographs of leaking equipment (e.g., OGI pictures), graph of noise (sound pressure) results and pure-tone evaluation (spectral analysis), and notation of Action Items requiring further attention. Any outstanding issues identified, including ordinance deficiencies, leaks still requiring attention, required NORM labels, etc., are summarized in Modern’s inspection reports as “Outstanding Action Items.”

View of leak repairs being confirmed during field inspection efforts.

Example report figure depicting equipment, wind direction, and fenceline monitoring points.

Example Noise monitoring summary graph with threshold limit (red) and average level (solid black line).

Example particulate matter summary chart from a padsite inspection report.


3. INFRASTRUCTURE SUMMARY

Modern was selected to perform inspections on 290 wells and associated production equipment located on 157 individual padsites in Denton, Texas. The nine (9) operators in Denton’s city limits include: Atmos Energy Corporation (Atmos); Devon Energy Corporation (Devon); EagleRidge Operating LLC (EagleRidge); Endeavor Energy Resources LP (Endeavor); EnerVest Operating, LLC (EnerVest); Hillwood Energy (Hillwood); Krocan Energy Corporation (Krocan); Sage Natural Resources (Sage); and XTO Energy Inc. (XTO). A summary of padsite information is provided below (Table 4) and presented on Figure 1 (attached). Additionally, Modern has provided individual Padsite Inspection Reports for each padsite with details from the near-equipment inspection results, fenceline monitoring results, and supporting optical gas imaging photos, figures, and Identified Action Items. These are available through the City website directly.

3.1. CITY OF DENTON PADSITES (TOTAL IN CITY LIMITS)

TABLE 4 – PADSITE DATA SUMMARY

Operator Number of padsites Number of natural

gas wells Number of separators

Number of ASTs

Atmos 7 9 1*** 1*** Devon 28 61 60 64 EagleRidge 61 100 105 132 Endeavor 9 15 17 37 EnerVest 23 50 59 65 Hillwood 5 14 15 18 Krocan 3 3 3 4 Sage 19 36 24 39 XTO 2 2 2 4

Total: 157* 290** 286** 364** *Padsite No. 157 was added after project initiation **Approximate - low priority padsites to be inspected in 2019 (13 Devon and 10 EagleRidge) ***Atmos wells are not technically production wells as they are utilized for storage only and do not need extensive

separators and AST systems.


3.2. FIRST HALF 2018 (HIGH, MODERATE, AND SELECTED LOW PRIORITY) This report provides a summary of Modern’s findings for the first half of 2018. Padsite inspections were performed between December 2017 and April 2018.

TABLE 5 – FIRST HALF OF 2018 PADSITE DATA SUMMARY



Number of ASTs

Atmos 7 9 1 1 Devon 15 33 33 26 EagleRidge 51 71 80 98 Endeavor 9 15 17 37 EnerVest 23 50 59 65 Hillwood 5 14 15 18 Krocan 3 3 3 4 Sage 19 36 24 39 XTO 2 2 2 4

Total: 134* 233** 234 292 *Does not include low priority padsites to be inspected in 2019 (13 Devon and 10 EagleRidge) **Does not include three (3) wells plugged prior to inspection on Padsite Nos. 32, 114, and 121.


3.3. SECOND HALF 2018 (HIGH PRIOIRTY) This report provides a summary of Modern’s findings for the second half of 2018. Padsite inspections were performed in July 2018.

TABLE 5 – Second HALF OF 2018 PADSITE DATA SUMMARY



Number of ASTs

Atmos 0 0 0 0 Devon 0 0 0 0 EagleRidge 19 37 44 44 Endeavor 4 5 5 11 EnerVest 6 15 16 32 Hillwood 0 0 0 0 Krocan 0 0 0 0 Sage 2 2 2 1 XTO 0 0 0 0

Total: 31* 59 67 88 *Only includes high priority padsites


4. INSPECTION RESULTS

The following presents a summary of Modern’s inspection results for 2018. Any item requiring corrective action by the operator is referred to as an Action Item. This may include signage for compliance, fencing issues, leaks, fenceline data exceeding applicable air quality criteria, etc. There are three categories of Action Items: Identified Action Items – These are any compliance item or inspection/monitoring exceedance noted in

the field by Modern. Includes all leaks, NORM exceedances, or other issues that requires corrective action by the operator;

Addressed Action Items – These are the Identified Action Items that were either addressed during our field inspection by the operator when found or reported to Modern by the operator to have been addressed after the inspection and before reporting; and

Outstanding Action Items – These are items that remained unaddressed by an operator as of the time

of our reporting to the City in our padsite-specific reports.

Completed Action Items – Outstanding Action Items that were addressed by the operator to the satisfaction of the City Inspector following Modern’s inspection are noted for this report.

Addressed and Outstanding Items receive follow up inspections by City staff and/or Modern until each item has been addressed to the satisfaction of the City.

4.1. IDENTIFIED ACTION ITEMS 4.1.1. FIRST HALF 2018

A total of 259 Identified Action Items on 76 padsites were noted during the inspection of 134 padsites.


Identified Action Items per Type by Operator

The above graphic provides a summary of the number of Identified Action Items per type for each operator.


Padsites with Identified Action Items by Operator

The above graphic provides a summary of the number of padsites with Identified Action Items for each operator.

4.1.2. SECOND HALF 2018 A total of 99 Identified Action Items on 26 padsites were noted during the inspection of 31 padsites.


Identified Action Items per Type by Operator

The above graphic provides a summary of the number of Identified Action Items per type for each operator.


Padsites with Identified Action Items by Operator

The above graphic provides a summary of the number of padsites with Identified Action Items for each operator.

4.2. ADDRESSED ACTION ITEMS 4.2.1. FIRST HALF 2018


Of the 259 Identified Action Items noted on 76 padsites, 211 were noted as Addressed Action Items at 58 padsites once corrected during our field inspection or reported as corrected prior to our reporting.

Addressed Action Items per Type by Operator

The above graphic provides a summary of the number of Addressed Action Items per type for each operator.


Padsites with Addressed Action Items by Operator

The above graphic provides a summary of the number of padsites with Addressed Action Items for each operator.

4.2.2. SECOND HALF 2018


Of the 99 Identified Action Items noted on 26 padsites, 22 were noted as Addressed Action Items at 7 padsites once corrected during our field inspection or reported as corrected prior to our reporting.

Addressed Action Items per Type by Operator

The above graphic provides a summary of the number of Addressed Action Items per type for each operator.


Padsites with Addressed Action Items by Operator

The above graphic provides a summary of the number of padsites with Addressed Action Items for each operator.

4.3. OUTSTANDING ACTION ITEMS


4.3.1. FIRST HALF 2018 Of the 259 Identified Action Items noted on 76 padsites, 48 remained as Outstanding Action Items at 18 padsites since they were not corrected during our field inspection or reported as corrected prior to our reporting.

Outstanding Action Items per Type by Operator

The above graphic provides a summary of the number of Outstanding Action Items per type for each operator.


Padsites with Outstanding Action Items by Operator

The above graphic provides a summary of the number of padsites with Outstanding Action Items for each operator.

At the time of Modern’s interim report, the City prioritized all First Half Outstanding Action Items and reported to Modern that all had been addressed to their satisfaction as of July 2018. All of the First Half 2018 Outstanding Action Items were addressed (Completed Action Items) by June 2018.


4.3.2. SECOND HALF 2018 Of the 99 Identified Action Items noted on 26 padsites, 77 remained as Outstanding Action Items at 20 padsites since they were not corrected during our field inspection or reported as corrected prior to our reporting.

Outstanding Action Items per Type by Operator

The above graphic provides a summary of the number of Outstanding Action Items per type for each operator.


Padsites with Outstanding Action Items by Operator

The above graphic provides a summary of the number of padsites with Outstanding Action Items for each operator.


All Outstanding Action Items were reported to Modern to have been addressed since the Second Half 2018 inspections to their satisfaction as of January 2019. All of the Second Half 2018 Outstanding Action Items are considered Completed Action Items as of the issuance of this report.


5. ACTION ITEM RESULTS (DETAIL)

5.1. FIRST HALF 2018 SUMMARY The following presents a detailed summary of Modern’s Action Items noted for the First Half of 2018.

Padsites per Status by Operator

The above graphic provides a summary of the number of padsites identified by Action Items status for each operator.


5.2. SECOND HALF 2018 SUMMARY The following presents a detailed summary of Modern’s Action Items noted for the Second Half of 2018.

Padsites per Status by Operator

The above graphic provides a summary of the number of padsites identified by Action Items status for each operator.


5.3. LEAKS (METHANE) 5.3.1. FIRST HALF 2018

A total of 162 individual leaks (methane) were identified during Modern’s padsite inspection activities.

Leaks per Equipment by Operator

The above graphic provides a summary of the number of leaks (methane) identified for typical padsite equipment for each operator. Total leaks identified for each operator are provided in the legend. Leaks identified at operational low bleed components or related to normal equipment function are not included in leak totals. “Other” indicates ancillary pieces of equipment including additional sales piping and compressors. Please see individual padsite inspection reports for the specific equipment noted with a leak and corresponding OGI images. All leaks were noted as Addressed Action Items and confirmed during inspection, if corrected during our field efforts, or reported as corrected by the operator prior to our final report.


5.3.2. SECOND HALF 2018 A total of 63 individual leaks (methane) were identified during Modern’s padsite inspection activities.

Leaks per Equipment by Operator

The above graphic provides a summary of the number of leaks (methane) identified for typical padsite equipment for each operator. Total leaks identified for each operator are provided in the legend. Leaks identified at operational low bleed components or related to normal equipment function are not included in leak totals. “Other” indicates ancillary pieces of equipment including additional sales piping and compressors.


Please see individual padsite inspection reports for the specific equipment noted with a leak and corresponding OGI images. All leaks were noted as Addressed Action Items and confirmed during inspection, if corrected during our field efforts, or reported as corrected by the operator prior to our final report.


5.4. NORM 5.4.1. TOTAL NORM EXCEEDANCES

5.4.1.1. FIRST HALF 2018 A total of 69 individual pieces of equipment (e.g., well, separator, AST) were identified during Modern’s padsite inspection activities that exceeded the RRC criteria for additional management and controls. When operational, this can be addressed through proper labeling and/or signage.

Total Norm Exceedances per Equipment by Operator

The above graphic provides a summary of the number of NORM exceedances observed, both labeled and unlabeled, for typical padsite equipment for each operator. “Other” indicates ancillary pieces of equipment including additional sales piping and compressors.


5.4.1.2. SECOND HALF 2018 A total of 8 individual pieces of equipment (e.g., well, separator, AST) were identified during Modern’s padsite inspection activities that exceeded the RRC criteria for additional management and controls. When operational, this can be addressed through proper labeling and/or signage.

Total Norm Exceedances per Equipment by Operator

The above graphic provides a summary of the number of NORM exceedances observed, both labeled and unlabeled, for typical padsite equipment for each operator. “Other” indicates ancillary pieces of equipment including additional sales piping and compressors.


5.4.2. UNLABELED NORM EXCEEDANCES 5.4.2.1. FIRST HALF 2018

A total of 35 NORM exceedances were not properly labeled when identified during Modern’s inspection. Of these, 26 remained as Outstanding Action Items (Table 6) until later verified by the City to have been addressed.

Unlabeled Norm Exceedances per Equipment by Operator

The above graphic provides a summary of the number of unlabeled NORM exceedances observed for typical padsite equipment for each operator. “Other” indicates ancillary pieces of equipment including additional sales piping and compressors. Twenty-six (26) unlabeled NORM exceedances at 12 padsites had not been addressed at the issuance of individual padsite inspection reports (Endeavor). Following reporting to the City and further inspection, the City verified these to now be Completed Action Items.


5.4.2.2. SECOND HALF 2018

A total of 1 NORM exceedance was not properly labeled when identified during Modern’s inspection and remains as an Outstanding Action Item (Table 7) as of the date of the individual padsite inspection report.

Unlabeled Norm Exceedances per Equipment by Operator

The above graphic provides a summary of the number of unlabeled NORM exceedances observed for typical padsite equipment for each operator. “Other” indicates ancillary pieces of equipment including additional sales


piping and compressors. One (1) unlabeled NORM exceedance has not been addressed at the issuance of the padsite inspection report (Endeavor).

Following reporting to the City and further inspection, the City verified this to now be a Completed Action Item.

5.5. FENCELINE MONITORING 5.5.1. FIRST HALF 2018

Modern’s fenceline monitoring included the evaluation of multiple parameters. The results of each are noted below for the first half of 2018. Total Volatile Organic Compounds (tVOCs) – One downwind exceedance of the 0.1 ppmv screening

criteria was noted.

o Padsite No. 33 - In accordance with the contingency sampling program, Modern collected one (1) upwind and two (2) downwind samples and analyzed for individual VOCs to allow for screening against Texas Commission on Environmental Quality (TCEQ) air criteria. None of the observed compounds identified in the upwind and downwind samples exceeded the applicable Air Monitoring Comparison Values (AMCVST) or Effects Screening Levels (ESLST) criteria (see individual padsite report for additional information).


Hydrogen Sulfide (H2S) – None of the up or downwind fenceline monitoring exhibited exceedances of the H2S screening criteria.

Radiation – None of the up or downwind fenceline monitoring exhibited exceedances of radiation screening criteria.

Methane – None of the up or downwind fenceline monitoring exhibited exceedances of methane screening criteria.

Particulate Matter (PM) – None of the up or downwind fenceline monitoring exhibited exceedances of PM screening criteria.

Noise – Two of the fenceline noise monitoring results exceeded screening criteria.

o Padsite No. 070 – Elevated compressor noise noted at padsite boundary. Modern further evaluated the noise exceedance with a second noise screening sample closer to the nearest structure which did not exceed the screening criteria. Modern noted additional off-site noise sources that likely affected noise screening results for this padsite (see individual padsite report for additional information). This exceedance will be re-evaluated during the next monitoring event in 2019.

o Padsite No. 138 – Elevated compressor noise noted at padsite boundary. Modern further

evaluated the noise exceedance with a second noise screening sample closer to the nearest structure which did not exceed the screening criteria; however, this sample was not deemed representative as the primary noise source (compressor) is located along the padsite boundary and adjacent to off-site receptors. Further evaluation recommended (see individual padsite report for additional information). This observation was noted as an Outstanding Action Item (Table 6) from First Half 2018, but is considered a Completed Action Item following City-verification following Modern’s inspection efforts.

5.5.2. SECOND HALF 2018 Modern’s fenceline monitoring included the evaluation of multiple parameters. The results of each are noted below for the second half of 2018. Total Volatile Organic Compounds (tVOCs) – None of the up or downwind fenceline monitoring

exhibited exceedances of the tVOCs screening criteria.


Hydrogen Sulfide (H2S) – None of the up or downwind fenceline monitoring exhibited exceedances of the H2S screening criteria.

Radiation – None of the up or downwind fenceline monitoring exhibited exceedances of radiation screening criteria.

Methane – None of the up or downwind fenceline monitoring exhibited exceedances of methane screening criteria.

Particulate Matter (PM) – None of the up or downwind fenceline monitoring exhibited exceedances of PM screening criteria.

Noise – One (1) of the fenceline noise monitoring results exceeded screening criteria.

o Padsite No. 138 – Elevated compressor noise noted at padsite boundary. The City of Denton Inspector further evaluated the noise exceedance with a second noise screening sample at the neighboring property, closer to occupied structures, which did not exceed the screening criteria. Additional noise monitoring will be conducted during Modern’s next inspection. Due to the City’s effort, this observation was not noted as an Outstanding Action Item.

5.6. COMPLIANCE MONITORING

5.6.1. FIRST HALF 2018 Modern’s compliance monitoring for the first half of 2018 identified Action Items related to the following:

Excessive Corrosion;

NORM;

Proper Signage;

Fencing;

Water Leakage; and

Water in Cellar (around well/subgrade).

Any of the above items not addressed during field inspections or noted as repaired by the operator (Addressed Action Items) are individually noted in the Outstanding Action Items (Table 6).


5.6.2. SECOND HALF 2018

Modern’s compliance monitoring for the second half of 2018 identified Action Items related to the following:

Excessive Corrosion;

NORM;

Fencing;

Noise Barrier; and

Landscaping.

Any of the above items not addressed during field inspections or noted as repaired by the operator (Addressed Action Items) are individually noted in the Outstanding Action Items (Table 7).


6. INSPECTION RESULTS (COMPREHENSIVE COMPARATIVE ANALYSIS)

To better estimate the occurrence of individual Action Items across multiple operators with various amounts of equipment, this section offers comparative analysis to normalize the observations from Modern’s inspection over the entire year. The data below offers comprehensive results on a “per well” basis for both the first (233 wells inspected) and second half (59 wells inspected) of 2018 inspections.

6.1. LEAKS PER WELL (ALL DATA) The data below provides a summary of all leaks (225; methane) observed on a per well (292) basis.


6.2. NORM PER WELL (ALL DATA) 6.2.1. TOTAL NORM PER WELL

The data below provides a summary of all recorded NORM observations that exceeded RRC criteria (77; >50 µR/hr) on a per well (292) basis.

6.2.2. UNLABELED NORM PER WELL The data below provides a summary of all recorded NORM observations without proper labeling/signage, during field inspection, that exceeded RRC criteria (36; >50 µR/hr) on a per well (292) basis.


6.3. ACTION ITEMS PER WELL (ALL DATA) 6.3.1. IDENTIFIED ACTION ITEMS PER WELL

The data below provides a summary of all padsites with Identified Action Items (102) on a per well (292) basis by operator.

The data below provides a summary of all Identified Action Items (357) on a per well (292) basis by operator.


6.3.2. ADDRESSED ACTION ITEMS PER WELL The data below provides a summary of all padsites with Addressed Action Items (64) on a per well (292) basis by operator.

The data below provides a summary of all Addressed Action Items (232) on a per well (292) basis by operator.


6.3.3. OUTSTANDING ACTION ITEMS PER WELL The data below provides a summary of all padsites with Outstanding Action Items (38) on a per well (292) basis by operator. No Outstanding Action Items remain as of the issuance of this report.

The data below provides a summary of all Outstanding Action Items (125) on a per well (292) basis by operator.


7. CONCLUSIONS AND RECOMMENDATIONS

7.1. NEAR-EQUIPMENT INSPECTION Modern identified the following during near-equipment inspection efforts: Modern identified a total of 225 leaks (methane) using an Optical Gas Imaging (OGI) camera during our

padsite inspection activities. No leaks were identified at Atmos and Krocan padsites. Modern identified a total of 36 exceedances of Texas Railroad Commission (RRC) NORM criteria (>50

µR/hr) requiring signage and proper management.

7.2. FENCELINE MONITORING Modern identified the following fenceline exceedances during this inspection period concerning noise (including Pure-Tone Levels), particulate matter, hydrogen sulfide, VOCs, or methane: Padsite No. 33 - In accordance with the contingency sampling program, Modern collected one (1)

upwind and two (2) downwind samples and analyzed for individual VOCs to allow for screening against Texas Commission on Environmental Quality (TCEQ) air criteria during the first half 2018 inspections. None of the observed compounds identified in the upwind and downwind samples exceeded the applicable Air Monitoring Comparison Values (AMCVST) or Effects Screening Levels (ESLST) criteria (see individual padsite report for additional information).

Padsite No. 070 – Elevated compressor noise noted at padsite boundary during first half 2018

inspection. Modern further evaluated the noise exceedance with a second noise screening sample closer to the nearest structure which did not exceed the screening criteria. Modern noted additional off-site noise sources that likely affected noise screening results for this padsite (see individual padsite report for additional information). This exceedance was not duplicated during the second half 2018 inspections. Additional noise monitoring will be conducted during Modern’s next inspection.

Padsite No. 138 – Elevated compressor noise noted at padsite boundary during first half 2018

inspection. Modern further evaluated the noise exceedance with a second noise screening sample closer to the nearest structure which did not exceed the screening criteria; however, this sample was not deemed representative as the primary noise source (compressor) is located along the padsite boundary and adjacent to off-site receptors. Elevated compressor noise was also noted at padsite boundary during second half 2018 inspection. The City of Denton Inspector further evaluated the noise exceedance with a second noise screening sample at the neighboring property, closer to occupied structures, which did not exceed the screening criteria. Additional noise monitoring will be conducted during Modern’s next inspection (see individual padsite report for additional information).


7.3. OUTSTANDING ACTION ITEMS Modern identified a total of 357 Action Items requiring operator attention across 102 individual padsites during our 2018 padsite inspection activities. Of these, a total of 48 Outstanding Action Items across 18 individual padsites were not addressed as of the issuance of the first half 2018 Padsite Inspection Reports. This is detailed in the table below, within the provided GIS data layers provided to the City, and within each Padsite Inspection Report.

TABLE 6 – FIRST HALF 2018 – OUTSTANDING ACTION ITEM SUMMARY Padsite No. Operator Outstanding Action Items

093 Devon Bare pipe/corrosion noted on separator piping 103 Devon Bare pipe/corrosion noted on AST piping 155 Devon Bare pipe/corrosion noted on AST piping 128 Endeavor Bare pipe/corrosion noted on Well A 129 Endeavor Unlabeled NORM exceedances noted on ASTs A, C, D, and F 137 Endeavor Unlabeled NORM exceedances noted on Well B and ASTs C, D, and E

138 Endeavor Compressor noise above comparison criteria noted at padsite boundary

Bare pipe/corrosion noted on Wells A and B Unlabeled NORM exceedances noted on Well B and ASTs A, B, and C

139 Endeavor Bare pipe/corrosion noted on Well A

Unlabeled NORM exceedances noted on AST C

140 Endeavor

Bare pipe/corrosion noted on AST piping Unlabeled NORM exceedances noted on Wells B, C, and D, Separator C,

and ASTs A, B, E, F, and H Hazardous material signage missing from AST H

141 Endeavor Unlabeled NORM exceedances noted on AST B

142 Endeavor Bare pipe/corrosion noted on Well A and AST piping

Unlabeled NORM exceedances noted on ASTs B and C 143 Endeavor Unlabeled NORM exceedances noted on AST B 151 Hillwood Bare pipe/corrosion noted on AST piping 049 Krocan Bare pipe/corrosion noted on separator and AST piping 050 Krocan Bare pipe/corrosion noted on separator piping 054 Krocan Bare pipe/corrosion noted on separator piping 005 XTO Bare pipe/corrosion noted on Well A, Separator A, Compressor A, and Ancillary A 154 XTO Bare pipe/corrosion noted on Well A

Following Modern’s inspection efforts, the City worked with operator representatives to ensure all

Outstanding Action Items were addressed to the City’s satisfaction. According to City verification


inspections, all 48 Action Items were addressed prior to the issuance of this report and are considered Completed Action Items at this time.

Subsequently, Modern identified a total of 77 Outstanding Action Items requiring operator attention across 20 individual padsites during our second half 2018 padsite inspection activities that have not yet been evaluated by the City of Denton Inspector. This is detailed in the table below, within the provided GIS data layers provided to the City, and within each Padsite Inspection Report.

TABLE 7 – SECOND HALF 2018 – OUTSTANDING ACTION ITEM SUMMARY Padsite No. Operator Outstanding Action Items

016 EagleRidge Leaks noted on Well A and ASTs A, B, C, and D Bare pipe/corrosion noted on Wells A and B

041 EagleRidge Leaks noted on Separator A and ASTs A and B

048 EagleRidge Leaks noted on Well A, ASTs A and E, and Compressor A

Bare pipe/corrosion noted on Wells A, B, and C

065 EagleRidge Leaks noted on Well A, Separators B, C, D, and E, and ASTs A, D, E, and F

Bare pipe/corrosion noted on well piping, separator piping, and AST piping

070 EagleRidge Leaks noted on AST A

Downed noise barrier wall 071 EagleRidge Landscaping overgrown 072 EagleRidge Leak noted on AST A 073 EagleRidge Landscaping overgrown 074 EagleRidge Leak noted on AST B 075 EagleRidge Leaks noted on Separators A, B, D, and E and Compressor A 077 EagleRidge Bare pipe/corrosion noted on AST piping

081 EagleRidge Leaks noted on Separators A, B, and C and ASTs B and D

Bare pipe/corrosion noted on AST piping 108 EagleRidge Bare pipe/corrosion noted on Well A, separator piping, and AST piping 115 EagleRidge Bare pipe/corrosion noted on ASTs A and B and AST piping 122 EagleRidge Bare pipe/corrosion noted on ASTs A and B and AST piping

136 EagleRidge Leaks noted on AST A and Compressor A

Bare pipe/corrosion noted on Well A, separator piping, and Compressor A piping 145 EagleRidge Bare pipe/corrosion noted on separator piping, ASTs A and B, and AST piping

138 Endeavor Leak noted on AST D

Bare pipe/corrosion noted on Wells A and B

139 Endeavor Unlabeled NORM exceedances noted on AST B

Bare pipe/corrosion noted on Well A 143 Endeavor Bare pipe/corrosion noted on Well A


Following Modern’s inspection efforts, the City worked with operator representatives to ensure all

Outstanding Action Items were addressed to the City’s satisfaction. According to City verification inspections, all 77 Action Items were addressed prior to the issuance of this report and are considered Completed Action Items at this time.

7.4. PROGRAM UPDATES

During the course of inspection activities, the padsite operations, surrounding receptor conditions, and other observations may necessitate an update to the current program approach. Based on the first half 2018 inspection results, Modern recommended the following updates to be considered by the City as part of the ongoing monitoring program: Updating the following padsite inspection status conditions.

o Padsite No. 014 – updating from Moderate to High due to nearby receptors; o Padsite No. 077 – updating from Moderate to High due to nearby receptors; o Padsite No. 081 – updating form Moderate to High due to nearby receptors; and o Padsite No. 086 – updating from High to Low due to the removal of nearby receptors.

Completing a final post-production inspection and summarizing in a report with all RRC plugging

documentation so this will be available when future development on or near this padsite is being considered. This should include a surface NORM survey, subgrade leak evaluation, and confirmation ordinance requirements have all been met.

o Padsite Nos. 032, 114, and 121 – Once all infrastructure is properly plugged and removed. Based on the second half 2018 inspection results, we recommend the following be considered by the City as part of the ongoing monitoring program: Updating the following padsite inspection status conditions.

o Padsite No. 039 – updating from Moderate to High due to nearby receptors;


8. IMPORTANT ACRONYMS

AMCV Air Monitoring Comparison Value (Short or Long Term Criteria)

AST Aboveground storage tank

ASTM ASTM International

BACT Best Available Control Technology

BMP Best Management Practice

CAA Clean Air Act

COC Chemicals of Concern

EPA United States Environmental Protection Agency

ESL Effect Screening Level (Short or Long Term Criteria)

ETJ Extra Territorial Jurisdiction

FID Flame Ionization Detector

FRP Fiberglass Reinforced Plastic

GC/MS Gas Chromatograph/Mass Spectrometer

HAP Hazardous Air Pollutant

HASP Health and Safety Plan

HQ Hazard Quotient

IDLH Immediately Dangerous to Life and Health

IHW TCEQ Industrial & Hazardous Waste Program

LDAR Leak Detection and Repair

LDCP Leak Detection and Compliance Plan

MACT Maximum Achievable Control Technology

MSDS Material Safety Data Sheet

NAAQS National Ambient Air Quality Standard

NESHAP National Emissions Standards for Hazardous Air Pollutants

NORM (Technologically Enhanced) Naturally Occurring Radioactive Material

NSPS New Source Performance Standard

OPM Open Path Monitoring

OSHA Occupational Safety & Health Administration

PEL OSHA Permissible Exposure Limit

PID Photo Ionization Detector

PM Particulate Matter


PPB Parts Per Billion (PPBV – by volume)

PPM Parts Per Million (PPMV – by volume)

RBEL Risk Based Exposure Limit

RCRA Resource Conservation and Recovery Act

RfC Reference Concentration

ROD Record of Decision

RRC Texas Railroad Commission

RSC Reduced Sulfur Compounds

SVOCs Semi-volatile Organic Compounds

TCEQ Texas Commission on Environmental Quality

TD Thermal Desorption

TOX Total Organic Halides

TPH Total Petroleum Hydrocarbons

TPWD Texas Parks and Wildlife Department

TRRP Texas Risk Reduction Program

tVOCs Total Volatile Organic Compounds

TVA Total Vapor Analyzer (Typically in the form of a Flame Ionization Detector or FID)

TWDB Texas Water Development Board

TXU Texas Utilities

URF Unit Risk Factor

USC United States Code

USGS United States Geological Survey

UST Underground Storage Tank

UV Ultraviolet

VOCs Volatile Organic Compounds


9. LIMITATIONS AND EXCEPTIONS

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. 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. The monitoring results collected as part of these services represent 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. Modern’s air sampling has been consistent with current regulatory guidance and 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. Our conclusions, opinions and recommendations are based only on the information available for review at the time of reporting. This included a limited number of observations and data points. It is likely that conditions will vary between or beyond the specific points evaluated. Environmental conditions at areas or portions of the Site where sampling was not conducted may vary from those encountered at actual sample locations. Further, certain indicators for the presence of hazardous materials or other constituents may have been latent, inaccessible, unobservable, or not present during Modern’s performance of its services, and Modern cannot represent that the Site contains no hazardous materials or other latent conditions beyond those identified in connection with this effort. There is no investigation that is thorough enough to identify the presence or absence of all materials at a site which is currently, or at some point in the future, may be considered hazardous. Modern offers various levels of investigative services to suit the varying needs of our clients. It should be recognized that definition and evaluation of geologic and environmental conditions are a difficult and inexact science. Judgments leading to conclusions and recommendations are generally made with incomplete knowledge of the atmospheric or subsurface conditions present due to the limitations of data from field studies. Although risk can never be eliminated, more exhaustive studies will produce additional data, which can help understand and manage the level of risk present. Since more detailed studies require greater expense, our clients participate in the determination of acceptable risk for their purposes.

WWW.MODERNGEOSCIENCES.COM

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PADSITE LOCATION MAPDenton, Texas

117153

01.12.18CS/LM

KT

K

PROJECT NO.DRAWN:DRAWN BY:CHECKED BY:FILE NAME:

FIGURE

0 1 2 3Miles

Sources: Esri, HERE, DeLorme, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), swisstopo, MapmyIndia, © OpenStreetMap contributors, and the GIS User Community

This figure was prepared using data from a variety of sources.No warranty is made as to the accuracy or completeness of dataprovided through third parties. All data contained herein issubject to change without notice. This figure is not intendedfor use as a legal survey or construction design document.

Denton_PadsiteLocation_180525.mxd

LegendPadsites by Operator (No. of Wells):") Eagleridge (100)") Devon (61)") Enervest (50)") Sage (36)") Endeavor (15)

") Hillwood (14)") Atmos (9)") Krocan (3)") XTO (2)

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PADSITE INSPECTIONSUMMARY MAP

Denton, Texas2

1715309.05.18

CS/LMKT

K

PROJECT NO.DRAWN:DRAWN BY:CHECKED BY:FILE NAME:

FIGURE

0 1 2 3Miles

Sources: Esri, HERE, DeLorme, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), swisstopo, MapmyIndia, © OpenStreetMap contributors, and the GIS User Community

This figure was prepared using data from a variety of sources.No warranty is made as to the accuracy or completeness of dataprovided through third parties. All data contained herein issubject to change without notice. This figure is not intendedfor use as a legal survey or construction design document.

Denton_Summary_190116.mxd

Legend") No Action Items Identified") Operator Addressed Action Item(s) (COD Confirmed)") Operator Addressed Action Items (Further Verification Planned)"S Padsite Not Scheduled for Inspection in Current Year

Denton City Limit

padsite inspection summary report - denton, texas...a succinct reporting format that provide sa...

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