                                                                               
MEMORANDUM   

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

FROM:	Bradley Nelson, EC/R, Inc.

DATE:	December 1, 2015

SUBJECT:	Summary of the November 30, 2015, Meeting with ConocoPhillips and the U.S. Environmental Protection Agency 
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I.	INTRODUCTION

ConocoPhillips 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).

II.	ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency
Bruce Moore
David Cozzie
Amy Hambrick
Lisa Thompson
Jodi Howard
Ravi Srivastava
Alex McPherson
Charlene Spells
Gerri Garwood

ConocoPhillips
Laura Perry
Jenny Yang
Josh Kindred (Alaska Oil and Gas Association)

EC/R Incorporated
Bradley Nelson
David Hendricks

III.	SUMMARY OF DISCUSSION

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

As a background, ConocoPhillips provided an overview of their operations on the Alaskan North Slope (See attached presentation) and offered the following comments.

NSPS Proposal
 Fugitive Emissions Monitoring Program
 Asked for clarification of the affected facility provisions in 60.5365a(i)(2). They noted that a well pad on the Alaskan North Slope may contain 10-40 wells, with each well housed in a small building only containing a heater. Each of the wells from a well pad are piped to a manifold or pipeline and directed to a central processing facility. No separation or processing takes place at the well pad. Noted that some facilities may have methanol storage tanks. The methanol is used to prevent freezing in the well heads, manifold and pipeline.
 Recommended that the well site definition be revised to take into account the operations in the Alaskan North Slope. Noted that there is no condensate produced from the wells and any gas generated from the well is used to fuel engines or turbines, or reinjected back into the well. Oil storage tanks are only located at the central processing facility.
 Pointed out that the OGI camera operating range is -4°F to 122°F and the temperatures on the Alaskan North Slope can be below this operating range.
 Noted that the well pads are remote and equipment leak repairs may take longer than a typical well site. 
            
ConocoPhillips requested a meeting after the end of the comment period to discuss their submitted comments.












                                       
                                       
                                       
                                       
                                       
            ConocoPhillips Meeting Presentation Provided to the EPA

                                       
                                       
                                       
                                       
                                       

                                       
                                       
                                       
                                       
                                       
                                       

                                       
                                       
                                       
                                       
                                       

                                       
                                       
                                       
                                       
                                       
