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Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 06/26/2024 08:08 AM (AKT) Announced: No 06/27/2024 03:22 PM (AKT) Access: Granted Resource Conservation and Recovery Act (RCRA) Compliance Evaluation Inspection (CEI) Company Name Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Geographic Coordinates Mailing Address/Secondary Address City, State, Zip Code ConocoPhillips Alaska Inc ConocoPhillips Alaska Inc - Kuparuk Oil Field AKD991281023 35 Miles West of Deadhorse Deadhorse, AK 99734 North Slope Borough Large Quantity Generator (LQG) 213111 Drilling oil and gas wells on the North Slope of Alaska 70.289666, -149.884468 Ms. Wendy Mahan, Environmental Coordinator n1438@conocophillips.com ConocoPhillips Alaska Inc. - Kuparuk Oil Field PO Box 196105 Kuparuk Operations - NSK61 Anchorage, AK 99519 Anchorage, AK 99519 Permit Number (If Applicable) N/A Lead Inspector: Jon Jones EPA Region 10 Jones.Jon@epa.gov (907) 271-6329 Supervisor Review: Matthew Quarterman EPA Region 10 Quarterman.Matthew@epa.gov (206) 553-2146 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: CEI EPA Region 10 Lead Inspector, Jon Jones, arrived at the ConocoPhillips Alaska Inc - Kuparuk Oil Field Facility (the "Site" or "Facility"), located at 35 Miles West of Deadhorse, Deadhorse, AK 99734, at 08:08 AM (AKT) on 06/26/2024 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and 1 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 informed Wendy Mahan (Environmental Coordinator) that this was an EPA Region 10 inspection to determine compliance with RCRA. The facility was inspected to ensure compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273) and used oil management (40 C.F.R. Part 279). The inspection was conducted as part of a Core Program requirement for FY 2024. This report is based on information supplied by ConocoPhillips Alaska Inc - Kuparuk Oil Field Facility representatives, observations made by the EPA REGION 10 inspector, and records and reports maintained by the facility and its HQ including, but not limited to: direct observations made by the EPA Region 10 Inspector(s), photographs taken by EPA Region 10 inspector(s), physical evidence collected by the EPA REGION 10 inspector(s), measurements or samples taken by EPA Region 10 inspector(s), verbal or written statements made by information supplied by the facility representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 10 inspector(s) by the facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of USEPA, State, and public records may be included in this report. Attendees Title/Organization Name Phone Lead Inspector/EPA REGION 10 Jon Jones (907) 2716329 RCRA Inspector-in- Vanessa training/Alaska Department of Schmidt Environmental Conservation (ADEC) (907) 2694581 Kuparuk Operations Scott Collins (907) 659- Superintendent/ConocoPhillips 7727 Alaska Inc. - Kuparuk Oil Field Kuparuk HSE Supervisor/ConocoPhillips Alaska Inc. - Kuparuk Oil Field Darren Burks (907) 6597220 Kuparuk Operations Johnny Superintendent/ConocoPhillips Gannon Alaska Inc. - Kuparuk Oil Field (907) 6597727 Kuparuk HSE Tamara Director/ConocoPhillips Alaska Hawkins Inc. - Kuparuk Oil Field (907) 6597590 Environmental Coordinator /ConocoPhillips Alaska Inc. Kuparuk Oil Field Wendy Mahan (907) 6590430 Email jones.Jon@epa.gov Opening Conf. Yes vanessa.schmidt@alaska.gov Yes n2073@conocophillips.com No n1023@conocophillips.com Yes n2073@conocophillips.com Yes n1153@conocophillips.com Yes n1438@ conocophillips.com Yes Closing Conf. Yes Yes Yes Yes No Yes Yes Opening Conference After arriving at the facility, Vanessa Schmidt (ADEC Inspector-in-training) and I were met by Wendy Mahan (Environmental Coordinator). I presented her with my credentials, provided her with my business card, and informed her of the purpose of the inspection. She informed Darren Burks (Kuparuk HSE Supervisor), Johhny Gannon (Kuparuk Operations Superintendent), and Tamara Hawkins (Kuparuk HSE Director) of the inspection 2 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 and they joined us in the conference room. We received a quick briefing on muster points in case of an emergency as well as a briefing on needed safety gear. We then began the opening conference. During the opening conference, Ms. Mahan informed us that there has not been much change at the facility since the last inspection in 2019. Their operations and processes continue to be that of oil and gas production; however, a "turnaround" event is currently occurring at Central Processing Facility (CPF) 1. This process is a maintenance shut down period that has a wide scope depending on the area of the facility and its condition. This process includes changing valves out at drill sites, cleaning vessels and replacing vessel components, performing internal inspections, and performing instrumentation upgrades and replacements. The waste during a turnaround is generally personal protective equipment (PPE), sandblast, sludge and slurries, tank bottoms, and aerosol cans. Ms. Mahan also informed us of the development of a new drill site (3T) and a new tank being built at CPF-2, both of which are currently in construction phases. There is also a pad expansion at 3S that is occurring. Ms. Mahan stated that ECC is their contractor for managing hazardous waste and that their last shipment of hazardous waste occurred on 6/18/24. Ms. Mahan provided us with a list of the current satellite accumulation areas (SAAs) with waste streams, as well as waste tracking sheets for each month to evaluate generator status and a map of the field. We discussed the records we would need to review at the end of this inspection which included manifests, the contingency plan and quick reference guide, training, and weekly inspections. We were accompanied throughout the inspection by Ms. Mahan and, for part of the first day, by Ms. Hawkins. We were not denied access to any part of the facility, and we were allowed to take photographs. Facility/Site Information Number of employees 280 ConocoPhillips employees/ 800-900 (on average) w/ contractors, 1,300 currently with turnaround occurring Length of Facility at Location The oil filed was discovered in 1969 and production began in 1981. ConocoPhillips took ownership of the field in 2004. Operating Hours 24 hours a day, 7 days a week, 365 days a year Safety Training No Provided to Inspector(s)? Size of Facility ~300 square miles What type of generator facility notified? Large Quantity Generator (LQG) What type of LQG generator facility verified as? Weather Conditions Day 1 and Day 2- Sunny and hot Process Description On Alaska's North Slope, ConocoPhillips operates the Kuparuk River Unit (Kuparuk), North America's second largest oil field, 40 miles west of Prudhoe Bay. Discovered in 1969, production at Kuparuk began in 1981, increasing to a record rate of 322,000 barrels per day in 1992. Kuparuk reached a milestone in July 2005 when cumulative production reached 2 billion barrels and has produced over 2.5 billion barrels to date. The Kuparuk Field is one of the largest onshore producing fields in the United States, with more than 500 active producing wells. Rotary-drilled wells and sidetracks from existing wellbores utilizing coiled-tubing drilling are the primary 3 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 means for development drilling at Kuparuk. In 2020, ConocoPhillips' net crude oil production at Kuparuk averaged 52 MBOED. Production is processed through the Kuparuk facilities. The Kuparuk satellites consist of the Meltwater, Tabasco, Tarn and West Sak fields. In 2020, they averaged 22 MBOED of net crude oil production. All the satellite fields produce through the Kuparuk production facilities. Waste generated at this facility include waste leather gloves, waste aerosol cans, waste paint related materials, waste solvents, waste solvent rags, universal waste lamps, and universal waste batteries. Aerosol cans are managed as universal waste; however, they are punctured when possible and any fluid recovered is managed as hazardous waste. During the inspection we examined the facility's processes, hazardous waste management practices, generation points, and accumulation areas. We looked for wastes that facility representative had not yet identified or designated as hazardous. We also observed the facility's universal waste management. Specifically, we inspected the areas of the facility listed below. Building(s) Building/Area/Sub-area Process Description Area of Concern 1 Ball Mill MI SWACO N/A No SAA Aerosol cans, leather articles, solvent rags, lamps, No batteries Airport Maintenance Facility (AMF) N/A No SAA Leather articles, aerosol cans, paint related No materials CPF-1 N/A Yes C/D Warehouse Aerosol Can Popping Aerosol cans, aerosol liquids No Area C/D Warehouse (Central Accumulation Receives waste streams from SAAs including aerosol Yes Area) CAA cans, compressed gas cylinders, aerosol liquids, leather articles, and batteries. C/D Warehouse CGC SAA D Warehouse Compressed gas cylinders No 1E Pad SAA Aerosol cans No Central Shops/Toolroom and Central Aerosol cans, lamps, propane cylinders, leather Yes Shops Rotating SAA articles, solvent rags, batteries, bulbs, H2S monitors Temp TA SAA PPE, sandblast, aerosol cans No Shipping/Receiving A/B Warehouse SAA Batteries, H2S monitors, aerosol cans, lather articles No CPF- 2 N/A No 4200 SAA Leather articles, aerosol cans, batteries, lamps, No bulbs Lab SAA Spent titration No Maintenance Shop SAA Leather articles, aerosol cans, glass bead media, H2S No monitors CPF-3 N/A No 4 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Maintenance Shop SAA Doyon 25 Mud lab SAA Rig SAA Shop SAA KCC Industrial Hygienist KO-14 SAA Rec Room Universal Waste Accumulation Area (UWAA) Roads and Pads (Cathouse) SAA Security Armory SAA Carpenter Shop SAA Dock (Housekeeping) SAA KCS Drilling Toolhouse SAA E&I Shop SAA Materials Tool Room SAA Pad Maintenance SAA Warehouse SAA Wireline SAA KIC Camp Maintenance SAA Halliburton SAA Heavy Duty Truck Shop SAA Light Duty Truck Shop SAA Light Duty Truck Shop Used Oil Area Outside of Shop Little Red SAA Leather articles, aerosol cans, solvent rags, lamps, No bulbs, batteries, blast media, H2S monitors N/A No Spent reagents No Leather gloves, lamps, batteries, aerosol cans, H2S No monitors Leather articles, aerosol cans No N/A Yes Aerosol cans, compressed gas cylinders, colormetric No tubes, waste methanol, oxygen sensors, dual-toxic sensors, H2S monitors Lamps, bulbs, batteries Yes Aerosol cans, leather articles, propane cylinders No Aerosol cans, solvent rags, pepper balls, batteries, No H2S meters Leather articles, batteries, aerosol cans No Aerosol cans, leather articles No N/A No Aerosol cans, leather articles, solvent rags, No batteries, bulbs, H2S monitors NO LONGER AN SAA LOCATION No Aerosol cans, leather articles, solvent rags, No batteries, bulbs, propane cylinders Lamps No Leather articles, aerosol cans, batteries No Aerosol cans, E&P blast media, leather articles, No batteries N/A Yes Lamps, aerosol cans, adhesives, leather articles, H2S No monitors, batteries, bulbs Aerosol cans, leather articles, lamps, bulbs, No batteries, H2S monitors Batteries, H2S monitors, aerosol cans, bulbs, solvent No rags, paint related materials, leather articles, chromium containing equipment Batteries, aerosol cans, leather articles, lamps, H2S No monitors Used oil Yes Aerosol cans, leather articles, lamps, bulbs, No batteries 5 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Valve Shop SAA Wash Bay SAA Wells Group SAA KOC Corrosion (D Wing) SAA Gas Station SAA Industrial Hygiene SAA Kakivik Connex A (Coupon Crew) SAA Kitchen SAA Lab (KLS) SAA Medical Clinic SAA Spill Response (KSRC) SAA Telecom Network Services SAA 3rd Floor UWAA Bus Barn SAA Hallway UWAA Nabors 7ES Mezzanine SAA Mud Lab SAA Shop SAA Nordic 3 Mud lab SAA Rig SAA Used Oil Collection Area Just Outside of Rig Seater Treatment Plant (STP) SAA Aerosol cans, leather articles, solvent rags, used No bead blast Leather articles No Leather articles, aerosol cans No N/A Yes Aerosol cans, leather articles, compressed gas Yes cylinders, batteries, H2S monitors Absorbents/ rags with gasoline No Compressed gas cylinders, oxygen sensors, dual- No toxic sensors Aerosol cans, leather articles, batteries No Aerosol cans No Aerosol cans, leather articles, solvent rags, spent No solvents, lead weights, aqueous solution pH<2, T.A.V. waste pH<1, aqueous solution with metals Aerosol cans, compressed gas cylinders, hazardous No waste pharmaceuticals, batteries Aerosol cans, leather articles, solvent rags, lamps, No bulbs Aerosol cans, leather articles, batteries No Lamps, batteries, bulbs No Aerosol cans No Lamps, bulbs No N/A Yes Aerosol cans, leather articles, lamps, H2S monitors, No batteries Spent reagents Yes Aerosol cans, batteries No N/A Yes Spent reagents No Aerosol cans, leather articles, bulbs, batteries No Used oil Yes N/A No Aerosol cans, leather articles, solvent rags, lamps, No batteries, H2S monitors SECTION II - OBSERVATIONS Building: KIC/ Light Duty Shop/Used oil tank outside shop Observation #: JJ1-OB-007 Date: 06/26/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Wendy Mahan Title: Environmental Coordinator 6 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 At the time of the inspection, we observed a used oil storage tank inside of a shed. On one side of the shed it was labeled as "waste oil". The tank and the rest of the shed were labeled "used oil". Personnel in the area were told to paint over the words "waste oil" and they stated that they would. Building: KIC/ Little Red/ SAA Observation #: JJ1-OB-012 Date: 06/26/2024 Person Interviewed: Wendy Mahan Contains AOC: No Contains CBI: No Title: Environmental Coordinator At the time of the inspection, we observed a container of waste lamps that was properly labeled with the words "used lamps" but did not have an accumulation start date. While labeling containers with an accumulation start date is an internal protocol, Ms. Mahan was able to determine an accumulation start date based on the waste log associated with the container in the SAA. This date was within a year and Ms. Mahan labeled the container with the date "5/24/24". Photo(s) 1. IMG-20240626115020502063286.jpg 2. IMG-20240626115028502845429.jpg 3. IMG-20240626115122512272188.jpg 4. IMG-20240626115648564874348.jpg 5. IMG-20240626115654565458500.jpg Building: CPF-1/ C/D Warehouse/ CAA Observation #: JJ1-OB-015 Date: 06/26/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Wendy Title: Ms. Mahan stated that the facility had a shipment of hazardous waste go out on 6/18/24 and therefore not much waste was present on site in the CAA at the time of the inspection. She stated that she believed universal waste had also been shipped out recently. At the time of the inspection, we observed one 55- gallon poly drum pending analysis. This drum was labeled both with a "hazardous waste" label and a "non-hazardous waste" label. It was not marked with a hazard indicator. Ms. Mahan stated that she would have CAA personnel add a hazard indicator. At the time of the inspection, we observed one 5-gal white bucket labeled "hazardous waste". It was not marked with a hazard indicator. Ms. Mahan labeled this container with a hazard indicator during the inspection. At the time of the inspection, we observed a small box of universal waste lithium batteries that was not closed properly because it contained too many batteries. Ms. Mahan stated that she would repackage this container. At the time of the inspection, we observed a large crate of waste leather gloves not labeled "hazardous waste", nor marked with a hazard indicator. However, two bags inside the box were labeled appropriately. Ms. Mahan stated that she would have CAA personnel label the crate with the words "hazardous waste" and with a hazard indicator. At the time of the inspection, we observed three drums on an upper shelf with labels that were difficult to read. Ms. Mahan stated that she did not believe these drums to contain hazardous waste. She stated that they were being held for analysis and she would inform us of the results when she received them. I recommended 7 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 that Ms. Mahan consider making the hazardous waste label larger as it is difficult to see information like the hazard indicator, specifically when a container is elevated on a shelf such as these. In an email received from Ms. Mahan after the inspection, photos were provided addressing areas of concern identified during the inspection. This included: labeling the crate of hazardous waste gloves with a hazardous waste label and a hazard indicator, repackaging the box of lithium batteries to ensure the container was closed, and labeling the appropriate containers as "non-hazardous" after receiving confirmation from analyses. In relation to these drums, she stated that the contents were found to be blast media, glycol A, and glycol B. Photo(s) 1. IMG-2024062613061361372998.jpg 2. IMG-202406261306286282000440.jpg 3. IMG-2024062613082082077307.jpg 4. IMG-2024062613082582570523.jpg 5. IMG-2024062613093093072478.jpg 6. IMG-2024062613125812581982146.jpg 7. IMG-2024062613160916978155.jpg 8. IMG-20240626131617161778743.jpg 9. IMG-20240626131623162371356.jpg 10. IMG-20240626132021202176882.jpg 11. IMG-20240626132038203858901.jpg 12. IMG-20240626132049204962767.jpg Building: KOC/ Medical Clinic/ SAA Observation #: JJ1-OB-030 Date: 06/27/2024 Person Interviewed: Wendy Mahan Contains AOC: No Contains CBI: No Title: Environmental Coordinator This SAA is where hazardous waste pharmaceuticals are handled. Clinic personnel stated that hazardous waste pharmaceuticals generated in the clinic are managed as hazardous waste. Non-hazardous waste pharmaceuticals that are expired are donated to a clinic in Anchorage to be re-used. This clinic does utilize a reverse distributor for any potentially creditable pharmaceuticals. Photo(s) 1. IMG-20240627081713171381632.jpg 2. IMG-20240627081720172067362.jpg 3. IMG-20240627081726172664934.jpg 4. IMG-2024062708200020058022.jpg 5. IMG-20240627082011201151273.jpg 6. IMG-20240627082020202068971.jpg Building: KCC/ Rec Room UWAA/ SAA Observation #: JJ1-OB-034 Date: 06/27/2024 Person Interviewed: Wendy Mahan Contains AOC: Yes Contains CBI: No Title: Environmental Coordinator 8 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 At the time of the inspection, we observed a broken bulb in a trash can. Ms. Mahan was unsure if this bulb was hazardous or non-hazardous. She removed the bulb from the trash can and placed it into the appropriate universal waste container. She stated that she would determine the kind of bulb it was to determine if hazardous or non-hazardous. In an email received from Ms. Mahan after the inspection, she stated that the bulb was a non-hazardous Sylvania brand 250-watt incandescent heat lamp. She provided a photo of this label and the Safety Data Sheet, as well as a photo of the stamp inside the bulb itself. Photo(s) 1. IMG-2024062708470547583203.jpg Building: KOC/ Corrosion (D Wing)/ SAA Observation #: JJ1-OB-039 Date: 06/27/2024 Person Interviewed: Wendy Mahan Contains AOC: Yes Contains CBI: No Title: Environmental Coordinator At the time of the inspection, we observed a container of waste leather gloves that was not closed. This container was labeled appropriately with the words "hazardous waste" and a hazard indicator. Ms. Mahan closed this container during the inspection. At the time of the inspection, we also observed a container of waste aerosol cans that was properly labeled as universal waste but did not have an accumulation start date. While labeling containers with an accumulation start date is an internal protocol, Ms. Mahan was able to determine a start date based on the waste log associated with the container in the SAA. This date was within a year and Ms. Mahan labeled the container with the appropriate date. Photo(s) 1. IMG-20240627091145114580099.jpg 2. IMG-20240627091149114970939.jpg 3. IMG-20240627091154115474025.jpg 4. IMG-20240627091715171577551.jpg Building: CPF1/ Central Shops/Toolroom and Central Shops Rotating/ SAA Observation #: JJ1-OB-040 Date: 06/27/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Wendy Mahan Title: Environmental Coordinator At the time of the inspection, we observed two containers of compressed gas cylinders that were labeled with the words "hazardous waste" but were not marked with a hazard indicator. Ms. Mahan asked shop personnel to label these containers with the correct hazard indicator. Photo(s) 1. IMG-202406270926032631177197.jpg 2. IMG-20240627092615261545873.jpg Building: Nabors 7ES/ Mud Lab/ SAA Observation #: JJ1-OB-044 Date: 06/27/2024 Contains AOC: Yes 9 of 33 Contains CBI: No ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Person Interviewed: Wendy Mahan Title: Environmental Coordinator At the time of the inspection, we observed a container of spent mud lab reagents that was labeled with the words "hazardous waste" but was not labeled with a hazard indicator. Ms. Mahan labeled this with the hazard indictor "toxic" and stated that she would ensure that there were no other appropriate indicators that need to be added. In an email received from Ms. Mahan after the inspection, photos were provided demonstrating that the container of spent mud lab reagents had been labeled with the hazard indicators "toxic" and "ignitable". Photo(s) 1. IMG-20240627101651165176996.jpg 2. IMG-2024062710170317358498.jpg Building: Nordic 3/ Rig/ Used oil collection area just outside rig Observation #: JJ1-OB-055 Date: 06/27/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Wendy Mahan Title: Environmental Coordinator At the time of the inspection, we observed two 300-gallon tanks of used oil outside of the rig labeled "waste oil". The containment device holding these two tanks was labeled "used oil". Ms. Mahan stated that these tanks would be re-labeled with the words "used oil". At the time of the inspection, we observed a container of waste lamps in the SAA in the rig that did not have an accumulation start date. While labeling containers with an accumulation start date is an internal protocol, Ms. Mahan was able to determine a start date based on the waste log associated with the container in the SAA. This date was within a year and Ms. Mahan labeled the container with the date "5/16/24". Photo(s) 1. IMG-20240627121654165499271.jpg 2. IMG-20240627121703173109086.jpg SECTION III - RECORDS REVIEW Record: Inspections Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 06/26/2024 At the time of the inspection, three years (2021-2024) of weekly inspections of the CAA were reviewed. There was found to be no record of inspection conducted for the week of 9/3/23-9/9/23. Jamie Allmond and his alternate, Corina Hasler (Hazardous Waste Specialists), conduct these inspections and state that the week when the inspection was not conducted was during a transitional period when staff changes were occurring. Photo(s) 1. IMG-202406261342004202204599.jpg Record: Exception Reports Ref #: JJ1-RR-002 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 06/27/2024 10 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 At the time of the inspection, three years (2021-2024) of hazardous waste manifests were reviewed. During this review, we did not find an exception report for manifest #004898398FLE. For this manifest, the date of shipment was 10/15/23 and the treatment, storage, and disposal facility (TSDF) received and dated the manifest 46 days later on 12/1/23. Ms. Mahan stated that she believed this to be an error because the transporter, Republic Services, informed her that this shipment would arrive on time when she inquired prior. She stated that the facility's procedure is to contact the transporter if a certain number of days is hit before receiving back a manifest. If it is determined that this time frame for return will be over 45 days, an exception report is submitted. She stated that she reached out to Republic Services when she had not received this specific manifest and was told that it would be within the appropriate time frame, therefore, she did not request an exception report. She stated that she would investigate this further with Republic Services. SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: C/D Warehouse JJ1-OB-015 Area: CAA Sub-area: One 55- gallon poly drum labeled as Regulation: "hazardous waste" pending analysis, not marked with a hazard indicator. Sections: Building: C/D Warehouse JJ1-OB-015 Area: CAA Sub-area: One 5-gallon white bucket labeled Regulation: "hazardous waste", not marked with a hazard indicator. Sections: Building: C/D Warehouse JJ1-OB-015 Area: CAA Sub-area: One small box of universal waste lithium batteries not closed due to box containing too many batteries. Regulation: Sections: Building: C/D Warehouse JJ1-OB-015 Area: CAA Sub-area: One large crate of waste leather Regulation: gloves, not labeled hazardous waste nor marked with a hazard indicator. Sections: Building: KCC Rec Room UWAA JJ1-OB-034 Area: SAA Sub-area: 11 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): One broken bulb observed in a trash Regulation: can. 06/26/2024 - 06/27/2024 Sections: Building: KOC Corrosion (D Wing) JJ1-OB-039 Area: SAA Sub-area: One container of waste leather gloves, not closed. Regulation: Sections: Building: Central Processing Facility (CPF) 1 JJ1-OB-040 Area: Central Shops/Toolroom and Central Shops Rotating Sub-area: Two containers of waste compressed gas cylinders, not marked with hazard indicators. Regulation: Sections: Building: Nabors 7ES JJ1-OB-044 Area: Mud Lab Sub-area: SAA One container of spent mud lab Regulation: reagents, not marked with a hazard indicator. Sections: Building: Nordic 3 Rig JJ1-OB-055 Area: Used oil collection area just outside rig Sub-area: Two 300-gal tanks labeled "waste oil". Regulation: Sections: Building: KIC Light Duty Shop JJ1-OB-007 Area: Used oil tank outside shop Sub-area: A used oil storage tank inside of a shed that is labeled "waste oil". Regulation: Sections: Record: Inspections JJ1-RR-001 Missing inspection for the week of Regulation: 9/3/23-9/9/23. Sections: Record: Exception Reports JJ1-RR-002 12 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Missing an exception report for manifest #004898398FLE. At the time of the inspection, the date of shipment was 10/15/23 and the TSDF received and dated the manifest 46 days later on 12/1/23. Regulation: Sections: SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference Following the review of paperwork, I held a closing conference to discuss the findings of my inspection. This was attended by Wendy Mahan (Environmental Coordinator), Darren Burks (Kuparuk HSE Supervisor), Scott Collins (Kuparuk Operations Superintendent), and Tamara Hawkins (Kuparuk HSE Director). I reiterated that the purpose of the inspection was to perform a routine hazardous waste compliance inspection and I thanked the facility staff for their time and cooperation. I reviewed areas of concern that were identified during the inspection. This included: Several hazardous waste containers missing hazard indicators Used oil receptacles being labeled "waste oil" Containers containing hazardous waste not being properly closed A broken bulb found in a trash can A missing weekly inspection A missing exception report Areas of concern that were addressed during the inspection were also noted. This included: Adding hazard indicators to hazardous waste containers Closing containers containing hazardous waste Removing the broken bulb from the trash can and into the appropriate satellite container The ability to address the remaining areas of concern and send photos was also discussed. I answered any questions they had and explained the follow up process including the receipt of the report and the possibility of enforcement. SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 13 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): APPENDIX 1: PHOTO LOG 06/26/2024 - 06/27/2024 Little Red SAA UW Lamps Container 06/26/2024 11:50 AM (AKT) No CBI KIC Little Red/SAA Container of waste lamps- no AOC. No PII IMG-20240626115020502063286.jpg Photographer: Jon Jones N/A Little Red SAA UW Lamps Container 06/26/2024 11:50 AM (AKT) No CBI KIC Little Red/SAA Bulb inside waste lamp container- no AOC. No PII IMG-20240626115028502845429.jpg Photographer: Jon Jones N/A 14 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Little Red SAA UW Lamps Container IMG-20240626115122512272188.jpg 06/26/2024 11:51 AM (AKT) No CBI No PII Photographer: Jon Jones KIC Little Red/SAA N/A Container of waste lamps with "UW Used Lamps" label- no AOC. Little Red SAA UW Lamps Container 06/26/2024 11:56 AM (AKT) No CBI KIC Little Red/SAA Container of waste lamps- no AOC. No PII IMG-20240626115648564874348.jpg Photographer: Jon Jones N/A 15 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Little Red SAA UW Lamps Container 06/26/2024 11:56 AM (AKT) No CBI No PII KIC Little Red/SAA Container of waste lamps with date added- no AOC. IMG-20240626115654565458500.jpg Photographer: Jon Jones N/A 55-Gallon Poly Container in CAA Pending Analysis IMG-2024062613061361372998.jpg 06/26/2024 01:06 PM (AKT) No CBI No PII Photographer: Jon Jones C/D Warehouse/CAA 70.32514905, -149.60603558 One 55-gallon poly pending analysis and marked "hazardous waste", not marked with a hazard indicator. 16 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 55-Gallon Poly Container in CAA Pending Analysis IMG-202406261306286282000440.jpg 06/26/2024 01:06 PM (AKT) No CBI No PII Photographer: Jon Jones C/D Warehouse/CAA 70.32514872, -149.60603582 One 55-gallon poly pending analysis and marked "hazardous waste", not marked with a hazard indicator. 5-Gallon Bucket in CAA without a Hazard Indicator IMG-2024062613082082077307.jpg 06/26/2024 01:08 PM (AKT) No CBI No PII Photographer: Jon Jones C/D Warehouse/CAA 70.3251482, -149.60603622 One 5-gallon white bucket labeled "hazardous waste", not marked with a hazard indicator. 17 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 5-Gallon Bucket in CAA without a Hazard Indicator IMG-2024062613082582570523.jpg 06/26/2024 01:08 PM (AKT) No CBI No PII Photographer: Jon Jones C/D Warehouse/CAA 70.32514934, -149.60603536 One 5-gallon white bucket labeled "hazardous waste", not marked with a hazard indicator. 5-Gallon Bucket in CAA without a Hazard Indicator IMG-2024062613093093072478.jpg 06/26/2024 01:09 PM (AKT) No CBI No PII Photographer: Jon Jones C/D Warehouse/CAA 70.32514934, -149.60603536 One 5-gallon white bucket labeled "hazardous waste" and marked with a hazard indicator. 18 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 CAA Overview IMG-2024062613125812581982146.jpg 06/26/2024 01:12 PM (AKT) No CBI No PII Photographer: Jon Jones C/D Warehouse/CAA 70.32515, -149.60603486 Overview of CAA and waste present at the time of the inspection. Box of Lithium Batteries in CAA not Closed IMG-2024062613160916978155.jpg 06/26/2024 01:16 PM (AKT) No CBI No PII Photographer: Jon Jones C/D Warehouse/CAA 70.32514954, -149.60603521 One small box of UW lithium batteries that is not closed. 19 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Box of Lithium Batteries in CAA not Closed IMG-20240626131617161778743.jpg 06/26/2024 01:16 PM (AKT) No CBI No PII Photographer: Jon Jones C/D Warehouse/CAA 70.32515003, -149.60603484 One small box of UW lithium batteries that is not closed. Box of Lithium Batteries in CAA not Closed IMG-20240626131623162371356.jpg 06/26/2024 01:16 PM (AKT) No CBI No PII Photographer: Jon Jones C/D Warehouse/CAA 70.32514748, -149.60603675 One small box of UW lithium batteries that is not closed. 20 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Crate of Waste Leather Gloves in CAA not Labeled Hazardous Waste or Marked with a Hazard Indicator IMG-20240626132021202176882.jpg 06/26/2024 01:20 PM (AKT) No CBI No PII Photographer: Jon Jones C/D Warehouse/CAA 70.32517244, -149.60601804 One large crate of waste leather gloves that is not labeled "hazardous waste" and is not marked with a hazard indicator. Crate of Waste Leather Gloves in CAA not Labeled Hazardous Waste or Marked with a Hazard Indicator IMG-20240626132038203858901.jpg 06/26/2024 01:20 PM (AKT) No CBI No PII Photographer: Jon Jones C/D Warehouse/CAA 70.32517242, -149.60601805 Two bags of waste leather gloves inside of an unlabeled crate. Bags are labeled as "hazardous waste" and with hazard indicators. 21 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Crate of Waste Leather Gloves in CAA not Labeled Hazardous Waste or Marked with a Hazard Indicator IMG-20240626132049204962767.jpg 06/26/2024 01:20 PM (AKT) No CBI No PII Photographer: Jon Jones C/D Warehouse/CAA 70.32515023, -149.60603469 Two bags of waste leather gloves inside of an unlabeled crate. Bags are labeled as "hazardous waste" and with hazard indicators. Weekly Inspection Log for CAA IMG-202406261342004202204599.jpg 06/26/2024 01:42 PM (AKT) No CBI No PII Photographer: Jon Jones [Building/Area] 70.32511169, -149.6060636 No inspection was conducted during the week of 9/3/23 thru 9/9/23. 22 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Hazardous Waste Pharmaceuticals in Medical Clinic SAA 06/27/2024 08:17 AM (AKT) No CBI No PII KOC Medical Clinic/SAA Medical Clinic SAA overview. IMG-20240627081713171381632.jpg Photographer: Jon Jones 70.32510136, -149.610406 Hazardous Waste Pharmaceuticals in Medical Clinic SAA 06/27/2024 08:17 AM (AKT) No CBI No PII KOC Medical Clinic/SAA Hazardous waste pharmaceuticals container. IMG-20240627081720172067362.jpg Photographer: Jon Jones 70.32510075, -149.6103541 23 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Hazardous Waste Pharmaceuticals in Medical Clinic SAA IMG-20240627081726172664934.jpg 06/27/2024 08:17 AM (AKT) No CBI No PII Photographer: Jon Jones KOC Medical Clinic/SAA 70.32510697, -149.61038169 Non-hazardous waste pharmaceuticals to be sent to Anchorage for re-use. Hazardous Waste Pharmaceuticals in Medical Clinic SAA IMG-2024062708200020058022.jpg 06/27/2024 08:20 AM (AKT) No CBI No PII Photographer: Jon Jones KOC Medical Clinic/SAA 70.32510572, -149.61038662 Non-hazardous waste pharmaceuticals to be sent to Anchorage for re-use. 24 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Hazardous Waste Pharmaceuticals in Medical Clinic SAA IMG-20240627082011201151273.jpg 06/27/2024 08:20 AM (AKT) No CBI No PII Photographer: Jon Jones KOC Medical Clinic/SAA 70.32510572, -149.61038403 Non-hazardous waste pharmaceuticals to be sent to Anchorage for re-use. Hazardous Waste Pharmaceuticals in Medical Clinic SAA IMG-20240627082020202068971.jpg 06/27/2024 08:20 AM (AKT) No CBI No PII Photographer: Jon Jones KOC Medical Clinic/SAA 70.32510805, -149.61040212 Non-hazardous waste pharmaceuticals to be sent to Anchorage for re-use. 25 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Broken Lamp in Trash in KCC Rec Room SAA 06/27/2024 08:47 AM (AKT) No CBI No PII KCC Rec Room UWAA/SAA One broken lamp found in a trash can. IMG-2024062708470547583203.jpg Photographer: Jon Jones 70.32528935, -149.60944402 Waste Leather Glove Container not Closed in KOC Corrosion SAA IMG-20240627091145114580099.jpg 06/27/2024 09:11 AM (AKT) No CBI No PII Photographer: Jon Jones KOC Corrosion (D Wing)/SAA 70.32547288, -149.61261297 One container of waste leather gloves that is not closed. 26 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Waste Leather Glove Container not Closed in KOC Corrosion SAA IMG-20240627091149114970939.jpg 06/27/2024 09:11 AM (AKT) No CBI No PII Photographer: Jon Jones KOC Corrosion (D Wing)/SAA 70.32547288, -149.61261297 One container of waste leather gloves that is not closed. Waste Leather Glove Container not Closed in KOC Corrosion SAA IMG-20240627091154115474025.jpg 06/27/2024 09:11 AM (AKT) No CBI No PII Photographer: Jon Jones KOC Corrosion (D Wing)/SAA 70.32545446, -149.61255916 One container of waste leather gloves that is not closed. 27 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Waste Leather Glove Container not Closed in KOC Corrosion SAA IMG-20240627091715171577551.jpg 06/27/2024 09:17 AM (AKT) No CBI No PII Photographer: Jon Jones KOC Corrosion (D Wing)/SAA 70.32545471, -149.61256408 One container of waste leather gloves that is closed during the inspection. Two Containers of Compressed Gas Cylinders without Hazard Indicators in CPF-1 Central Shop SAA IMG-202406270926032631177197.jpg 06/27/2024 09:26 AM (AKT) No CBI No PII Photographer: Jon Jones Central Processing Facility (CPF) 1/Central Shops/Toolroom and Central Shops Rotating 70.32512004, -149.61037659 Two containers of waste compressed gas cylinders without hazard indicators. 28 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Two Containers of Compressed Gas Cylinders without Hazard Indicators in CPF-1 Central Shop SAA IMG-20240627092615261545873.jpg 06/27/2024 09:26 AM (AKT) No CBI No PII Photographer: Jon Jones Central Processing Facility (CPF) 1/Central Shops/Toolroom and Central Shops Rotating 70.32512004, -149.61037659 Two containers of waste compressed gas cylinders without hazard indicators. Container of Spent Mud Lab Reagents in Nabors 7ES SAA without a Hazard Indicator IMG-20240627101651165176996.jpg 06/27/2024 10:16 AM (AKT) No CBI No PII Photographer: Jon Jones Nabors 7ES /Mud Lab 70.32581735, -149.60990396 SAA container of spent mud lab reagents that is not marked with a hazard indicator. 29 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Container of Spent Mud Lab Reagents in Nabors 7ES SAA without a Hazard Indicator IMG-2024062710170317358498.jpg 06/27/2024 10:17 AM (AKT) No CBI No PII Photographer: Jon Jones Nabors 7ES /Mud Lab 70.32581735, -149.60990396 SAA container of spent mud lab reagents that is not marked with a hazard indicator. Two Containers of Used Oil at Nordic 3 Rig Labeled as "Waste Oil" IMG-20240627121654165499271.jpg 06/27/2024 12:16 PM (AKT) No CBI No PII Photographer: Jon Jones Nordic 3 Rig/UO collection area just outside rig 70.33323657, -149.67739675 Two 300-gal tanks labeled "waste oil". Containment device labeled as "used oil". 30 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Two Containers of Used Oil at Nordic 3 Rig Labeled as "Waste Oil" IMG-20240627121703173109086.jpg 06/27/2024 12:17 PM (AKT) No CBI No PII Photographer: Jon Jones Nordic 3 Rig/UO collection area just outside rig 70.33323657, -149.67739675 Two 300-gal tanks labeled "waste oil". Containment device labeled as "used oil". 31 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded By CBI PII Date Received Communications RE EXTERNALInspection No No Jon Jones Photos-Contacts Email.msg Communications RCRA Inspection follow- No No Jon Jones up waste items.msg Other - Safety Data Sheet 19. No No Jon Jones SylvaniaDataSheet.pdf Communications Requested documents.msg No No Jon Jones Personnel Training 1. 2024 SAA and RCRA No No Jon Jones Basics Training Tracking (1).xlsx Contingency Plan 4. 2023 LQG Waste No No Jon Jones Contingency Plan Kuparuk_FINAL.pdf Other - Monthly CAA 8. HWCAA Monthly No No Jon Jones Inspections Inspection JAN - DEC 2024.xlsx Facility SOPs 2. 2021 Red Book_Rev No No Jon Jones 11.pdf Other - AK Waste Mgmt 3. 2023 Alaska Waste No No Jon Jones Plan Management Plan (Rev. 5).pdf Other - Gen Status documentation Gen Status 1.xlsx No No Jon Jones Other - Gen Status Documentation Gen Status 2.xlsx No No Jon Jones Other - Corrective action 9. Leather Gloves mud No No Jon Jones photo box labeled.jpg Other - Corrective action 10. Batteries photo repackaged.jpg No No Jon Jones Other - Corrective action 11. Nonhaz blast photo media.jpg No No Jon Jones Other - Corrective action 12. Nonhaz Glycol A.jpg No No Jon Jones photo Other - Corrective action 13. Nonhaz Glycol B.jpg No No Jon Jones photo Other - Corrective action 14. Spent mud reagents No No Jon Jones photo placard.jpg 07/03/2024 07/03/2024 07/03/2024 07/03/2024 07/03/2024 07/03/2024 07/03/2024 07/03/2024 07/03/2024 07/03/2024 07/03/2024 07/03/2024 07/03/2024 07/03/2024 07/03/2024 07/03/2024 07/03/2024 32 of 33 ConocoPhillips Alaska Inc - Kuparuk Oil Field Inspection Date(s): 06/26/2024 - 06/27/2024 Other - Corrective action 15. Spent mud reagents No No Jon Jones photo label.png Other - Corrective action 16. Heat Lamp photo package.jpg No No Jon Jones Other - Corrective action 17. Heat lamp photo stamp.jpg No No Jon Jones 07/03/2024 07/03/2024 07/03/2024 33 of 33