PADSITE INSPECTION AND AIR MONITORING REPORT (JULY 2015)

Transcription

1 DATE August 28, 2015 PROJECT Town of Flower Mound Monthly Air Sampling Flower Mound, Denton County, Texas PADSITE INSPECTION AND AIR MONITORING REPORT (JULY 2015) PREPARED FOR Town of Flower Mound 1001 Cross Timbers Road Flower Mound, Texas PREPARED BY REVIEWED BY Lisa Marinangel PROJECT MANAGER Kenneth S. Tramm, PhD, PG, CHMM PRINCIPAL 5100 THOMPSON TERRACE, COLLEYVILLE TEXAS F P MODERN GEOSCIENCES. ALL RIGHTS RESERVED.

2 TABLE OF CONTENTS 1. INTRODUCTION Project Description Project Activities FIELD ACTIVITIES Ambient Air Sampling Sample Methodology Quality Control Padsite Inspection Padsite Inspection Points Leak Definitions Radiation Monitoring CriterIa Fenceline Air Monitoring Quality Control and Verification AMBIENT AIR SAMPLING RESULTS Regulatory Comparison Values Background Ambient Air Quality Data TCEQ CAMS Results Ambient Air Sample Results PADSITE INSPECTION RESULTS Padsite No. 1-Obenchain Leaks Identified Elevated NORM Fenceline Monitoring Results Weather Conditions General Comments Padsite No. 2-Furst Ranch C Leaks Identified Elevated NORM Fenceline Monitoring Results...14 PROJECT I AUGUST 28, 2015 I PAGE 1

3 Weather Conditions General Comments Padsite No. 3 Furst Ranch D Leaks Identified Elevated NORM Fenceline Monitoring Results Weather Conditions General Comments OPERATOR INFORMATION Operator Inspection Results Operator Monitoring Results FINDINGS AND CONCLUSIONS IMPORTANT ACRONYMS LIMITATIONS AND EXCEPTIONS...23 APPENDICES PROJECT I AUGUST 28, 2015 I PAGE 2

4 1. INTRODUCTION This report was prepared on behalf of the Town of Flower Mound (Client; Town) by Modern Geosciences, LLC (Modern) in accordance with our authorizing agreement, proposal and agreed scope of work PROJECT DESCRIPTION In response to the development of natural gas exploration and production pad sites within the urban environment, ambient air sampling was initiated in Flower Mound in Concerns for ambient air quality have included the potential for fugitive emissions, or subsequent atmospheric formation of, volatile organic compounds (VOCs), carbonyl compounds, reduced sulfur compounds, methane, ozone, and selected nitrogen compounds. Flower Mound primarily utilized ambient monitoring in conjunction with limited padsite inspections and field monitoring events to ensure that ambient air quality was maintained through December As part of the Town s desire to include more focus on the padsite equipment and identification of potential concerns early (e.g., equipment leaks), the ambient program has been augmented to include detailed padsite inspections every month as well as quarterly sampling of three existing ambient air sampling points (AA-1, AA-5, and AA-6). More detail on the padsite inspections is included below PROJECT ACTIVITIES Modern visited one (1) of three (3) pre-determined sampling points and performed field monitoring activities concurrent with sample equipment deployment. Each of these three (3) sampling points will be sampled quarterly. Following approximately 24 hours of sampling, the equipment was collected and submitted to a Texas Commission on Environmental Quality (TCEQ) accredited laboratory for analysis of the samples. All monitoring was completed in a manner such that potential disruption to site operations was minimal. Modern visited natural gas padsites and performed inspection activities as detailed below. Each padsite in the Town of Flower Mound is anticipated to be inspected at least twice annually. Modern performed the following monitoring activities at each padsite. Audio, Visual, and Olfactory (AVO) Inspection Modern performed an AVO inspection of the Site for signs of spills or releases. This included assessment of conditions at the boundary of fenced perimeters, in close proximity to operating equipment components (i.e., well controls, valves, separators, fluid lines, ASTs), and near obvious operations areas. Near-Equipment Monitoring Modern performed discrete field monitoring near site equipment to identify obvious fugitive emission points that may require maintenance with optical gas imaging equipment. When a leak was indicated, monitoring parameters included total volatile organic compounds (tvocs) measured in per billion by volume (ppbv), methane and hydrogen sulfide measured in parts per million by volume (ppmv). Additionally, a representative evaluation of equipment was also monitored for radiation measured in microroentgens per hour (µr/hr). Perimeter monitoring for tvocs, PROJECT I AUGUST 28, 2015 I PAGE 3

5 methane, hydrogen sulfide, and radiation was included at selected points at the boundary of obvious operations areas. Fenceline Air Monitoring Modern performed air sampling at one upwind location relative to production areas and one downwind location relative to production areas. This included the collection of a sample over a specific time period that was later evaluated for a broad list of volatile organic compounds. More detail of the sample collection and analysis is included within applicable sections of this report. PROJECT I AUGUST 28, 2015 I PAGE 4

6 2. FIELD ACTIVITIES Prior to deployment of sampling equipment, Modern confirmed site access requirements, planned sampling points, and prepared a project-specific Health and Safety Plan (HASP) for use by field personnel AMBIENT AIR SAMPLING The following sampling point was selected for this event: AA-1 Furst Ranch Padsite. The sample point is approximately 300 feet east of the fence line surrounding the active pad site located at Furst Ranch D Padsite. Please see attached Figure 1 for sample point location SAMPLE METHODOLOGY The selected sampling point was evaluated over a 24-hour sampling period. The target compounds selected for this event included VOCs. The field sampling approach conformed to applicable elements of ASTM D1357 (Standard Practice for Planning the Sampling of the Ambient Atmosphere) and current Town of Flower Mound ambient air sampling protocol. A laboratory prepared and certified sampling container was obtained from ESC Lab Sciences in Mt. Juliet, Tennessee (Texas Certification Number T ) and placed within dedicated sampling shrouds following installation of the sample flow regulator and confirmation of canister vacuum. An inert sampling tube was then affixed to a static portion of the sampling equipment to allow collection of air from approximately five feet six inches (5.5 ) above ground (breathing zone). To maintain sample flow throughout the duration of this study, Modern specified a 24-hour flow controller. The flow rates were preset and calibrated by the laboratory at approximately 4 ml/min for a sampling period of 24 hours and a total sample volume of approximately six liters. The canister and associated hardware were checked for mechanical integrity upon receipt and prior to use. The initial and final canister vacuum readings prior to and at the end of the sampling interval were recorded as specified by the TO-15 sampling specifications. Following sample collection, the canisters were shipped to ESC Lab Sciences in Mt. Juliet, Tennessee, for analyses of VOCs by EPA method TO-15. Proper chain of custody documentation was maintained throughout the sampling process in accordance with Modern quality assurance protocols. PROJECT I AUGUST 28, 2015 I PAGE 5

7 QUALITY CONTROL The sample collection included confirmation of sampling train integrity during field placement and an evaluation of the starting and ending canister pressure. Based on the observed differences, no indication of regulator malfunction or sample interference was indicated. Additionally, no indication of tampering was noted during collection of the field sample PADSITE INSPECTION The following padsites were selected for inspection: Padsite No. 1-Obenchain Padsite No. 2-Furst Ranch C Padsite No. 3-Furst Ranch D Please see attached Figures 1 through 4 for padsite locations and fenceline monitoring location details PADSITE INSPECTION POINTS Below is a listing of site inspection points included. Perimeter Inspection Points Perimeter inspection points were utilized to represent current conditions at the edges of the padsite. Well Head (Needle Valve, Controls, High/Low Valve) Well equipment was inspected to ensure no signs of a release was indicated. Obvious equipment wear was noted to facilitate preemptive maintenance where appropriate. Well head evaluation includes individual monitoring of the well casings (generally the first 24 from grade), valves/connections/controls (generally 24 and above), and ancillary components (lateral piping, connections, well fluids). The highest observations are recorded in the attached tables; Well Head Fluid Containment/Spillage Anti-corrosion, scale inhibitors, and other fluids are sometimes utilized to maintain the well(s). If fluid is within secondary containment, the integrity of the secondary containment system(s) is evaluated as well. Well Head to Separator Piping The fittings and piping between the well and separator was inspected, where visible, for signs of corrosion or leakage. Separators Each separator was evaluated for audible, olfactory and visual signs of leakage, emissions, or staining. Four areas of each separator are generally evaluated. This includes flow line piping, separator tank, saltwater discharge components, and gas outflow/sales line piping. The highest concentrations noted in each area are recorded in the attached tables; and PROJECT I AUGUST 28, 2015 I PAGE 6

8 Tank Battery The piping connecting the separator to the ASTs is typically within secondary containment. System piping was visually inspected, where visible, for signs of corrosion or leakage. Equipment wear was noted to facilitate preemptive maintenance where appropriate. To aid in the presentation of our findings, a summary of equipment specifications is provided in the appendix of this report. 2.4.LEAK DEFINITIONS For the purposes of this monitoring effort, the following leak definitions have been utilized for near-equipment monitoring: Optical Gas Imaging Camera: Visible evidence of a leak* during screening If a leak is indicated with the OGI equipment, screening with higher resolution equipment will be performed. The leak definitions will then include the following: Methane: 10,000 ppmv (20% LEL)* Hydrogen Sulfide (H 2 S): 10 ppmv tvocs: 500 ppmv** *This definition does not include normal periodic operational emissions such as a gas-actuated dump valve, pneumatic equipment, or AST pressure relief event. Continuous bleed devices will be considered within our leak definition for the purpose of this study. **The EPA updated Leak Definitions in April 2012 for valves and equipment leaks at natural gas processing plants under 40 CFR Part 63 (EPA-HQ-OAR ; FRL-RIN 2060-AP76) 2.5.RADIATION MONITORING CRITERIA The Texas Railroad Commission (RRC) regulates NORM under 16 TAC 4 (Environmental Protection, Subchapter F, Oil and Gas NORM; Subchapter F). 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 Town and operator(s) to allow further inspection and where appropriate compliance with RRC signage and management requirements. PROJECT I AUGUST 28, 2015 I PAGE 7

9 2.6. FENCELINE AIR MONITORING After wind direction was determined and an initial perimeter evaluation completed, Modern used conditioned thermal desorption tubes to collect an upwind and downwind air sample at each padsite. A calibrated pump was connected to the tube to allow collection of a representative sample. The air was sampled at a rate of 100 ml/min for approximately 20 minutes. The sampling tube was 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) were evaluated before and after each sampling event to ensure sample integrity was maintained. Upon completion of the sampling event, the tubes were placed in a sealed inert container and placed on ice and sampling information (e.g., tube serial number, sample ID, time, flow rate) was recorded on the chain of custody. The sampling and monitoring efforts were performed in accordance with applicable elements of EPA Method TO-17. Following sample collection, the thermal desorption tubes were analyzed by Modern using a gas chromatograph/mass spectrometer (GC/MS) to allow identification and quantification of individual chemicals of concern. All analyses were performed in accordance with Modern s internal Quality Assurance Project Plan (QAPP) governing sample analysis procedure QUALITY CONTROL AND VERIFICATION Modern performed periodic calibration on field inspection equipment in compliance with manufacturer specifications. In accordance with Modern s QAPP, periodic continuing calibration verification (ccv), sample duplicates, and blank samples were prepared for analysis by the GC/MS. Additionally, Modern reviewed 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. TICs are further discussed in Section 4. 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. PROJECT I AUGUST 28, 2015 I PAGE 8

10 3. AMBIENT AIR SAMPLING RESULTS This section includes reporting and evaluation of the laboratory analysis results as well as applicable regulatory comparison values REGULATORY COMPARISON VALUES The TCEQ maintains Air Monitoring Comparison Values (AMCVs) for evaluation of monitoring samples such as the ones collected in this study. These include criteria for short-term (acute) and long-term (chronic) exposure as well as permissible odor thresholds. Monitoring for short durations such as this event is most applicable to the short-term AMCVs (AMCV ST ). Additional criteria maintained by the TCEQ for modeling and forecasting purposes also include the Effects Screening Levels (ESLs) which have short-term, long-term, and odor values. When an AMCV ST is not available, the ESL ST has been utilized. The TCEQ Toxicology Division developed these regulatory thresholds in accordance with Guidelines to Develop Effects Screening Levels, Reference Values, and Unit Risk Factors (RG-442; November 2006). Please refer to the data summary table for the date of both the AMCV and ESL values. Both AMCVs and ESLs are guideline thresholds set by the TCEQ and are not formal ambient air quality standards. These criteria are set to approximate significant margins of safety for the most sensitive members of the community, such as the elderly, children, and persons with pre-existing health conditions. AMCVs and ESLs are generally set well below levels at which adverse health effects would be anticipated. If the measured concentration of a constituent does not exceed the corresponding screening level, then adverse health or welfare effects are not expected. Conversely, consistent exceedances of the AMCV or the ESL values should warrant a more in depth review of the occurrence and potential emission source(s) BACKGROUND AMBIENT AIR QUALITY DATA Ambient air quality data has been collected throughout the Town of Flower Mound beginning in Available VOC data from 2011 through 2013 and carbonyl data from January through May 2011 were tabulated and values were calculated to provide background ambient air quality information specific to the Town of Flower Mound. Table R1 below lists commonly detected compounds and their respective statistical results. A NA or not applicable listing under the 95% upper confidence limit (UCL) indicates that the sample variance does not support the projection of a UCL. Table R1 Town of Flower Mound Background Ambient Air Quality ( ) COC Median Mean Standard Deviation Max 95% UCL 1,2,4-Trimethylbenzene Pentene Acetylene Benzene Butane NA Chloromethane PROJECT I AUGUST 28, 2015 I PAGE 9

11 Table R1 Town of Flower Mound Background Ambient Air Quality ( ) COC Median Mean Standard Deviation Max 95% UCL Dichlorodifluoromethane Ethane NA Ethene Isobutane Isopentane NA Isoprene Isopropylbenzene n-petane Propane NA Toluene NA Acetaldehyde Butyraldehyde All concentrations presented as ppbv 3.3. TCEQ CAMS RESULTS The TCEQ continuous monitoring air station (CAMS) 1007 in Flower Mound reported the following VOC monitoring results and CAMS 70 in Grapevine reported the following nitric oxide, nitrogen dioxide, and ozone monitoring results for this month. Table R2 Maximum Observations TCEQ CAMS 1007 COC 7/20/15 7/21/15 Max* COC 7/20/15 7/21/15 Max* Ethane Cyclohexane Ethylene Methylhexane Propane ,3-Dimethylpentane Propylene Methylhexane Isobutane ,2,4-Trimethylpentane n-butane n-heptane Acetylene Methylcyclohexane t-2-butene ,3,4-Trimethylpentane Butene Toluene c-2-butene Methylheptane Cyclopentane Methylheptane Isopentane n-octane n-pentane Ethyl Benzene ,3-Butadiene p-xylene + m-xylene t-2-pentene Styrene Pentene o-xylene c-2-pentene n-nonane ,2-Dimethylbutane Isopropyl Benzene PROJECT I AUGUST 28, 2015 I PAGE 10

12 Table R2 Maximum Observations TCEQ CAMS 1007 COC 7/20/15 7/21/15 Max* COC 7/20/15 7/21/15 Max* Isoprene n-propylbenzene n-hexane ,3,5-Trimethylbenzene Methylcyclopentane ,2,4-Trimethylbenzene , n-decane Dimethylpentane Benzene ,2,3-Trimethylbenzene Ozone Nitrogen Dioxide Nitric Oxide *Maximum monthly concentration- 07/01/15-07/31/15 All concentrations presented as ppbv Table R3 Maximum Observations TCEQ CAMS 70 None of the observed VOCs reported by the TCEQ exceeded the AMCV ST or ESL ST criteria 3.4. AMBIENT AIR SAMPLE RESULTS Volatile Organic Compounds Maximum VOC concentrations reported at sampling point (AA-1) included the following: Table R4 Maximum VOC Observations Ambient Air Samples COC Result COC Result 1,1,2-Trichlorotrifluoroethane J Ethanol 7.6 1,2,4-Trimethylbenzene 0.16 J Ethylbenzene ,2,4-Trimethylpentane 0.46 Heptane Butanone 0.74 J m&p-xylene Propanol 7.4 Methyl methacrylate 0.17 J 4-Methyl-2-Pentanone 0.16 J Methylene Chloride 0.3 Acetone 8.3 n-hexane 0.75 Benzene 0.21 o-xylene 0.23 Carbon Tetrachloride J Styrene 0.23 Chloromethane 0.62 Toluene 0.94 Cyclohexane 0.16 J Trichlorofluoromethane 0.27 Dichlorodifluoromethane 0.64 All concentrations presented as ppbv None of the observed VOCs reported by the laboratory exceeded the AMCV ST or ESL ST criteria. PROJECT I AUGUST 28, 2015 I PAGE 11

13 4. PADSITE INSPECTION RESULTS For the purposes of this inspection, the wells were given unique identifiers during our monitoring events. A listing of the individual well names, separator names, AST names, and corresponding RRC Permit Number is provided below. Additionally, Figures 2, 3, and 4 provide a depiction of the individual wells, separators, and ASTs at each padsite. Please refer to Tables 2A through 2C for a summary of the highest observed readings noted during the near-equipment inspection efforts. The summarized table format allows for the monitoring of individual padsite equipment over time. Fenceline (thermal desorption tubes) results are provided in Table PADSITE NO. 1-OBENCHAIN Wellhead Identification: Separator Identification: AST Identification: A: Obenchain D1H (RRC# ) A: Obenchain D1H A: Obenchain B: Obenchain D2H (RRC# ) B: Obenchain D2H LEAKS IDENTIFIED The following leaks were identified during the inspection of the wellhead(s), separator(s), and aboveground storage tank(s) on July 20, 2015: Actuator at Separator B. All leaks were subsequently repaired by the operator and verified by Mr. John Luxton, Town of Flower Mound inspector, on July 28, 2015 to no longer have a leak exceeding monitoring goals. Photos of leaks identified during field screening are included in the appendix of this report ELEVATED NORM No equipment was noted to have NORM readings in excess of 50 µr/hr FENCELINE MONITORING RESULTS None of the observed compounds identified in the upwind and downwind samples (UW-1 and DW-1) exceeded the applicable AMCV ST or ESL ST criteria. Following analysis, Modern reviewed the resulting chromatograms for indication of Tentatively Identified Compounds (TICs).The TIC evaluation for UW-1 suggested very low levels of butane, hexane, methylcyclohexane, 1,3-dimethylbenzene, nonane, decane, and dodecane. The TIC evaluation for DW-1 suggested very low levels of 2-methylbutane, hexane, methylcyclohexane, nonane, propylbenzene, 1-ethyl-2- methyl-benzene, decane, indane, 1-methyl-2-propylbenzene. PROJECT I AUGUST 28, 2015 I PAGE 12

14 A summary of the VOCs observed and estimated quantified during fenceline monitoring is included in Table WEATHER CONDITIONS Modern deployed a mobile weather station to record weather conditions during site sampling efforts. The following was noted at this padsite: Average wind speed: 3 mph Average wind direction (blowing to): North-Northwest Temperature: 93 ⁰F Humidity: 49 % Precipitation: None GENERAL COMMENTS No elevated monitoring results were noted at the padsite perimeter to suggest concern to properties off of the padsite during our monitoring effort. No spills or releases to the ground were observed during the inspection. PROJECT I AUGUST 28, 2015 I PAGE 13

15 4.2. PADSITE NO. 2-FURST RANCH C Wellhead Identification: Separator Identification: AST Identification: A: Furst Ranch C 2H (RRC# ) A: Furst Ranch C 2H A: Furst Ranch C B: Furst Ranch C 1H (RRC# ) B: Furst Ranch C 1H B: Furst Ranch C C: Furst Ranch C D: Furst Ranch C LEAKS IDENTIFIED The following leaks were identified during the inspection of the wellhead(s), separator(s), and aboveground storage tank(s) on July 20, 2015: Actuator at Separator B. All leaks were subsequently repaired by the operator and verified by Mr. John Luxton, Town of Flower Mound inspector, on July 30, 2015 to no longer have a leak exceeding monitoring goals. Photos of leaks identified during field screening are included in the appendix of this report ELEVATED NORM The following equipment was noted to have NORM readings in excess of 50 µr/hr and was unlabeled: Wellhead B and the associated piping; Elevated NORM levels can be an early indication of scale build up within padsite equipment and suggestive that maintenance includes cleaning of these components. Continued operation under RRC will generally require that proper signage be applied to the equipment for future management as NORM-containing material. Modern communicated the elevated NORM results to allow the operator to incorporate this information into their management of the padsite. These components did not appear to be labeled as per the Texas Railroad Commission requirements when elevated NORM-containing equipment is present FENCELINE MONITORING RESULTS None of the observed compounds identified in the upwind and downwind samples (UW-2 and DW-2) exceeded the applicable AMCV ST or ESL ST criteria. Following analysis, Modern reviewed the resulting chromatograms for indications of Tentatively Identified Compounds (TICs). The TIC evaluation for UW-2 suggested very low levels of benzaldehyde. The TIC evaluation for DW-2 suggested very low levels of hexane. A summary of the VOCs observed and estimated quantified during fenceline monitoring is included in Table 3. PROJECT I AUGUST 28, 2015 I PAGE 14

16 4.2.4.WEATHER CONDITIONS Modern deployed a mobile weather station to record weather conditions during site sampling efforts. The following was noted at this padsite: Average wind speed: 9 mph Average wind direction (blowing to): North-Northwest Temperature: 95 ⁰F Humidity: 45 % Precipitation: None GENERAL COMMENTS No elevated monitoring results were noted at the padsite perimeter to suggest concern to properties off of the padsite during our monitoring effort. No spills or releases to the ground were observed during the inspection. PROJECT I AUGUST 28, 2015 I PAGE 15

17 4.3. PADSITE NO. 3 FURST RANCH D Wellhead Identification: Separator Identification: AST Identification: A: Furst Ranch D 1H (RRC# ) A: Furst Ranch D A: Furst Ranch D B: Furst Ranch D 2H (RRC# ) B: Furst Ranch D B: Furst Ranch D C: Furst Ranch D 3H (RRC# ) C: Furst Ranch D C: Furst Ranch D D: Furst Ranch D E: Furst Ranch D F: Furst Ranch D LEAKS IDENTIFIED No leaks were identified during the inspection of the wellhead(s), separator(s), and aboveground storage tank(s) on July 20, ELEVATED NORM The following equipment was noted to have NORM readings in excess of 50 µr/hr and was unlabeled: Separator C and the associated piping; Elevated NORM levels can be an early indication of scale build up within padsite equipment and suggestive that maintenance includes cleaning of these components. Continued operation under RRC will generally require that proper signage be applied to the equipment for future management as NORM-containing material. Modern communicated the elevated NORM results to allow the operator to incorporate this information into their management of the padsite. These components did not appear to be labeled as per the Texas Railroad Commission requirements when elevated NORM-containing equipment is present FENCELINE MONITORING RESULTS None of the observed compounds identified in the upwind and downwind samples (UW-3 and DW-3) exceeded the applicable AMCV ST or ESL ST criteria. Following analysis, Modern reviewed the resulting chromatograms for indications of Tentatively Identified Compounds (TICs). The TIC evaluation for UW-3 suggested very low levels of acetone and dodecane. The TIC evaluation for DW-3 suggested very low levels of benzaldehyde. A summary of the VOCs observed and quantified during fenceline monitoring is included in Table 3. PROJECT I AUGUST 28, 2015 I PAGE 16

18 4.3.4.WEATHER CONDITIONS Modern deployed a mobile weather station to record weather conditions during site sampling efforts. The following was noted at this padsite: Average wind speed: 4 mph Average wind direction (blowing to): North Temperature: 97 ⁰F Humidity: 43 % Precipitation: None GENERAL COMMENTS No elevated monitoring results were noted at the padsite perimeter to suggest concern to properties off of the padsite during our monitoring effort. A saltwater leak was noted at Separator B. It is recommended this leak be repaired. PROJECT I AUGUST 28, 2015 I PAGE 17

19 5. OPERATOR INFORMATION As part of the padsite inspection, Modern requested that operator personnel provide a summary of their padsite operations over the last six months through both on-site inspection as well as distance monitoring. This section includes the responses provided to Modern OPERATOR INSPECTION RESULTS According to the periodic inspection efforts reported to Modern, the following issues were noted and addressed. Component/Parameter Leak Indicated Spill Indicated Leak Indicated Spill Indicated Leak Indicated Spill Indicated Padsite: Obenchain Furst Ranch C Furst Ranch D Operator: Trinity River Energy Eagle Ridge Eagle Ridge Tubing Pressure NR NR No No No No Production Casing Pressure NR NR No No No No Braden Head Pressure NR NR No No No No Needle Valve, Controls, NR NR No No No No High/Low Valve Wellhead Fluid Containment NR NR No No No No Wellhead to Separator Piping NR NR No No No No Separator NR NR No No No No Tank Battery NR NR No No No No Water Transfer Connection NR NR No No No No Ancillary Equipment NR NR No No No No Other NR NR No No No No NR-No Response No response was received from the Trinity River Energy at the time of the issuance of this report. Modern understands that Town staff is continuing to reach out to Trinity River Energy for information concerning inspection results during the last six months. If a response is received that alters the findings and conclusions of this report, an addendum will be issued. PROJECT I AUGUST 28, 2015 I PAGE 18

20 5.2. OPERATOR MONITORING RESULTS According to the distance monitoring efforts reported to Modern, the following issues were noted and addressed. Component/Parameter Leak Indicated Spill Indicated Leak Indicated Spill Indicated Leak Indicated Spill Indicated Padsite: Obenchain Furst Ranch C Furst Ranch D Operator: Trinity River Energy Eagle Ridge Eagle Ridge Tubing Pressure NR NR No No No No Casing Pressure NR NR No No No No AST Fluid Levels NR NR No No No No Emergency Shutoff Events NR NR No No No No Other NR NR No No No No NR-No Response No response was received from the Trinity River Energy at the time of the issuance of this report. Modern understands that Town staff is continuing to reach out to Trinity River Energy for information concerning inspection results during the last six months. If a response is received that alters the findings and conclusions of this report, an addendum will be issued. PROJECT I AUGUST 28, 2015 I PAGE 19

21 6. FINDINGS AND CONCLUSIONS Modern has prepared the following findings and conclusions based on this pad site inspection and monitoring event: A limited number of VOCs were noted at both the TCEQ CAMS 1007 (Shiloh Road) in the ambient air sample and the fenceline monitoring points evaluated this month. Based on the low concentrations observed, these appear consistent with ambient urban air and previous sampling results from the Town. None of the ambient air sampling results exceeded their respective TCEQ AMCV ST or ESL ST values. Additionally, none of the fenceline monitoring observations completed at each padsite exhibited elevated levels of hydrogen sulfide, methane, or tvocs suggestive of padsite contribution. Padsite Inspection efforts identified leaks at the Obenchain and Furst Ranch C padsites. Elevated NORM levels were noted within equipment that was unlabeled at the Furst Ranch C and Furst Ranch D padsites. The inspection results were communicated to the operator to allow further inspection and equipment maintenance/labeling in accordance with RRC requirements. According to the Town of Flower Mound inspector, each of the leaks were addressed and re-inspected with levels below leak criteria. No visual evidence of significant spills or releases other than noted above was identified during the inspections this month. No significant spills or leaks were reported by the operators for the three padsites evaluated this month within the last six (6) months other than these noted by Modern during our inspection. The inspection program will continue to include an evaluation of each padsite every six (6) months. Additional inspection and monitoring is planned for next month. PROJECT I AUGUST 28, 2015 I PAGE 20

22 7. IMPORTANT ACRONYMS AMCV AST ASTM BACT BMP CAA COC EPA ESL ETJ FID FRP GC/MS HAP HASP HQ IDLH IHW LDAR LDCP MACT MSDS NAAQS NESHAP NORM NSPS OPM OSHA PEL PID PPB PPM Air Monitoring Comparison Value (Short or Long Term Criteria) Aboveground storage tank ASTM International Best Available Control Technology Best Management Practice Clean Air Act Chemicals of Concern United States Environmental Protection Agency Effect Screening Level (Short or Long Term Criteria) Extra Territorial Jurisdiction Flame Ionization Detector Fiberglass Reinforced Plastic Gas Chromatograph/Mass Spectrometer Hazardous Air Pollutant Health and Safety Plan Hazard Quotient Immediately Dangerous to Life and Health TCEQ Industrial & Hazardous Waste Program Leak Detection and Repair Leak Detection and Compliance Plan Maximum Achievable Control Technology Material Safety Data Sheet National Ambient Air Quality Standard National Emissions Standards for Hazardous Air Pollutants (Technologically Enhanced) Naturally Occurring Radioactive Material New Source Performance Standard Open Path Monitoring Occupational Safety & Health Administration OSHA Permissible Exposure Limit Photo Ionization Detector Parts Per Billion (PPBV by volume) Parts Per Million (PPMV by volume) PROJECT I AUGUST 28, 2015 I PAGE 21

23 RBEL RCRA RfC ROD RRC RSC SVOCs TCEQ TD TOX TPH TPWD TRRP tvocs TVA TWDB TXU URF USC USGS UST UV VOCs Risk Based Exposure Limit Resource Conservation and Recovery Act Reference Concentration Record of Decision Texas Railroad Commission Reduced Sulfur Compounds Semi-volatile Organic Compounds Texas Commission on Environmental Quality Thermal Desorption Total Organic Halides Total Petroleum Hydrocarbons Texas Parks and Wildlife Department Texas Risk Reduction Program Total Volatile Organic Compounds Total Vapor Analyzer (Typically in the form of a Flame Ionization Detector or FID) Texas Water Development Board Texas Utilities Unit Risk Factor United States Code United States Geological Survey Underground Storage Tank Ultraviolet Volatile Organic Compounds PROJECT I AUGUST 28, 2015 I PAGE 22

24 8. LIMITATIONS AND EXCEPTIONS Modern s services were performed in a manner consistent 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). 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. 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. PROJECT I AUGUST 28, 2015 I PAGE 23

25 FIGURES

26 Source: 2010 Microsoft Corporation and its data suppliers 1 K " ) 2 3 " ) <AA-1 " )! 4 6 " ) 5 " ) " ) " ) 10 " ) # * " ) Map ID Lease Obenchain Furst Ranch C Furst Ranch D Furst Ranch I Furst Ranch L Crow-Wright Pad 3 Armstrong-Higgins Cummings Pad C Cummings-Hodge Pad B Sam Wilson Pad 5,6 Bob Smith Pad A Bob Smith Pad B Bob Smith Pad C Sam Wilson CS Pad Bunn Hillard 0.75 " ) " ) " )13! <AA-5 " ) 15 " )! <AA-6 " ) Operator Trinity River Energy Eagle Ridge Energy Eagle Ridge Energy Eagle Ridge Energy Eagle Ridge Energy Red Oak Gas Operating Keystone Exploration, Ltd. Trinity River Energy Trinity River Energy Trinity River Energy Trinity River Energy Trinity River Energy Trinity River Energy Trinity River Energy Trinity River Energy Atlas Energy, LLC 1.5 Miles The information included in this figure was obtained from multiple sources and is subject to change without notice. Modern Geosciences does not warrant the accuracy or rights concerning use of third party information. This figure is not intended to represent a legal survey. The use or misuse of the data provided is at the sole risk of the party using or misusing the information. 16 Legend " ) Active Padsite # *! < TCEQ Monitoring Station Ambient Air Sampling Point Surrounding Area PROJECT NO DRAWN: DRAWN BY: LM CHECKED BY: FILE NAME: KT " ) PADSITE LOCATION MAP Flower Mound Air Monitoring 2014 Flower Mound, Texas FIGURE 1 TOFM_Air_SampLoc_ mxd Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community

27 Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community Wind Direction observed during sample collection K ") ") ") ")!< ") Ú[ "J DW-1 ") B ") A!( A B #* #* A "J UW Feet This figure was prepared using data from a variety of sources. No warranty is made as to the accuracy or completeness of data provided through third parties. All data contained herein is subject to change without notice. This figure is not intended for use as a legal survey or construction design document. Legend "J Air Sample Point!( AST ") Separator #* Well Padsite Boundary PROJECT NO DRAWN: DRAWN BY: LM CHECKED BY: KT FILE NAME: TOFM_Obenchain_ mxd PADSITE MAP Obenchain Padsite Flower Mound, Texas FIGURE 2

28 Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community Wind Direction observed during sample collection K ") ") ") ")!< ") Ú[ "J DW-2 ") A ") B!( A!(!( B D!( C #* A #* B "J UW Feet This figure was prepared using data from a variety of sources. No warranty is made as to the accuracy or completeness of data provided through third parties. All data contained herein is subject to change without notice. This figure is not intended for use as a legal survey or construction design document. Legend "J Air Sample Point!( AST ") Separator #*Well Padsite Boundary PROJECT NO DRAWN: DRAWN BY: LM CHECKED BY: KT FILE NAME: TOFM_FurstC_ mxd PADSITE MAP Furst Ranch C Padsite Flower Mound, Texas FIGURE 3

29 Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community ") ") ") ")!< ") ")!< ") Ú Wind Direction observed during sample collection [ K "J DW-3!( F!( D!( B!( E!( C A!( ") A ")") B C "J #* C #* B #* A UW Feet This figure was prepared using data from a variety of sources. No warranty is made as to the accuracy or completeness of data provided through third parties. All data contained herein is subject to change without notice. This figure is not intended for use as a legal survey or construction design document. Legend "J Air Sample Point!( AST ") Separator #*Well Padsite Boundary PROJECT NO DRAWN: DRAWN BY: LM CHECKED BY: KT FILE NAME: TOFM_FurstD_ mxd PADSITE MAP Furst Ranch D Padsite Flower Mound, Texas FIGURE 4

30 LEAK DOCUMENTATION PHOTOS

31 LEAK DETECTION DOCUMENTATION Site: Obenchain Padsite, Flower Mound, Texas Data Collection Period: July 20, 2015 OGI Equipment: FLIR GF320 Exhibit 1 Separator B Leak noted at an actuator (red arrow). Exhibit 2 Leak shown in High Sensitivity Mode (red arrow). Methane reading was noted to be 1.3% by volume at leak. The operator was notified of the leak Modern Geosciences

32 LEAK DETECTION DOCUMENTATION Site: Furst Ranch C Padsite, Flower Mound, Texas Data Collection Period: July 20, 2015 OGI Equipment: FLIR GF320 Exhibit 1 Separator B Leak noted at an actuator (red arrow). Exhibit 2 Leak shown in High Sensitivity Mode (red arrow). Methane reading was noted to be 1.6% by volume at leak. The operator was notified of the leak Modern Geosciences

33 PHOTOGRPAHIC DOCUMENTATION

34 PHOTOGRAPHIC DOCUMENTATION Site: Obenchain Padsite, Flower Mound, Texas Photo Date: July 20, 2015 No. 1 View of Wellhead A. No. 2 View of Wellhead B. No. 3 View of the Separators. No. 4 View of AST A. No. 5 View of air sample point UW-1. No. 6 View of the weather station.

35 PHOTOGRAPHIC DOCUMENTATION Site: Furst Ranch C Padsite, Flower Mound, Texas Photo Date: July 20, 2015 No. 1 View of Wellheads A and B. No. 2 View of ASTs. No. 3 View of ASTs labeled with NORM stickers.

36 PHOTOGRAPHIC DOCUMENTATION Site: Furst Ranch D Padsite, Flower Mound, Texas Photo Date: July 20, 2015 No. 1 View of Wellheads A and B. No. 2 View of Separators. No. 3 View of ASTs. No. 4 View of padsite inspection activities. No. 5 View of the saltwater leak noted at Separator B. No. 6 View of air sample point UW-3.

37 TABLES

38 Table 1: Ambient Air Results- VOCs Sample Point: AA-5 AA-6 AA-1 Flower Mound, Texas Sample Date: Sample Time: 8/22/ :1614 9/17/ :932 10/29/ :951 AMCV ESL Max RDL Result RDL Result RDL Result 1,1,1-Trichloroethane ,700 H 510 H 1.8 1,1,2,2-Tetrachloroethane H 10 H 0 1,1,2-Trichloroethane H 100 H 0 1,1,2-Trichlorotrifluoroethane NE 5000 H ,1-Dichloroethane H 1000 H 0 1,1-Dichloroethene H 54 H 0 1,2,4-Trichlorobenzene NE 6.74 H ND 0.63 ND 0.63 ND 1,2,4-Trimethylbenzene O 140 O J J 0.2 ND 1,2-Dibromoethane H 0.5 H ,2-Dichlorobenzene NE 100 H 0 1,2-Dichloroethane H 40 H 0 1,2-Dichloropropane H 100 H 0 1,2-Dichlorotetrafluoroethane NE H 0 1,3,5-Trimethylbenzene H 250 H ,3-Butadiene O 230 O 0 2 ND 2 ND 2 ND 1,3-Dichlorobenzene NE 100 H 0 1,4-Dichlorobenzene NE 120 O ,4-Dioxane NE 250 H 0.7 2,2,4-Trimethylpentane O 670 O ND J 0.2 ND 2-Butanone (MEK) O 440 O J 1.25 ND 2-Chlorotoluene NE 45 O 0 2-Propanol NE 2000 H J J Ethyltoluene O 8.1 O Methyl-2-pentanone (MIBK) O 170 O ND J 1.25 ND Acetone H 3300 H Allyl chloride NE 10 H ND ND Benzene * H 54 H ND J Benzyl Chloride NE 10 H 0 Bromodichloromethane NE 100 H 0 Bromoform NE 5 H ND 0.6 ND 0.6 ND Bromomethane H 30 H 0 Carbon tetrachloride H 20 H Chlorobenzene H 100 H 0 Chloroethane NE 190 H 0 Chloroform H 20 H 0 Chloromethane H 500 H cis-1,2-dichloroethene NE NE 1.3 cis-1,3-dichloropropene H 10 H 0 Cyclohexane H 1000 H 0.27 Dibromochloromethane NE H 0 Dichlorodifluoromethane H H Ethanol NE 1010 O J E Ethylbenzene O 170 O ND J 0.2 ND Heptane O 670 O ND J J Hexachloro-1,3-butadiene NE 0.2 H ND 0.63 ND 0.63 ND Isopropylbenzene O 48 O 0 m&p-xylene O 58 O J J 0.4 ND Methyl Butyl Ketone H 10 H ND 1.25 ND 1.25 ND Methyl methacrylate NE 210 O J J 0.2 ND Methylene Chloride H 1100 H J J MTBE O 130 O 0 Naphthalene O 38 O ND J ND 0.63 ND n-hexane O 1500 O J o-xylene O 380 O ND J 0.2 ND Propene O NE ND 0.4 ND 0.4 ND Styrene O 25 O 0.23 Tetrachloroethene O 300 H ND 0.2 ND J Tetrahydrofuran NE 70 O 0.34 Toluene O 170 O J trans-1,2-dichloroethene NE 2000 H 0 trans-1,3-dichloropropene H 10 H 0 Trichloroethene H 100 H ND 0.2 ND Trichlorofluoromethane O 5000 O J Vinyl acetate NE 40 H 0 Vinyl Bromide NE 50 H 0 Vinyl chloride H 7800 H 2.2 Remarks: All concentrations in ppbv ESL = Effects Screening Level (short term); TCEQ March 2014 AMCV = Air Monitoring Comparison Value (short term); TCEQ March 2014 *utilizes a 24-hour specific criteria (TCEQ) J3=The associated batch QC was outside the established quality control range for precision E=Greater than upper calibration limit: actual valve is known to be greater than the upper calibration range. J=Estimated value below the lowest calibration point. Confidence correlates with concentration. H = human health; O = Odor; V=Vegetation; A=Asphyixiant; RDL = Reporting Detection Limit Please see laboratory data sheets for additional detail Copyright 2015 Modern Geosciences Page 1 of 4

39 Table 1: Ambient Air Results- VOCs Sample Point: Flower Mound, Texas Sample Date: Sample Time: AMCV ESL Max 1,1,1-Trichloroethane ,700 H 510 H 1.8 1,1,2,2-Tetrachloroethane H 10 H 0 1,1,2-Trichloroethane H 100 H 0 1,1,2-Trichlorotrifluoroethane NE 5000 H ,1-Dichloroethane H 1000 H 0 1,1-Dichloroethene H 54 H 0 1,2,4-Trichlorobenzene NE 6.74 H 0 1,2,4-Trimethylbenzene O 140 O ,2-Dibromoethane H 0.5 H ,2-Dichlorobenzene NE 100 H 0 1,2-Dichloroethane H 40 H 0 1,2-Dichloropropane H 100 H 0 1,2-Dichlorotetrafluoroethane NE H 0 1,3,5-Trimethylbenzene H 250 H ,3-Butadiene O 230 O 0 1,3-Dichlorobenzene NE 100 H 0 1,4-Dichlorobenzene NE 120 O ,4-Dioxane NE 250 H 0.7 2,2,4-Trimethylpentane O 670 O Butanone (MEK) O 440 O Chlorotoluene NE 45 O 0 2-Propanol NE 2000 H Ethyltoluene O 8.1 O Methyl-2-pentanone (MIBK) O 170 O 0.2 Acetone H 3300 H 10 Allyl chloride NE 10 H 0.21 Benzene * H 54 H 0.59 Benzyl Chloride NE 10 H 0 Bromodichloromethane NE 100 H 0 Bromoform NE 5 H 0 Bromomethane H 30 H 0 Carbon tetrachloride H 20 H Chlorobenzene H 100 H 0 Chloroethane NE 190 H 0 Chloroform H 20 H 0 Chloromethane H 500 H 0.87 cis-1,2-dichloroethene NE NE 1.3 cis-1,3-dichloropropene H 10 H 0 Cyclohexane H 1000 H 0.27 Dibromochloromethane NE H 0 Dichlorodifluoromethane H H 0.64 Ethanol NE 1010 O 22 Ethylbenzene O 170 O 0.22 Heptane O 670 O 0.31 Hexachloro-1,3-butadiene NE 0.2 H 0 Isopropylbenzene O 48 O 0 m&p-xylene O 58 O 0.67 Methyl Butyl Ketone H 10 H 0.37 Methyl methacrylate NE 210 O 0.18 Methylene Chloride H 1100 H 0.44 MTBE O 130 O 0 Naphthalene O 38 O 0.15 n-hexane O 1500 O 0.96 o-xylene O 380 O 0.23 Propene O NE 0 Styrene O 25 O 0.23 Tetrachloroethene O 300 H 0.57 Tetrahydrofuran NE 70 O 0.34 Toluene O 170 O 0.94 trans-1,2-dichloroethene NE 2000 H 0 trans-1,3-dichloropropene H 10 H 0 Trichloroethene H 100 H 0.55 Trichlorofluoromethane O 5000 O 0.28 Vinyl acetate NE 40 H 0 Vinyl Bromide NE 50 H 0 Vinyl chloride H 7800 H 2.2 Remarks: All concentrations in ppbv ESL = Effects Screening Level (short term); TCEQ March 2014 AMCV = Air Monitoring Comparison Value (short term); TCEQ March 2014 *utilizes a 24-hour specific criteria (TCEQ) J3=The associated batch QC was outside the established quality control range for precision E=Greater than upper calibration limit: actual valve is known to be greater than the upper calibration range. J=Estimated value below the lowest calibration point. Confidence correlates with concentration. H = human health; O = Odor; V=Vegetation; A=Asphyixiant; RDL = Reporting Detection Limit Please see laboratory data sheets for additional detail AA-5 11/19/ :951 AA-6 12/17/ :927 AA-1 1/21/ :942 RDL Result RDL Result RDL Result J 0.2 ND 0.2 ND 0.63 ND 0.63 ND 0.63 ND J 0.2 ND 0.2 ND 2 ND 2 ND 2 ND 0.2 ND 0.2 ND J3 0.2 ND 0.2 ND ND J J 1.25 ND J J J 1.25 ND 1.25 ND 1.25 ND J J ND 0.6 ND 0.6 ND J 0.2 ND 0.2 ND J 0.2 ND 0.2 ND J J 0.2 ND 0.2 ND 0.63 ND 0.63 ND 0.63 ND J 0.4 ND J 1.25 ND 1.25 ND 1.25 ND J 0.2 ND 0.2 ND J J J 0.63 ND 0.63 ND ND 0.4 ND 0.4 ND J J Copyright 2015 Modern Geosciences Page 2 of 4