                                                                               
MEMORANDUM   


TO:		Amy Hambrick, EPA/OAQPS/SPPD/FIG

FROM:	David Hendricks, EC/R, Inc.

DATE:	April 18, 2016

SUBJECT:	Summary of the January 27, 2016, Meeting with ConocoPhillips and the U.S. Environmental Protection Agency 
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I.	INTRODUCTION

Conoco Phillips requested this meeting with EPA to present an overview of their comments on the September 18, 2015 proposed Oil and Natural Gas Sector NSPS (80 FR 56593). This summary addresses those comments and other concerns regarding this action.

II.	ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency
Bruce Moore
Eric Goehl
Jody Howard
Charlene Spells
Brenda Shine
David Cozzie
Matthew Witosky

Conoco Phillips
Laura Perry
Jenny Yang
Larry Baker
Terry Lawd

EC/R Incorporated
David Hendricks (by phone)

III.	SUMMARY OF DISCUSSION

Bruce Moore opened the meeting and explained to the attendees that because the EPA is in the post-proposal phase of the NSPS and CTG, EPA personnel would listen to their comments but cannot respond to any of the issues raised. However, the EPA welcomed the comments. The attendees offered the following comments.

NSPS Proposal
 North Slope Operational Overview
 Kuparuk has 150 sq. mi. oilfield with 49 drill sites 3 processing facilities, (Alpine - 1, and BP - Prudhoe Bay 6), with 1200 wells distributed across well sites, 10 - 70 wells per drill site, approximately 800 miles of pipeline. 
 Kuparuk is unique, with its own water treatment plant and power generation.
 Unique feature of the site is permafrost to 1700 ft. Thus, need onsite storage for freeze protection fluid. Some sites have pumps, 2/3 use pump trucks.
 Central processing facilities (CPF) with holding tanks, not in continuous use. There is no tank loading.
 Site must produce gas to keep power running at site. CPF tanks hold 50k barrels. There is no offloading, no sales point. Not all CPFs have holding tanks, ex. Alpine.
            
 Shutdowns
 There are 1-2 summer shutdowns per year, plus other weather related events preventing boats from reaching Valdez; other pipeline issues, 1-10 times a year. Most common issues are weather at Valdez and planned maintenance for shutdown.
 Shutting down drill site involves freeze protecting all wells year-round within 48 hours. In winter, need to de-inventory flow lines from drill site to CPF. If not, pipes will freeze 48-72 hours.
 Winter challenge of shut down is cold soak, then must pre-warm pipes before fluids can be run through them. This involves circulating warm gas for days to warm pipe up. 
 Processing facilities are all enclosed, not open to air. Manned 24/7. Drill sites are not manned 24/7 but visited daily pending weather.
            
            
 Current LDAR Program
 State mandated LDAR program. 
 Stated mandated AVO checks monthly. CP requires once a day weather permitted checks and leaks found are put into a work order system if not immediately reparable.
 Hundreds of times a month someone is out there with a gas detector looking for leaks or other before turning on arc or spark generating equipment; even a flash camera can cause a problem.
 An auto gas detection system is in place at all facilities but well houses.
 Leak detection techniques used include olfactory and AVO. 
 Leaks are detected and repaired by an operator if able to or passed on to maintenance crew. 
 Valve crew technicians working 24/7 routinely look at valves, sealing body, stem leaks, and perform onsite repairs when possible. Most valves and stems have 2 seals, primary and secondary. 
 Alaska does not require LDAR beyond AVO.
            
 Climate and Meteorological Impacts on Technology
 Temperature and wind are the largest factors. Site is located at edge of NPRA. Temperature 5 months per year average below 0[o]F. 
 November through May are intense winter temperatures with high winds and blowing snow. 
 Site operates under a 3-phase system, under which different types of work are allowed.
 Weather is a consideration in getting to/from the North Slope. Crews must be flown in, with frequent flight restrictions winter and summer due to wind and fog which affect availability of personnel and supplies. 
 OGI  -  operating limiting temperature of -4[o]F, but many times of year the average is below 0, so cameras may not operate as intended.
 FLIR cameras in their experience have had success with up to 8 mph wind, but 46% of the time they have wind above 10 mph. This is not specific to any time of year or day.
 Other operating system restrictions in winter include that well houses are only heated to just above freezing. Thus, inspecting for leaks outdoors exposes staff and cameras to temperature extremes.
            
 Repair Times
 The onsite biggest challenge is planned vs emergency shutdown.
 Getting specialized equipment to site is a challenge. The required valves are a different spec from most used in country with lead times up to 36 months because they have a rating to -50[o]F, rather than the commonly used valves rated to -20[o]F.
 Planned facility shutdowns every 3 years are required.
 Challenges to repair of leak are lead time, leak repair time, getting parts, storing parts, transportation, process safety, and managing safety risks and considerations.
 Concern that 15-day deadline would be problematic due to difficulties procuring parts etc. Some parts are in Anchorage, some in Texas. Many valves require a 16-week lead time. 
 Concern that 6 months may not be long enough lead time for some repairs though 99% of the time they could comply.
 Concern that they are set up for noncompliance due to the site's unique factors.
 Believe a North Slope exemption should be allowed to be consistent with other subparts such as GGG, KKK and OOOO. Reasons for the exemption include the site's great distance from population centers, its low temperatures and the fact that it provides extraordinary services.
 Note that there is no place to take offload oil between the wellsite and Valdez.
            
 Language Clarification
 Regarding gathering and boosting terminology, they commented that definitions were not provided but are needed for clarification.
 Stated that the wellsite definition was confusing in terms of where one clause ends and another begins. Concerned that a process facility could be considered a wellsite though they have no producing wells.
