United States
           Environmental
           Protection
           Agency
Office of Water    Office of Solid Waste EPA
Regulations and    and Emergency     530-SW-87-005C
Standards (WH-552) Response
Washington, D.C.   "jJfQ'J?9*011' D'C>    V
20460         20460          Y
                  . I
&EPA
         TECHNICAL REPORT: APPENDIX C
                                ft

       EXPLORATION, DEVELOPMENT, AND PRODUCTION
                CRUDE OIL A
TURAL GAS
                                   USEnvifonmentatPfOtectiorv Agency

                                   Region 5. Library (Pl-I2J)
                                   77 West Jackson Boulevard, ion
                                   Chicago, IL 60604-3590

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      APPENDIX  C
 SAMPLING REPORTS
           VOLUME 1
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, It 60604-3590

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11

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                   TABLE  OF  CONTENTS  - VOLUME  1
                                                             Paqe
INTRODUCTION	'.	    1

ALABAMA  	    5

     Investigation of Separation and Filtration Enterprises
     (SAFE), Incorporated, June 12 and 13, 1986,  Mobile  .  .    7

ALASKA   	   41

     Investigation of Standard Alaska Production Company's
     Gathering Center 2 (GC2),  August 1,  1986, Prudhoe Bay  .   43

     Investigation of Standard Alaska Production Company's
     Drill Pad G, Well No. G-30, August 2, 1986,  Prudhoe Bay   57

     Investigation of ARCO Alaska, Inc.'s Drill Site 3N,
     August 3,  1986, North Slope 	   73

     Investigation of Marathon Oil Company's Trading Bay
     Production Facility,  August 7, 1986, Cook Inlet ....  107

     Investigation of Union Oil Company's Kenai Gas Field
     Production Site 41-7, August 8, 1986, Kenai 	  133

CALIFORNIA	183

     Investigation of Sun Exploration and Production
     Company's Oxnard Oil Handling Facility, July 14,  1986,
     Oxnard	185

     Investigation of Shell California Production,  Inc.'s
     Central Water Treating System, July 15, 1986,  Ventura     203

     Investigation of Shell California Production,  Inc.'s
     River Bottom Unit Gosnell Well No. 51,  July 15, 1986,
     Ventura	225

     Investigation of McFarland Energy, Inc.'s Section 24
     Production Facility Midway Sunset Oil Field, July 16,
     1986,  Kern County	247

     Investigation of Shell California Production,  Inc.'s
     Gore C Lease Oil Well No.  50-3P Midway Sunset Oil
     Field, July 16, 1986, Kern County	265

COLORADO	295

     Investigation of E-Vap,  Limited,  July 11, 1986, Greeley  297
                              111

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            TABLE OF CONTENTS  - VOLUME  1  (Continued)
                                                             Page

KANSAS   	313

     Investigation of Cindy Van Dyke's Gentry Lease Well
     No. 2A, July 1, 1986, Montgomery County	315

     Investigation of American Energies Corporation's
     Munsell F Well No. 1, July 7, 1986, Pendennis 	  333

     Investigation of DaMar Resources, Incorporated's 9067
     Randa Well No.  1,  July 7,  1986, Hays	351

     Investigation of Ritchie Exploration, Inc. and Cross
     Wind Petroleum, Inc.'s Keith Garrett Well No. 1,
     July 8, 1986,  Wakeeney	365

     Investigation of Oil Producers, Inc. of Kansas'  Ott
     Well No.  2, July 9, 1986,  Wakeeney	381

KENTUCKY	411

     Investigation of Maverick Production, Inc.'s Glassco
     Lease Well No.  1,  August 21,  1986, Henderson County .  .  413

     Investigation of Ecus Corporation's Gamblin Lease
     Production Facility, August 22, 1986, Hopkins County   .  435

LOUISIANA	453

     Investigation of FMP Operating Company's S/L 195 No. 2
     Oil Well, June 14, 1986, Plaquemines Parish  	  455

     Investigation of Sun Exploration and Production
     Company's Sweetbay and Bateman Lake Tank Battery No. 2,
     June 16,  1986,  St. Mary Parish	493

     Investigation of Mobil Oil's Bayou Blue Production
     Facility, Jun 17,  1986, Iberville Parish  	  517

     Investigation of Westland Oil Development Corporation's
     Joseph Earl Bajoie No. 1 Oil Well, June 17, 1986,
     Pointe Coupee Parish  	  535

MICHIGAN	557

     Investigation of Wolverine Gas and Oil Company,  Inc.'s
     Hanover 7 Central Production Facility, July 29,  1986,
     Jackson County  	  559

     Investigation of Sun Exploration and Production
     Company's Cameron Lease Well No. 1-10, July 30,  1986,
     Gladwin County  	  579


                               iv

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             TABLE  OF  CONTENTS  - VOLUME  1  (Continued)


     Investigation of Powell Production, Inc.'s Savarino and
     Stoll Well No. 6-21, July 31, 1986, Hillsdale County  .  619


                   TABLE  OF  CONTENTS  - VOLUME  2

NEW MEXICO	637

     Investigation of Basin Disposal, Inc.,  Jun 25,  1986,
     Bloomfield	639

     Investigation of Amoco Production Company's USG
     Section 18 Well No.  43, Jun 26,  1986, San Juan County .  715

     Investigation of Cities Service Oil and Gas Corpora-
     tion's State E Lease, June 27, 1986,  Lea County ....  745

OKLAHOMA	761

     Investigation of Ward Petroleum Corporation's Rowe
     Lease Well No. 1-20, June 26, 1986, Grady County  . .  .  763

     Investigation of George Kahn Operating Company's Mary
     Allen Tank Battery,  Jun 27,  1986,  Oil Center	793

     Investigation of Royce Kelly's Centralized Disposal
     Pit, June 29,  1986,  McClain County	309

PENNSYLVANIA 	  827

     Investigation of Franklin Brine Treatment Corporation,
     September 3, 1986, Franklin 	  829

     Investigation of Mark Resources Corporation's Hazlett
     Well No. 1, September 4, 1986, Venango County 	  855

TEXAS	867

     Investigation of Exxon Company,  USA's Hawkins Field
     Unit Well No.  1210,  June 19,  1986,  Wood County  ....  869

     Investigation of Mobil's C.  W. Belcher Lease Production
     Facility,  Jun 20, 1986, Talco	886

     Investigation of Murexco Petroleum, Inc.'s Frye Lease
     Oil Well No. 1-29, June 23,  1986,  Wheeler County  . .  .  925

     Investigation of Chevron USA, Inc.'s W. V. Lister No.  1
     Gas Well Production Facility, June 24,  1986, Wheeler
     County	999


                               v

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            TABLE OF CONTENTS - VOLUME  2  (Continued)
                                                             Page

UTAH	1015

     Investigation of Meridian Oil Company's Navajo-Federal
     Well No.  23-4,  June 29,  1986, San Juan County 	 1017

     Investigation of Marathon Oil Company's Tin Cup Mesa
     Well No.  1-25,  Jun 30,  1986,  San Juan County  	 1031

     Investigation of Wexpro Company's Island Unit No.  27,
     July 2, 1986,  Uintah County	1077

WEST VIRGINIA	1099

     Investigation of Scott Oil Company's Garvin Lease Well
     No. S-614, August 19, 1986,  Jane Lew	1101

WYOMING	1123

     Investigation of Diamond Shamrock Exploration Company's
     Myers State Well No. 41-16,  July 13, 1986,  Gillette  .  . 1125

     Investigation of Amoco Production Company's LACT No. 4,
     July 14,  1986,  Midwest	1147

     Investigation of Waste,  Incorporated1s Lawrence Brown
     Disposal Lagoon, July 15, 1986, Uinta County  	 1173

     Investigation of Sun Exploration and Production
     Company's Luckey Ditch Fed B Well No. 4, July 16,  1986,
     Uinta County	1189
                               vi

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                           INTRODUCTION








This appendix is comprised of Sampling Reports for each site




visited during the field sampling portion of this Project.  There




are 46 reports, including 44 Sampling Reports and 2




Reconnaissance Reports.








The reports in this appendix are grouped together by state, and




are arranged chronologically within each state.  The states are




arranged in alphabetical order.








Three sites were visited that are not among the Sampling Reports




in this appendix.  These sites were sampled by a team from EPA's



Office of Research and Development Environmental Research




Laboratory (ERL) in Gulf Breeze, Florida, in cooperation with the




Louisiana Department of Environmental Quality.  The ERL




performed the sampling at these sites in a cooperative effort




designed to provide both ERL and this Project with needed data.




The ERL is testing the applicability of existing aquatic



toxicological test procedures, using produced water as the test



medium.  Therefore, all the sites visited by the ERL team were




specifically selected production facilities.  Sampling was



conducted according to the protocols described in the Sampling




Plan and Sampling Quality Assurance/Quality Control Plan in




Appendix G.  Sampling Reports are not included for these sites




because, at this time, the operators have not reviewed the




information to be included in the reports.
                             C-l

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All reports in this appendix include the following topics:  SITE




SELECTION, SITE LOCATION, ATTENDEES, SITE DESCRIPTION, DISPOSAL




PRACTICES, and PERMITS.  Sampling Reports include the following




additional sections:  SAMPLING INFORMATION,  SAMPLE POINT




LOCATION, and SAMPLING METHODS AND EQUIPMENT.  Attachments to the




reports include photo documentation of sampling activities,




copies of drilling or operating permits, and miscellaneous




information provided by the site operators and state officials



regarding the sample site.








Draft copies of these Sampling Reports were sent to each of the




site operators for their review and clarification of specific




details within the reports.  The reports in this appendix reflect




the comments returned by the operators.








Finally, the following notes are included to clarify .the contents



of the Sampling Reports:








  o  Most information regarding sample site characteristics




     was provided by the site operators.  Exceptions to this




     include measurements made by the sample teams, such as



     pit dimensions and liquid and sludge depths.  Unless




     otherwise noted, all remaining quantities are estimates




     provided by the operators.
                             02

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o  Terms such as "brine tank",  "slop tank",  and "free



   water knockout" are used in the Sampling Reports as



   they were used by the site operators and state



   officials.  Use of the word "brine", for example,  does



   not indicate that the produced water at a particular



   site was chemically classified as a brine.  The words



   "brine," "produced fluid," and "produced water" are



   used interchangeably in the Sampling Reports because of



   the manner in which operators and state representatives



   used these terms in the field.








o  Documents provided by state officials and site



   operators, such as permits and laboratory reports, were



   often provided in the form of photocopies.  The clarity



   of such documents reproduced in the Sampling Reports is



   typically poor.
                           C-3

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n
 i

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ALABAMA
  C- 5

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o
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cr>

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                          Sampling  Report
           Investigation of Separation and Filtration
                 Enterprises  (SAFE),  Incorporated
                         Mobile, Alabama
                       June 12  and  13,  1986


SITE INFORMATION

Site Selection

This site was specifically selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA 530-SW-87-005).  The selection was based on personal
communication with the Alabama Department of Environmental
Management.  At the request of EPA, the Department of
Environmental Management identified four facilities treating oil
and gas wastes in Alabama.  Of the four sites, Separation and
Filtration Enterprises, Incorporated was the only site actively
treating wastes available during the sampling time frame.  Thus,
it was selected.

Site Location

SAFE, Inc.'s centralized waste treatment facility is located on
the southwest end of Pinto Island at the mouth of the Mobile
River as it empties into Mobile Bay.  Figure 1 is a map
indicating the plant site.  The mailing address for SAFE, Inc.
is:

          Separation and Filtration Enterprises, Inc.
          P.O. Box 1691
          Mobile, Alabama  36633
          205-428-4028 or Baton Rouge,  LA  504-293-7107

The property is leased from Alabama Dry Dock and Shipbuilding
Company (ADDSCO).

Attendees

Sampling at the SAFE,  Inc. facility was performed by CENTEC
Corporation personnel  on June 12 and 13, 1986.  Following is a
list of people present at the time of sampling:

     CENTEC Corp. (sample team):  Bill  Lane, Technician
                                  Jamie Mclntyre,  Team Leader

     EPA Representative:          Susan de Nagy, Office" of Water,
                                    Project Officer

     State Representative:        Edgar Hughes, Alabama
                                  Department of Environmental
                                    Management, Industrial
                                    Branch,  Water  Division


                             C- 7

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                                  m"tu   j - •
 i  ^*&^\  ^--^3 c,mer»oni«3ci)""«.va^::='!=:'!	.• j
HQ
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     Operator Representatives:    Jay Simon, Vice President SAFE,
                                    Inc.
                                  Doug Staub, Operations Manager

Site Description

SAFE, Inc. is located in a suburban, coastal area where the depth
to groundwater is between 0 and 25 feet, and the nearest surface
water is at the boundary of the property.  The soil in this area
is mostly sand.  The climate at this site location is net
precipitation.

The site consists of a 400-foot pier, 4.4 acres of land, a
warehouse, and a concreted process area.  Figure 2 is a plot plan
of the SAFE, Inc. facility, showing the waste treatment area in
relation to the adjacent barge slip and pier.  At the time of
sampling, the area northwest of Pier X  (right of Pier X in Figure
2) was occupied by a semisubmersible drilling rig that was docked
for repairs.  This rig appears in photographs taken at the time
of sampling, located in Attachment A.

One of SAFE, Inc.'s storage barges was in the slip, as shown in
Figure 2 and Photos 2, 3, and 4.  This barge was full of drilling
waste and was therefore sampled.  The other storage barge was
moored to Pier X, and was not in use at the time of sampling.

The operations manager's office is located in the warehouse,
north of the waste treatment area, and is visible in the
background of Photo 3.

Process Description

The following process description is also illustrated in a
simplified process flow diagram, Figure 3.  Both the description
and the diagram were provided by SAFE, Inc.

     "Material can be received by barge or by truck.
     Holding tanks and barges supply the surge capacity
     needed for fast turnaround.  The customer barge will be
     secured along the 400-foot dock.  The content will be
     circulated as much as possible using a submersible
     pump.  The material will then be pumped to the process
     or to a permanently moored (10,000 bbl) barge.  If
     additional storage capacity is needed, a second barge
     will be utilized.  Dock space will not be a problem
     since the dock is 400-feet long with access to both
     sides.

     "From the holding barge, the mud is pumped through
     shaker screens for cuttings removal and into a 450
     barrel mud tank.  To allow continuous feed to the mud
     tank, batches are fed to the clarifier for pH control
     and flocculation.


                              C- 9

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Figure 2.  Schematic  of Treatment Facility
                C- 10
",. &C-A.*_E-; V» *o'
_" PLOT  PLAU

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                                 LAUD FILL
o
I
                                                                                                    TO

                                                                                                   SEUUER
                       Figure  3.  Flow  Diagram of Treatment Process
        JUG.
        LE, AL^.

       JAkJ. 2i , ' 985



PROCESS  FLOLU

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     "The solids from the clarifier are pumped to a
     separator feed tank, which are continuously fed to the
     system.  Conditioning of sludge takes place prior to
     the separator to ensure maximum de-watering.  A
     bladeable solid is conveyed from the discharge of the
     unit to a solids holding area.

     "The liquid streams from the clarifier and the
     separator are pumped to a process tank which feeds the
     final filter.  The final filter is set up to
     continuously filter liquid while adding material to
     prevent blinding.   The filter capacity is in excess of
     300 gpm which far  exceeds the anticipated flow rate.
     The oversize filter will also allow for low-solids
     material to bypass the separator and efficiently
     increase the capacity of the plant.

     "The water is then pumped to the city sewer for final
     treatment.  Solids are trucked off to the municipal
     landfill for disposal."

The facility is designed to operate 24 hours per day, 365 days
per year, although the  market has not demanded such operation as
yet.  The daily capacity of the facility is 1,500 to 4,000
barrels of waste, depending on the properties of the mud
(particularly its density).

The State of Alabama does not permit the discharge of any wastes
from drilling rigs located in State waters.  The wastes must be
hauled to shore for treatment and disposal.  Therefore, the
proximity of SAFE, Inc.'s clientele is within a 50-mile radius.
In addition, SAFE, Inc. accepts only water-based drilling muds
and associated drilling wastes.

The price schedule for  waste treatment at SAFE, Inc. is based on
the density of the incoming material.  The draft of the barge is
used to calculate the weight of the material.  The material's
volume is measured from each compartment of the barge before
pumping starts.  The weight and volume measurements are then used
to derive the overall density of the material.  The density is
then used to determine  the price per barrel of material
processed.

Permits

Permits and approvals obtained by SAFE, Inc. to properly operate
the waste treatment facility include the following:

o    Alabama Department of Environmental Management (ADEM)
     State Indirect Discharge (SID) Permit allowing
     operation of the facility and discharge into the City
     sewer, issued April 1, 1985.
                             C- 12

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o    The Board of Water and Sewer Commissioners of the City
     of Mobile approval to discharge into the sewer system,
     dated March 4, 1985.

o    The Certificate of Need from the Mobile County
     Commission authorizing the handing of the solids, dated
     March 11, 1985.

o    City of Mobile, Alabama Department of Flood Plain
     Management Construction, and Engineering Services
     building application for facility construction, dated
     March 20, 1985.

o    ADEM Solid Waste Section, Land Division approval to
     utilize any of four local landfills, dated April 15 and
     June 4, 1985.

Copies of these documents are located in Attachment B.

The ADEM State Indirect Discharge permit sets discharge
limitations and monitoring requirements for the water leaving the
facility.  A copy of the discharge limitations and monitoring
requirements as presented in the SID permit is located in
Attachment C.

The ADEM approval to utilize local landfills for disposal of
solid waste includes the following four conditions:

     "1.  An analysis (E.P. Toxicity) of the mud from each
          Company must be submitted to this office prior to
          disposal.

     "2.  A certification from the generator that the mud is
          non-hazardous must be submitted to this office prior
          to disposal.

     "3.  The mud must be dewatered/solidified to a bladeable
          consistency.

     "4.  Trucks hauling the mud shall be secured to prevent
          spillage en route to the disposal site."

To fulfill the analysis requirements for disposal of solid waste,
SAFE, Inc. samples and tests each incoming barge for E.P.
Toxicity and other analytes.  Figure 4 is a laboratory report
listing the results of tests performed on barge samples, as
ordered by SAFE, Inc.

A copy of the waste shipping control ticket used by SAFE, Inc. at
the points of transfer of solid waste between generator,
transporter, and disposer is located in Attachment D.
                             C-13

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ir>
 u.
                   7 r ° 7 1 " n ri
                   I Lu I h. J. h.

                   -r  •::•:  P •.<:
                                    PHON.B
MARCM 13,  19t?o
SAFE. I PC.   -
MOBILE, ALABAMA
SAMPLES COLLECTED & TRANSPORTED B'/ EA^E,  INC.
SAMPLE I.D.:        BARGE # WGH 73
              SAFE SAMPLE tf WGH 7C-9
              VOLUME HANDLED: 5,509 k?L3,

AET PROJECT NO.:  10012
ANALYTICAL
PARAMETER RESULT
PHYSICAL CHARACTARISTICS
COLOr' (DESCRIPTIVE) GREY
FLASH POINT > 145 F
ODOR (DESCRIPTIVE) KEROSENE FUZ_
pH 10.1 £TL '.'I'-:
PHYSICAL STATE @ 70F LIC1UTD SL'.'l - '
SPECIFIC GRAVITY i . 1 c
CHEMICAL ANALYSIS sr.z. i T
AMMONIA 12.C
BOD 101
COD 11,. : :.
CHLORIDE 116';
Ci'ANIDE 
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EAFE,  ir-C.
MOBILE,  .'.LA'dArVi
AET
             PC.
PARAMETER
                     ANAL/TICAI-
                        RES ULT
EP TOXICITY ANALYSIS
ARSENT C
BARIL',1
CADMIUM
CHROMIUM
CHROMIUM-HEXAVALENT
LEAD
MEPCL1' /
SELEN:MM
SILVER
                          mg/1
                          <0.05
                          8.97
                          0. 01
                          0. 33
                          <0. 05
                          0.12
                          O. O03
                          ••"0.05
                          0. 05
IhE
DATE
1 <~ '
!-!
hi'j; •
RDH
^'DM
PDH
KPH
r •.:•'•-,
I-.L:
^_(
10
9
12
4
3
1 1
S
9
O U D 'Tl
30 c-in
10 an-!
15 p m
00 pm
15 p m
30 am
** ^-
*• w.' - ,Ti
25 am
Oi /30
'.^ *_ / ^ J -'
02/<..3
01 / "3
02 / 1 1
01/31
0 1 / 0 7
01/31
02/03
 ALL OF  THE ABOVE TESTS WERE PERFCRr-ZD AS CuTi.I[.;£!• IN THE  U.S.  E.P.A
 "METHODS  FOR CHEMICAL  ANALYSIS  OF t-'ATER A. IL>  k'iTjTES," 1~33,  AND
 "STANDARD METHODS FOR  THE EXAMINATION OF W.-'-TEK  ,-."D t-.-^TEl-'ATER. " 1985.

 CERTIFICATION:
 H.  f -.li  LE',1/
 CSIEF IMEM 1ST
                  Figure 4.   Laboratory Report on  Barge
                              Samples  (Continued)
                                    C-15

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SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).

Sample Point Locations

At SAFE, Inc., the influent liquid sample was defined as the
combined supernatant and solid contents of the waste material in
the holding barge.  The effluent liquid sample was defined as the
stream discharging to the Mobile Publicly-Owned Treatment Works.
The point at which this stream was accessible to sampling was the
flow to a storage tank located upstream from the metered effluent
line.  The sludge sample was obtained from the dry mud area (see
Figure 2) where mud collects in a concreted holding area prior to
removal by truck.

Figure 5 indicates the measured sample points as well as the
actual sample points from which the barge sample was composited.
The northeast end of the barge was covered with sheet metal that
made it possible to sample very near the measured sample points
at that end (Photos 2 and 3).   Note that sampling shown in Photo
3 is done through a 6-inch gap in the cover.  The southwest end
of the barge was accessible only from the side, so that the
actual sample points are closer to the sides than to the measured
quadrant centers.

Figure 6 indicates the measured and actual sample points in the
dry mud area from which the sludge sample was composited.  The
differences between measured and actual sample points were also
the result of limited accessibility.  Both Figure 6 and Photo 5
show the retaining wall that was used to obtain samples from the
northeast end of the area.  The southwest end was accessed by
standing on wood planks placed on the solids pile and reaching as
close to the desired sample points as safely possible.

Sampling Methods and Equipment

The first sample to be collected was the effluent liquid.  To
obtain this sample, a one-gallon glass container was held under
the flow from the input pipe to a water storage tank.  In
Photo 1, the input pipe is shown slanted down from left to right
into the storage tank.  Also shown in Photo 1 is the sample being
poured from the 1-gallon container to the 5-gallon compositing
carboy.

The next sample to be collected was the barge contents, which was
in distinct liquid and solid phases.  After measuring the barge,
the covered end was sampled first with the thief, then with the
coring device.  A 6-inch opening in the barge cover made it


                             C-16

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Figure 5.  Measured vs. Actual Sample Points
           Holding Barge
                     017

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                                   KEV
                                o : M«
Figure 6.  Measured vs.  Actual Sample Points:
           Dry Mud Area
                   C-18

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possible to lower the sampling equipment to the barge contents.
The surface of the liquid was approximately 10 feet below the
cover.  The uncovered end of the barge was sampled in the same
manner as the covered end, except that the samplers stood on the
edge of the barge and reached in to get samples (Photo 4).   The
liquid and sludge were composited in the steel bucket.

The last sample collected was the sludge from the dry mud area
(Photo 5).  The average depth of the mud was 2 feet.   The coring
device was used with a 5-foot extension rod attached.  The
sampler stood on the retaining wall at the northeast end of the
area and on wood planks at the southwest end.  The mud was thick
enough that a core catcher in the end of the glass core sleeve
was not necessary.  The mud was composited in the steel bucket.

The first two samples were collected on June 12, 1986. The last
sample was collected the following day, June 13, 1986 because
sampling on June 12 was not completed before 7:00 PM.

The liquid and sludge samples were tested onsite for pH after
sampling was completed.  The pH was 8 for all samples.
                             C- 19

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C-20

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-21

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C- 22

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Photo 1.  Pouring  liquid  sample  composite
                                                                 Photo 2.   Holding  barge
 O
  I
 to
 OJ
                                  Photo  3.   Sampling through cover over NE end  of  barge

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frZ-D

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ATTACHMENT B:  PERMITS
          C-25

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C-26

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                ALABAMA DEPARTMENT OF  EJA'IRON^ENTAL MANAGEME!I7
                        STATE  INDIRECT DISCHARGE PEP.M1T
       Ir. accordance with  the  provisions  of  the  Alaba-a  Water  Pollution
Control A.ct, as amended, (Code of Alahana 1975,  £§22-22-1  to 22-22-U; the
"State Act") and  the Alabaca Environmental Management  Act  (Code  of  Alabama
1975  $$22-22A-l  to 22-22A-13;  the  "State Act")  and  rules  and  regulations
adopted thereunder;
        f.AFE, Inc.
              , Alabama
(hereinafter, ."the  permittee")  is  hereby authorized  to discharge industrial
wastes resulting from   treatment of drilling] waste.
to waters of  the  State  through Publicly Owned Treatment  Works (hereinafter,
"POTV") located  at   McDuffie Island
in accordance  with  the  monitoring requirements and other terms and conditions
set forth  herein.

       This  permit  and  the authorization to discharge shall expire at midnight
on   March 31, 1990.

       Issued  this   1st   day of  April, 1985.
                            By:
                                   a-.a7 Department of Environmental Management
                                  C-27

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               The Board of Vrater and Sswer Commissioners
                                     cJ tit
                                City of Mobile
                                  P. O. BOX 236S

                              MOBILE. ALABAMA 36652


                                March 4, 1985
Kr. G. P.
Safe, Inc .
P. 0. Box
Theodore,
Dear Mr. Stu.*rdi:
                    36590
         ye jare  writing you in regard to you and your
engineers' r"e
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               C- REVcWUE
 FRAK'CHISL  TAX  DIVISION

      MONTGOMERY. AL 36130
     FOR THE YEAR ENDING DECEMBER 31.   19E5
                                                          CORPORATION PERMF
This is 1o certify that Ihe corporation shown has caicJ tns
Alabama Department o? Revenue as reouired. by Tide 4D-14-21
or 40-U-22 CoOe cl Aiifcama 1975. This permit is therefore
issued a-'tnorijmp the aomp  of business in the State ot Ala-
bama by sard corporation tor Ins eoove year and is subject
to trie terms and conditions ol said code.
                         TOM
   JAMISC.U-H1TE, SR.
      Coaoittioner
FK   1*2196
SEPARATION'  C  FILTRATION  ENTERPRISES,  INC.
10*: ST. JOSEPH  ST.,  STE.  325
KOBILC, AL
36602

II a check has been accepted in payment of this permit and such check is not paid. THIS PERMIT IS VOID.

                              MOBILE COUNTY COMMISSIONERS
                                  MOBILE COUNTY, ALABAMA

                                              P.O. Box 1443
                                             Mobile, Ala. 36633
                                       CERTIFICATE OF NEED
                                                 FOR


                                              Hauling
                                                                                     CERTIFICATE

                                                                                         NO.

                                                                                        97
                                             (Type ol Operation)
     This certifies that.
                           SAFE.  Inc.
                                                    (Name ol Company)

      Owned or operated hy    Separation Systems,  Inc. John R.  Dyas  & G.  TR.  Stuardi

              100  St.  Joseph  Street, Mobile,  AL  36602
      at
                 has submitted the information
      as required under Act #81-450,  and the County Commissioners of Mobile County has found such

      documents to conform with the laws and regulations as provided for in this Act. It is further declared

      that the services to be performed do not violate the requirements of this Act.

                                                      this  llth  day ot _  March      1 9 _8.5
     Certificate expires

     	March	1JD	19 86
                                                         Cooniy
                                                        ol Mobile Cour-.ty/Alatama
                                             C/29
                                This ;'s not a Permit To Opersle This Service
                                , Chairman

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                         err; or ,"02114:-, AL.'IBAKA
                              Di?>.r.Trj::iT or •-• \ .
                  FLOOD PLAK> <"""J ACE.KEN7, CONSTRUCTION
                        AND L^CINEEKING SERVICES
     /rr, I CATION FOR
LAI"' »,,slti»ans.
Applicant's
                                        Telephone  Number
Authorized Representative
                                        Telephone  Number
Street Address
                                         Site  Location
City
             State
                         Zip Coe
                                        Application Approved By:
SignaFure^7
                                         City  Engineer
Permit above applied for  (will)(will  not)  comply with the Mobile Zoning
Regulations.
By:
                                             Zoning Examiner
Refer to construction plans  on  file  in City Engineer's Office  and  in
Inspection Services prepared /°r compliance with Ordinance 65-045  and
accompanying standards.   It  is  required that-a licensed Professional
Engineer certify  to Inspection  Services that this project has  been
completed in conformance  with plans  approved by the City Engineer  prior
to receiving a Certificate of Occupancy.

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                                            ALABAMA
                  DEPARTMENT OF  ENVIRONMENTAL MANAGEMENT
               April  15,  1985
    p Addrrsi:
    Capital
Montgomery. AL
3613C
20S/53*-1303
F.cld Oflicei

P. 0 Box 9i3
Dccalui. AL
3SC.02
Unit 806. Building 8
225 Oimoor Circle .
Birmingham, AL
35709
20S/9<2-6168
4358 Midmost Drive
Mobile, AL '
-  *9
   43-7841
Mr. Jay A. Simon,  V.P.
SAFE, Inc.
P. 0. Box 15203
Baton Rouge, LA  70895

Dear Mr. Simon:

     We have reviewed  your request to dispose of drilling mud
at the Chunchula  and Dirt, Inc. landfills in Mobile County  and
the Magnolia landfill  in Baldwin County.  We have also discussed
your request with Ms.  Sonja Massey of the Water Division of ADEM.

     We are approving  the disposal of drilling mud by SAFE,  Inc.
at the above landfills under the following conditions:-.-

     1.  An analysis  (E. P. Toxicity) of the mud must be submitted
         to this  office prior to disposal.

     2.  A certification from the generator that the mud is non-hazardous
         must be  submitted to this office prior to disposal.

     3.  The mud  must  be dewatered/solidified to a bladable consistency.

     4.  Trucks hauling the mud shall be secured to prevent spillage
         enroute  to the disposal site.

     We want to point  out that it is the responsibility of  SAFE,
Inc. to insure that only non-hazardous mud is hauled to any of
these sites.  You should also contact the Baldwin and Mobile County
Commissions concerning disposal at the Magnolia and Chunchula
sites.  Mr. Lamar Harrison of Dirt, Inc. should be contacted concerning
disposal at his  landfill in Theodore.

     If you have  any questions or if we can be of further assistance,
please contact us.

Sincerely,
               (Jack" Horfeycut^., Chief
                Solid Waste Section
                Land  Division
                JH:sl
                cc:   Honorable Clarence  Pishop,  Chairman-Baldwin County Commission
                     Kr .  Gurnpy Owens, Kobife" Bounty
                     "r .  !.a:r.ar Harrison,  Dirt,  Inc.
                                                                                1 C  ^O

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                     ; i. v.
                June  4,  1985
                                   OF I^
                                                                                'Vi...   '   .v
       ' Dt
203 3J3-1713
Unit £C6. Ei-!a.:ig 8
225 Oxnio-jr Circle
Birmmghf.i. AL
35209
205 3'.2-6168
4353 Midmost Drive
"obile, AL
  09
—,5,'343-7841
Mr. Jay Simon
SAFE, Inc.
P. 0. Box 15203
Baton Rouge, LA  70895

Dear Mr. Simon:

     This office recently  revised Mr. Lee Jackson's Landfill Permit
No. 49-]7R thereby authorizing him to accept drilling mud  for
disposal.  The landfill  is located-on Lott Road in Mobile  County.

     Pursuant to your  telephone request, wetwill approve the disposal
of drilling mud by SAFE,  Inc.  from Exxon, :Shell and Mobile Oil
Companies at the Lee Jacksonrlandfill under the following  conditions:

     1.  An analysis  (E.P. Toxicity.). of the mud from each  Company
         must be submitted to  this Office prior to disposal.

     2.  A.certification  from  the generator that the mud is non-hazardous
         must be submitted to  this office prior to disposal.

     3.  The mud must  be  dewatered/solidified to a bladable consistency.

     4.  Trucks  hauling  the mud shall be secured to prevent spillage
         enroute to the  disposal site.

     I want to again point out to you that it is the responsibility
of SAFE, Inc. to ensure  that only non-hazardous mud is hauled
to the Lee Jackson or  any other landfill within the State.

     You should  contact  Mr. Lee Jackson concerning delivery schedules,
fees, etc.

     If you have any questions, please contact us.

Sincerely,
                Jack Honeycutt, Chief
                Solid Waste Section
                Land Division

                JH:sl
                cc:   Mr. Lee Jarkson
                     Mr. Gurney Owens
                     Mr. Jamos Fibbo
                                                     \    0 8 1335
                                             C-3 2

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ATTACHMENT C:  DISCHARGE LIMITATIONS PRESCRIBED
                 BY SID PERMIT
                     C-33

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 i
U)

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   IMschar   Serial  Number:   001  -  Total  Facility Discharp-
          Discharge Limitations

Ibs/day                 inP»/l (except as noted)
                                                                                        Monitoring RCCJU I rements
     l-'low
     Total  Suspended
      Solids
     Arsenic,  total
     Cadmium,  total
     Chromium,  total
     Chromium,  hexavalun
     Lead,  total
     Copper,  total
     Nickel,  total
     011 and  Crease
     Cyanide,  total
lonthly Avg. Dally Max.** ^Monthly AVR. Dally Max.''*
80,000 GPD
150
1.0
0.2
— — — 1.0
ten -- — — 0.2
-7 — — 0.2
1.0
1.0
100
1.0
Frequency
Dally
2/week
2/week
2/week
2/week
2/week
2/week
2/week
2/week
2/week
2/week
Sample Type
Meter or Recorder
Grab
Crab
Crab
Crab
Crab
Crab
Crab
Crab
Crab
Crab
n   Uncontdininated  stormwater  and  non-contact cooling water shall not be discharged  to  the  POTW.
t_n
   The pH  ^hall  not  be less than 6.0   i-i-Jnrc! units nor nore  than  9.5    standard units and shall be ran! cored
    -.--.i : -..: ,ttl. -_y grab sa:-,;.le.

    Samp Jl up, locution for discharge:   After  final  treatment  but  prior  to  mixing with the contents  of  the s .1 \\ i t.. ry
                                       sewer  or  any other  wastewater.
     "The arithmetic average of all sample  results  from  a  given calendar month monitoring perloi!.
    A-:The ma:;lmum value ohtalncd for any single sample.

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o
 I
U)
CTi

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ATTACHMENT D:  WASTE SHIPPING CONTROL TICKET
                    C-37

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o
 I
00

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                         WASTE SHIPPING CONTROL TICKET
Part I:   TO BE COMPLETED BY GENERATOR
          Company Name	
          Business Address __J^^^~~~"^^^~~~^^^~~~~~~~~~~~~~"~~~~~~
          Telephone Number "^^^^^^~~~~~~~~
          Originator of Was"telArea:                          Well;
                     OProduction Facility  O Drilling Operations
          Description of Waste:
          Quantity of Waste:	
          DESTINATION:
          Disposer's Name
          Business Address
          CERTIFICATION:  The waste described above was consigned to the
          carrier named below.  I certify that the foregoing is true and
          correct to the best of my knowledge.
          Signature of Generator's Authorized Agent  Date & Time of Shipment

Part II:  TO BE COMPLETED BY TRANSPORTER  (NOTE:To be completed in presence of
          Generator, before removing Generator's copy)

          Transporter's Name 	
          Business Address  	
          Telephone Number 	
          License Plate of Truck 	
          License Plate of Trailer 	
          If Transported by Barge, Barge and Tug Identification
          CERTIFICATION: I certify that the waste in the quantity above and the
          description in Part I was received by me for proper disposal.
          Signature of Transporter's Agent           Date & Time Received

Part III: TO BE COMPLETED BY DISPOSER

          Disposer's Name 	
          Disposal Site Address
          Telephone Number 	
          License Plate of Truck 	
          License Plate of Trailer 	
          If received by Barge, Barge and Tug Identification
          Quantity of Waste Received:
          CERTIFICATION: I certify that the waste in the quantity above and the
          description in Part I was received by me for proper disposal.
          Signature of Disposer's Agent              Date & Time Received

DISTRIBUTION:  Original:      Disposer's Copy for Report to Permit Agency
               Green:         Generator's 2nd. Copy
               Yellow:        Disposer
               Pink:          Transporter 3^
               Golden Rod:    Generator's 1st.Copy

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n
 i
o

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ALASKA
  C-41

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C-42

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                         Sampling Report
      Investigation of Standard Alaska Production Company's
                    Gathering  Center  2  (GC2)
                       Prudhoe Bay, Alaska
                         August  1,  1986
SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical-
Report (EPA 530-SW-87-005).  This site was selected randomly from
a list of North Slope Basin production sites developed by EPA
Region X Alaska .Operations Office at the request of EPA.  The
list was transmitted via telephone to the EPA contractor on July
22, 1986.  Site selection from this list took place during the
telephone conversation.

EPA Region X Alaska Operations Office preferred to list the
possible sample sites as shown below.  The EPA contractor had no
interest in the manner the particular sites were listed (by site
name, location, operator, permit number, API number,  etc.) as
long as the site could be identified in detail upon selection.
Thus, the EPA contractor had minimal information which kept to a
minimum the amount of bias.   No other information was known about
the sites on the list at the time of selection.  Detailed
information was obtained only after selection of primary and
back-up sites.  The list consisted of three North Slope Basin
production sites:

        1.  CPF 1
        2.  CPF 2
        3.  GC 2

As indicated above, the EPA contractor assigned numbers to the
members of the list as they were transmitted.  A random number
table was used to select the primary and back-up sample sites.
No. 3 on the above list  (GC 2) was selected as the primary sample
site.  No. 2 on the above list (CPF 2) was selected as a back-up
site should sampling at the primary site prove inaccessible or
inappropriate.  A second back-up site was selected by default as
a precautionary measure.

Sampling of GC 2 (Gathering Center 2) was scheduled on August 2,
1986.  Due to difficulties arising from the attempted sampling of
Pad F (see "Site Selection" of the trip report of Standard
Alaska's Drill Pad G) and at the request of Standard Alaska, the
sampling of GC2 was rescheduled on August 1, 1986.  The back-up
sites were not required.
                              C-43

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Site Location

Gathering Center 2 is located 15 miles northwest of Deadhorse,
AK.  Figure 1 is a map locating the production site.

The site is operated by Standard Alaska Production Company, whose
mailing address and telephone number are:

               PO Box 196612
               900 East Benson Boulevard
               Anchorage, AK 99519-6612
               907-659-4362
               Contact Name: Dale Calven

Attendees

Sampling of Gathering Center 2 was performed by CENTEC
Corporation personnel on August 1, 1986.  The following is a list
of people present at the time of sampling:
    CENTEC Corp. (Sample Team):

    EPA Representatives:




    Operator Representatives:
    American Petroleum
      Institute Representatives:
Site Description
Bruce Hoskins, Team Leader

Susan de Nagy, Office of Water,
  Project Officer
Ted Rockwell, Region X, Alaska
  Operations Office

Randy Hammack, Operations
  Supervisor
Lynn Billington, Standard
  Alaska Production Co.
Jim Collins, Observer
Arden Ahnell, Observer
Bob Zahray, Contracted Sample
  Team Member
Gathering Center 2 is located within the North Slope Basin in an
area characterized as rural coastal tundra.  The depth to
groundwater is approximately 1,800 feet, and the nearest surface
water is less than 1/2-mile away.  There are no drinking water
wells within a 25-mile radius of this site.

This site consists of actively producing oil and gas wells with
an average total production of 300,000 bbl/day oil and 350
million SCF/day gas.  Water production at this site is 65,000
bbl/day.  Production at this site is sweet.  There are 56
individual flow lines entering the facility.  The average well
depth is 12,000 feet.  The site is producing using primary and
secondary techniques.  Primary production is accomplished with
                             C-44

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                                                    WEST DOCK
                                                                          PRUDHOE   B A '
UK DEAD ARM C\
(TRACTION ARE*
                 Figure 1.  Location of Gathering  Center 2, North
                             Slope,  Alaska
                                          C- 45

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both natural and artificial drive.  Water and gas flooding is
also used as secondary production.

Figure 2 is a schematic diagram of the production facility.  The
flow lines feed into a -dehydration chamber and then into a series
of settlers and a slug catcher.  At the slug catcher,  emulsi-
fiers, corrosion inhibitors, scale inhibitors, and antifoamants
are added.  The water line from the slug catcher combines with
the water removed from the dehydration chamber and is  fed into a
skimmer; here,  biocide X-cide 105 is added.

Disposal Practices

From the skimmer, the water goes to booster pumps and  is then
sent to injection pumps.  The water is injected as its final
disposal.

Permits

No facility permit was available to the sample team at the time
of sampling.  It is unknown whether a permit is required for this
facility.
SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).The following
is a description of site-specific sampling information and
activities.

Sample Point Locations

The samples collected at Gathering Center 2 consisted of two
liquid samples, one before oil separation and one after
separation.   The samples were collected at valves in the process
flow lines designated for grab sample collection.

Sampling Methods and Equipment

The sample bottles were filled directly from the valve at the
direction of the EPA Project Manager.  There was no photo
documentation for this site as the facility was indoors and
facility representatives did not allow the taking of photographs
with a flash.

Both liquid samples were tested onsite for pH and free chlorine
content after completion of sampling.  For both liquid samples,
pH was 8 and free chlorine was less than the lowest detectable
level of 0.2 ppm.
                              C-46

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n
                  I/VHIBITOR
                3
                  CATCHERS*
                                             5ETTLBKS
                                                                                  \HK-T £"R
                                   A
                               Figure 2.  Flow  Diagram, Gathering Center 2

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The samples were shipped the day of collection.   Sample shipment
from the North Slope required the use of air cargo.   A.S a result,
a greater time elapsed between shipment and laboratory receipt
than if overnight mail service had been available.   The samples
were shipped to two laboratories:  S-Cubed in California and CAS
in Virginia.  The shipment to California arrived 4  days after
collection.  The shipment to Virginia arrived 11 days after
collection.
                              C- 48

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-49

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C-50

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No photodocumentation specific to the
 operation  of this site is available.
                C-51

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C-52

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ATTSCHM2NT B:  PERMITS
        C-53

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No permit specific to the operation
     of  this  site  is  available.
              C- 55

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o
 I

Cn
CTi

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                         Sampling Report
      Investigation of Standard Alaska Production Company's
                   Drill Pad G, Well No. G-30
                       Prudhoe Bay,  Alaska
                         August 2,  1986
SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA 530-SW-87-005).   This site was selected randomly from
a list of active North Slope Basin drill sites developed by EPA
Region X Alaska Operations Office at the request of EPA.  The
list was transmitted via telephone to the EPA contractor on July
22, 1986.  Randomization and site selection took place during the
telephone conversation.

The EPA contractor had no interest in the manner the particular
sites were listed (by site name, location, operator, permit
number, API number,  etc.) as long as the site could be identified
in detail upon selection.  Thus, the EPA contractor had minimal
information which kept to a minimum the amount of bias.  No other
information was known about the sites on the list at the time of
selection.  Detailed information was obtained only after
selection of primary and back-up sites.

EPA Region X Alaska Operations Office with input from Alaska
Department of Environmental Conservation, ARCO, Standard Alaska,
and Amerada-Hess listed the possible sample sites by location.
The list consisted of fifteen sites:

          1.  Drill Site 1
          2.  Endicotte SDI
          3.  Endicotte MDI
          4.  Drill Site 16
          5.  Drill Site 11
          6.  Pad F
          7.  Pad J
          8.  Pad X
          9.  Pad B
         10.  Pad R
         11.  Drill Site 18
         12.  Drill Site 3N
         13.  Drill Site 31
         14.  Drill Site 1C
         15.  Pad C
As indicated above, the EPA contractor assigned numbers to the
members of the list as they were transmitted.  A random number


                              C-57

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table was used to select the primary and back-up sample sites.
The randomly-selected primary site was No. 2 on the above list
(Endicotte SDI).  No. 7 on the above list (Pad J) was selected as
a back-up site in the event the primary site was inaccessible or
inappropriate.

A public meeting was held in Anchorage, AK on July 29, 1986,
during which the site selections for the North Slope were
announced by EPA.  At the meeting, Standard Alaska voiced
concerns over the selection of Endicotte SDI for sampling because
it is a permitted offshore island.  Because of these concerns,
the primary site was deemed inappropriate for sampling by EPA.

On August 1, 1986, the day of scheduled sampling at the back-up
site (Pad J), a meeting was held between Standard Alaska, ARCO,
EPA, EPA Region X, and the EPA contractor.  Standard Alaska and
ARCO raised issues regarding the qualifications of the back-up
site as described in the May 5, 1986,  draft sampling strategy
document (see Appendix B of the EPA Technical Report [EPA
530-SW-87-005]).  At that time, EPA negotiated with ARCO and
Standard Alaska to develop a new list of appropriate sites.
The second list of sites was:

          1.  Pad F
          2.  Pad G
          3.  Pad C
          4.  Drill Site 11

A second set of primary and back-up sites was selected from this
list.  The randomly-selected primary site was No. 2 on the above
list (Pad G)  No. 3 on the above list (Pad C) was selected as a
back-up site in the event the primary site was inaccessible or
inappropriate.

Further inquiry identified the primary sample site as the well
No. G-30 of Drill Pad G operated by Standard Alaska.  Sampling
was arranged for August 2, 1986.

Site Location

Drill Pad G is located about 12 miles northwest of Deadhorse, AK.
Figure 1 is a map indicating the drilling site.

The site is operated by Standard Alaska Production Company, whose
mailing address and telephone number are:

          900 East Benson Blvd.
          PO Box 196612
          Anchorage, AK  99519-6612
          (907) 561-5111
                              C-58

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                                          . FUTURI
                                                                          BULL I»L»KO
                                                                            PRUDHOE    BAY
K DEAD ARM <\. ( ^
TDACTION ARE*
                 Figure 1.  Location of  Drill  Pad G, North Slope,  Alaska
                                            C-59

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Attendees

Sampling of Drill Pad G, Well No. G-30 was performed by CENTEC
Corporation personnel on August 2, 1986.  The following is a list
of people present at the time of sampling:
    CENTEC Corp. (sample team)

    EPA Representatives:
    Operator Representatives:
                              Bruce Hoskins,  Team Leader

                              Susan de Nagy,  Office of Water,
                                Project Officer
                              Ted Rockwell,  Region X, Alaska
                                Operations Office

                              Jerry Haberthur,  Standard Alaska
                                Production Co.  Drilling
                                Foreman
                              Lynn Billington,  Standard Alaska
                                Production Co.
                              Donny Fields,  Alaska United
                                Drilling Co.
                              Dean Bryan, Mud Engineer,
                                 Macgobar

American Petroleum
  Institute Representatives:  Jim Collins, Observer
                              Arden Ahnell,  Observer
                              Bob Zahray, Contracted Sample
                                Team Member
Site Description

Drill Pad G is located within the North Slope Basin in a rural
area of coastal tundra.  The depth to groundwater is
approximately 1,800 feet, and the nearest surface water is less
than 1/2 mile away.  There are no drinking water wells within a
25-mile radius of the site.  The soil in this area is tundra.
The climate at this site is net evaporation.

This site was a developmental oil drilling site.  Well drilling
began on July 23, 1986 with a completion date of August 7, 1986.
On the day of -sampling, the well was at a depth of 9,500 feet.
The final completion depth was 9,772 feet.  Drilling was
accomplished with low-solid, lightly dispersed mud.  This mud
consisted of bentonite (Magcogel), caustic, carboxy methyl
cellulose, ferrous chrome lignosulfonate (spersene), and sodium
bicarbonate.  Chloride concentration in the mud was 400 ppm.  Mud
pH was 11.

Figure 2 is a schematic diagram of the drilling site.  One large
pit was constructed for the site.  The pit was 1,000 feet long
and 300 feet wide.  The purpose of the pit was long-term storage.
The pit was unlined and had no special preparation prior to use.
The pit received drilling muds, rig wash-down water, completion
                             C- 60

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                                       LOCATION MAP
Figure 2.  Schematic Diagram of Pad G



                      06]

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fluids, spent acids, stimulation fluids,  produced effluent,  and
snow melt.  Well G-30 was the fifteenth well drilled at this pad
since May, 1975.  It was estimated that the reserve pit consisted
of 80 percent drilling fluids,  19 percent snow melt, and 1
percent associated wastes.  The pit area was not fenced.  The pit
construction was above grade.  Photos 1-6 (in Attachment A)  show
the pit and the drilling rig.  The facility oil and gas lines
were constructed above the pit surface to ensure that they are
out of the way of the drilling rig during its operations.  Figure
3 shows the reserve pit with the flow lines.  These pipes have
not leaked any fluids into the reserve pit.

About 30 percent of the drilling muds were disposed by annular
injection; the remaining fluids were piped into the pit.  The
liquid depth in the pit was 2-3 feet.  The total volume of
drilling fluids for Well G-30 was estimated at 8,000 bbl.

A total of 520 bbl of diesel oil were stored in tanks at this
facility.  It was unknown how much waste diesel oil would be
generated.  The waste oil would be taken to a recycling facility.

Disposal Practices

The pit was designed for long-term storage of drilling effluents
and eventual disposal of drilling solids.  The pit was
constructed during 1974 and 1975.  There was no testing of pit
contents, nor was there treatment of pit contents.  The pit was
not to be closed at the end of current drilling activities;  it
would be closed at the end of the field life (beyond the year
2000).

Permits

No permit was available to the sample team at the time of
sampling.


SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report  (EPA 530-SW-87-005).The following
is a description of site-specific sampling information and
activities.

Sample Point Locations

The samples collected at Drill Pad G Well No. G-30 consisted of
one drilling mud, one supernatant, and one sludge sample.  A
partial field duplicate was also taken.  Figure 3 shows the
sampled pit and the location of the sample points.  Four
                              C-62

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o
                                                  CViTTIMG-S LIA/E
                                                         •* i
                                                        U
                                                   RESERVE  ?\T
                                                                                                   PIPES
                                                                                        -l--
                                                                                  ?0\NT
                                                     1000'
                                  Figure 3.  Reserve  Pit - Drill  Pad G

-------
quadrants were established for supernatant sampling.  Sample
points were accessed by boat.  There were no discrepancies
between designated and actual sample points.

Sampling Methods and Equipment

The supernatant was sampled from the boat with a sampling thief.
The sludge was collected from the boat with the dredge.  Photos
7-9 show the sample collection in the pit from the boat.  The
drilling mud sample was collected at the rig.  The mud sample
represented fresh mud collected from the current drilling
operation.

The pit supernatant was tested onsite for pH and free chlorine
content after completion of sampling.  The pH value was 8 and the
free chlorine content was less than the lowest detectable level
of 0.2 ppm.

The samples were shipped the day of collection.  Sample shipment
from the North Slope required the use of air cargo.  As a result,
a greater time elapsed between shipment and laboratory receipt
than if overnight mail service had been available.  The samples
were shipped to two laboratories:  S-Cubed in California and CAS
in Virginia.  The shipment to California arrived 2 days after
collection.  The shipment to Virginia arrived 3 days after
collection.
                              C- 64

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-65

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C-66

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                                            ^                                                    ; ^
     Photos  1,2,3.  Drill  Pad 6  drilling rig  and  reserve  pit
CTl
    Photos  4,5,6.
Drill  Pad  G reserve  p it

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 Photo 7.  Sample collection from  reserve  pit
O
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                                                                 Photo  8.   Sample collection from reserve pit
                                 Photo  9.   Sample  collection  from  reserve pit

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ATTACHMENT B:  PERMITS
        C-69

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o
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No permit specific to the operation
     of  this  site  is  available.
              C-71

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CM
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                         Sampling Report
        Investigation of ARCO Alaska, Inc.'s Drill Site 3N
                       North Slope,  Alaska
                         August  3,  1986
SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA 530-SW-87-005).   This site was selected randomly from
a list of active North Slope Basin drill sites developed by EPA
Region X Alaska Operations Office at the request of EPA.  The
list was transmitted via telephone to the EPA contractor on July
22, 1986.  Randomization and site selection took place during the
telephone conversation.

The EPA contractor had no interest in the manner the particular
sites were listed (by site name, location, operator, permit
number, API number,  etc.) as long as the site could be identified
in detail upon selection.  Thus, the EPA contractor had minimal
information which kept to a minimum the amount of bias.  No other
information was known about the sites on the list at the time of
selection.  Detailed information was obtained only after
selection of primary and back-up sites.

EPA Region X Alaska Operations Office with input from Alaska
Department of Environmental Conservation, ARCO, Standard Alaska,
and Amerada-Hess listed the possible sample sites by location.
The list consisted of fifteen sites:

          1.  Drill Site 1
          2.  Endicotte SDI
          3.  Endicotte MDI
          4.  Drill Site 16
          5.  Drill Site 11
          6.  Pad F
          7.  Pad J
          8.  Pad X
          9.  Pad B
         10.  Pad R
         11.  Drill Site 18
         12.  Drill Site 3N
         13.  Drill Site 31
         14.  Drill Site 1C
         15.  Pad C

As indicated above,  the EPA contractor assigned numbers to the
members of the list as they were transmitted.  A random number
table was used to select the primary and back-up sample sites.
The randomly-selected primary site was No. 8 on the above list


                              C-73

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(Pad X).  No. 11 on the above list (Drill Site 18) was selected
as a back-up site in the event the primary site was inaccessible
or inappropriate.

A public meeting was held in Anchorage,  AK on July 29, 1986,
during which the site selections for the North Slope were
announced by EPA.

On August 1, 1986,  two days before scheduled sampling at Pad X, a
meeting was held between Standard Alaska, ARCO, EPA, EPA Region
X, and the EPA contractor.  Standard Alaska and ARCO raised
issues regarding the qualifications of the primary and back-up
sites as described in the May 5, 1986, draft sampling strategy
document (see Appendix B of the EPA Technical Report [EPA
530-SW-87-005]).  At that time, EPA negotiated with ARCO and
Standard Alaska to develop a new list of appropriate sites.
The second list of sites was:

          1.  Pad F
          2.  Pad G
          3.  Pad C
          4.  Drill Site 11

A second set of primary and back-up sites was selected from this
list.  The randomly-selected primary site was No. 1 on the above
list (Pad F).  No.  4 on the above list (Drill Site 11) was
selected as a back-up site in the event the primary site was
inaccessible or inappropriate.

On August 2, 1986,  the EPA sampling team conducted a
reconnaissance of Pad F.  Upon arrival onsite, EPA was told that
no sampling of the site would be allowed (see letter from
Standard Alaska in Attachment C).

The EPA sampling team successfully conducted reconnaissance of
Drill Site 11 on August 2, 1986, one day prior to scheduled
sampling.  However, on August 3, 1986, the sampling team was
unable to obtain access to the drill site.  The rig was being
dismantled (see letter from ARCO Alaska, Inc. in Attachment D).

Given the history of problems associated with locating and
conducting sampling at appropriate North Slope drill sites, the
Agency opted to specifically select a site rather than to attempt
sampling the second back-up site.  ARCO Alaska, Incorporated's
Drill Site 3N was selected.  Sampling was arranged to be
conducted the same day.

Site Location

Drill Site 3N is located about 50 miles west of Deadhorse, AK.
Figure 1 is a map indicating the drilling site.
                             C-74

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                            C-75

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The site is operated by ARCO Alaska, Incorporated,  whose mailing
address and telephone number are:

               Kuparuk Operations
               PO'BOX 6105
               Anchorage, AK 99502
               (907) 659-2821

Attendees

Sampling of Drill Site 3N was performed by CENTEC Corporation
personnel on August 3, 1986.  The following is a list of people
present at the time of sampling:
    CENTEC Corp. (sample team)

    EPA Representatives:




    Operator Representatives:
    American Petroleum
      Institute Representatives:
Bruce Hoskins, Team Leader

Susan de Nagy, Office of Water,
  Project Officer
Ted Rockwell, EPA Region X,
  Alaska Operations Office

Charlie Dixon, ARCO Drilling
  Supervisor
Al Schuyler, ARCO
Jay Turner, Mud Engineer,
  NL Benoid
Jim Collins, Observer
Bob Zahray, Contracted Sample
  Team Member
Arden Ahnell, Contracted Sample
  Team Member
Site Description

Drill Site 3N is located in rural coastal tundra; the depth to
groundwater is over 100 feet,  and the nearest surface water is
less than 1/2 mile away.  There are no drinking water wells
within a 1-mile radius of the site.  The soil in this area is
tundra.  The climate at this site is net evaporation.

This site was a developmental oil drilling site.  Nine different
wells (Well Nos. 10-18) were drilled from late March-May, 1986.
Wastes from drilling activities at these wells were placed in the
pit chosen for sampling.  The following information was available
for the nine individual wells:

Well 3N-10 was drilled from March 29-April 5, 1986.  Well depth
was 9,394 feet.  Total drilling costs were [confidential].  Mud
costs were [confidential].  Drilling was accomplished with a
                              C-76

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 low-solids,  nondispersed  polymer  mud  with  the  following
 components:   gel,  caustic,  quick  gel,  SAPP,  benex,  barite,
 dextrid,  Q-broxin,  drespac,  and aquagel.

 Well  3N-11 was drilled  from April 6-14,  1986.   Well depth was
 8,691  feet.   Total  drilling costs were [confidential].   Mud  costs
 were  [confidential].  Drilling was accomplished with a
 low-solids,  nondispersed  polymer  mud  with  the  following
 components:   aquagel, benex, caustic,  quick  gel,  gel, soda ash,
 barite, SAPP, cellex, drespac, and dextrid.  Completion  fluids
 composed  of  sodium  chloride and sodium bromide were used.

 Well  3N-12 was drilled  from April 12-22, 1986.  Well depth was
 8,100  feet.   Total  drilling costs were [confidential].   Mud  costs
 were  [confidential].  Drilling was accomplished with a low
 solids, nondispersed polymer mud  with  the  following components:
 gel, benex,  caustic, quick  gel, aquagel, drespac, SAPP,  cellex,
 dextrid,  thermathin, and  condet.   Chloride content  in the mud was
 450-500 ppm.  A 400 ppm sodium chloride  solution  was used as
 completion fluid.
                             /
 Well 3N-13 was drilled  from April 22-28, 1986.  Well depth was
 7,792  feet.   Total  drilling costs were [confidential].   Mud  costs
 were [confidential].  Drilling was accomplished with a low
 solids, nondispersed polymer mud  with  the  following components:
 aquagel,  benex, caustic,  quick gel, soda ash,  barite, gel,
 cellex,lime,  and drespac.   Chloride content  in the  mud was
 500-700 ppm.

 Well 3N-14 was drilled  from April 28-May 6,  1986.   Well  depth was
 7,460  feet.   Total drilling costs were [confidential].   Mud costs
 were [confidential].  Drilling was accomplished with a low
 solids, nondispersed polymer mud  with  the  following components:
 gel, benex,  caustic, quick  gel, aquagel, barite,  cellex, dextrid,
 drespac,  baroid, and thermathin.   Chloride content  in the mud was
 500-550 ppm.

 Well 3N-15 was drilled  from May 6-12,  1986.  Well depth  was 8,508
 feet.  Total  drilling costs were  [confidential].  Mud costs were
 [confidential].  Drilling was accomplished with a low solids,
 nondispersed polymer mud with the following  components:  aquagel,
 barite, benex, caustic,  quick gel, dextrid,  drespac, and cellex.

 Well 3N-16 was drilled  from May 12-20, 1986.  Well  depth was
 9,189  feet.  Total drilling costs  and  mud costs were not
 available.   Drilling was accomplished  with a low  solids,
 nondispersed polymer mud with the  following  components:  aquagel,
 x-tend, caustic,  quick gel, barite, gel, baroid, thermathin,  EP
mud lube,  lime,  defoamant, dextrid, drespac, and Q-broxin.

Well 3N-17 was drilled from May 20-26, 1986.  Well  depth was
 9,005 feet.  Total drilling costs were [confidential].  Mud costs
were [confidential].  Drilling was accomplished with a low
                              C-77

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 solids, nondispersed polymer mud with the following components:
 aquagel,  x-tend, caustic, quick gel, barite, gel, baroid,
 thermathin, EP mud lube, lime, defoamant, dextrid, drespac, and
 Q-broxin.

 Well  3N-18 was drilled on May 26-June 4, 1986.  Well depth was
 10,630  feet.  Total drilling costs were  [confidential].  Mud
 costs were [confidential].  Drilling was accomplished with a  low
 solids, nondispersed polymer mud with the following components:
 aquagel,  x-tend, caustic, quick gel, barite, gel, baroid,
 thermathin, EP mud lube, lime, defoamant, dextrid, drespac, and
 Q-broxin. Chloride content in the mud was 600 ppm.

.Figure  2  is a schematic diagram of the drilling site.  Two large
 pits were constructed for the site.  The purpose of the pits  was
 for long-term storage.  The pits were unlined and had no special
 preparation prior to use.  The pits received drilling cuttings.
 The pit area was not fenced.  The pit construction was above
 grade.  The facility oil and gas lines were constructed above the
 pit surface to ensure that if any of these lines leaked, the
 leakage would fall into one of the pits.

 This  rig  operated as a nearly alosed system.  The drilling muds
 were  disposed by direct annular injection.  The cuttings were
 piped into the pits.  There was no .discrete liquid surface over a
 major portion of the pits.  The sludge depth in the sampled pit
 was 2-3 feet.  The total volume of drilling fluids was estimated
 to be less than 2,500 bbl.

 A total of 1,500 bbl of diesel oil was stored in tanks at this
 facility.  Waste oil totaling 589 bbl was generated.  The waste
 oil was disposed by injection.

 Disposal  Practices

 The pits  were designed for long-term storage.  There was no
 testing of pit contents.  There was no treatment of pit contents.
 The pits  were not to be closed at the end of current drilling
 activities.  It was unknown when the pits would be closed.  The
 following injection information was available for Wells 10-18:

 Well  3N-10 injected 1,355 bbl mud.

 Well  3N-11 injected 3,467 bbl mud, 1,300 bbl water, and 16 bbl
 diesel  oil.

 Well  3N-12 injected 2,743 bbl mud, 300 bbl water, and 26 bbl
 diesel  oil.

 Well  3N-13 injected 4,834 bbl mud, 300 bbl water, and 20 bbl
 diesel  oil.

 Well  3N-14 injected 4,184 bbl mud, 300 bbl water, and 106 bbl
 diesel  oil.
                              C-78

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   O\L£<;A
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Well 3N-15 injected 3,979 bbl mud,  300 bbl water,  and 28 bbl
diesel oil.

Well 3N-16 injected 9,931 bbl mud,  300 bbl water,  and 287 bbl
diesel oil.

Well 3N-17 injected 3,464 bbl mud,  300 bbl water,  and 76 bbl
diesel oil.

Well 3N-18 injected 978 bbl mud, 455 bbl water,  and 40 bbl diesal
oil.

Permits

Permit applications for Wells 3N-10 to 3N-18 are shown in Attach-
ment B.
SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).The following
is a description of site-specific sampling information and
activities.

Sample Point Locations

The sample collected at Drill Site 3N consisted of one pit sludge
sample taken from the eastern reserve pit.  Figure 2 shows the
sampled pit and the location of the sample points.  Four
quadrants were established for sludge sampling.

Sampling Methods and Equipment

The pit contained a supernatant on only one-half of the pit in
which two of the four quadrants were located.  In these
quadrants, the coring tube was not used, since the sludge was too
liquid to remain in the tube.  The sludge was collected from the
boat with the stainless steel spoon and bucket in two quadrants.
In the other two quadrants, the sample was collected using the
coring tube lined with Teflon.  Photos 1-4 (see Attachment A)
show the sample collection in the pit from the boat.  Photos 5
and 6 show the sample collection with the coring tube.

The samples were shipped on the day of collection.  Sample
shipment from the North Slope required the use of air cargo.  As
a result, a greater time elapsed between shipment and laboratory
receipt than when overnight mail service was utilized.  The
samples were shipped to two laboratories:  S-Cubed in California,
and CAS in Virginia.  The shipment to California arrived 3 days
after collection.  The shipment to Virginia arrived 4 days after
collection.


                              C-80

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-81

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C-82

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Photo 5.  Sample collection with coring tube
                                                                 Photo 6.  Sample collection with  coring  tube

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ATTACHMENT B:  PERMITS
       C-85

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                                         STATE OF ALASKA
                     ALASKA OIL AND GAS CONSERVATION COMMISSION
                                     PERMIT TO  DRILL
                                             20 AAC 25.005
 la. Type of work    Drill     Redrill Z,
              Re-Entry"Z  Deepen C
                                  1b. Type of well. Exploratory _   Stratjgrapnic Test _   Development Oil
                                      Service  Z  Developement Gas _  Single Zone % Multiple Zone
 2. Name of Operator
ARCO  Alaska,  Inc.
 3. Address
 '.0.  Box 100360 Anchorage,  AK
                                  99510
                                                   5. Datum Elevation (OF or KB)

                                                   RKS  63',  PAD 3» '
             6. Property Designation
             AOL  2SS20   ALK 2556
                             10. Field and Pool

                             Kuparuk  River Field
                             Kuparuk  River Oil  Pool
 4. Location of well at surface

1561'FSL, 105'FEL,  Sec.29,  T13N,  R9E, UM
    At top of productive interval
1358'FNL, 1817'FWL,  Sec.28,  T13N,  R9E, UM

    At total depth

 178'FNL, 196»'FWL.  Sec.28.  T13N,  R9E, UM
                                                   7. Unit or property Name

                                                   Kuparuk  River Unit
                                                   8. Well number
                                                   3N-13
                                                   9. Approximate spud date

                                                               0*721/86
                                        11. Type Bond (s»« 20 AAC 250251

                                       Statewi de
                                        Number
                                       *8088-26-27

                                        Amount

                                         $500.000
 12. Distance to nearest
 property line
 105'  (8 surf aca_
                     feet
                          13. Distance to nearest well
             14. Number of acres in property
                             15. Proposed depth IMO and
                                7850'MO
                                     'Tun i
                                                                                                 feet
16. To be completed for deviated wells
Kickoff depth 23 i»i    feet	Maximum hole angle ,
                                                    17. Anticipated pressure OM 20 AAC 21035 («m>

                                                    Maximum surface  2915     ^"^ ** tot1' ^*°tn ^0)   3 3 1* 2
  18. Casing program
         size
                          Specifications
                                                        Setting Depth
               Top
               Bottom
                  Quantity of cement
    Hole   Casing
                  Weight Grade Coupling  Length
            MO
       TVD
MO
TVD
(include stage data)
 fl V,
                           I -US
                                         7 fll fi '
                          HF-ERW
 19. To be completed for Redrill, Re-entry, and Deepen Operations.
    Present well condition summary
    Total depth:       measured                  feet     Plugs (measured)
                    true vertical                feet
    Effective depth:


    Casing
      Structural
      Conductor
      Surface
      Intermediate
      Production
      Liner
    Perforation depth:
                   measured
                   true vertical

                         Length
       feet
       feet
    Junk (measured)
Size
Cemented
  Measured depth
                True Vertical deotn
                   measured
                   true vertical
 20. Attachments  Filing fee £   Property plat %  BOP Sketch J&  Diverter Sketch .S_ Drilling program^
 Drilling fluid program ^ Time vs depth plot S3  Refraction analysis Z Seabed report _ 20 AAC 25.050 requirements  _
 21. I hereby caflify trat the foreggitfg is tfue and correct to the best of my knowledge
    Signec
                                                Title
                                                      Regional  Drilling Engineer
                                           Commission Use Only
                                                                    (LWK)   PO/P0252
 Permit Nu*ber
         '  86-81
                          API number
                           50-   029-21584
                  Approval date
                      04/18/86
                             See cover letter
                             for other requirements
 Conditions of approval  Samples required   _ Yes  XNo  Mu<* '°9 required  _. Yes
 Hydrogen sulfide measures  Z Yes   Z No  Directional survey required  X Yes   Z No'
 Required workingowssureJor^SOP^i—Z2M< If 3M;  1. 5M;   Z 10M;   Z 15M


 Approved by  \^    , f,  \   iZ&iwktifSt)     C-87     Commissioner      the commission
Form 10-401 Rev. 12-1-85
                                                                                                triplicate

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                          GENERAL DRILLING PROCEDURE
                              KUPARUK RIVER FIELD
                               DEVELOPMENT WELLS
 1.  Move in rig.
 2.  Install Tankco diverter system.
 3.  Drill 12V hole to 9-5/8" surface casing point according to directional
     plan.
 A.  Run and cement 9-5/8" casing.
 5.  Install and test blow out preventer.  Test casing to 2000 psig.
 6.  Drill out cement and 10' new hole.  Perform leakoff test.
 7.  Drill 8V' hole to logging point according to directional plan.
 8.  Run open hole logs.
 9.  Continue drilling 8*5" hole to provide 100' between plug back total depth
     and bottom of Kuparuk sands.
10.  Run and cement 7" casing.  Pressure test to 3500 psig.
11.  Downsqueeze Arctic Pack and cement in 7" x 9-5/8" annulus.
12.  Nipple down blow out preventer and install temporary Xmas tree.
13.  Secure well and release rig.
14.  Run cased hole logs.
15.  Move in workover rig.  Nipple up blow out preventer.
16.  Pick up 7"  casing scraper and  tubing,  trip in hole to  plug back total
     depth.   Circulate  hole  with clean brine  and  trip out  of  hole  standing
     tubing back.
17.  Perforate and run completion assembly.
18.  Nipple down blow out preventer and install Xmas tree.
19.  Change over to diesel and set packer.
20.  Flow well to tanks.  Shut in. .
21.  Secure well and release rig.
22.  Fracture stimulate.
LWK4/ih
                                       sysrcm
                             C-88

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                 Spud to
                             DRILLING FLUID PROGRAM
                              Drill out

Density
PV
YP
Viscosity
Initial Gel
10 Minute Gel
Filtrate API
pH
Z Solids
9-5/8" Surface Casing
9.6-9.8
15-30
20-40
50-100
5-15
15-30
20
9-10
104
to Weight Up
8.7-9.2
5-15
8-12
35-40
2-4
4-8
10-20
9.5-10.5
4-7
Weight Up to TD
10.3
9-13
8-12
35-45
3-5
5-12
6
9.5-10.5
9-12
Drilling Fluid System;

    Triple Tandem Shale Shaker
    2 -Mud Cleaners
    Centrifuge
    Degasser
    Pit Level Indicator (Visual & Audio Alarm)
    Trip Tank
    Fluid Flow Sensor
    Fluid Agitators
Notes:
Drilling fluid practices will be in accordance with the
appropriate regulations stated in 20 AAC 25.033.

Maximum anticipated surface pressure is calculated with
an unexpanded gas bubble at surface, including temperature
effects.
LWK5/ih
                                C-89

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                                         STATE OF ALASKA
                         ALASKA OIL AND GAS CONSERVATION COMto.^SION
                APPLICATION  FOR  SUNDRY  APPROVALS
1. Type of Request  Abandon _  Suspend I  Operation Shutdown N Re-enter suspended well I  Alter casing I
Time extension I.  Change approved program ~ Plugging ~ Stimulate ^ Pull tubing Z  Amend order ~ Perforate % Other
                                                                                              ^ '
 2. Name of Operator
     ARCO Alaska,  Inc
                                                                    5. Datum elevation (OF or KB)
                                                                    68 '  RKB                  feet
 3. Address
     P.  0. Box  1QQ360	Anchorage, AK
                                                                    6. Unit or Property name
 4. Location of well at surface
     1561'FSL, 179'FEl, Sec.29, T13N,  R9E,  UM
   At top of productive Interval
     1381'FSL, 1825'FWL, Sec.33, TUN,  R9E, UM  (approx.)
   At effective depth
     1496'FSL, 1874'FWL, Sec.33, T13N,  R9E, UM  (approx.)
   At total depth
     1191'FSL, 1996'FWL, Sec.33, T13N,  R9E, UM  (approx.)
                                                                    7. Well number
                                                                    3N-i n
                                                                    8. Permit number
                                                                    86-72
                                                                    9. API number
                                                                     50—029-21576
                                                                   10. Pool
                                                                    Kuparuk  River Oil  Pool
 11. Present well condition summary
    Total depth:      measured    9 3 9 if <
                   true vertical   57291
    Effective depth:   measured
true vertical

      Length
     80'

     4535'
9271 '
6440'
                                           feet
                                           feet

                                           feet
                                           feet
                     Plugs (measured)

                     Junk (measured)
                                                  Nona
                                                                     None
Size
16"

9-5/8"
Casing
 Conductor

 Surface


 Producti on         9365 '
                (iZ'cUxwc i
Perforation depth:  measured    None

                true vertical  None

Tubing (size, grade and measured depth)      None

Packers and SSSV (type and measured depth)  None
                                                Cemented
                                                              Measured depth
                                               Conductor  report    115'
                                               not available.
                                               1400 sx  AS  III &    4572 '
                                               315 sx Class C
                                                300 sx Class G &
                                                175 sx AS  I
                                                                    9353
                                                     True Vertical depth
                                                     115'

                                                     3567'


                                                     6702'
 l2.Attachments        Description summary of proposal _
                     Well  History
                                                   Detailed operations program _   BOP sketch C
 13. Estimated date for commencing operation
    May, 1986	
 14. if proposal was verbally approved
    Name of approver
                                                                   Date approved
 15. I hereby certify that the foregoing is true and correct to the best of my knowledge
 Signed     df,   /7O    uMxA^Title Associate Engineer
                                                                                 Date 5-I-8L*
                                         Commission Use Only
                                                              (DAM) SA/012
 Conditions of approval    Notify commission so representative may witness
                       ~ Plug integrity  3 BOP Test  Z Location clearance
 Approved by
                                                                   Approval No.
                                                   Commissioner
                                      by order of         <
                                      the commission Date •
Form 10-403 Rev 12-1-85
                                        C-90
                                                      Submit in triplicate

-------
                                         STATE OF ALASKA
                         ALASKA OIL AND GAS CONSERVATION COMMISSION
                APPLICATION  FOR  SUNDRY  APPROVALS
 1. Type of Request:  Abandon _  Suspend _  Operation Shutdown    Re-enter suspended well _  Alter casing ~

 Time extension Z Change approved program ~ Plugging Z Stimulate ~ Pull tubing ~ Amend oraer  ~ Perforate  '  Otner
 2. Name of Operator
     ARCO Alaska,  Inc.
                                                               5. Datum elevation (OF or KB)
                                                               68' RKB                  «eet
 3. Address
     P. 0. Box  100360  Anchorage. AK   99510
                                                               6. Unit or Property name
                                                               Kuoaruk  River U n < t
 4. Location of well at surface
     1561'FSL,  155'FEL, Sec.29, T13N,  R9E,  UM
   At top of productive interval
     1267'FSL,  785'FEL, Sec.20, T13N,  R9E,  UM (approx.)

   At effective depth
     1441'FSL,  915'FEL, Sec.20, T13N,  R9E,  UM (approx.)

   At total depth
                                                               7. Well number
                                                               3N-1 1
                                                               8. Permit number
                                                               86-77
                                                               9. API number
                                                                50—029-21580
otal depth
509'FSl,  931'FEL,  Sec.20, T13N,  R9E, UM  (approx.)
                               10. Pool
                                Kuparuk River  Oil  Pool
 11. Present well condition summary
    Total depth:      measured    8790
                   true vertical   6648

    Effective depth:   measured    g691
                   true vertical   65?8
                                      feet
                                      feet

                                      feet
                                      feet
              Plugs (measured)   None


              Junk (measured)
    Casing
     Conductor

     Surface

     Production
                   Length
                  .80'

                  4523'

                  8786'
Size
16"


9-5/8"

7"
Cemented       Measured depth
Conductor report    115'MO
not  available.
1300  sx  AS III &    4558'MD
350  sx  Class G
300  sx  Class C &    8777'MO
175  sx  AS I
True Vertical depth

115'TVO


3643'TVO

6639'TVO
    Perforation depth: measured    None


                   true vertical   None


    Tubing (size, grade and measured depth)     None
    Packers and SSSV (type and measured depth)
                                         None
                                                G   Detailed operations program i_i  SOP sketch ~
 13. Estimated date for commencing operation
    June,  1986
 14. If proposal was verbally approved

    Name of approver
                                                              Date approved
 15. I hereby certify that the foregoing is true and correct to the best of my knowledge

 Signed     iQmU  Axku             Title  *»•«"".  Engineer
                                                                            Date  5-12-Sb
                                        Commission Use Only
                                                               (DAM)  SA/028
 Conditions of approval
 Approved by
Form 10-403 Rev 12-1-85
                 Notify commission so representative may witness
                 Z! Plug integrity  C BOP Test  Z  Location clearance
                                              Commissioner
                              Approval No.
                              by order of
                              the commission Date
                                                                              Submit m triplicate

-------
                                        STATE OF ALASKA
                        ALASKA OIL AND GAS CONSERVATION COMMISSION
               APPLICATION FOR SUNDRY APPROVALS
1. Type of Request:  Abandon I  Suspend I  Operation Shutdown ^  Re-enter suspended well _  Alter casing .
Time extension ~ Change approved program I  Plugging ~ Stimulate I Pull tubing I Amend order : Perforate  " Other
2. Name of Operator
    ARCO Alaska,  Inc.
                                                                   5. Datum elevation (OF or KB)
                                                                   68'  RKB                   'eet
3. Address
       0, Box 10(nfifl  Anchor-ape.  AK	9,*} 
-------
                                        STATE OF ALASKA
                         ALASKA OIL AND GAS CONSERVATION COMMISSION
                APPLICATION  FOR SUNDRY APPROVALS
 1. Type of Request:  Abandon _  Suspend Z  Operation Shutdown J? Re-enter suspended well _  Alter casing ~

 Time extension Z Change approved program Z  Plugging ~ Stimulate Z Pull tubing Z Amend order Z  Perforate ~  Otner
 2. Name of Operator
     ARCO Alaska^  Inc.
                                                                   5. Datum elevation (OF or KB)
                                                                   68*  RK8                  feet
 3. Address
     P. 0. Box  100360  Anchorage. AK
                                                                   6. Unit or Property name

                                                                   Kuoaruk  RfV(,r  Unit-
 4. location of well at surface
     1561'FSL,  105'FEL, Sec.29,  T13M, R9E,  UM
   At top of productive interval
     1358'FNL,  1817'FVHL, Sec.28, T13N, R9E,  UM (approx.)

   At effective depth
     1213'FNL,  1960'FWL, Sec.28, T13N, R9E,  UM (approx.)

   At total depth
     1169'FNL,  1990'FWL, Sec.28, T13N, R9E,  UM {approx.)
                                                                   7. Well number
                                                                   3N-13
                                                                   8. Permit number
                                                                   86-81
                                                                   9. API number
                                                                    50—029-21580
                                                                  10. Pool
                                                                   Kuparuk River 011  Pool
 11. Present well condition summary
    Total depth:      measured    7875
                   true vertical   6667
    Effective depth:   measured
                   true vertical
                              7792
    Casing

     Conductor


     Surface


     Productlon
                              6604

                        Length       Size

                       80'          16"


                       3737'        9-5/8"


                       7882'        7"
                       (91  above rotary)
feet
feet

feet
feet
    Plugs (measured)    None


    Junk (measured)     ..
                     None


Cemented       Measured depth

Conductor report    115'MO
not  available.
1100  sx  AS III &    377VMD
300  sx  Class G
320  sx  Class G      7873 'MO
                                       True Vertical depth

                                       115'TVIT


                                       3631 'TVO


                                       6665'TVD
    Perforation depth:  measured   None


                   true vertical  None


    Tubing (size, grade and measured depth)      None


    Packers and SSSV (type and measured depth)  None
                                                              -  a C.l i •- - " •••
                                                                      •  . — -3
 12.A1
            story
                    Description summary of proposal G  Detailed operations program G  BOP sketch _
 13. Estimated date for commencing operation
     July,  1986
 14. if proposal was verbally approved
    Name of approver	ua

          certify that the foregoing is true and correct to the best of my knowledge
          1 "       LA   ,                  —    Associate Engineer
                                                                  Date approved
15. I hereby

Signed
                                          Tltte
                                     Date 5-fc.Qu
                                        Commission Use Only
                                                               (DAM)   SA/039
 Conditions of approval
                      Notify commission 30 representative may witness
                      G Plug integrity  C  BOP Test  G Location clearance
                       Approval No.
 Approved by
                                                  Commissioner
                       by order of           •—
                       the commission Date  3 -
Form 10-403 Rev 12-1-85
                                        C-93
                                                                                  Submit in triplicate

-------
                                         STATE OF ALASKA
                         ALASKA OIL AND GAS CONSERVATION COMMISSION
                APPLICATION  FOR  SUNDRY  APPROVALS
 1. Type of Request:  Abandon _  Suspend 2  Operation Shutdown x  Re-enter suspended well Z  Alter casing I
 Time extension ~ Change approved program Z Plugging ~ Stimulate ~ Pull tubing ~ Amend order I  Perforate ~ Other ~
 2. Name of Operator
    ARCO  Al aska,  Inc.
                                                5. Datum elevation (OF or KB)
                                                68'  RK8                   feet
 3. Address

    P.  0.  Box 1QQ360
                                                6. Unit or Property name
                                    A K
 4. Location of well at surface
    1561'FSL, 79'FEL,  Sec.29,  T13N,  R9E, UM
   At top of productive interval
    1327'FSL, 1792'FWL,  Sec.28,  T13N, R9E, UM  (approx.)
   At effective depth
    1327'FSL, 1958'FWL,  Sec.28,  T13N, R9E, UM  (approx.)
   At total depth
    1318'FSL, 2030'FVrL,  Sec.28,  T13N, R9E, UM  (approx.)
                                                7. Well number
                                                8. Permit number
                                                86-86
                                                9. API number
                                                 50-029-21589
                                               10. Pool
                                               Kuparuk River  Oil  Pool
 11. Present well condition summary
    Total depth:      measured   7lf60
                   true vertical 6687

    Effective depth:   measured
                       feet     Plugs (measured)   None
                       feet
                   true vertical
         7356
         6612
        feet
        feet
                               Junk (measured)
                                                                    None
    Casing

    Conductor


    Surface
    Product i on
    Length
   80'

   2542'



   71*40'
 Size
16"
 Cemented

238 sx  CS  II
Measured depth

     110'MO
                                    10-3/4"   1150  sx AS  III  &   2579'MD
                                               150  sx  Class C
                                               Top  job w/100  sx AS I
                                    7"
                                               660  sx  Class C
                                               7440'MO
 True Vertical depth

110'TVO

2579'TVD



6673'TVO
    Perforation depth: measured   None


                   true vertical None


    Tubing (size, grade and measured depth)     None


    Packers and SSSV (type and measured depth) None
 12-Attachments
    Well  History
Description summary of proposal G  Detailed operations program ~   BOP sketch ~
 13. Estimated date for commencing operation
    July,  1986	
 14. if proposal was verbally approved
    Name of approver
                                               Date approved
 15. I hereby certify that the foregoing is true and correct to the best of my knowledge

           do (}fmj Ajud)4^	Title Associate  Engineer
                                                             Date
                                         Commission Use Only    (0AM)   SA/042
 Conditions of approval    Notify commission so representative may witness
                       G Plug integrity  G BOP Test  G Location clearance
                                               Approval No.
 Approved by
                               Commissioner
                     by order of
                     the commission Date
                                                    - 2- 1~
Form 10-403 Rev 12-1-85
                     C-94
                                               Submit m triplicate

-------
                                         STATE OF ALASKA
                         ALASKA OIL AND GAS CONSERVATION COMMISSION
                APPLICATION  FOR  SUNDRY  APPROVALS
 1. Type of Request:  Aoandon _  Suspend _  Operation Shutdown    Re-enter suspended well 1  Alter casing  I
 Time extension ~  Change approved program Z Plugging ~ Stimulate Z Pull tubing I Amend order ~ Perforate I Other 3
 2. Name of Operator
    ARCO  Alaska ,  Inc.
                                                5. Datum elevation (OF or KB)
                                                68'  RK8                   feet
 3. Address
    P. 0.  Box 100.330   Anrhnraq..,  AK
                                                6. Unit or Property name
                                                tf up j r,.L P {
 4. Location of well at surface
    1561'FSL, 54'FEL,  Sec.29,  T13N, R9E,  UM
   At top of productive interval
    1323'FSL, 844'FEL,  Sec.28,  T13N, R9E,  UM (approx)
   At effective depth
    1402'FSL, 755'FEL,  Sec.28,  T13N, RT9E,  UM (approx)
   At total depth
    1415'FSL, 694'FWL,  Sec.28,  T13N, R9E,  UM (approx)
                                                7. Well number
                                                3N-15
                                                8. Permit number
                                                86-90
                                                9. API number
                                                 50-029-21592
                                               10. Pool
                                                Kuparuk River Oil Pool
 11. Present well condition summary
    Total depth:      measured   8508
                   true vertical 6700
                       feet     Plugs (measured)    N0ne
                       feet
    Effective depth:   measured
                   true vertical
         8409
    Casing
    Conductor

    Surface

    Product!on
         6623
    Length        Size
   80'           16"
        feet
        feet
                               Junk (measured)
                                               None
           Cemented
           255 sx  CS  II
                Measured depth
                     115'MO
   4284 •

   8496'
9-5/8"

7"
1250  sx  AS III &    4321'MO
350 sx Class C
325 sx Class C      8496'MO
 True Vertical depth
115'TVO

3639'TVD

6690'TVD
    Perforation depth: measured   None

                   true vertical None

    Tubing (size, grade and measured depth)     None

    Packers and SSSV (type and measured depth) None
 12.Attachments
    Well  History
Description summary of proposal  _  Detailed operations program _  BOP sketch _
 13. Estimated date for commencing operation
    July, 1986	
 14. If proposal was verbally approved

    Name of approver
                                               Date approved
 15. I hereby certify that the foregoing is true and correct to the best of my knowledge
 Signed     J-, %i/R^  ^UJfXXJ           Title Associate Engineer
                                                             Date
           J
                    Commission Use Only     (DAM)  SA/043
 Conditions of approval    Notify commission so representative may witness
                       2 Plug integrity  Z BOP Test  ~ Location clearance
                                               Approval No.
 Approved by
                               Commissioner
                               by order of
                               the commission Date  £ • H ~*l:
Form 10-403 Rev 12-1-85
                                           C-95
                                                               Submit in triplicate

-------
                           STATE OF ALASKA
                ALASKA OIL AND GAS CONSERVATION COMM, ,iON

           APPLICATION FOR SUNDRY APPROVALS
1 Type Of Request: AQanaon : Suspend _ Operation Shutdown/^ He-enter suspended well ~ Alter casing
Time extension .1 Change approved program 1 Plugging ~ Stimulate 7 Pull tuGmg ~ Amend order Perforate " Otner
2. Name of Operator
ARCO Alaska, 1 no
3. Address
p n R*r innicn an^hn...^ si/ aaein
4. Location of well at surface
1561' PSL, 29' PEL, Sec. 23, H3N, S9E,
At top of productive interval
1289' PNL, 840' PEL, Sec. 33, T13N, R9E,
At effective depth
1288' PNL, 561' PEL, Sec. 33, T13N, R9E,
At total depth
1320' FNL, 487' PEL, Sec. 33, T13N, R9E,
11. Present well condition summary
Total depth: measured 9235' feet
true vertical 6950. feet
Effective depth: measured feet
true vertical 91°2' feet
6744'
Casing Length Size
Conductor 80' 16"
Surface 4760' 9-5/8"
Production 9189' 7"
Perforation depth: measured None
true vertical None
Tubing (size, grade and measured depth) None
Packers and SSSV (type and measured depth) None
l2.Attachments Description summary of proposal
Well History
5. Datum elevation (OF or KB)
68' RKS 'eet
6. Unit or Property name
7. Well number
U.M ™-lfi
8. Permit number
UM (approx) 86-91
9. API number
UM (approx) 50— 029-21593
10. Pool
UM (approx) Kuparuk River OH Pool
Plugs (measured) None
Junk (measured)
None
Cemented Measured depth True Vertical depth
249 sx CS I I 1 1 5 ' MO 1 1 5 ' 1 VD
1350 sx AS 1II& 350 sx Class C 4797'MO 2598' 1VD
300 sx Class C 9189'MO 6813' 1VO
, i -
~ Detailed operations program ~ BOP sketch Z
13. Estimated date for commencing operation
July, 1986
u. if proposal was verbally approved
Name of approver
Date aporoved
15. I hereby certify that the foregoing is true and correct to the best of my knowledge
Signed d '!/V)O xJ't
-------
                                         STATE OF ALASKA
                         ALASKA OIL AND GAS CONSERVATION COMMISSION
                APPLICATION  FOR SUNDRY  APPROVALS
 1. Type of Request:  Abandon _  Suspend _, Operation Shutdown £  Re-enter suspended well _  Alter casing ~
 Time extension ~ Change approved program ~ Plugging ~ Stimulate 1 Pull tubing ~ Amend order 1 Perforate Z  Other ~
 2. Name of Operator
     ARCO Alaska,  Inc.
                                                                    5. Datum elevation (OF or KB)
                                                                    68'  RKB                   feet
 3. Address
     P.  0. Box  100360  Anchorage. AK   99510
                                                                    6. Unit or Property name
                                                                    Kuoarulc  River U ni 1-
 4. Location of well at surface
     1561'FSL, VFEL, Sec.29,  T13N, R9E,  UM
   At top of productive interval
     850'FNL, 838'FEL, Sec.28,  T13N, R9E,  UM (approx.)
   At effective depth
     710'FNL, 651'FEL, Sec.28,  T13N, R9E,  UM (approx.)
                  'FEL, Sec.28,  T13N, R9E,  UM (approx.)
                                                                    7. Well number
                                                                    3N-17
                                                                    8. Permit number
                                                                    86-92
                                                                    9. API number
                                                                     50—029-2159'*
                                                                   10. Pool
                                                                    K u'p a r u k  River Oil  Pool
 11. Present well condition summary
    Total depth:      measured    9005
                   true vertical   5727
    Effective depth:   measured
   Casing
    Conductor
    Surface
    Production
                  true vertical

                        Length
                       80'
                               8912
                               6658
       feet
       feet

       feet
       feet
                                                   Plugs (measured)    None

                                                   Junk (measured)
Size
16"
9-5/8"
                       8997'
                     None

Cemented       Measured depth
250  sx  CS I I         115 'MO
1 350  sx  AS I II &    1*606 'MO
350  sx  Class  C
Top  job  H/AS   I cmt.
300  sx  Class  C 4    8997'MO
175  sx  AS I
True Vertical depth
1 15 'TVO
3625'TVD
                                                                                   6721'TVO
    Perforation depth: measured   None

                   true vertical None

    Tubing (size, grade and measured depth)     None

    Packers and SSSV (type and measured depth) None
                                                                        JUMl > 1386
                                                                 -'asxa C
 l2.Ayachme.pts
            story
                    Description summary of proposal u  Detailed operations program _   BOP sketch _
 13. Estimated date for commencing operation
    July,  1986
 14. If proposal was verbally approved

    Name of approver
                                                                   Date approved
15. I hereby certify that the foregoing is true and correct to the best of my knowledge
Signed      Jv'/,/^U  *!/'/v'w.V^           Title  Associate  Engineer
                                                                                  Date
                                         Commission Use Only
                                                               (DAM)   SA/055
 Conditions of approval
 Approved by
                      Notify commission so representative may witness
                      ~ Plug integrity  "I BOP Test  Z  Location clearance
                                                   Commissioner
                               Approval No.
                               by order of
                               the commission Date srl V
Form 10-403 Rev 12-1-85
                                          C-97
                                                                                   Submit in triplicate

-------
                                        STATE OF ALASKA
                         ALASKA OIL AND GAS CONSERVATION
                APPLICATION  FOR SUNDRY  APPROVALS
 1. Type of Request:  Aoandon _  Suspend Z  Operation Shutdown X  Re-enter suspended well ~  Alter casing Z
 Time extension Z  Change approved program C  Plugging Z Stimulate ~ Pull tubing  Z Amend order I Perforate  ~ Other I
 2. Name of Operator
     ARCO Alaska, Inc.
                                                                   5. Datum elevation (OF or KB)
                                                                   68'  RK8                  feet
 3. Address
     P. 0.  Box  100360  Anchorage. AK  99510
                                                                   6. Unit or Property name

                                                                   Kuo
                                                                        aru
4. Location of well at surface
    1561'FSL,  21'FWL, Sec. 28,  T13N, R9E, UM
  At top of productive interval
    1479'FSL,  920'FEL, Sec. 33,  T13N, R9E, UM  (approx.)

  At effective depth
    99g'FSL, 566'FEL, Sec. 33,  T13N, R9E,


   '          510'FEL, Sec. 33,  T13N, R9E, UM  {approx. )
                                                                    7. Well number
                                                                    3N-18
                                                                    8. Permit number
                                                                    86-93
                                             UM  (approx.)
                                     9. API number
                                      50—029-21595
                                                                   10. Pool
                                                                    Kuparuk  River Oil  Pool
 11. Present well condition summary
    Total depth:      measured     10630
                   true vertical   5339
    Effective depth:


    Casing
     Conductor
     Surface

     Product!on
                  measured
                  true vertical

                       Length
                       80'
                       5107'

                       10599'
10517
6765
feet
feet

feet
feet
                                                  Plugs (measured)    None
                    Junk (measured)
None
      Size
      16"
      9-5/8'


      7"
    Cemented        Measured depth

    2*2  sx CS  I I         115'MO
    1500  sx  AS I I I  &    51*4 'MO
     ~ <-
Form 10-403 Rev 12-1-85
                                        ("••—o i
                                        \.  ^ o
                                                    Submit m tnpiicat

-------
            ATTACHMENT  C:
LETTER FROM STANDARD ALASKA PRODUCTION
               C-99

-------
n
 i

o
o

-------
       Standard Alatfca
       Production Company
       900 Eon Benson Boulevard
       PO Bo. 196612
       Anchorage. Alaska 99519-6612
       (907, 561-5111
                                                            STANDARD
                                                            ALASKA PRODUCTION
August 8, 1986
Ms. Suzan DeNagy
Industrial Technology Division
U.S. Environmental Protection  Agency
Waterside Mall
401 M Street SW
Washington  D.C.  20460
Dear Ms. DeNagy:

As you  requested,  Standard's  decision requiring that the  drilling  mud pit at
Standard's Prudhoe Bay Unit F Pad  not be sampled on  August  2nd  is  documented
herein.  During  August  1st and  2nd the drilling  rig was recovering  damaged
casing, a dual string of pipe, and  cutting the pipe with  an  open  flame as it
was retrieved on the  rig  floor,   "his operation made it unsafe  for personnel
to be on site sampling  the drilling mud pit.   Since safety  of  all personnel
entering our operating area  is a primary concern of  Standard, we  appreciated
your  cooperation   in  selecting  another  available  site  that   met  your
criteria.

I  hope  this documentation is sufficient  for  your  records.   Please  let  me
know if further information is necessary.
   P. Lucid'o
Manager Environment/Regihia^ory  Affairs
JPL:LMB/6284V
cc:  L. Billington, SAPC
     T. Rockwell, EPA-Anchorage
     J. Collins,  Ar co-Da lias
     A. Ahnell, Standard
                       O" Co^po™*
                      « I87C        p_ 101

-------
C-102

-------
     ATTACHMENT D:
LETTER FROM ARCO ALASKA
       C-103

-------
C-104

-------
ARCO Alaska, Inc.
     Post Office Box 100360
     Anchorage, Alaska 99510-0360
     Telephone 907 276 1215
August 4, 1986
Ms. Suzan DeNagy
Industrial Technology Division
U.S. Environmental Protection Agency
Waterside Mall
401  M  Stret SW
Wasington, DC 20*60

Dear Ms. DeNagy:

As  you requested,  I  am  documenting  ARCO's decison that sampling  the
drilling mud pit at ARCO's Prudhoe Bay  Unit Drill Site 11 would not be safe
on Sunday, August 3, 1986 because the drilling rig adjacent to the pit testing
area was  rigging down and moving that day.  It was also  stated by  ARCO
representatives that the pit could be tested Monday, August 
-------
C-106

-------
                         Sampling Report
             Investigation of Marathon Oil Company 's
                 Trading Bay Production Facility
                        Cook  Inlet,  Alaska
                          August 7,  1986
SITE INFORMATION

Site Selection

EPA specifically selected the Trading Bay Production Facility to
obtain technical information and analytical data regarding the
practice of using centralized facilities to treat and dispose of
wastes from multiple oil and gas sources in Alaska.  The Agency
is interested in the developing information about the
constituents of the wastes, and about the effectiveness of the
treatment processes.  A more detailed discussion of the rationale
for selection of centralized treatment facilities is contained in
Appendix B of the EPA Technical Report (EPA 530-SW-87-005).

No problems were encountered arranging for sampling to be
conducted on August 7, 1986.

Site Location

Trading Bay Facility is located on the west coast of Cook Inlet,
across from the city of Kanai and south of Tyonek.  Figure 1 is a
map indicating the facility.

The site is operated by Marathon Oil Company, whose mailing
address and telephone number are:

             3201 C Street
             Anchorage, AK 99503
             907-564-6337
             Contact Name: Tom Brooks

Attendees

Sampling of Trading Bay Facility was performed by CENTEC
Corporation personnel on August 7,  1986.   The following is a list
of people present at the time of sampling:

    CENTEC Corp. (sample team):   Bruce Hoskins, Team Leader

    EPA Representative:           Susan de Nagy, Office of Water,
                                    Project Officer

    State Representative:         John Catlin, Environmental
                                    Scientist, Bureau of Land
                                    Management,  Anchorage
                                    District Office
                             C-107

-------
k •»
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Figure I.  Location of Trading Bay Facility, Cook
           Inlet, Alaska
                  0108

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    Operator Representatives:     Tony Swan, Production Foreman
                                  Keith Woods, No. 1 Operator
                                  Jack Shan, Operator

    American Petroleum
      Institute Representatives:  Tom Brooks, Contracted Observer
                                  Bob Zahray, Contracted Sample
                                    Team Member

Site Description

Trading Bay Facility is located in the Cook Inlet Basin in a
rural coastal area; the depth to groundwater is 25-50 feet, and
the nearest surface water is less than 1/2 mile away.  There are
three drinking water wells within a 1/4-mile radius of the site.
The climate at this site is net precipitation.

This site is a centralized treatment facility.  Figure 2 is a
schematic diagram of the facility.  The facility operates as a
continuous process as final treatment prior to discharge.  Annual
operation hours are 8760.  The facility accepts process fluids
(oil, gas, and water) from drilling rigs in Cook Inlet.  The
facility receives 97,000 bbl/day oil-water emulsion.  Seventy-
five thousand bbl/day water is discharged while 22,000 bbl/day
oil is recovered as well as 9-10 million SCF/day gas.  The
facility uses no system to account for all influent.

Unprocessed oil, gas, and water enter the facility and are passed
through a pig trap building.  Here the gas is separated and
proceeds to gas compressors and then to a liquid extraction
plant.  The oil and water proceed through a series of free water
knockout tanks and heater treaters.  The separated oil is placed
in storage tanks.  The water goes into one of three skim tanks.
Any solids removed are placed in another tank prior to being
incinerated.  The water flows into one of two retention pits
prior to discharge into Cook Inlet.  The facility is required to
test for oil and grease in the effluent every 3 hours.

The facility also operates a landfill onsite to hold all solid
waste from process operations including oil spills,  pig wax,  tank
bottoms, residue from the sludge incinerator,  and untreatable
emulsions.  This pit is shown in Figure 3.  The pit dimensions
are 100 ft x 80 ft.  The pit is 17.5 feet deep and is lined with
plastic.  Attachment C is the facility landfill waste deposit
record.  This record shows the dates on which waste was placed in
the landfill, along with amounts and waste sources,  from August
17, 1985 to August 1, 1936.   Attachment D is a report dated May,
1985 which details the dates of all tank cleaning and maintenance
since 1978.
                            C-109

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                    _[_
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                                                V .-sSEs^Cr
                                                                                            -5A/1PLE
                                                                                             LOCATION
                    Figure 2. -Schematic  Diagran, Trading Bav Facility

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n
i
                                                                                            SAM PLe
                     Figure  3.   Sampling  Locations in Facility Landfill

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Permits

The landfill operates under Permit No.  SG-26-77 issued by the
Alaska Dept. of Environmental Conservation.  A copy of this
permit is shown in Attachment B.   The facility operaton permit
was not available to the sample team at the time of sampling.


SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).The following
is a description of site-specific sampling information and
activities.

Sample Point Locations

The following samples were collected at the Trading Bay facility:

     Influent after oil separation
     Final effluent
     Landfill sludge
     Incinerated sludge
     Landfill supernatant
     Pig wax

The latter three samples were taken at the direction of the EPA
Project Officer.  Figure 2 shows the sampling locations
throughout the facility.  Figure 3 shows the sampling locations
within the landfill pit.

Sampling Methods and Equipment

The influent sample was collected from a sample valve in the pipe
prior to entering Skim Tank 2, as shown in Photos 1 and 2.  The
sample bottles were filled directly from the valve at the
direction of the EPA Project Officer.  The effluent sample was
collected at a pumping station between the water retention pits
and the discharge point.  The bottles were filled directly from a
sampling line.  Photos 3 and 4 show the sampling of the landfill
pit.  The pit had no discrete liquid surface.  There were a few
very shallow liquid pools from which the supernatant sample was
collected.  The supernatant was collected with a glass cup.  Four
quadrants were established for sludge sampling of the landfill.
The sample was collected using the Teflon lined coring tube and a
stainless steel spoon.  The incinerated sludge sample was
collected at Building 18, as shown in Photos 5 and 6.  The sample
bottles were filled directly from a valve.  Photos 7 and 8 show
sampling of the pig wax.  The wax from the pig trap building was
placed in metal drums and stored by the pig cooker next to Skim
Tank 1.
                             C-112

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The influent and final effluent were tested onsite for pH and
free chlorine content after the completion of sampling.  For both
influent and effluent, pH value was 6 and free chlorine was less
than the lowest detectable level of 0.2 ppm.

Sample shipment required 2 days in travel time from the site to
the laboratories.
                            C-113

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C-1 14

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-1 15

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C-116

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^    Photo t.  Skim tank f2, Influent sample  collection point
'•".<**->'- '.'r'^*' . V>: '  "" *-•*' " ••""",' •  •  ~
~—^-^ ^.~u_/. .•«. .«* J?*.-_i.>*^,; . — -*-••'  's _1- •  r-


 Photo 3.  Sample collection In landfill
                                                                   \ mm. •.  • "T •
                                                               A  \m- - - n
                                                    ^,  '..:V«i"^-/'i
                                                    Photo 2.  Influent  sample collection point
                                                Photo 4.  Sample collection In landfill

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   Photo 5.  BuiIdlng 18
or
         •:V:.:--f ^^^^mmim^m^ ••<
         • i//is^lmit^^K
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                    _ \j_' —' '^ ^ ,-,...-.».>-«» ^... *•-*
    o. - J. . T  01-
                                          Photo 6.  Building IB, sludge collection point

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ATTACHMENT B:  PERMITS
       C-119

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C-120

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                                 STATE OF ALASKA
                    DEPARTMENT OF ENVIRONMENTAL CONSERVATION
                                     POUCH O
                              JUNEAU,  ALASKA  99811
                              WASTE DISPOSAL PERMIT
                         (SOLID WASTE MANAGEMENT PERMIT)
Permit No.     SC-26-77                                Date    "OV 2 9 1977
This Waste Disposal Permit is issued to  Marathon Oil Company,  3201 - C Street,

 Anchorage, Alaska  99503 for the construction,  operation and maintenance of

 an oil'y waste disposal facility to be
located in the NW 1/4, Sec. 6, T8N, R14W,  Seward Meridian,  Trading Bay,

 Alaska.

and is subject to the conditions and stipulations in sections A.I through
D.9, of this permit and the applicable State laws and regulations.

This permit is issued under provisions of Alaska Statutes,  AS 46.03.100-110,
Water, Air, and Environmental Conservation, Alaska Administrative Code as
amended or revised, and other applicable State laws and regulations.

This permit is effective upon issuance and expires _ December 31, 1980
it may be terminated or modified in accordance with AS 46.03.120.


This permit is not valid until signed by the Commissioner of the Department
of Environmental Conservation.
                                                      ner
                                                      t of Environmental Conservation
                                     C-121

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 to

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     ATTACHMENT C:
LANDFILL DEPOSIT RECORD
        C-123

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C-124

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                               TBPF LANDFILL
                          OILY WASTE DEPOSIT RECORD
 CELL NO.
  OILY WASTE
DEPOSITED CYD3}
 DATE
BLENDED
   c,
  DATE
O>!PACTED
LAYER THICKNESS
SOURCE
   le
    I*
    t,
   Is
                  //-*-*r
    (c
TES:am
                                      C-125

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                                TBPF LANDFILL
                          OILY WASTE DEPOSIT RECORD
 CELT, NO.
  OILY WASTE
DEPOSITED (YD3-)
 DATE
BLENDED
  DATE
OT4PACTED
  APPROXIMATE
LAYER THICKNESS
SOURCE
    c
      1 yo
                                                                          SAlt
    b
                                                                        df» '•
TES:a;n
                                       C-126

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            ATTACHMENT D:
TANK CLEANING AND MAINTENANCE SCHEDULE
               0127

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C-128

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                           MARATHON  OIL  COMPANY

                                      ENGINEERING DEPARTMENT
    SUBJECT-
                                                                 DATE_



                                                                 BY	
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                                             A. S
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                         Sampling Report
              Investigation of Union Oil Company's
              Kenai Gas Field Production Site 41-7
                          Kenai,  Alaska
                         August 8, 1986


SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix 3 of the EPA Technical
Report  (EPA 530-SW-87-005).  The gas field was selected randomly
from a  list of Kenai Peninsula, Cook Inlet Basin production
fields  developed by the Anchorage District Bureau of Land
Management at the request of EPA.  The list was transmitted via
telephone to the EPA contractor on July 22, 1986.  Field
selection from this list took place during the telephone
conversation.  A random number table was used to select the Kenai
Gas Field for sampling to be conducted August 8, 1986.

On August 8, Union Oil Company, in the presence of EPA, the
Anchorage District Bureau of Land Management Office, and the EPA
contractor, developed a list of Kenai Gas Field production sites
for random selection of the specific site to be sampled.
Possible sample sites were listed as shown below.  The EPA
contractor had no interest in the manner the particular sites
were listed (by site name,  location,  operator, permit number, API
number, etc.) as long as the site could be identified in detail
upon selection.   Thus, the EPA contractor had minimal information
which kept to a minimum the amount of bias.  No other information
was known about the sites on the list at the time of selection.
Detailed information was obtained only after selection of primary
and back-up sites.  The list consisted of 6 Cook Inlet Basin -
Kenai Gas Field production sites:

        1.  Site 33-30
        2.  Site 43-32
        3.  Site 34-31
       4.  Site 14-6
        5.  Site 41-18
        6.  Site 41-7

As indicated above,  the EPA contractor assigned numbers to the
members of the list as they were transmitted.   A random number
table was used to select the primary and back-up sample sites.
No. 6 on the above list (Site 41-7)  was selected as the primary
sample site.  No. 1  on the above list (Site 33-30)  was selected
as a back-up site should sampling at the primary site prove
inaccessible or inappropriate.

No problems were encountered in arranging sampling  of Site 41-7
on August 8, 1986.  The back-up site was not required.
                             C-133

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Site Location

Kenai Gas Field Production Site 41-7 is located 10 miles south of
Kenai, along Kasilof Road.  Figure 1 is a map locating the
production site.

The site is operated by Union Oil Company of California, whose
mailing address and telephone number are:

               PO Box 190247
               Anchorage, AK 99519-0247
               907-276-7600
               Contact Name: Roy Roberts

Attendees

Sampling of Kenai Gas Field Site 41-7 was performed by CENTEC
Corporation personnel on August 8, 1986.  The following is a list
of people present at the time of sampling:
    CENTEC Corp. (sample team):

    EPA Representative:


    State Representative:
    Operator Representative:

    American Petroleum
      Institute Representatives:
Site Description
Bruce Hoskins, Team Leader

Susan de Nagy, Office of Water,
  Project Officer

John Catlin, Environmental
  Scientist, Bureau of Land
  Management, Anchorage
  District Office

Bob Smith, Production Foreman
Tom Brooks, Marathon Oil
Bob Zahray, Contracted Sample
  Team Member
Kenai Gas Field is located in a. rural coastal area; the depth to
groundwater is 30 feet and the nearest surface water is less than
1/2 mile away.  There is one drinking water well within a 1/4-
mile radius of this site.  The climate at this site location is
net precipitation.

This site consists of actively producing gas wells with an
average total production of 172 mmcf/day.  Production at Site
41-7 on the day of sampling was 117 mmcf.  Water production at
this site is 9 bbl/day.  Production at this site is sweet.  There
are 18 active gas wells at Site 41-7.  The average well depth is
4,500 feet.  The site is producing using natural drive.  Figure 2
is a schematic diagram of the production facility.  The facility
collects the wastewater from the gas field and has its own water
                             C-134

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     GULF  OF  ALASKA

           PROJECT LOCATION MAP
                                    ITE ci:u-i
CANNERY LOOP UNIT
   KENAI GAS FIELD
                                 S1TE"33-30
                                         SITE 43-32
                                  SITE 14-6
                                            SITE LOCATION
                                     • SITE 41-18
   Figure  1.  Location of  Kenai Gas Field  Production
             Site #41-7,  Kenai, Alaska
                           C-135

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TYPICAL SITEFLOW PAGAM
                                                                          '  \i" GAS

                                                         i  3" WASTE V.'AlfR   |//
                                                                          pun
                                                                          LiiiiJ
           I	



PROCESS FACILITIES O SITE  34-31
                                                           KENAI GAS  Flf:LO

                                                                                           	J
                                                           Figure  2.   Kenai Gas Field  Waste Water
                                                                       Gathering System Flow Diagram

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separation system.  The typical site flow diagram in Figure 2
illustrates the system used at Site 41-7.  Triethylene glycol is
used for separation.  No waste glycol is generated,  since it is
filtered and recycled.

Disposal Practices

The water is sent to a central battery where it is combined with
produced water from the Beaver Creek gas field.  The water is
disposed by reinjection.  Included in Attachment C are monthly
injection well monitoring reports for January-July,  1986.  In
this period, a total of 2,144,436 gallons of water were injected.
February had the largest injection volume of 517,272 gallons,
while May had the lowest volume at 165,396 gallons.

Permits

The facility has been reinjecting water under UIC Permit No. AK-
2D0217-E and Alaska Dept. of Environmental Conservation Permit
No. 8423-DB015.  Copies of these permits are shown in Attachment
B.  The UIC permit requires the monitoring of total dissolved
solids, suspended solids, and pH at no greater than 1-year
intervals.  The AK DEC permit requires in addition the monitoring
of sodium, potassium, magnesium, iron, calcium, chloride,
carbonate, bicarbonate, and sulfate on an annual basis.  There
are no other produced wastes unless a spill occurs.   The facility
is currently storing a maximum of 200 cubic yards of spilled oily
waste.
SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).The following
is a description of site-specific sampling information and
activities.

Sample Point Locations

The sample collected at Kenai Gas Field Site 41-7 consisted of
one liquid sample.  The sample collection point was at a valve at
the bottom of the free water knockout tank.

Sampling Methods and Equipment

The liquid sample was collected at the base of the free water
knockout tank.  At the direction of the EPA Project Officer, the
sample bottles were filled directly from a valve at the base of
the tank.
                             C-137

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The liquid sample was tested onsite for pH and free chlorine
content at the completion of sampling.   The value of pH was 6.
The free chlorine content was less than the lowest detectable
level of 0.2 ppm.

The samples were shipped the day of collection.   Two days of
travel time were required from shipment point to laboratory
receipt.
                             C-138

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
               C-139

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C-140

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No photodocumentation specific to the
 operation of this  site  is available.
              C-141

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C-142

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ATTACHMENT B:  PERMITS
       0143

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C-144

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                :N\NRON,
 U.S.  ENVIRONMENTAL  PROTECTION* AGENCY

                      REGION  X                          " A- Gn-'N

                  1200 SIXTH  AVEN U E                      ' . |

i              SEATTLE, WASHINGTON  98101

                     OCT  b
 REPIYTO   M/c ..,,                                                        OCT 10198?
 ATTN OF:   M/S 437                                                                iJOJ

                                                                    C.JV;.. LOCKWQOI
Gerry A. Graham
District Operations  Manager
Union Oil Company of California
P.O. Box 6247
Anchorage, Alaska 99502

RE:  Kenai Gas Field Class II Emergency Underground Injection Control
     (UIC) Permit

Dear Mr. Graham:

     Enclosed is  the emergency UIC permit for injection well  KU  WD-1 .  This
permit is issued  in  accordance with 40 CFR 144.34.   The permit is based on
Union's permit application of June 24, 1985, as supplemented  and modified
August 12, 1985.

     The emergency permit will remain in effect until  either  final  EPA
action is taken on the permit application, the state of Alaska is granted
primary responsibility for the UIC program and has  taken final action on the
state permit application, or the permits have been  otherwise  modified,
revoked and reissued, or terminated in accordance with 40 CFR 144.39-144.41.

                                       Sincerely,
                                       Rbbert S.  Burd
                                       Director,  Water Division
Enclosure

cc:   C.  V.  Chatterton, AOGCC
     Bill  Lamoreaux, ADEC
                                                  DECEIVED

                                                  OCT 0 9 1985
                                 C-145

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                                                  Permit No.  AK-2D0217-E
                      AUTHORIZATION TO INJECT UNDER THE

                    UNDERGROUND INJECTION CONTROL PROGRAM


In compliance with the provisions  of  the  Safe  Drinking  Water  Act,  as  amended
(42 U.S.C.  300f et seq).


                       Union Oil Company of California
                              Anchorage, Alaska


is authorized to inject  into the Sterling Formation  through  injection well
Number KU WD-1  at the  Alaska Kenai  Gas  Field  (location  of  well:  Section 31,
T.5N, R.11W,  Section 31,  1/4 Section  SE,  606  feet  from  south  line  and 2297
feet from east line),  in  accordance with  conditions  set forth herein.

This permit shall become  effective  on October  3,  1985.



Signed this   3rd     of     October  1985.
                                   Robert  S.  Burd
                                   Director,  Water  Division
                                   Environmental Protection Agency
                                   Region  10
                               0146

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                 r
                                                       Permit No.  AK-2D0217-E
                                                       Page 2 of 12
                                TABLE OF CONTENTS
Cover Sheet - Issuance Date and Signature Page
     A.   Effect of Permit                                           3
     B.   Construction, Operating and Monitoring Requirements         3
     C.   Reporting and Record Keeping Requirements                   4
     D.   Plugging and Abandonment                                   6
     E.   Financial  Responsibility                                   7
     F.   Mechanical  Integrity                                       7
     G.   General  Requirements                                       8
          1.   Duty to Comply                                         8
          2.   Duty to Provide Information                            8
          3.   Need  to Halt  or Reduce  Not  a  Defense                   8
          4.   Signatory Requirements                                 8
          5.   Proper  Operation  and Maintenance                       9
          6.   Duty  to Mitigate                                       9
          7.   Inspection  and  Entry                                   9
          8.   Prohibition of  Injection of Hazardous Waste           10
          9.   Penalties                                             10
         10.   Permit  Actions                                        10
         11.   Transfers                                             10
         12.   Confidentiality of  Information                        11
         13.   State Laws                                            1 ]
         14.   Property  Rights                                       11
         15.   Severability                                          11
    Attachment 1  -  Plugging and Abandonment Plan                 12
                              C-147

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                 c                                c
                                                       Permit No.  AK-2D0217-E
                                                       Page 3 of 12
A.   EFFECT OF PERMIT
     The permittee is authorized to engage in underground injection in
     accordance with the conditions of this permit.   The underground injection
     shall not allow the movement of fluids into or  between  underground
     sources of drinking water.   Compliance with the terms of this permit does
     not constitute a defense to any action brought  under Section 1431  of the
     Safe Drinking Water Act or  any other law governing protection of public
     health or the environment for any imminent  and  substantial  endangerment
     to human health, or the environment.

     This permit is an emergency permit as provided  for in 40 CFR 144.34. The
     permit shall  be effective until  final  action is taken on the permit
     application or the permit is otherwise modified,  revoked and reissued,  or
     terminated in accordance with Section G.10.  of  this permit.

     This permit is based on the permit application  dated June  12,  1985, and
     supplemental  information dated August 12, 1985.   The permit  application
     requests an emergency permit for  an  existing Class  II produced water well
     operated by the Union Oil Company of  California at  its  Kenai  Gas  Field.
     Any underground injection which  violates  any authorization by permit is
     subject to appropriate enforcement action.

B.    CONSTRUCTION.  OPERATING AND MONITORING REQUIREMENTS

     1.    Construction Requirements

          a.    The  permittee shall  case  and  cement the well  to prevent  the
               movement of fluids  into or  between  underground sources of
               drinking water.

          b.    The  casing and cement used  in  the  construction of  the well
               shall  be designed  for the  life expectancy of  the well.

          c.    Casing and cement  shall  be  placed  in  accordance with general
               construction  details as  shown  in Attachment M of the permit
               application.

          d.    Tubing and packer  shall  be  located at 2,150 feet.  A revised
               Attachment M  shall  be submitted to the Regional Administrator
               no  later than  November  15,  1985.

          e.    Injection  interval  shall be between 3,030-3,250 feet.

     2.    Operating  Requirements

          a.    The maximum  injection pressure, measured  at the wellhead,  shall
               not exceed  900 pounds per square inch absolute (psia).

          b.    The maximum  injection pressure may be increased to 1,500  psia
               once  the  Regional  Administrator approves  the permittee's
               demonstration  that  the  increased pressure will not fracture the
               confining  zone (2,820-2,915 feet).
                              C-14f

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                 r                                c
                                                       Permit No. AK-2D0217-E
                                                       Page 4 of 12


          c.   The Regional Administrator will notify the permittee of the
               acceptability of the demonstration within 15 days of receipt of
               the data.  If the Regional Administrator does not respond
               within 15 days, injection at 1,500 psia may commence.

     3.   Monitoring Requirements

          a.   Observation and recording of injection pressure, injection
               rate, cumulative volume and annulus pressure shall be made at
               intervals no greater than seven (7) days, beginning on the
               effective date of this permit.

          b.   Monitoring of the injected fluid shall be made at intervals no
               greater than 12 months, beginning on the effective date of this
               permit.  The following tests shall be conducted:

               (i)   Total dissolved solids

               (ii)  pH

               (iii) Suspended solids

          c.   Samples and measurements taken  for the purpose of monitoring
               shall be representative of the  monitored activity.

          d.   Monitoring must be conducted according to test procedures
               approved under 40 CFR 136.3, unless otherwise approved by  the
               Regional  Administrator.

C.   REPORTING AND RECORD KEEPING REQUIREMENTS

     All  reporting and notification required by this permit shall  be signed
     and  certified in accordance with the requirements  of Section G.4.,  and
     submitted to the Regional  Administrator at the following address:

               United States  Environmental  Protection Agency
               Region 10
               Attn:   Mail  Stop 409
               1200 Sixth Avenue
               Seattle,  Washington   98101

     A  copy  of all  reports shall  be submitted  to the State  at the  following
     address:

               Alaska Oil  and  Gas Conservation Commission
               3001  Porcupine  Drive
               Anchorage,  Alaska 99501

     1.    Monitoring results,  as  specified  in  Section B.  3.,  shall  be  reported
          each month  on  EPA  Form 7520-8.   Reports  shall  be  postmarked  by  the
          20th day  of the  month following  the  reporting  period.

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            c                               c
                                                  Permit No. AK-2D0217-E
                                                  Page 5 of 12
2.   Monitoring results as specified in 40 CFR 146.23(b) for the period
     June 25, 1985, through September 30, 1985, shall  be reported on EPA
     Form 7520-8 no later than October 20, 1985.

3.   The permittee shall  retain records of all monitoring information,
     including the following:

     a.   Original strip  chart recordings for continuous monitoring
          instrumentation, copies of all  reports  required by this permit,
          and records of  the data or methods used to complete the
          application for this permit, for a period of at least 3 years
          from the date of the sample, measurement, report,  or
          application. This period may be extended by the Regional
          Administrator at any time; and

     b.   The nature and  composition of all  injected fluids  until 3 years
          after the completion of any plugging and abandonment procedures
          specified by this permit.  The  permittee shall continue to
          retain the records after the 3  year retention period unless he
          delivers the records to the Regional Administrator or obtains
          written approval from the Regional  Administrator to discard the
          records.

     c.   Records of monitoring information  shall  include:

          (i)   The date, exact place, and time of sampling  or
                measurements;

          (ii>  The name(s) of the individual(s)  who performed the
                sampling  or measurements;

          (iii)  The date(s) analyses were performed;

          (iv)  The name(s) of the indi vidua.l (s)  who performed the
                analyses;

          (v)   The analytical  techniques or methods used;  and

          (vi)  The results of such analyses.

     d.   Dates  of most recent calibration or maintenance of gauges and
          meters used for monitoring required by  this  permit shall be
          noted  on the gauge or meter.

4.   The permittee shall  give  notice to the  Regional Administrator as
     soon as possible of  any planned physical  alterations or additions to
     the permitted facility which may cause  the movement of  fluids into
     an underground source of  drinking water.

5.   The permittee shall  give  advance notice  to the Regional
     Administrator of any planned changes in  the  permitted facility or
     activity which may result in noncompliance with permit  requirements.
                          0150

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                  r                                c
                                                        Permit  No. AK-2D0217-E
                                                        Page 6  of  12
      6.    The  permittee  shall report any noncompliance which may endanger
           human  health or  the environment,  including;

           a.   Any monitoring or other  information which indicates that  any
               contaminant may cause an endangerment to an underground source
               of drinking water; or

           b.   Any noncompliance with a permit condition or malfunction  of the
               injection system which may cause fluid migration into or
               between underground sources of drinking water.

           Any  information shall be provided orally (Phone number:
           (206)  442-1846 or (206) 442-1225) within 24 hours from the time the
           permittee becomes aware of the circumstances.  A written report
           shall  also be provided within 5 days of the time the permittee
           becomes aware of the circumstances.  The written report shall
           contain a description of the noncompliance and its cause, the  period
           of noncompliance, including exact dates and times, and if the
           noncompliance has not been corrected,  the anticipated time it  is
           expected to continue; and steps taken  or planned to reduce,
           eliminate, and prevent recurrence of the noncompliance.

     7.    The  permittee shall  report all instances of noncompliance not
           reported under paragraph 5.  of this section,  at the time monitoring
           reports are submitted.   The reports shall  contain the information
           listed in paragraph 5.  of this section.

     8.   Where  the permittee becomes  aware that it failed  to submit  any
          relevant facts in a permit application,  or submitted  incorrect
           information in a permit application or in any report  to  the Regional
          Administrator, it shall  promptly  submit  such  facts  or information.

     9.   The permittee shall  notify the Regional, Administrator upon
          completion of conversion or  construction of the  well, and prior to
          commencing injection.

    10.   The permittee shall  notify the Regional  Administrator no  later  than
          30 days after conversion of  the well to  other than  an injection well.

D.   PLUGGING AND ABANDONMENT

     1.   Plugging and  abandonment shall  be  conducted in accordance with
          Attachment 1  of this  permit,  unless  an alternative  method of
          pl.ugging and  abandonment is  approved in  advance by  the Regional
          Administrator.

     2.   Plugging and  abandonment shall be  conducted such  that movement  of
          fluids  will not be allowed  into an  underground source of  drinking
          water nor  will  one underground source of drinking water be  allowed
          to move into  another.

     3.   The permittee  shall notify the Regional  Administrator 30  days prior
          to the  plugging and abandonment of  the well.
                               C-151

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                 c                               C
                                                       Permit No.  AK-2D0217-E
                                                       Page  7 of 12


     4.   Within 60 days after plugging the  well,  the  permittee shall  submit a
          report to the Regional  Administrator which shall  consist of either:

          a.   A statement that the  well  was plugged in accordance with
               Attachment 1  of this  permit;  or

          b.   Where actual  plugging differed from Attachment 1  of this
               permit,  an updated version of the  plan,  on  the form supplied by
               the Regional  Administrator,  specifying  the  different procedures
               used.

          The report shall  be  certified as  accurate by  the  person  who
          performed the plugging  operation.

E.    FINANCIAL RESPONSIBILITY

     The permittee shall  maintain financial  responsibility  and resources  to
     close,  plug,  and abandon  the well.   The Regional Administrator may
     require the permittee to  submit a  revised demonstration  of financial
     responsibility if  the Regional  Administrator  has reason  to believe that
     the original  demonstration is no longer adequate to cover the cost of
     closing, plugging  and abandoning the well.

F.   MECHANICAL INTEGRITY

     1.  Standards

          The injection well must have  and maintain mechanical  integrity
          pursuant to 40 CFR 146.8.

     2.  Prohibition Without Demonstration

          Injection operations  are prohibited 45 days after  the  effective  date
          of this  permit unless the  permittee has,  submitted  data to detect
          leaks  in the  casing,  tubing,  or packer.   The  casing-tubing annulus
          must be  completely filled  with  a corrosion inhibited liquid  and
          pressure tested to 1,500 pounds per square inch absolute (psia)  for
          thirty minutes.   Pressure  loss  may not exceed  150  psia at the end of
          the thirty minute  test.

     3.   Terms  and Reporting

          a.    Mechanical  integrity  tests identified in  F.2.  shall  be
               submitted  within 45 days of the  effective date  of this  permit.

          b.    Mechanical  integrity  shall also  be  demonstrated by  the  pressure
               test in  F.2.  any time  the  tubing is  removed from  the well,  or
               if  a loss  of  mechanical  integrity becomes evident during
               operation.   The  permittee  shall  report the results  of such
               tests within  45  days  of  completion  of the tests.

          c.    The permittee shall notify the  Regional  Administrator of his
               intent  to  demonstrate  mechanical integrity at  least 30  days, or
               as  soon  as  possible,  prior to such  demonstration.
                               C-152

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                 c                               c
                                                       Permit No.  AK-2D0217-E
                                                       Page  8 of 12
          d..   The Regional  Administrator will  notify the  permittee  of the
               acceptability of the mechanical  integrity demonstration within
               15 days of receipt of the  results  of the  mechanical  integrity
               tests.   If the Regional  Administrator does  not  respond within
               15 days, injection may continue.

G.    GENERAL REQUIREMENTS

     1 .    Duty to Comply

          The  permittee must comply with  all  conditions  of this  permit.   Any
          permit noncompliance  constitutes  a  violation of  the  Safe Drinking
          Water Act  and is grounds  for  enforcement  action;  for permit
          termination,  revocation and reissuance, or modification; or for
          denial  of  a  permit renewal  application.

     2.    Duty to Provide  Information

          a.    The permittee shall  furnish  to the Regional  Administrator,
               within  a time specified, any information  which  the Regional
               Administrator may  request  to determine whether  cause  exists  for
               modifying,  revoking  and  reissuing, or terminating this  permit,
               or to determine  compliance with this  permit.  The permittee
               shall also  furnish to  the  Regional Administrator, upon  request,
               copies of records  required to be kept by  this permit.

          b.    When  the permittee becomes aware that it  failed to submit  any
               relevant facts in  a  permit application, or  submitted  incorrect
               information in a permit  application or any report to  the
               Regional  Administrator,  it shall promptly submit such  facts  or
               i nformation.

     3.    Need  to Halt  or Reduce  Not  a  Defense

          It shall not  be a  defense for a permittee  in an enforcement  action
          that  it would  have been necessary to halt  or reduce  the permitted
          activity in order  to maintain compliance with  the conditions of this
          permit.

     4.    Signatory  Requirements

          a.   All permit applications, reports required by this  permit and
              other information  requested by the Regional  Administrator  shall
              be  signed by a principal executive officer of at least  the
              level  of vice-president, or by a duly authorized representative
              of that person.  A person is a duly authorized representative
              only  if:

              (i)   The authorization  is  made in writing by a  principal
                    executive of at  least the level of vice-president.

              (ii)  The authorization specifies  either an  individual or a
                    position having responsibility  for the overall  operation
                    of the regulated facility or activity, such  as  the
                              C-153

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            c                               C
                                                  Permit No. AK-2D0217-E
                                                  Page 9 of 12


                position of plant manager, operator of a well  or a well
                field, superintendent, or position of equivalent
                responsibility.  A duly authorized representative may
                thus be either a named individual or any individual
                occupying a named position.

          (iii) The written authorization is submitted to the  Regional
                Admini strator.

     b.   If an authorization under paragraph a. of this section is no
          longer accurate because a different individual or position has
          responsibility for the overall  operation of the facility, a new
          authorization satisfying the requirements of paragraph a. of
          this section must be  submitted  to the Regional Administrator
          prior to or together  with any reports, information or
          applications to be signed by an authorized representative.

     c.   Any person signing a  document under paragraph a.  of  this
          section shall make the following certification:

                "I certify under the penalty of law that I  have
                personally examined and am familiar with the information
                submitted in this document and all  attachments and that,
                based on my inquiry of those individuals immediately
                responsible for obtaining the information,  I believe that
                the information is true,  accurate,  and complete.  I am
                aware that there are significant penalties  for submitting
                false information, including the possibility of fine and
                impri sonment."

5.   Proper Operation and Maintenance

     The permittee shall  at all  times properly operate and  maintain all
     facilities and systems of  treatment  and control  (and related
     appurtenances) which are installed or used by the permittee to
     achieve compliance with the conditions of this permit.  Proper
     operation and maintenance  include effective performance,  adequate
     funding, adequate operator staffing  and training, and  adequate
     laboratory and process controls, including appropriate  quality
     assurance procedures.   This provision requires the operation of
     back-up or auxiliary facilities or similar systems only when
     necessary to achieve compliance with the conditions of  the permit.

6.   Duty to Mitigate

     The permittee shall  take all  reasonable steps  to minimize or correct
     any adverse impact on  human health or the environment  resulting from
     noncompliance with this permit.

7.   Inspection and Entry

     The permittee shall  allow  the Regional  Administrator, or  an
     authorized representative,  at reasonable times,  upon the
     presentation of credentials and other documents  as may  be required
     by law to:
                          C-154

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            c                               c
                                                  Permit No.  AK-2D0217-E
                                                  Page 10 of 12


     a..  Enter upon the permittee's premises where a regulated facility
          or activity is located or conducted, or where records must be
          kept under the conditions of this permit.

     b.   Have access to and copy any records that must be kept under the
          conditions of this permit.

     c.   Inspect any facilities, equipment (including monitoring and
          control equipment), practices, or operations regulated or
          required under this permit.

     d.   Sample or monitor for the purposes of assuring permit
          compliance or as otherwise authorized by the Safe Drinking
          Water Act, any substances or parameters at any location.

8.   Prohibition of Injection of Hazardous Waste

     Injection of hazardous waste as defined in 40 CFR Part 261 is
     prohi bi ted.

9.   Penalties

     The Safe Drinking Water Act provides that any person who violates
     any requirement of an applicable underground injection control
     program is subject to a civil  penalty of not more than $5,000  for
     each day of violation, or, if such a violation is willful, such
     person may, in lieu of the civil penalty, be fined not more than
     $10,000 for each day of such violation.

10.   Permit Actions

     a.   This permit may be modified,  revoked and reissued,  or
          terminated in accordance with the provisions of 40  CFR 144.39 -
          144.41.

     b.   This permit will  be terminated when final  EPA action  has  been
          taken on the permit application, or when the State  of Alaska is
          granted primary enforcement responsibility for the  underground
          injection control program pursuant to the Safe Drinking Water
          Act, applicable to the injection activity regulated by this
          permit, and the State has taken final  action on the State
          permi t application.

     c.   The filing of a request by the permittee for a permit
          modification,  revocation .and  reissuance, or termination,  or a
          notification of planned changes or anticipated noncompllance,
          does not stay any permit  conditions.

11.   Transfers

     This permit is not transferable to any person except after notice to
     the Regional  Administrator on  EPA  Form 7520-7 and in accordance with
     40 CFR 144.38.  The Regional  Administrator  may require modification
     or revocation and reissuance of the permit  to change the name  of the
     permittee and incorporate  such other requirements as may be
     necessary under the Safe  Drinking  Water Act.

                          C-155

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                                              r
                                                  Permit  No.  AK-2D0217-E
                                                  Page  11  of  12
12.  Confidentiality of Information
     a.   In accordance with  40 CFR Part  2  (Public  Information),  any
          Information submitted to the  Regional  Administrator  pursuant to
          this permit may be  claimed as confidential.   Any  such  claim
          must be asserted at the  time  of submission  by stamping  the word
          "confidential" on each page containing such  information.   If no
          claim is made at the time of  submission,  EPA may  make  the
          information available to the  public  without  further  notice.  If
          a claim is  asserted, the information will be treated in
          accordance  with the procedures  in  40 CFR  Part 2  (Public
          Information).

     b.   Claims  of confidentiality for the  following  information will  be
          denied:

          (i)    The name and  address of any  permit  applicant or  permittee.

          (ii)  Information which  deals with the existence, absence, or
                level  of contaminants in  drinking water.

13.   State Laws

     Nothing in this  permit shall  be construed to preclude  the
     institution  of any legal  action or relieve  the permittee  from any
     responsibilities,  liabilities,  or  penalties  established pursuant to
     any applicable State law or regulation.

14.   Property  Rights

     This permit  does  not convey any property  rights of any sort, or any
     exclusive privileges,  nor does  it  authorize  any  injury to private
     property  or  any  invasion of personal rights, nor  any  infringement of
     Federal,  State,  or local  laws  or regulations.

15.   Severabi1i ty

     The provisions of  this permit  are  severable, and  if any provision of
     this permit, or  the application of any provision  of this  permit to
     any circumstance,  is held invalid, the application of  such provision
     to other  circumstances,  and the remainder of this  permit  shall  not
     be affected  thereby.
                          C-156

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   ATTACHMENT 1
                                                                          form
                                                                      Permit No. AK-2D0217-E
                                                                      Page  12  of 12
                                                                                    QMS Ha 2U40 OO4
                                               UNITED
   wEPA
                                                     TATES ENVIRONMENTAL PROTECTION AQENC\
                                                          WASHINGTON. OC 2046O
                            PLUGGING AND ABANDONMENT PLAN
   NAME AND ADDRESS OF FACIL.TY
     Kenai  Gas  Field,  Kalifonsky Beach Road
     near  Kenai, Alaska   •
                                                            NAME ANO AOORESS OF OWNER/OPERATOR
                                              Union Oil Company of  California
                                              P.O.  Box  6247,  909 W.  9th, Anchorage,  AK  99502
     LOCATE WELL ANO OUTLINE UNIT ON
     SECTION  PLAT — S4O ACRES
            I   T
            I	I
                       I   I    I
                            STATE
                             AK
                       COUNTY

                          Kenai Borouah
                                                PERMIT NUMBER
                                                   samole
                                         SURFACE LOCATION DESCRIPTION
                                           SW   '/.OF  SW    ViOF  SE
                                                                       v. SECTION
                                                                   31
                                                                                       TOWNSHIP
                                                                     5N
                                                                                                       aiNGE
                                                                   12W
                           LOCATE WELL IN TWO DIRECTIONS FROM NEAREST LINES OF QUARTER SECTION ANO DRILLING UNIT

                             sun-ace 605            S
                             Location —— ft. from IN/SI __
                                                                 . Una of quanar saction
                             ,n<,343
                                                            W
                                                 TYPE OF AUTHORIZATION
                            53 Individual Permit
                            Q Area Permit
                            QRul.

                            Number of Wells _1
                                         Lease Nam.  A-028055
                                                             WELL ACTIVITY

                                                  Q CLASS I
                                                  % CLASS II
                                                    £ Snne Disposal
                                                    C Enhanced Recovery
                                                    C Hydrocarfion Storage
                                                  C CLASS III
                                                                Well Number   KU VD-1
                 CASING ANO TUBING RECORD AFTER PLUGGING
    SIZE
    7"
             WTILB/FTl  TrOSEPUTlNWELLlFTl
                                     TOaELEFTINWELLlFTI
              47
29
               118
3276
                118
3276
                                                        HOLE SIZE
          Drive pipe
8/2
 METHOD OF EMPLACEMENT OF CEMENT PLUGS

G3 The Balance Method
Q The Dump Sailer Method
D The Two-Plug Method
D Other
         CEMENTING TO PLUG ANO ABANDON DATA
                                                 PLUG »^   I  PLUG »2  I  PLUG '3  I  PLUG '*  I  PLUG »S
                                                                                                  PLUG •
  Sue of Hot« or Ptpg m wntcn Plug Will fl« Ptactd oncnesi
                                                                            I
  Daoin to Bonom of Tubing or OnH P'o« tft)
                                                2980
                                            2980
     I of C«fn«m To 8« Us»o it ten plug)
                                     18
                                 50	I
  Slurry
            To 9e Pumo*d ./G»I I
                                    15.8
                                                           15.8
  Type Cam«nt or Otnar Ma tan at (Class HI)
                                  Class  G
                             :iass G  i
                   UST ALL OPEN HOLE ANO/OR PERFORATED INTERVALS AND INTERVALS WHERE CASING WILL as VARIED »/,»«»/
             From
                                          To
                                                                      From
                                                                                                    To
     iiad Cost 10 Plug Walls
        $250,000
                                                 CERTIFICATION
          / certify under the penalty of law that I have personally examined and am familiar with the information
          submitted in  this document and all attachments and that, based on my inquiry of those individuals
          immediately responsible for obtaining the information. I believe that the information is true, accurate.
          and complete. I am aware that there are significant penalties for submitting false information, including
          the possibility of fine and imprisonment. (Ref. 40 CFR  144.32)
 NAME ANO OFFICIAL TTTU lfl»itt run or primi
    Gerry A.  Graham
    District  Cceraticns Manaoer - Alaska
                                            SIGNATURE
                                                                           DATE SIGNED
EPA Form 7520-14 (3-84)
                                              C-157

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                            r                                c
                                                Unlon Q\\ Company
Union Oil Compan\ jf California

                                    In Reply Give
                                                   February 17, 1986
           TO:      J.  T.  Beitia
                   J.  R.  Callender
                   C.  H.  Case
           FROM:    Candy Lockwood
                                                   Permit Requirements
                                                   W.D. No. 1, Kenai Gas Field


           Attached for your information are the permit requirements for Kenai  Gas  Field,
           W.D.  No. 1.   Please ask your field personnel to provide the requested  data  to
           the Environmental Department for further handling with the agencies  involved.

           For those so inclined, I have attached a copy of the complete W.D. No. 1
           permit to answer any questions that may arise.  You will note that all
           up-to-date changes have been noted on the permit.  However, if you need
           further assistance please feel free to contact the Environmental Department.
           cwl
           cc:  G.A.  Graham
                R.D.  Roberts
                R.R.  Culver
                B.  Smith
                L.  Abeuiathy
                                          C-158
FORW 1.0C03 REV ».7I) niNTto'lN u.l.A.

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                                                  r
                                                                 00260
  •k                              STATE OF ALASKA
                ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION
                           WD#1  PERMIT NO. 8A23-DB015


 REPORTING REQUIREMENTS

 Report  due within  30 days  of sampling.

 1.   DRILLING  FLUIDS  - Test fluid from each new well and workover to be
 injected  down WD#1 for the following:

          Sodium  x              Carbonate "                     Arsenic ^
          Potassium '           Bicarbonate/                    Barium ^
          Magnesium /           pH  -                           Cadmium ^
          Iron —                Sulfate x                       Chromium -
          Calcium /             Total Dissolved SolidsX^       Cyanide'"
          Chloride  x             Lead


 2.   PRODUCED  WATER

 Representative Sample due  annually by January 31.)


     Sample must be tested  for the following:

          Sodium  x                     Carbonate ^
          Potassium ^                   Bicarbonate/
          Magnesium ^                   pH ^
          Iron   •'                       Sulfate'
          Calcium '                     Total Dissolved Solids x
          Chloride

Analysis must be performed in accordance with Standard Methods for  the
Examination of Water and Wastewater.


3.  INJECTION LOG -  (must be  available  for inspection  at site)

Report due annually, by January  31

Log  must contain:

    1.  Date-of receipt  and source  of waste received.
    2.  Volume from each  source.
    3.   Composition  of  the waste.
    4.   Type  of monitoring performed and  the results.
    5.   Date  of injection
    6.   Level of injection
    7.   Surface  pressures  at beginning  and end of  each  injection activity  or
         daily,  whichever occurs first.
    8.   Maintenance  activities
    9.   Record of  any unusual complications.
                               C-

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              •  r                               r
                               STATE OF ALASKA
                ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION
                          WD #1 PERMIT NO. 8A23-OB015   *
                             GENERAL REQUIREMENTS
    1.   Discharge shall be contained between  2710-3250 below surface  of the
         ground.

    2.   Discharge shall not exceed 5,000 barrels  per  day  (210,000 gal/day)
         and 150,000 barrels per year (6.3 million gal/year).

    3.   Maximum wellhead pressure is limited  to 1,100 psi.

    4.   Only produced waters,  drill fluids dilution water and equipment
         washwater associated with drilling and production activities  are
         approved for injection.
PERMIT EXPIRES JANUARY 1,  1990
                                C-160

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                          BUREAU OF LAND MANAGEMENT
                                 W.D.  NO.  1
                             PERMIT REQUIREMENTS
The following items must be reported  on  a  monthly  basis:
    1.   Volume of produced water,  drilling  fluid,  and  dilution water
         injected.
    2.   The range and average tubing and  casing pressures.
    3.   An analysis of pH, chlorides, and total solids from each well,
    4.   Temperature logs are  to  be run  within 30  days  of continuous
         injection, then after 6  months  and  then yearly.
                                C-161

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              •   r                               c
                     U.S. ENVIRONMENTAL PROTECTION AGENCY
                          KENAI GAS FIELD W.D.  NO.  1
                               PERMIT REQUIREMENTS	
1.  Surface injection pressure of 1,100 psi.
2.  Injection depth approved at 2710'.

REPORTING REQUIREMENTS

Due monthly
Form 7520-8 - Injection well monitoring report.  146.23  (b)(2)(i)

Due annually,
Annual report containing the following:
    Summary of 146.23 (b)(2)(i) to include  monthly  records  of  injected  fluids,
    and any major changes in characteristics  or  sources of  injected  fluid.
    May include previously submitted information by reference.
    Additionally, a demonstration of mechanical  integrity pursuant to 146.08
    at least once every five years during the life  of the injection  well.
cwl/00260
                                C-162

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                                     STATE OF ALASKA
                         DEPARTMENT OF ENVIRONMENTAL CONSERVATION
                               SOUTHCENTRAL REGIONAL OFFICE
                                437 "E" Street, Suite 200
                                 ANCHORAGE,  ALASKA  99501

                                    Mr. Larry Cutting
                             Union Oil Company of  California
                                      P.O.  Box 6247
                                 Anchorage,  Alaska  99502
     PERMIT NO.  8423-DB015                  DATE  ISSUED:   June 7,  1985
     This permit is  issued  to Union Oil Company  of California  for the injection of
/    a. maximum  of  5,000 barrels/day   (210,000  gal/day)  and   150,000  barrels/year
/V   (6.3 million gal/year)  of  wastewater  associated with the production  of natural
     gas located at Waste Disposal Well #1, Kenai Gas Field, off the Kalifonsky Beach
     Road,  606'N and  2297'W  of  S.E.  Cor.,  Sec.   31,  T5N,  R11W,  Seward  Meridian.

     This permit  is subject  to the conditions  contained  in Appendices A  and B,  which
     are incorporated herein by reference.

     This permit  is  issued  under  provisions  of Alaska Statutes  46.03, the  Alaska
     Administrative Code  as  amended or  revised, and other applicable State laws  and
     regulations.

     This permit  is effective on  issuance  and expires January 1,  1990.  This permit
     may be modified  or terminated before that time should the classification of  the
     waste  change.   It  may be terminated or modified in  accordance  with AS  46.03.120.
                                          Bill H/Tjamoreaux
                                          Regional Supervisor
                                     C-163

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PERMIT NO. 8423-DB015                                           Page 1 of 4




                             APPENDIX  A

SPECIFIC CONDITIONS

  A.  Application Compliance

      The Permittee shall comply with all parts of their permit application
      dated November 30,  1984, except as specified otherwise in this permit.
      Additional modifications may be requested,  but must  be authorized by
      a permit amendment signed by the Regional Supervisor to be effective.

  B.  Site Operation
                                                   --' " -  - 3 ~*3 C
      1.  The discharge shall be  contained  between 3030•'-  3250—feet below
          the surface of  the ground, unless authorized by a permit modifica-
          tion issued by the Regional  Supervisor of the Alaska  Department
          of Environmental Conservation.

      2.  The discharge  shall  not exceed 5,000 barrels per day  (210,000
          gal/day) and  150,000  barrels  per year(6.3  million   gal/year).
                     i  i    *-/    r>
                     '**U^J »I.A n. .*
      3.   The maximum pressure -at—the—reservoirs is limited to 1,500 psi.

      4.   The  discharge shall  b^limited  to  those wastes directly related
          to drilling • activities7u""'"1This -includes, produced water.;  drill
          fluids and  dilution  water." '^Ofher—\vastej—-including—equipment
         washwater—is~not-authorized"~tar*be -discharged.

      5.  The injection of hazardous waste is prohibited.  Hazardous wastes
         are defined according to Title 40,  Part 261 of the Code of Federal
         Regulations.

      6.  Should the monitoring required in Section C of  this  permit indicate
         leaks in the casing, or the waste entering areas other than what is
         authorized by this permit,  the  permittee  shall  cease  injection
         ijmmediately and take  the necessary remedial  steps to  step this
         violation.   Injection will  not begin until adequate  repairs are
         complete and  the  Department   authorizes  start-up  in   writing.

     7.   The waste shall be collected and injected without loss or spillage
         onto the surface  of the ground.
                              C-164

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PERMIT NO. 8423-DB015                                             Page 2 of 4

C.  Monitoring and Reporting

      1.  Hazardous Wastes

          The Permittee shall test all materials that are suspected  of being
          hazardous and exclude them from injection under Sec.  B.5.

      2.  Produced Water

          The permittee shall  conduct  a representative chemical  analysis  of
          produced water to be injected as required by the  BLM.   The follow-
          ing chemical analysis are required:

              Sodium                Carbonate
              Potassium             Bicarbonate
              Magnesium             pH
              Iron                  Sulfate
              Calcium               Total Dissolved Solids
              Chloride

          This analysis shall be conducted annually and the results  shall  be
          submitted to the Department's Southcentral Regional Office and the
          Kenai District Office by January 31  of  each year during  the term
          of this permit.

      3.  Drilling Fluids

          The Permittee shall  conduct  a  composite,  representative  chemical
          analysis of the drilling fluids  to  be injected from each  new well
          and workover.   The following  chemical analysis  are required:

              Sodium       Carbonate                Arsenic
              Potassium    Bicarbonate               Barium
              Magnesium   .pH                       Cadmium
              Iron         Sulfate                   Chromium
              Calcium      Total Dissolved Solids    Cyanide
              Chloride     Lead

          This analysis  shall be submitted to the Department's Southcentral
          Regional Office  and  the  Kenai District  Office within  30  days  of
          sampling during  the  term of  this permit.   Following a review  of
          two of these reports, the Department may modify this requirement.

      4.   The analysis required in Sec.  1. 2.  and 3., shall be performed  in
          accordance with   Standard Methods for the Examination of Water and
          Wastewater.   (American .PUDIIC Heaitn  ASSOC.;~	
                               C-165

-------
PERMIT NO. 8423-DB015
                                                           Page 3 of 4
 5.  Injection Log

     The Permittee shall maintain a log which will  contain the date
     of receipt and  source  of  waste  received,  volume  frcra  each
     source,  composition of the waste, type of  monitoring performed
     and the  results.   This log  shall also  include  the dates  of
     injection, the level  of  injection,  surface pressures at  the
     beginning and end of each injection  activity or  daily, which-
     ever occurs  first,  maintenance  activities,  and  any  unusual
     complications.  A copy  of this log  will  be submitted to  the
     Department's Southcentral  Regional Office and  the Kenai  Dis-
     trict Office on an  annual basis.   The log shall be  submitted
     by January 31  of each  year during  the  term  of this  permit.
     The log  must  be available  for inspection at the  site.

 6.   Temperature Monitoring

     A  temperature log run in  accordance  with your monitoring plan
     filed for  the BLM Permit  to Drill shall  be submitted to the
     Southcentral  Regional  Office  and  the Kenai  District  Office
    upon completion.

7.   Injection Level

    Any changes  in injection  levels  other than  as  authorized  in
    this permit,  requires  the  written approval in   the  form  of  a
    permit modification from the Southcentral Regional Supervisor.

8.  Noncompliance Notification

    If for any reason  the Permittee  does not comply  with or will be
    unable to comply with any limitation specified in this appendix,
    the Permittee shall report the  noncompliance to  the Kenai  Dis-
    trict Office  within  24  hours,  by  telephone,  telegraph, or  in
    the absence  of  both,  by  mail.  This  notification  does   not
    relieve the permittee of any civil or  criminal penalties  for
    noncompliance.

    For purposes  of  this permit,  non-compliance  is  defined   as:

    a.   Discharging waste other than authorized.
    b.   Operating the  injection well with a leak in  the  casing,  as
        identified by  pressure  monitoring.
    c.   Causing discharges to surface waters and lands, and to fresh
      ' water aquifers.
    d.   Injection into a formation and level other than as author-
        ized  in this  permit, or as may be amended by  the  Regional
        Supervisor.
    e.   Violating any  conditions of  this permit.
                         C-166

-------
PERMIT NO. 8423-DB015                                         Page  4  of 4



    9.   Reporting

        All reporting required in  this section  shall  be  submitted to:

            Alaska Department  of Environmental  Conservation
                         Kenai District Office
                            P.O.  Box 1207
                          Soldotna, AK  99669
                         Phone (907) 262-5210

            Alaska Department  of Environmental  Conservation
                      Southcentral Regional Office
                       427 E  Street, Suite 200
                       Anchorage, Alaska  99501
                          Phone (907) 274-2533
                            C-167

-------
PERMIT NO. 8423-DB015                                          Page 1 of 2
                                   APPENDIX B
GENERAL CONDITIONS  '

A.   Access and Inspection

     The Department's representatives shall be allowed access to the Permittee's
     facilities to  conduct  scheduled  or unscheduled inspections  or  tests to
     determine compliance with this  permit and  State  laws and  regulations.

B.   Availability of Records

     Except for information  relating to secret processes  or methods  of manu-
     facture, all records and reports submitted in accordance with the terms of
     this permit shall be available for public inspection at  the  Southcentral
     Regional Office of the Alaska Department of  Environmental Conservation at
     437 "E" Street, Suite 200, Anchorage, Alaska.

C.   Civil and Criminal Liability

     Nothing in this permit  shall  be  construed to relieve the Permittee  from
     civil or criminal penalties for nonccmpliance, whether or not  such nonccm-
     pliance is due to factors beyond his control, including but not limited to
     accidents, equipment breakdowns,  or labor disputes.

D.   Property Rights

     The issuance of this permit does not convey  any property rights in either
     real or personal property, or any other privileges; nor does  it authorize
     any damage to private property or any invasion of personal rights, nor any
     infringements of federal, State,  or local laws and  regulations.

E.   Severability

     The provisions of this permit are severable  and, if any provision of this
     permit or the application of  any  provision of this permit to  any circum-
     stances is held invalid,  the  application  of  such  provision  to  other
     circumstances and the  remainder  of this  permit  shall  not  be  affected
     thereby.  .Notwithstanding  the  above,  in  the  event  such   invalidation
     materially alters the scope or conditions  of this  permit, the Department
     shall have the right,  at  its  sole option,  to  terminate  the  permit.
                                 C-168

-------
 PERMIT NO.  8423-DB015                                       Page 2 of 2
 F.    State Laws

      Nothing in this  permit shall  be construed  to preclude  the institution
      of any legal action or relieve the Permittee  from any responsibilities,
      liabilities, or  penalties established pursuant to any  applicabble State
      law or regulation.

 G.    Adverse Impacts

      The Permittee  shall  take all  necessary  means to minimize  any  adverse
      impact to  the  receiving waters  or  lands resulting frcra  noncoropliance
      with any limitations  specified in this permit,  including  such additional
      monitoring as  necessary  to  determine  the  nature  and  impact  of  the
      noncomplying discharge.   The  Permittee is  required to  undertake  cleanup
      activities in  the  event  of  any  adverse  impact  resulting   from  nonccm-
      pliance.

 H.    Modifications or Changes

     Anticipated facility  expansion,  production increases or  process  modifi-
      cation  resulting in changes to operation will be  reported to the  Depart-
     ment, at  least  30  days  prior to  the implementation  of such  changes.

 I.   Permit Availability

     The Permittee shall retain a copy  of this permit at the disposal  facility.

J.   Transfers

     Should operation of the facility be contracted or  a change in contractors
     be made, the  new contractor  shall be notified of the  existence of  the
     permit and its conditions.  A copy of the  written notification shall  be
     forwarded to the  Regional  Supervisor of the  Department's   Southcentral
     Regional Office,  437  "E"  Street,  Suite  200,  Anchorage,  Alaska   99501
     (274-2533).
                                 C-169

-------
                                                             CSG-
             L   :'J;     ;n>:i_  ^.'"..      '         BILL SHEFFIELD, GOVERNOR
DEPT. OF ENVIRONMENTAL CONSERVATION
  SOUTHCENTRAL  REGIONAL OFFICE
  437  E STREET,  SUITE  200
  ANCHORAGE, ALASKA  99501                                274-2533
                               July  3,  1985       _ __
                                                 \\\\ '
                                                       :!••! 031363
                                                       v W -^


 Mr. Larry Cutting                                   ^ Erw'ro	
 Union Oil Company of California
 PO Box  6247
 Anchorage, Alaska   99510


 Dear Mr. Cutting:

 RE:  WD #1
      8423-DB015

 The Department has  reviewed your June  20, 1985  letter regarding
 the referenced permit.  It appears  that  some  confusion in  termi-
 nology  and permit wording is the basis for all  but  the last item
 covered by your  letter.  In response to  these issues,  we hereby
 grant the following permit modifications:

      -Permit Cover, first paragraph, shall be changed to read:
       This permit is issued to Union Oil Company  of California
       for the injection of a maximum of  5,000 barrels/day
        (210,000 gal/day) and 150,000 barrels/year  (6.3 million
       gal/year)  of  wastewater associated with the drilling and
       production of oil and natural gas.  The wastewater will be
       injected at Waste Disposal Well  #1, Kenai Gas Field,  off
       Kalifonsky Beach Road, 606' N and  2297' W of  S.E. Cor., Sec.
       31, TSN, Rll  W., S.M.

      -Appendix A, Part B.3, shall be changed  to read:  The maximum
       well head  pressure is limited to 1500 psi.

      -Appendix A, Part B.4, shall be changed  to read:  The dis-
       charge shall  be limited to those wastes directly related
       to drilling and production activities.  This  includes
       produced waters, drill fluids and dilution  water.  Other
       waste, including equipment washwater is not authorized to
       be discharged.

 In regards to your  comments concerning Appendix A.  Part B  and C,
 as it relates to well safety, the Department  believes  that the
 requested data is appropriate to establish that all  concerns of
 our Department are  being reviewed and addressed,  whether by this
                           C-170

-------
           • r  r                       r
Mr. Larry Cutting             2              July 3,   1985
Union Oil Company
Department or other governmental authorities and that these re-
quirements are fixed for the term of the permit.  We will consult
with the BLM and AOGCC where safety issues and environmental pro-
tection are of joint concern.  It is our position that the requested
information represent data critical to evaluating characteristics
of discharged materials and the assurance that this discharge is
only into the authorized injection zone.

Department of Environmental Conservation regulations provide
that any person (s)  who disagrees with any portion of this deci-
sion may request an adjudicatory hearing in accordance with 18
AAC 15.200-315.  The request should be mailed to the Commissioner
of the Alaska Department of Environmental Conservation, Pouch 0,
Juneau, Alaska 99811, or delivered to his office at 3220 Hospital
Drive, Juneau.  Failure to submit a hearing request within thirty
(30) days of receipt of this letter shall constitute a waiver of
that person's right to judicial review of this decision.
                              Sincerely
                              Bill H. Lamoreaux
                              Regional Supervisor

BHL/JH/pkk
cc:  Kenai District Office
     Mary Core, Alaska Center for the Environment
     Jerry Opatz, EPA, Seattle
                         C-171

-------
C-172

-------
     ATTACHMENT  C:   MONTHLY WELL
INJECTION REPORTS,  JANUARY-JULY, 1986
           KENAI GAS FIELD
              C-173

-------
C-174

-------
* t^TED STATES ENVIRONMENTAL PROTECTION AGS^f
A •— -« a '^ WASHINGTON. DC 20460 '^J
^E PA INJECTION WELL MONITORING REPORT
YEAR 1986
Injection Pressure (PSI)
1. Minimum
2. Average
Injection Rate (Gal/Mm)
1. Minimum
2. Average
3. Maximum
Annular Pressure (PSI)
1. Minimum
2. Average
3. Maximum
Injection Volume (Gal)
1. Monthly Total
2. Yearly Cumulative
Temperature (F°)
1 Minimum
2. Average
3 Maximum
pH
1 . Minimum
2. Average
Other
MONTH
Jan .
55D
7PR
qnn

n fl
5.5
10.2

o
n
n

344.73?
!U4.?3?














MONTH





























Name and Address of Perm.nee Union Oil Company of California (Unocal)
P.O. Box 190247, Anchorage, AK. 99519-0247
Name and Official Title /Please type or print/
Roy D Roberts
Environmental Specialist
Signature
T^f-. Oa£~'7\£k''
-------
IjgBED STATES ENVIRONMENTAL PROTECTION AGE|g|^
ft _ — * - ^F WASHINGTON. DC 20460 WW
^C PA INJECTION WELL MONITORING REPORT
YEAR 1986
Injection Pressure (PSI)
1. Minimum
2. Average
3. Maximum
Injection Rate (Gal/Min)
1. Minimum
2. Average
3. Maximum
Annular Pressure (PSI)
1. Minimum
2. Average
3. Maximum
Injection Volume (Gal)
1 . Monthly Total
2. Yearly Cumulative
Temperature (F°)
1. Minimum
2. Average
3. Maximum
pH
1. Minimum
2. Average
3. Maximum
Other
Water from Beaver Creek
Water from Well KBU 33-7
Water from Kenai Gas Field


• MONTH
Feb.
700
800
900

1.3
5.1
8.8

0
0
0

517.272
861,504








162,918
264.264
90,090



MONTH





























Name ana Address of Permittee Union Oil Company Of CalifOmdi (UHOCal)
P.O. Box 190247, Anchorage, AK. 99519-0247
Name and Official Title iPleasa type or print)
Roy D. Roberts
Environmental Engineer
Signature f
&& 0 f\i£c''*£
'i
Form Approved
OMB No. 200O-O042
Approval expires 9-30-86
MONTH



-



—








-•












Permit Numoer
AK-2D217-E
Date Signed
02/04/86
EPA Form 7520-8 (2-84)
                                                  C-176

-------
UNITfelpttATES ENVIRONMENTAL PROTECTION AGENCY tegl
fl _ _ _ ^^ WASHINGTON. DC 20460
^E PA INJECTION WELL MONITORING REPORT
YEAR
Injection Pressure (PSI)
1. Minimum
2. Average
3. Maximum
Injection Rate (Gal/Mm)
1. Minimum
2. Average
3. Maximum
Annular Pressure (PSI)
1. Minimum
2. Average
3. Maximum
Injection Volume (Gal)
1 . Monthly Total
2. Yearly Cumulative
Temperature (F°)
1. Minimum
2. Average
3. Maximum
pH
1. Minimum
2. Average
3. Maximum
Other
Water from Beaver Creek
Water from well 33-7
Water from KGF


MARCH MONTH

790
Q4R
1100

1 n
5 Q
9.0

0
0
0

480,396
1,341,900









183,120
202, 6bU
94,416


MONTH





























Name and Address of Permittee
Union Oil Co. of Calif, P.O. Box 190247, Anch, Ak. 99519-0247
Name ^93 Official 1jyfl-/£0?f3? 'W* or prim)
Environmental Engineer
Signature
/|02;>,£/ T^Qht^L^fy
Form Approved
OMB No. 2000-00*2
Approval expires 9-30-86
MONTH







—





















'ermit Number
AK 2D217 E
Date Signed
4/3/86

-------
U^BO STATES ENVIRONMENTAL PROTECTION AGENgj^
A jp—jrtA ^^ WASHINGTON, DC 20460 H*^
^E PA INJECTION WELL MONITORING REPORT
YEAR
Injection Pressure (PSI)
1. Minimum • •
iV '
2. Average --*'
3. Maximum
Injection Rate (Gal/Mm)
1. Minimum
2. Average
3. Maximum
Annular Pressure (PSI) ^
\
V
1. Minimum
2. Average
3. Maximum
Injection Volume (Gal)
1 . Monthly Total
2. Yearly Cumulative
Temperature (F°)
1. Minimum
2. Average
3. Maximum
pH
1. Minimum
2. Average
3. Maximum
Other
Water from Beaver Creek
Water from Well 33-7
Water from Kenai Gas Field
MONTH
APRIL
805
900
995

0.7
5.1
9.5

0
0
0

291,900
1,633,800








189,966
26,880
75,054



MONTH













CX *--f.
-














Name and Address of Permittee
Unocal , P.O. Box 190247, Anchorage, Ak. 99519-0247
Name and Official Title (Please type or print)
Roy D. Roberts
Environmental Engineer
Signature
Form Approved
OMB No. 20OO-0042
Approval expires 9-30-86
MONTH



-



—





, ^ /<. c 7^ : . '-'.•-'-• i *•<-.
s














Permit Number
AK-2D0217-E
Date Signed
5/5/86
EPA Form 7520-8 (2-84)
                                                  C-178

-------
JJ^D STATES ENVIRONMENTAL PROTECTION AGEi^9
Ar-mA WASHINGTON. OC 20460 ^^
^81 PA INJECTION WELL MONITORING REPORT
YEAH 1QSfi
Injection Pressure (PSI)
1. Minimum
2. Average
3. Maximum
Injection Rate (Gal/Min)
1. Minimum
2. Average
3. Maximum
Annular Pressure (PSI)
1. Minimum
2. Average
3. Maximum
Injection Volume (Gal)
I. Monthly Total
2. Yearly Cumulative
Temperature (F°)
1. Minimum
2. Average
3. Maximum
pH
1. Minimum
2. Average
3. Maximum
Other
Water from Beaver Creek
Water from Kenai Gas Field



MONTH
MAY
700
800
900

0.7
3.9
7.1

-0-
-0-
-0-

165,396
1,799,196





^



83,370
82,026



MONTH




















r r








Name and Address of Permittee
Unocal, P.O. Box 190247, Anchorage, Ak. 99519-0247
N^e an- Of
-------
                                  STATES ENVIRONMENTAL PROTECTION
                                       WASHINGTON. DC 20460

                         INJECTION WELL MONITORING REPORT
form Approved
OMB No. 2000-0042
Approval expires 9-30-86
X" YEAR
Injection Pressure (PSD
1. Minimum
2. Average
3. Maximum
Injection Rate (Gal/Min)
1. Minimum
2. Average

Annular Pressure (PSI)
1. Minimum
2. Average
3. Maximum
Injection Volume (Gal)
1. Monthly Total
Temperature (F°)
1. Minimum
2. Average
3 Maximum
pH
1. Minimum
2. Average
Other
Water from Beaver Creek
Water from Kenai Gas Field
MONTH
JUNE
700
800
900

0.7
3.9
7.1

-0-
-0-
-0-

167.95R






• r-


104.454

63,504



MONTH





























Name and Address of Permittee
Unocal. P.O. Box 190247, Anchorage, Ak. 99519-0247
Name and Official Title (Please type or print)
Roy D Roberts
Environmental Enaineer
Signature
MONTH







—





















AK 2D0217-E
Date Signed
7/11/86
EPA Form 7S20-8 (2-84)
                                                C-180

-------
Uiq§pb STATES ENVIRONMENTAL PROTECTION AGENTS
^^ _____ WASHINGTON. DC 20460
^E PA INJECTION WELL MONITORING REPORT
YEAR
Injection Pressure (PSI)
1. Minimum
2. Average
3. Maximum
Injection Rate (Gal/Min)
J. Minimum
2. Average
3. Maximum
Annular Pressure (PSI)
1. Minimum
2. Average
3. Maximum
injection Volume (Gal)
f
1. Monthly Total
2. Yearly Cumulative
Temperature (F°)
1. Minimum
2. Average
3. Maximum
pH
1. Minimum
2. Average
3. Maximum
Other
Water from Beaver Creek
Water from Kenai Gas Field


MONTH
JULY
700
800
900

0.7
4.1
7.1

-n-
-0-
-0-

177,282
2,144,436





s



1 1 9 , 784

57,498


MONTH





























Name and Address of Permittee
Unocal P.O. Box 190247, Anchorage, Ak. 99519-0247
Name and Official Title ff tease type or print/
Roy D Roberts
Environmental Engineer
Signature
faa/fct**
form Approved
OMB No. 2000-0042
Approval expires 9-30-3S
MONTH







—





















'ermit Number
AK 2D0217-E
Date Signed
8/5/86
EPA Form 7520-8 (2-84)

-------
C-182

-------
CALIFORNIA
    C-183

-------
C-184

-------
                         Sampling Report
    Investigation of Sun Exploration and Production Company's
                  Oxnard Oil Handling Facility
                        Oxnard, California
                          July 14,  1986


SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA 530-SW-87-005).   This site was selected randomly from
a list of active Santa Maria or Ventura Basin production sites
developed by the California  Department of Conservation at the
request of EPA.  The list was transmitted via telephone to the
EPA contractor on July 8, 1986.  Randomization and site selection
took place during the telephone conversation.

The EPA contractor had no interest  in the manner the particular
sites were listed (by site name,  location, operator, permit
number, API number,  etc.)  as long as the site could be identified
in detail upon selection.  Thus,  the EPA contractor had minimal
information which kept to a  minimum the amount of bias.  No other
information was known about  the sites on the list at the time of
selection.  Detailed information was obtained only after
selection of primary and back-up sites.

The Department of Conservation listed the possible sample sites
by operator and general location.  For simplicity of selection,
the list was transmitted as  shown below.  The list consisted of
five production sites:

          1.  Santa  Fe Energy - Sespe Field
          2.  Arco - Ojai
          3.  Sun Oil - Oxnard
          4.  Sun Oil - Ojai
          5.  Conoco - San Miguelito

As indicated above,  the EPA  contractor assigned numbers to the
members of the list  as they  were transmitted.  A random number
table was used to select the primary and back-up sample sites.
The randomly-selected primary site  was No. 3 on the above list
(Sun Oil - Oxnard).

Further inquiry identified the primary sample site as Sun
Exploration and Production Company's Oxnard Oil Handling Facility
in Oxnard, California.  No problems were encountered in arranging
sampling for July 14, 1986.   No back-up site was required.
                              C-185

-------
Site Location

The Oxnard Oil Handling facility is located approximately 2 miles
south of Highway 101 via Rice Road and East Fifth Street in
Camarillo, CA.  Figure 1 is a map indicating the production
facility site.  The full name and mailing address for Sun is:

          Sun Exploration and Production Company
          25322 West Rye Canyon Road
          Valencia, California  91355-0560
          Main Office Ph.: 805-257-6228
          Main Office Contact: B.J. Atkins
                               Environmental Coordinator

Attendees

Sampling at the Sun production site was performed by CENTEC
Corporation personnel on July 14, 1986.  Following is a list of
people present at the time of sampling:

     CENTEC Corp. (sample team):  Bill Lane, Technician
                                  Jamie Mclntyre, Team Leader

     State Representative:        Mike Stettner, California
                                    Department of Conservation,
                                    Division of Oil and Gas

     Operator Representatives:    B.J. Atkins, Environmental
                                    Coordinator
                                  Diana Visser, Segment
                                    Production Engineer
                                  Jim Wilson, Lease Operator
                                  Lloyd Hill, Segment Foreman

     American Petroleum
       Institute Representatives: George Holliday, Contracted
                                    Observer
                                  Lloyd Deuel, Contracted Sample
                                    Team Member
                                  Shawn Hokanson, Contracted
                                    Sample Team Member

Site Description

The Sun production facility is located in a rural, flatland area
in the Oxnard Flood Plain.  The climate at this site location is
net precipitation.  The soil consists largely of sand and clay.
Wells serviced by this facility are completed in the Vacca Tar
Sand formation of the Ventura Basin.

The depth to the groundwater in the area is between 0 and 25
feet.  The nearest surface water is the Santa Clara River,
located approximately 3 miles west of the site.  There are fresh
water wells within a 1/2- to 1-mile radius of the site, but these


                              C-186

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                       O X NV R D   AIR   FORCE   BASE
• 9
FE LOCATION . .
V
\ I
1 !.OilW«H
>
Figure 1.  Location of Sun Exploration and Production
           Company's Oxnard Oil Handling Facility,
           Oxnard, California
                        C-187

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are not drinking water wells.   Their main use is for irrigation
and watering cattle.

The site was being tested as a pilot operation by Sun,  to assess
the productivity of the facility and its associated wells.  If
the site proved to be productive, Sun expected to upgrade all _the
equipment.  Otherwise, Sun would consider selling the property.
For this reason, Sun representative B.J. Atkins requested that he
direct CENTEC's photo documentation, intending to avoid
documenting poor quality equipment that was out of use  or soon to
be removed.  The CENTEC team complied with his request.

At the time of sampling, the site consisted of one 2,500-barrel
steam heated oil and water separating tank called a "wash tank,"
two 3,000-barrel crude storage tanks, an 80-barrel skim tank, a
500-barrel diluent tank, a waste sump, and one injection well.
Figure 2 is a diagram of the site, dated 1984, as provided by
Sun.  Several vessels on the site had been taken out of service
since Sun purchased the site from the previous owner.  Well
No. 1 was in use as an injection well at the time of sampling.

The oil from wells in this area has an average API gravity
between 3 and 6 (water has an API gravity of 10).  This means
that the oil is very thick and difficult to move.  In order to
pump the oil, a diluent is introduced down-hole to thin and
lighten the oil.  The diluent  Sun used was KD-40, a kerosene
distillate.  In addition, the  wells are stimulated using a cyclic
steam recovery method referred to as "huff and puff."

Seven wells were serviced by this production facility at the time
of sampling.  These were the W.R. Livingston Well No. 2, the C.V.
Lenox Well No.s 77 and 82, and the E.E. Lenox Well No.s 49, 60,
64, and 69.  The average depth of these wells is 2,200  feet.

Each of the seven producing wells generated a daily average of 15
to 20 barrels of oil.  Total oil production was approximately 120
barrels per day, and total water production was 150 barrels per
day.  In addition to oil and water, production included small
amounts of natural gas containing
Oil enters the production area from the seven producing wells.
Referring to Figure 2, the wash tank receives the oil,  where it
is heated by steam through coils in order to separate the oil and
produced water.  The oil layer goes to the stock tanks  and the
produced water goes to the skim tank where it is held for
disposal (this water is essentially oil-free) .   From here, the
water goes to the injection well.   Prior to injection,  the water
goes through a spun-fiber filter to remove any remaining solids.
The injection well head and filter are shown in Photos  4 and 5.
The crude oil is piped across East Fifth Street to the  Chase
Oxnard Refinery where the diluent  used in Sun's wells is
separated out and returned to the  Sun facility.
                             C-188

-------
o
oo
vr
                                  HOTf: $U*P » HT TMK

                                         TO K cuumaeo.
                           »4»CK MEM.EY 2    •          «t         »S     ^^*»

      I I  I I I  I I  I I  I I I  I I I I I I  I I I  I I  I I  I I  I I I  I I  I I  I  I I  I I I I I  I I  I
                                                                                         • JACK HCRttY «
                  I/
                                                                , CHASf PRODUCTION CO
II
."          ."          *'°
                            Figure  2.  Schematic Diagram of  Production Site

-------
Other chemicals in use at the time of sampling included a
demulsifier, used continuously at a rate of 1-pint per day; a
corrosion inhibitor, used continuously at a rate of 0.5 gallons
per day; and a scale inhibitor, added every two days at a rate of
0.1 gallon per day.

All tanks in use at the facility are cleaned as needed.  The
western crude storage tank had been cleaned 1 week prior to the
time of sampling.

Disposal Practices

Produced water is disposed of in an injection well located within
the  production area.  This is the E.E. Lenox Well No. 1, as
shown in Figure 2.

Permits

Annual inspections of the Oxnard Oil Handling Facility are
conducted by the California Department of Conservation Division
of Oil and Gas, the Ventura County Air Pollution Control
District, and the Ventura County Environmental Health Department.

A copy of the Report on Operations for the E.E. Lenox Well No. 1
is located in Attachment B.


SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report  (EPA 530-SW-87-005).

Sample Point Locations

At Sun's Oxnard Oil Handing Facility, the sample was defined as
the fluid entering the injection well, E.E. Lenox Well No. 1.
Figure 2 indicates the sample point from which the fluid sample
was composited.

Attempts were also made to collect a tank bottoms sample from the
wash tank.  The tank was found to have no collectable solids at
the time of sampling.

Sampling Methods and Equipment

The produced fluid sample was obtained through a tap in the line
between the injection well head and the solids filter.  Photos 4
and 5 show the well head to the left of the sign, and the solids
filter, vertically oriented to the right of the sign.
                              C-190

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The sample was collected in a clean 1-gallon glass jar,  and
composited in a 5-gallon glass carboy (Photo 5).   Immediately
after the CENTEC team was through collecting their sample,  the
API sample team collected their samples from the  same tap.

Photo 6 shows operator representative,  Lloyd Hill, at the top of
the wash tank attempting the collect a  tank bottoms sample.
CENTEC samplers were not permitted to climb the tank because of
the presence of natural gas containing  I^S.  Anyone entering the
stairs to the wash tank is required by  Sun to wear an air supply
and respiratory mask for which the wearer has been trained.

Only the coring device could be used to sample the wash  tank
because the opening at the top was too  small for  the dredge. Sun
representatives, Wilson and Hill, first attempted to obtain a
sample using the coring device connected to 20 feet of steel
extension rods.  The rods were found to be too heavy and
inflexible to manage at the top of the  tank.  The rods were
replaced with plastic tubing, shown in  Photo 8.  The coring
device came up empty each time it was inspected.   Finally,  a rope
was attached to the device, but proved  to be no more productive
than the tubing.  Thus, it was concluded that there were not
enough bottoms in the tank to be collected.
                             C-191

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C-192

-------
ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-193

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C-194

-------
o
Ul
HfplflptSVufln^Vl I  HpjqA^UMMKMm^^^^H^^^H^HHp  i*^ *p"»*r • * **

•"'ij«^:^"ar-  .- /_ * .!JLW^?i^-"-*£*j* KViT
;   -,»- 'i""i;Ms*'-j—. »**• •-•jXiMsa?'^'1'* '• ^ ^5.^1
m--^?:-*+ni/*y&.f!;*0>ixt	>yy«*^""gB;^j..-v  ,»>r<..>?':

 - -Rvf.-.«'. . r^--'^%-*V'tl^.^M*t^^*ffliP*'**f^>
t-«c.:-r-:i4s-.-.-- r-.„-   -• \•  t^S^sSfii^i'vy
          Photo  I .   Wash tank
                                                                 Photo 2.   Skim  tank
                                                                  Photo  3.   Skim tank

-------
Photo 4.  Well head and filter
                                                               Photo 5.  Pouring liquid composite

-------
O
I
«a
vo
-vj
           Photo 6.   Lloyd Hill accessing wash tank


                                                           Photo 7.  CENTEC  sample  team  examining empty coring device
                                                           Photo  8.   Accessing  wash tank

-------
C-198

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ATTACHMENT B:  PERMITS
         C-199

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C-200

-------
                          c.
                                                              c
                                    MHOURCM AOINCT or CALirOKMIA
                                   OEPAHTMCNT OF CONSERVATION
                          DIVISION  OF  OIL AND  GAS

                                   Report on Operations
                                                                            T 284-52
        Stanley  W.  Blossom. Agent
        Eyeter Oil  Company, Ltd.
        P. 0. Box 55060	
        Valencia. CA
                                                                   Santa Paula
                                                                   March 20,
                                                                                       Calif.
                                                       , API No.
Your operations at w»n   "Lenox"  1	p API
S^.  6  T T.1N, R.21W  S.B.B.A M.     Oxnard	Field, in
were witnessed ™»  VL4/84	H. Fulco	~
die supervisor,was present from	1200	to —
	MeCulloch	
                                                                    111-OlOy?
                                                                   V«?ntura
                                                                                    .County,
                                                                            , representative of
                                                      There were also pr»«»n» Geor.Te Johns
'  Present condition of well:   11 V*»" cem.
                                          ;  8 5 /P." com. 257^'.  e.n. 112?': 6  5/3" Id.
        2529-288?'.  perf. 2585-2883'.  T.D.  23?5'.
 The operations were performed for the purpose of   demonstrating that  the injected fluid  is
        f*r\m -Ci WAS-) ±t*  *»^*••*+•-* V««n ^M.t OCXC I
        confined  to  strata below 2585*
DECISION:


THE OPERATIONS ARE APPROVED AS INDICATI?JG  THAT ALL OF THE  INJECTION FLUID IS  CONFINED TO
THE FORMATIONS BELOW  2585'  AT THIS TIME.
00109 (9/S3/CSR1/1SM)
                                         C-201
                                                               Murray W. Dosch

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C-202

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                         Sampling Report
       Investigation of Shell California Production, Inc.'s
                  Central Water Treating System
                       Ventura, California
                          July 15,  1986

SITE INFORMATION

Site Selection

This site was specifically selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA 530-SW-87-005).  This site was selected from active
Santa Maria or Ventura Basin production sites in the vicinity of
sampling already underway near Ventura, California.  Planned tank
bottom sampling at another production site in the area could not
be achieved because the tanks contained no collectable solids.
Thus, an alternate site (near the original production site)  was
selected.  The California Department of Conservation was integral
in the identification and selection of this site.

Site Location

Shell CPI Central Water Treating System is located west on
Highway 33, and approximately 5 miles north of the intersection
of Highways 33 and 101 in Ventura,  CA.  Figure 1 is a map
indicating the treatment site.  The full name and mailing address
for Shell is:

       Shell California Production,  Inc.
       P.O. Box 11164
       Bakersfield, California  93309
       Main Office Ph.:      805-326-5000
       Main Office Contact:  D. L.  Oreolt, Manager
                             Environmental Conservation
                             West Coast Production Division

Attendees

Sampling at the Shell CPI Central Water Treating System was
performed by CENTEC Corporation personnel on July 15,  1986.
Following is a list of people present at the time of sampling:

     CENTEC Corp.  (Sample Team):  Bill Lane, Technician
                                  Jamie Mclntyre, Team Leader

     EPA Representative:           William Telliard, Chief, Energy
                                    and Mining Industries Branch,
                                    Industrial Technology Div.,
                                    Office of Water

     State Representative:         Mike Stettner, California
                                    Department of Conservation,
                                    Division of Oil and Gas


                              C-203

-------
Figure 1.  Location of Shell Production's  Central Water Treating
           System, Ventura,  California
                           C-204

-------
     Operator Representatives:    Carl Brown, Production Operator
                                    for Central Water Treating
                                    System
                                  Tod Stallings, Field
                                  Surveillance Technician

     American Petroleum
       Institute Representatives: George Holliday, Contracted
                                    Observer
                                  Lloyd Deuel, Contracted Sample
                                    Team Member
                                  Shawn Hokanson, Contracted
                                    Sample Team Member

Site Description

The Central Water Treating System is located in suburban
piedmont.  The climate at this site location is net precipi-
tation.  The soil is described as sand over rock and clay.  The
area is a dried-up river bed.

The depth to the groundwater in the area is approximately 10
feet.  The nearest surface water is the Ventura River, less than
1/2 mile west of the site.  The nearest drinking water well is
estimated to be greater than 10 miles from the site.

At the time of sampling, the site consisted of two "slop" tanks,
one "production wash tank," two Wemco flotation cells, two stock
tanks, and one sump pit that receives bottoms from three free
water knock out (FWKO) tanks.  The sump pit was sampled for tank
bottoms.  Figure 2 is an approximate schematic diagram of the
site, indicating the directions in which photos were taken.  This
figure is based on a diagram provided by the operator, and
therefore does not include all the tankage discussed in this
report.

At the time of sampling, each well serviced by this facility
produced a daily average of 45 to 50 barrels of oil.  The average
depth of these wells is 6,813 feet, and range in depth from 4,000
to 15,000 feet.  Primary production techniques include both
natural and artificial drives.  Produced water from these wells
is reinjected for waterflooding the producing wells in the area.

Oil enters the production area from approximately 250 producing
wells located on the Taylor and RBU (River Bottom Unit)  leases.
Photos 6 through 9 show the major elements of the production
system.  In particular, Photo 7 shows the three FWKOs that dump
bottoms to the sump pit every 8 hours.   Photo 8 shows the sump
pit viewed from between the two slop tanks.

The sump pit functions as a skim tank for any oil that is not
separated from the produced water in the FWKOs, and as a settling
tank for solids.  The pit receives mainly sand and produced water
that has a chlorides content of 12,000  parts per million.  The


                              C-205

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O
I
to
O
                                                       11
II
                                             O.
photo
1

\


1
0
0
0
0




1 1

.0 WAS 111**, k-
L- O.la^W^


O
O
O
O



\
1 1
•*s " — '•— '


                                                                           N
                Figure  2.   Schematic Diagram of Central Water Treating System

-------
pit is constructed with 6-inch-thick concrete walls, and has an
automatic level controller that keeps no more than 8 feet of
contents in it at all times.  A cover over the pit can be raised
automatically for access to the pit, as shown in Photos 2 and 3.
Actual construction requirements are not known because the pit is
20 years old, and records from that time are not available.

The treatment chemicals which are used as part of the production
process are:

     Emulsion Breakers:  Tretolite RP 4005
     Scale Inhibitor:    Baker Chemical Calnox 214 R
     Coagulating Agent:  Baker Chemical Magna Clear W 107

In regard to the question of whether the contents of the sump pit
are ever analyzed, the operator submitted the following remarks:

     Pit contents are not routinely tested.  However,
     enclosed is an analysis [see Attachment C]  of tank
     bottoms which would be expected to consist of similar
     material to the pit.  Possibly the only difference
     would be that the pit contains coarser sand grains than
     the tank bottoms because of the limited residence time
     in the FWKO vessels compared to the tanks.

The pit is cleaned out once every 4 months, and was last cleaned
two weeks prior to EPA's sampling visit.  The two slop tanks and
one wash tank at the site are cleaned once per year.   The FWKOs
are cleaned three times per day, every 8 hours,  and the stock
tanks are cleaned only as needed.

Disposal Practices

Produced water leaving the sump pit is pumped to a clarifier (not
shown in Figure 2), where the liquid polymer "Magna-Clear W-170"
is added to further separate solids from the water.  The water is
sent from the clarifier to the wash tanks, then  to an injection
well for enhanced recovery.

The solids from the pit are hauled to the Ventura Regional
Sanitation District Landfill in Santa Clara.  Solids separated
from the produced water in the clarifier are also hauled to the
landfill after they have been dewatered.  The company that hauls
the solids is Offshore Crane.

Permits

No operating permits were made available to the  sample team at
the time of sampling.
                             C-207

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SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).

Sample Point Locations

The sample collected at this site was a tank bottoms sample, and
was defined as the sludge layer in the sump pit.   Figure 2
indicates the points at which the samples were taken.  The pit
was sampled from the sides, so that the centers of measured
quadrants were inaccessible.  Actual sample points were directed
by EPA representative William Telliard.

Sampling Methods and Equipment

The sump pit was sampled by tossing the dredge from the side of
the pit.  The coring device was not used due to time constraints.
Photos 10 and 11 show sampling in progress.

The sludge contained considerable sand and oil, and appeared
black in the sample bottles.

The pH of the sludge sample was measured onsite after sampling
was completed.  The pH of this sample was 8.
                              C-208

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-209

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C-210

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o
. I
to
Photo 1.  Cover rising from sump pit
                                                                  Photo 2.  Cover  rising  from  sump  pit
    Photo 3.  Cover rising from sump pit
                                                              Photo 4.  Sump pit pump  (lower  right  corner

-------
i,s>|ue +  ao|s,,


-------
o
I
to

U>
    Photo 9.   "Wemco Flotation Cells" and oil  stock tank
                                                                  Photo 10.  Sampling sump  pit
                                  Photo II.   Sampling sump pit

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C-214

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ATTACHMENT B:  PERMITS
        C-215

-------
n
 i

-------
No permit specific to the operation
     of  this  site  is  available.
             C-217

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o
 I
10

CO

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ATTACHMENT C:  LABORATORY REPORT ON
    TANK  BOTTOMS SAMPLE  FROM A
       STOCK TANK AT SHELL'S
   CENTRAL WATER TREATING SYSTEM
              C-21y

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C-220

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JACOBS LABORATORY
  DIVISON OF CHEMCAL RESEARCH LABORATORIES
29 NORTH OLIVE. VENTURA. CALIFORNIA 93001

   October 8, 1985
                    TELEPHONE (805) 648-2735
   Shell California Production Inc.
   P.O.  Box  11164
   Bakersfield, CA    93389

   Attn: Ray Ouelette
8509131
   CAM analysis of one sample received on Sept 30, 1985.
   bottom.
      Sample identified  as  tank
   Respectfull^subrndrtte^,
   Thomas K. Mikel
   Laboratory Director
   TKM/jm
                                        C-221

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                                 FORM i




      ' W.-*57E COMPONENT AND V.\S7£ EXTRACTION TEST SUMMARY



Laboratory Sample // _  8509131
Type of Sample Tested tank bottom
1. Chemical Analyses and
Component
Inorganic Analysis:
Antimcnv
Arsenic
Scriurn
Bervlhum
Cadmium
Chromium (Hi)
Chromium (VI)
Cobalt
Coooer
Fluoride
Lead
Mercury
Molvbdenum
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Extractions
STLC TTLC
LIMITS LIMITS CO;
L3 500 '•
5.0 500
-00 10000
0.75 75
i.i 100
5dv iJOO
o puu
60 iO'OO .
H 2500
loo iyuou
3.U iOUU
u.2 20
JOU JiOO
20 2000
1.0 100
5 500
7.0 /UO
24 Z'+UU
2iC JUUU

TOTAL CALIFORNIA
:.CE:-rrRATioN EXTRACTION TEST
(=g/kg) (mg/l)
60* 4.4
2.7
82 -
<0.2
1.2* <0.01
29.2
<1
8.6
185* 0.02
1.2
180* 0.4
1.3* <0.001
16
110* 0.5
<0.2
0.8
16* 0.2
32* <0.1
340* 2.16
Organic Analysis:
Chlorinated Pesticides
Polvchiorinated Biohenvls
Chlorophenoxy Acid
Pesticides
Nitroaromatics
Organophosphorus
Pesticides
Phenols
Polynuciear Aromatic
Hydrocarbons
Priority Pollutants
Volatile Orcanics
Carbamates
Other (Soecifv)
oH
Not Aoolicable


* Exceeds STLC
** Exceeds TTLC
- 7 -
C-222


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 II.  Sic&ssay-
                                             Concentration (mg/1)
   95-hr LC,, for  Waste
                                             333 mg/1
   95% Confidence Interval
III.  Head Specs Vapor Concentration
306 mg/1 ± v <. 582 mg/1
Weight of
component
Molecular in syringe
Component weigh : (mg)
Head
space vapor
concentration




          (CA) =
                   (QA) (SO
                   (MW)  (G)
              where (QA) = quantity  of component in  head  space vapor (mg)
                    (MW) = molecular weight (mg/mmole)
                    (R) = 2'4.5  ml/mmole
                    (G) = 2 x 10"6 M3
                    (CA) = Head space vapor concentration (ppm)
                                   C-223

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                                     FORM  3

             cc-niicsivrrsr, FLAMMABILITY, REACTIVITY OF
Pzramsrsr
                                 Experiment;:! data or ,
                               certification by chemist
                         Reference
Corrosivity
         0% dilution
                         see item  tb
' ^u JG-4 dil-:::cn , 7, , ,«<>„
- corrosion r^ta"* (rr.m/vr':
sec item *b
seo item tb

Flammability 0
- Flash ooint* (°O 36.0 C
see item &b
- Causes fire
- Fia.T.maole »as
- Fiam.TiabLe solid
- Oxidizer

Reactivity
- Unstable
- Reacts with H.O
  - Forms potentially  explosive
    mixture with H,O
  - Generates toxic~gases
    with H.O
  - Is  a cyanide  or suifide
    between  pH 2 and  12.5
    which generates toxic
    gases	
    Detonates or reacts at
    standard temperature,
    pressure
    Detonates if heated under
    confinement or with
    initiating  source
    Forbidden or class  B
    exolosive
NOTES:
    Fill in as  follows:
    Code
      Y
      N
      X
if  Optional
             Certification
              yes
              no
              not applicable
    Supply experimental data
* comments or attachments
                                    C-224

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                          Sampling Report
       Investigation of Shell California Production,  Inc.'s
              River Bottom Unit Gosnell Well No. 51
                       Ventura, California
                          July 15, 1986


SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report  (EPA 530-SW-87-005).  This site was selected randomly from
a list of active Santa Maria or Ventura Basin drill sites
developed by the California Department of Conservation at the
request of EPA.  The list was transmitted via telephone to the
EPA contractor on July 8, 1986.  Randomization and site selection
took place during the telephone conversation.

The EPA contractor had no interest in the manner the particular
sites were listed (by site name, location, operator, permit
number, API number, etc.) as long as the site could be identified
in detail upon selection.  Thus, the EPA contractor had minimal
information which kept to a minimum the amount of bias.  No other
information was known about the sites on the list at the time of
selection.  Detailed information was obtained only after
selection of primary and back-up sites.

The Department of Conservation listed the possible sample sites
by operator and operator representative.  For simplicity of
selection, the list was transmitted as shown below.  The list
consisted of four sites:

          1.  Conoco - Mr. Dave Dooley
          2.  Sun - Mr. Terry Carter
          3.  Santa Fe - [Contact kept private by Department of
                Conservation.]
          4.  Shell - [Contact kept private by Department of
                Conservation.]

Usually the EPA contractor assigned numbers to the members of the
list as they were transmitted and a random number table was used
to select the primary and back-up sample sites.   In this case,
however, the Department of Conservation had already contacted the
proposed sample sites.  Only site No.  4 (Shell)  was amenable to
participation in the sampling program.  The sampling time frame
would not allow pursuit of EPA's authority to sample a random
site at its discretion; thus, the Shell site was selected.  It  is
considered a random sample,  however,  because no  bias was
introduced into its selection.  It was selected  from a random
list on the basis of availability.  No information was available


                              C-225

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to indicate this site was a particularly "good" or
for sampling.
                 "poor" site
Further inquiry identified the primary sample site as Shell
California Production, Incorporated's River Bottom Unit Gosnell
Well No. 51, near Ventura, California.  No problems were
encountered in arranging sampling for July 15,  1986.  No back-up
site was required.

Site Location

The location of the River Bottom Unit (RBU) Gosnell Well No.  51
is approximately 1,500 feet east of Highway 33, and approximately
5 miles north of the intersection of Highways 33 and 101 in
Ventura, CA.  Figure 1 is a map indicating the drilling site.
The full name and mailing address for Shell is:

       Shell California Production, Inc.
       P.O. Box 11164
       Bakersfield, California  93309
       Main Office Ph.:      805-326-5000
       Main Office Contact:  D. L. Oreolt, Manager
                             Environmental Conservation
                             West Coast Production Division

Attendees

Sampling at the RBU Gosnell site was performed by CENTEC
Corporation personnel on July 15, 1986.  Following is a list  of
people present at the time of sampling:
     CENTEC Corp. (Sample Team)
     EPA Representative:
     State Representative:
     Operator Representatives:
Bill Lane, Technician
Jamie Mclntyre, Team Leader

William Telliard, Chief, Energy
  and Mining Industries Branch,
  Industrial Technology Div.,
  Office of Water

Mike Stettner, California
  Department of Conservation,
Division of Oil and Gas

Ron Cox, Environmental
  Engineering Technician
D. L. LeVan, Operations
  Foreman, Ventura Production
  Unit, Coastal Production Div.
Tod Stallings, Field
  Surveillance Technician
Wayne Kabrich, Drilling
  Supervisor, WCO-Drilling
                             C-226

-------
Figure 1.  Location of Shell Production's River Bottom Unit
           Gosnell Well #51, Ventura, California
                          0227

-------
     American Petroleum
       Institute Representatives:  George Holliday,  Contracted
                                    Observer
                                  Lloyd Deuel,  Contracted Sample
                                    Team Member
                                  Shawn Hokanson,  Contracted
                                    Sample Team Member

The drilling contractor for this well was Cal Pacific Drilling
Company.

Site Description

The RBU Gosnell site is located in a suburban,  piedmont area.
The climate at this site location is net precipitation.  The soil
is described as sand over rock and clay.  The area  is a dried-up
river bed.  The well was completed in the C-Block  formation of
the Ventura basin.   Figure 2 is a map of the exact  location of
the hole.

The depth to the groundwater in the area is approximately 10
feet.  The nearest  surface water is the Ventura River, less than
1/2 mile west of the site.  The nearest drinking water well is
estimated to be greater than 10 miles from the  site.

At the time of sampling, the site consisted of  one  oil well and
four sludge collection bins.  Figure 3 is an approximate
schematic diagram of the site, indicating directions  in which
photos were taken (Attachment A).   The drilling rig for Well No.
51 is shown in the  center of Photo 1.  Figure 4 is  a  schematic
diagram of a typical Cal Pacific drilling rig,  provided by
Operator Representative Wayne Kabrich.  The rig layout has been
enhanced to show the sludge collection bins as  they were situated
at Well No. 51;

This site was originally a developmental oil drilling site but
was changed to an injection well to be used for waterflooding
producing wells in  the vicinity.  Eight wells that  were expected
to benefit from the waterflooding of Well No. 51 included the
following:

               Edison    19
               Citrus    1A
               Gosnell   17, 39, 48, 49
               Notten    7, 11

These wells are also indicated in Figure 2.

Well No. 51 was to be completed at 6,570 feet.   The depth at the
time of sampling was 5,070 feet.  Drilling began on July 7, 1986.

Drilling was accomplished with a saturated saltwater  mud.  The
chlorides content of the mud was estimated to be 12,000 parts per
million.


                             C-22B

-------
                                          ENTURA
Figure 2.
Location of
by Water ?looing
                                       Eiaht Wells Affected
                           C-229

-------
   N

                                  \
                                  \
pkvcfo
Ken
  Figure 3.  Schematic  Diagram of Drilling Site
                         C-230

-------
         Cal Pacific Drilling Company, Inc.
                          RIG 4,5, & 6
                                            TO CATWALK
                                               -a'   y-i
                                                y-Cfca
                                                     tf-W
                                                                 r4 01 A. X
                                                                22-0' DEEP
                                                             rRATHOLE
                                                   VcuLX B'-O'DEEP
                                                MOUSE HOLE
                                               (WELL .
                                                             ri
                                                            RATHOLE  MOUSEHOLC
                                                             ANCLE    ANGLE
                                                            TOWARD  TOWARD
                                                            CATWALK  CATWALK
                                                    **rHOLf/UOUS£HOLf
                                             GfiOUHO
                                            * OCPTH.
NOTE.LOCATION SIZE SHOULD ACCOMMODATE TRUCK ACCESS
     MAX. TRUCK • TRAILER LENGTH M'-O? MAX. WIDTH I2*-0*
     MAX TRUCK • TRAILER WIEGHT; »4,000 LSS
     Na OF LOADS: • LEGAL LOADS AND • PERMIT LOADS
                                          •) MAX. WELL CELLAR DIMENSIONS tt-0' DEEP BY
                                            •'-0* * t'-O* SOUAME.ON ST $'-0' OAMETER
                                          kl KELLY SUSMIH8MIEGHTFROM WOUND LEVEL ZS'-C*
                                          c) LEFT HAND ««, MUD TANK ON OFF-DRILLERS SIDE
                                          4) GROUND LEVEL TO IOTTOM OF ROTART BUMS St-ff
                      TYPICAL  RIG LAYOUT


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Four plastic lined bins were located on the east side of the rig
to provide temporary storage of drill cuttings, residual drilling
muds from the circulation system, and water used to wash off the
equipment around the mud tank.  The pit contents were dropped
from shale shakers at the mud tank, shown in Photos 5, 6, and 7.


One bin holds approximately 300 cubic feet (54 barrels) of
drilling waste.  Figure 3 shows the dimensions of the bin that
was measured and sampled by the CENTEC team.  The operator
estimated that 50 bins will be filled by completion date.  That
is, an estimated 2,700 barrels of cuttings and drilling mud will
be generated from this well.

The depth of liquid in the bin chosen to be sampled was one to
two inches, and the depth of the sludge was between one-half and
three feet.

Disposal Practices

The contents of the disposal bins is vacuumed into trucks and
taken to a facility that treats the sludge to make it a solid
before it is landfilled.  The name and address of the company is:

               VenVirotek
               1536 Eastman Avenue
               Suite 6-A
               Ventura, CA  93003
               Phone:  805-654-1900

The VenVirotek treatment process turns the sludge into a
substance having a gel-like consistency that eventually hardens.
The final product can be used to cover landfills. VenVirotek
cannot accept sludge from drill sites with greater than 5 percent
oil content.

The final disposition of the drilling wastes is the Santa Clara
Landfill.  The main office address for the landfill is:

               Ventura Regional Sanitation District
               1001 Partridge Drive
               Suite 150
               Ventura, CA  93003-5562

Permits

A copy of the drilling permit secured by Shell California
Production, Inc. for the RBU Gosnell Well No. 51 is located in
Attachment B.  In addition, a copy of a Supplementary Notice,
stating that the designation of the well was changed from
"producer" to "injector," is also located in Attachment B.
                              C-232

-------
SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).

Sample Point Locations

At the RBU Gosnell site, the samples were defined as the
supernatant and solid contents of the waste material in one of
four disposal bins in use at the time of sampling.  The bin
immediately north of the southernmost bin was chosen to be
sampled because it had the most even distribution of liquid and
solid contents.

Sample points were identified based on measurements of bin
dimensions.  Howeverr the small quantity of liquid on the surface
of the sludge did not allow for placing every sample point at the
center of measured quadrants,  as with rectangular reserve pits.
In addition, the sludge was too shallow to be collected by the
coring device in particular places, so there is some discrepancy
between measured and actual sample points.  Figure 3 indicates
the measured sample points as well as the actual  sample points
from which the bin samples were composited.

Sampling Methods and Equipment

To collect samples from the disposal bin, measurements were made
to identify the four quadrants shown in Figure 3, and to locate
the center of each quadrant.

The first sample to be collected was the liquid composite.  A
clean 1-quart glass jar was dipped into the supernatant liquid as
shown in Photo 9.  The thief was not used because there was not
enough liquid to submerge it in.  Liquid sample point locations
depended largely upon where the liquid could be safely reached.
The liquid from each sample point was composited  in a
5-gallon carboy.

The reserve pit was then sampled for sludge.  The coring device
was used with a 5-foot extension rod attached.  The sludge was
deepest at the western end, directly under the shale shaker.
Three of the four gallons of sludge collected came from the two
sample points in the western end of the bin.  Photo 11 shows
samplers emptying the coring device into the steel bucket used to
composite the sample.

Tests for the pH and free chlorine content of the samples were
performed onsite after sampling was completed. The pH of both
the liquid and sludge samples  was 7.  The free chlorine content
of the liquid sample was less  than 0.2 ppm (the lowest detectable
level).
                             C-233

-------
C-234

-------
ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-235

-------
C-23*.

-------


    ^	
<~>     Photo  1.   Dril I Ing  r Ig
       Photos
2,3,4.  Northwester.y view of drill site  (rig  In  Photo  #2)

-------
Photo 5.   Two waste bins at mud circulation tank
Photo 6.
                                                                        Waste bin and two shale  shakers
          Waste bin and two shale shakers
Photo 8.  Close-up of bin contents

-------
6F7-D

-------
eidu.es  p|nb||  Bu|jnod  '
                                                                  6u| iduies e6pnis  M I  °4-°Md
                                                                                                            I
                                                                                                           CJ

-------
ATTACHMENT B:  PERMITS
        C-241

-------
C-242

-------
                                    f
                                    \
                                               ll ACCNCY Or CJU.iro*M1A

                                        DEPARTMENT Or CONSERVATION
                                                GAS
                              DIVISION  OF  OIL  AND  GAS
                              Notice of Intention to Drill New Well
CE.Q.A. INFORMATION
EXEMPT Q
OASS 	
NEC. DEC rj
&.CM. NO 	
E-Ll. Q
S.CH. NO 	
DOCUMENT NOT
IEOUHED m
IY LOCAi. liJ
AHISDICDON
SM »r-»rvt SicU
                                                                   "FOB OfVJSON USE ONLY
                                                                                      VENTURA.  CAIiPpPKHA
                                                         MJkf
       •MAP
       «OOK
                                                                                          J2<_
    In compliance with Section 3203, Division 3, Public Resources Code, notice is hereby  given that it is our

  intention to commence drilling well  "RBU  GosnelT'51       weD H™ Producer
                     23W    SB
  Legal description of mineral-right lease,

    attached
                                                                  .Field,
                    Ventura
                                                                                       (Asicacd by Divuioo)
                                     .County.
                                               n(
                                                                icres, is as
                       .  Ple3Se ^66  map
                                                                                  (Attach mmp or
                                      to icale)
 Do mineral and surface leases coincide? Yes_JL
 surface and mineral leases, and map or plat to scale.
.. If answer is no, attach legal description of both
Location of well
feet
                               (Direction)
                                        along
                                                 (Crou out one)
          and
                                                                                  feet
                                                                                          (Dinction)
 at right angles to said line from the
      .corner of
       706'  South  and 879' West from R.C.L.  Cornpr 11
                                                                           (Cira oot on*)
                                                                                                    or
 Is this a critical well according to the definition on the reverse side of this form?      Yes Q        No

 If well is to be directionally drilled, show proposed coordinates (from surface location)  at total depth:
 	4££	feet	tlarlb__and	521	feet   West	
                                   (Direction)                                             (Direction)
 Elevation of ground above sea level	15fi	feet.
All depth measurements taken from top of.
                                             Kelly Bushing
                                      (Dwaek Floor, Rotuy T«bk.or 1UB> Boifcia()
                                PROPOSED  CASING PROGRAM
            .that is.
                    22
                                                                                    .feet above ground.
•IZC Or CASING
INCHES API
13 3/8"
9 5/8"
7"
WEIGHT
54. 5#
36??
26#
CMAOC AND TYPE
K-55 STC
K-55 LTC
K-55 LTC
TOP
0
0
0
•OTTOM
fifin1
2800'
6600'
CEMENTING
DEPTH*
fifin1
2800'
6600'
CALCULATED FILL
BEHIND CASING
fifin1
2800'
6600'
              (A complete drilling program is preferred and may be nibmitted in lieu of the above program.)
Intended zone(s) __ ._
of completion,   C3/C4>   47001.
                                      Hydrostatii
Estimated true vertical depth
                 (None, drptt.tnd exp»ct»d pranw*)

     It is understood that if changes in this  plan become necessary we are to notify you immediately.
Shell Cal
Addrca
P.O. Box
5 326-5684
ifornia Production Inc.
11164
N«m« of Penon FUmf Node*
S. Dormier - Agent P_9
Type of Orsaniza&an (Corporttxxx. Putnenhjp, Indfvidutl. etc.)
Corporation
City
Bakers^ield, CA^
A^^^y
93389-1164
Date
6/06/86
	                         • ^   i    ^        	   f^^t^rfi^J

"his notice and indemnity or cash bond »h.i!l b« filed, and approval given, before d>ffling begins. If
                    operations have not commenced

-------
                                    RESOURCES AGENCY OF CALIFORNIA
                                    DEPARTMENT OF CONSERVATION
                                     DIVISION OF OIL AND GAS
                                                                             No. P 286-193
                                                                                    814
                PERMIT TO  CONDUCT  WELL  OPERATIONS
    S. F. Dormeir, Agent
    Shell Calif. Prod.  Inc.
    P.O. Box 11164
                                                            Ventura
    Bakersfield, CA 93339-1164
                                                           June 16,
                                                                                  (field code}
                                                                                    00	
                                                                                  (area code)
                                                                                    00	
                                                                                 (new pool code)

                                                                                 (old pool code)
                                                                                	, California
 Your	
 A.P.I. No..
          111-21415
                        , proposal to.
                                     drill
                                   Section
                       28
                                    .well.
                                                           "RBU Gosnell"  51
                              ., T. 3N
                                                               23W
    Ventura
S-B-  B. & M.,
  Ventura
 filed in this office.
. County,  dated  6/6/86 - , received
                                                            . area,.
                                                                    no breakdown
                                                                                    - pool,
                                                            been examined in conjunction with records
THE PROPOSAL IS APPROVED PROVIDED THAT:
1.  Hole  fluid  of  sufficient quality and quantity shall  be maintained in the hole to
    control any subsurface  condition,  and a  reserve  supply shall be on hand for emergencies
2.  Blowout prevention  equipment of at least DOG Class  III 3M B shall be installed on the
    13  3/8" casing  and  maintained  in operating  condition at all times.
3.  Sufficient  cement shall  be  used to fill  the annular  space to at least 500 feet above
    oil and gas zones and anomalous pressure intervals,  and to at least 100 feet above
    the base of the  freshwater  zone.
4.  This  office shall be consulted  before placing any plugs or sidetracking any hole.
5.  The Division routinely monitors monthly  well production data, and if anomalous water
    production  is indicated,  remedial  action will be ordered.
6.  This  office shall be consulted  before initiating any changes or additions to this
    proposed operation, or if operations  are to be suspended.
7.  THIS  DIVISION SHALL BE NOTIFIED:
    a.  TO WITNESS a pressure test  of  the blowout prevention equipment before
        drilling below  660'.
Blanket Bond
BW:Ijg
Engineer

Phone
            Bill winkJer
          (805)  654-4761
                                        M. G. MEFFERD, State Oil and Gas Supervisor

                                           6t
                                                               f      deputy Supervisor

 A copy of this permit and the proposal must be posted at the well site prior to commencing operations.
 Records for work done under this permit are due within 60 days after the work has been completed
 or the operations have been suspended.
                                          C-244

-------
                                  RESOURCES AGENCY OF CALIFORNIA
                                    DEPARTMENT OF CONSERVATION

                          DIVISION  OF OIL  AND  GAS
                                  SUPPLEMENTARY NOTICE
 DIVISION OF OIL AND GAS

                Ventura
FOR DIVISION USE ONLY
ftOND
dft
fOKMS
114
*—
121
L-""
                                         .Calif.
A notice to yon dated.. 	 	
Drill
(Drill, rework, tbudon)
^ 28 T 3N p 23W
Ventura
June 6
W»TI Mrt "RBU GosnelT1 SI
S.B.R f, vr
County «hnnM fw> omAnd*"*
1986 stating
APT^n
Ventura
because of chai
111-21415
f,-»7rl
ieed conditions.
 The present condition of the well is as follows:

 Total depth

 Complete casing record including plugs and perforations:
                                                                          'f r-
                                                                                    'AS
         We now propose   to change  well designation to injector.  Please  see attached
         casing diagrams of all wells withing  1/4 mile radius.
     It is understood that if changes in this plan become necessary we are to notify you immediately.

          P.O. Box  11164	      r£frglL Call fern la Production Inc.
                      (Street)
          Bakersfield,  CA
               93389-1164
      (City)

Telephone
         (Sute)

(80S) 326-5684
                                      (Zip)
(D»u)
                                                Type of Organi2arion__^£!!P°E£i2£D	
                                                                  (Corpnndon, PiitDcnbip, lodividuil, etc.)
FO»K 123 IMCV. 1.71)
                                          C-245

-------
                                    RESOURCES AGENCY OF CALIFORNIA
                                    DEPARTMENT OF CONSERVATION
                                     DIVISION OF OIL AND GAS
                                                                                p 286-224
                                                                                      814
                PERMIT TO  CONDUCT  WELL  OPERATIONS
                                                      WATERFLOOD
     S. F. Dormier, Agent
     Shell Calif. Prod.  Inc.
     P.O. Box 11164	
     Bakersfied, CA 93389-1164
                                                               Ventura
                                                               July 9, 1986
                                                                                   (liold code)
                                                                                      00
                                                                                   (area code)
                                                                                      40
                                                                                 (new pool code)
                                                                                     00
                                                                                 (old pool  code)
                                                                                 	, California
 Your.
         supplementary
 A.P.I. No  HI- 21415
 	\7onf TIT" a	
                         , proposal to.
                                       drill
            .well.
                     'RBU Gosnell"   51
                                    Section—
                                field,   any
23-
., T
., B.  23W	S.B.  B. & M.,
	area,  C-3/C-4A(W)	pool,
                  .County,  dated—7/1/86    .received,  7/7/86   ha* been examined in conjunction with records
 filed in this office.

 THE PROPOSAL IS APPROVED PROVIDED THAT:
 1.  Injection shall cease if any evidence of damage  is observed,  or upon written notice
     from the Division.
 2.  This office shall be consulted before initiating any changes  or additions to this
     proposed operation, or if operations are to be suspended.
 3.  THIS DIVISION SHALL BE NOT-IFIED:
     a.   TO WITNESS a survey to demonstrate that injected fluid  is confined
         below the highest perforated interval.
     b.   TO WITNESS a step rate test.
 Blanket  Bond
 MS:ljg
           Michael  Stettner
Engineer

Phone  _(805) 654-4761
                                                          M. G. MEFFERD. State Oil and Gas Supervisor

                                                          By
                                                                             visor
                                                                      Deputy'Supervi:

A copy of this permit and the proposal must be posted at the well site prior to commencing operations.
Records for work done under this permit are Qae&dthin 60 days after the work has been completed
or the operations have been suspended.
or.n,    	                         C~246

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                          Sampling  Report
             Investigation of McFarland Energy, Inc.
                  Section  24  Production  Facility
                     Midway Sunset Oil Field
                     Kern County, California
                          July 16, 1986


SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA 530-SW-87-005).  This site was selected randomly from
a computerized list of 335 active San Joaquin Basin production
sites developed by the California Bureau of Land Management at
the request of EPA.  The list was transmitted via overnight
service to the EPA contractor on July 3, 1986.  Randomization and
site selection took place immediately upon receipt.

The EPA contractor had no interest in the manner the particular
sites were listed  (by site name, location, operator, permit
number, API number, etc.)  as long as the site could be identified
in detail upon selection.   Thus, the EPA contractor had minimal
information which kept to a minimum the amount of bias.  No other
information was known about the sites on the list at the time of
selection.  Detailed information was obtained only after
selection of primary and back-up sites.

The computerized listing showed the possible sample sites by
operator, type of operation, permit number, general location, and
disposal practice.  For simplicity of selection,  the sample site
was randomly selected based on the permit number.  The list was
too extensive to include herein.

As indicated above, the EPA contractor used permit numbers for
randomization.  A random number table was used to select the
primary and back-up sample sites.  The randomly-selected primary
site was SAC 021030, McFarland.

Further inquiry identified the primary sample site as McFarland
Energy, Incorporated's Section 24 Production Facility in the
Midway Sunset Oil Field in Kern County,  California.  No problems
were encountered in arranging sampling for July 16, 1986.

In case the primary site was inaccessible or inappropriate, a
back-up site was also randomly selected.  The back-up site was
McFarland SAC-065975.   On investigation, it was discovered that
the back-up site was shut-in.  However,  the back-up site was not
needed.
                              C-247

-------
Site Location

The McFarland production facility is located approximately
1/2-mile east of Highway 33,  3 miles north of Fellows,  CA in Kern
County.  Figure 1 is a map indicating the production facility
site.  The full name and mailing address for McFarland  Energy is:

          McFarland Energy,  Inc.
          P.O. Box 3608
          10425 South Painter Avenue
          Santa Fe Springs,  California  90670
          Main Office Ph.: 213-944-0181
          Main Office Contact: Andrew McFarland
                               Vice President for Production

Attendees

Sampling at the McFarland production site was performed by CENTEC
Corporation personnel on July 16, 1986.  Following is a list of
people present at the time of sampling:
     CENTEC Corp. (sample team):
     EPA Representative:
     State Representatives:
     Operator Representatives:
Bill Lane, Technician
Jamie Mclntyre, Team Leader

William Telliard, Chief, Energy
  and Mining Industries Branch,
  Industrial Technology
  Division, Office of Water

Ted Anderson, Physical
  Scientist, U.S. Dept. of the
  Interior Bureau of Land
  Management, Bakersfield Dist.
  Minerals Division
Hal Stoops, Supervisory
  Petroleum Engineering
  Technician, Bureau of Land
  Management, Bakersfield
  Dist. Minerals Division

Leroy Woods, Foreman, Midway
  Sunset Field
     American Petroleum
       Institute Representatives: George Holliday, Contracted
                                    Observer
                                  Lloyd Deuel, Contracted Sample
                                    Team Member
                                  Shawn Hokanson, Contracted
                                    Sample Team Member
                              C-248

-------
             x\  \M,^4.V i: ^/rn^T^-^-rr'^,. J

               Wi^arNt.a^s/feiJ.r-'V^-.!?'  srh  =uy
             • \«  ^^^^n /  v ;'' P: ;;;^;-::., •'•  '=;;y_ ~  —
Figure 1.   Location of McFarland Eneray, Inc.'s  Section 24

            Production Facility,  Kern County, California
                              C-249

-------
Site Description

The McFarland production facility is located in a rural flatland
area in the Midway Sunset Oil Field.  The climate at this site
location is net evaporation.  The soil consists largely of sand.
Wells serviced by this facility are completed in the Gusher
formation of the San Joaquin Basin.

The depth to the base of fresh groundwater in the area is between
1,400 and 1,500 feet.  The nearest surface water is Buena Vista
Lake, located approximately 10 miles east of the site.  The
nearest drinking water wells are located 10 to 15 miles from the
site.

Figure 2 is a map identifying the wells on U.S. Lease No.
SAC-021030, serviced by the McFarland facility.  Wells 2, 4,
and 5 are still functional, but only No. 4 was operating the day
of sampling.  Daily production for these wells averages 4 to 5
barrels of oil, and 30 barrels of produced water.  The average
depth of the wells on this lease is 1,800 feet.

At the time of sampling, the site consisted of one 2,500-barrel
oil and water separating tank (referred to by the operator as a
"wash tank") and one oil skimming sump.  Figure 3 is an
approximate schematic diagram of the site location, indicating
the directions in which photos were taken (Attachment A).
Produced water leaving the wash tank is shown in Photos 2 and 3.
The water flows from this outfall to the sump shown in Photos 4
and 5.  Finally, the water is discharged to the surface,  shown in
Photos 8 through 11.  The reddish residue along the path of the
water suggested a high iron content.

A corrosion inhibitor made by Baker Chemical is added to the wash
tank at a rate of approximately 2 quarts per week.

The sump is cleaned once per year.  The wash tank has been
cleaned only once in the 25 years it has been in use.  It has
been 6 to 8 years since the wash tank was cleaned.

Disposal Practices

Produced water is discharged to the surface and is carried by
natural drainage to commercial disposal sumps operated by Valley
Waste Disposal.  This facility has recently been using injection
wells for disposal, due to public concern about endangered
species in the area.

McFarland representative Leroy Woods stated that the produced
water leaving the production site generally evaporates or
percolates into the ground before it reaches the commercial
disposal site.
                              C-250

-------
                                                          13
• „ •. ,/»t • -,•••
           ^^Q
                                                               MIDWAY SUNSET
                                                               KERN CO       CALIF
                                                                 SCALE I" = i200'
                                                                    Moren I, 1986
           Figure  2.   Locations of Wells  and Production  Facility
                                   C-251

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                                           Oil
                                0( 1
                          PWuttc/ ^^-^'

                          f« $)<;„..>.'•*.  '
                             'iuv^Sb
V
Fiaure  3.   Schematic Diaaran of  Production Facility
                        C-252

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Permits

No operating permits were made available to the sample team at
the time of sampling.


SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).

Sample Point Locations

At the McFarland production facility, the sample was defined as
the fluid leaving the wash tank, shown in Photo 2.  The produced
fluid sample was obtained at the end of the pipe leaving the wash
tank.

Sampling Methods and Equipment

Samplers at this site were U.S.  EPA representative William
Telliard and CENTEC representative Bill Lane.  At the direction
of Mr. Telliard, the sample was  collected in individual sample
bottles by holding the bottles under the running stream shown in
Photo 2.

Tests for the pH and free chlorine content of the fluid sample
were conducted onsite after sampling was completed.  The pH was
7, and the free chlorine content was less than 0.2 ppm (the
lowest detectable limit).                                    \
                             C-253

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C-254

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-255

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C-256

-------
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                            C-258

-------
o
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Photo  8.  Discharge from wash  tank flowing down hll
                      i—;- u-^Tir v. • ,-n s » ,•: ^>
                      i ^r  *. .'fir'B jF/  I'-TS'"*'
                      r/*roifc$«s
                                                                          Photo 9.  Discharge from  wash tank

                                                                                   fIowIng down hill
           Photo  7.  Samplers and observers

-------
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      Photo 10. Close-up of stream created by tank discharge
                                                      y**ii» •.
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                                                      Photo 11. Discharge flowing toward

                                                             dra I nage d i ten

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ATTACHMENT B:  PERMITS
         C-261

-------
C-262

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No permit specific to the operation
    of  this site  is  available.
               C-263

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C-264

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                          Sampling Report
       Investigation of Shell California Production, Inc.'s
                 Gore C Lease Oil Well No.   50-3P
                     Midway  Sunset Oil  Field
                     Kern County, California
                          July 16, 1986


SITE INFORMATION

Site Selection

This site was intended to be  randomly selected by EPA as
described in the sampling strategy document in Appendix B  of the
EPA Technical Report (EPA 530-SW-87-005), with the changes noted
below.  This site was originally planned to be selected randomly
from a list of active San Jouquin Basin drill sites developed by
the California Bureau of Land Management at the  request of EPA.
The list was to be developed  immediately prior to July 17, 1986,
the scheduled sampling date.  The short time frame was deemed
necessary because of the rapid nature of drilling in this  basin.
It would be impossible to plan drill site sampling more than a
day or two in advance. Randomization and site selection were to
take place at BLM the day before sampling.

One day prior to the scheduled sampling time the Bureau of Land
Management was unable to locate a drill site at or near
completion for sampling.  George Holliday, of Holliday
Environmental Services (formerly of Shell Oil Company, currently
representing the American Petroleum Institute), took the
initiative of calling his own industry contacts in the area.
Mr. Holliday was able to locate a drill site.  The EPA contract
sampling team opted to obtain this sample rather than to depart
without sampling a drill site in the San Jouquin Basin.  The site
is considered a random sample because it was the only site known
in the desired area during the necessary time frame.

The site was identified as Shell California Production
Incorporated's Gore C.  Lease, Oil Well No. 50-3P, in the Midway
Sunset Oil Field in Kern County,  California.  Shell was amenable
to participating in the sampling program, but could not guarantee
that the drilling wastes would still be onsite  on July 17, 1986.
The sampling team proceeded immediately to the  site.  Sampling
was conducted well into the evening.


Site Location

Gore C Lease Well No. 50-3P is located approximately 3 miles west
of Highway 33,  and approximately 5 miles northwest of Fellows,  CA
in Kern County.   Figure 1 is a map indicating the well site.   The
full name and mailing address for Shell is:
                              C-265

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Fiqure 1.  Location of Shell Production's Gore C Lease Well
           #50-3P, Midway Sunset Oil Field,  Kern County,  California
                             C-266

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          Shell California Production, Inc.
          P.O. Box 11164
          Bakersfield, California  93309
          Main Office Ph.:      805-326-5000
          Main Office Contact:  D. L. Oreolt, Manager
                                Environmental Conservation
                                West Coast Production Division
Attendees
Sampling at the Gore C Lease Well No. 50-3P was performed by
CENTEC Corporation personnel on July 16, 1986.  Following is a
list of people present at the time of sampling:
     CENTEC Corp.  (sample team):
     State Representative:
     Operator Representative:
Jamie Mclntyre, Sample Team
  Leader
Bill Lane, Technician

None present (Ted Anderson of
  the Bureau of Land Manage-
  ment, Bakersfield District,
  was asked but could not
  attend)

Jim Simpson, Drilling Foreman
     American Petroleum
       Institute Representatives: George Holliday, Contracted
                                    Observer
                                  Lloyd Deuel, Sample Team Member
                                  Shawn Hokanson, Sample Team
                                    Member

The contractor to drill at this site was the Golden State
Drilling Company.


Site Description

Figure 2 is a diagram, provided by Shell, of the exact location
of the Gore C Lease Well No. 50-3P.  The well location is in
rural flatland, although the site was situated on a slight grade.
The climate at this site location is net evaporation.  The soil
in the area is a mostly sand.  The well was planned to be
completed in the Potter formation of the San Jouquin basin.

The depth to the base of fresh groundwater in the area is between
1400 and 1500 feet.  The nearest surface water is Buena Vista
Lake, located approximately 10 miles east of the site.  The
nearest drinking water wells are located 10 to 15 miles from the
site.

At the time of sampling, the site consisted of the Golden State
Drilling Rig No. 6 and one reserve pit.  Figure 3 is an
                               C-267

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Figure 2.  Grading Plan and Well Location



                    C-268

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O '
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      Figure  3.   Schematic Diagram  of Drilling Site
                          C-269

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approximate schematic diagram of the site location, indicating
the directions in which photos were taken (Attachment A).
Although the site is not fenced in, the entire lease is fenced,
requiring access through a supervised gate.

This site was a developmental oil drilling site.  The well was
planned to be completed at 1,287 feet, and was at a depth of
1,100 feet the day of sampling.  Drilling began July 15,  1986 and
was estimated to be completed by July 20 or 21, 1986.

Drilling was accomplished first with a water base spud mud,
followed by a low-solids polyacrylic mud.  The estimated total
volume of cuttings and drilling mud associated with drilling this
well was between 400 and 600 barrels.

The reserve pit at the site is shown in relation to the drilling
rig in Photos 2 and 3.  The pit was designed for the temporary
storage of drill cuttings and residual drilling mud that left the
mud circulation system.  Drill cuttings entered the pit from the
shale shaker, shown in a side view in Photo 4.  Fluids from the
mud circulation tanks leaked from the rig and down the side of
the pit.  Photo 5 shows a stream of fluid flowing into the pit
from an overhead view.  Nothing was piped into the pit.

The only requirement regarding construction of the reserve pit is
that it must be large enough to contain 300 barrels of liquid and
solids.  The operator stated that the size of reserve pits in
this area is arbitrary and site specific for the particular well
being drilled.  The size is estimated by calculating the amount
of cuttings to be obtained and by estimating the amount of fluid
volume generated when changing from drilling mud to a completion
fluid system.

There, are no specific statewide requirements concerning the size
of reserve pits.  However, each local agency may impose
restrictions if they choose.  Kern County does not have any such
restriction on size.

The pit was constructed below grade, approximately as wide as a
bulldozer blade.  Figure 3 shows the dimensions of the pit
measured by the sample team.  Three sides of the pit were
vertical with an 8-foot drop to the surface of the liquid.  The
fourth side was inclined enough to allow walking to the edge of
the liquid surface.  Photo 6 views the pit from the top of the
inclined side.  The depth of the liquid in the pit at the time of
sampling was 1 to 1-1/2 feet, and the sludge depth was 1 to 2
feet.

Approximately 1,500 gallons of diesel were being stored onsite in
tanks.  An estimated volume of 2 gallons of waste oil from engine
oil leaks was expected to be generated onsite.  This oil could
have possibly made its way into the reserve pit.
                              C-270

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In regard to analyzing the contents of the reserve pit, the
operator made the following remarks:

     Because of the numerous wells that have been drilled in
     the area, each and every pit is not routinely analyzed
     during drilling or prior to disposal.  However, the
     drilling muds used are formulated according to the
     Department of Health Services Approved List of
     additives which will not render the mud hazardous when
     used according to the manufacturer's recommended
     practices.  In addition, representative cuttings from
     the field have been analyzed to determine whether any
     formations are penetrated which might render the pit
     contents hazardous.

A copy of the "Approved List" of drilling mud additives is
included in Attachment C.  A copy of a laboratory report on well
cuttings from another well on the Gore C lease is included in
Attachment D.

Disposal Practices

The free liquid and sludge from the reserve pit would be removed
by a vacuum truck owned by B&L Vacuum Trucking Co., and hauled to
Petroleum Waste, Inc., a disposal facility in nearby
Buttonwillow, CA.  The solid residue remaining in the pit would
be allowed to dry, and the pit would be backfilled and restored
to natural contours.

Permits

A copy of the drilling permit secured by Shell California
Production, Inc. to drill Well No. 50-3P on the Gore C Lease in
the Midway Sunset Oil Field is located in Attachment B.


SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report  (EPA 530-SW-87-005).

Sample Point Locations

At the Shell site, the samples were defined as the supernatant
and solid contents of the waste material in the reserve pit.

The sample points were obtained by standing on the sides of the
pit rather than from a boat within the pit for two reasons.
First, sampling began at approximately 5:00 p.m., and there was
concern about getting the samples shipped on time.  Second, the
pit was considered small enough to obtain samples by accessing
the pit from the sides.  Figure 3 indicates the measured sample

                               C-271

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points as well as the actual sample points from which the pit
samples were composited.  Samples were not taken along the side
of the pit nearest the rig because it was unsafe to walk there.

Sampling Methods and Equipment

To collect samples from the reserve pit, the pit was measured to
identify the four quadrants shown in Figure 3, and to locate the
center of each quadrant.  The measured points were marked with
stakes to facilitate locating sample points.

The first sample to be collected was the liquid composite.  The
thief was used by attaching the gaging tape to the thief and
lowering it to the liquid in the pit.  Care was taken not
to allow oil floating on the surface of the liquid to enter the
thief.  The liquid from each sample point was composited in a
5-gallon carboy.

The reserve pit was then sampled for sludge.  The dredge was used
at this site because the sludge was too dense to enter the glass
core sleeve without breaking it.  Sludge was collected at each
point where liquid was collected, as well as from the cuttings
pile.  The sludge was composited in the steel bucket.

Tests for the pH and free chlorine content of the samples were
performed onsite after sampling was completed.  The pH of both
the liquid and sludge samples was 6.  The free chlorine content
of the liquid sample was less than 0.2 ppm (the lowest detectable
level).

The samples were held overnight under refrigeration before
shipment to the laboratories.  This was necessary because
sampling activities extended past the time when shipping on the
day of sampling was possible.
                             C-272

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                 C-273

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C-274

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O
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       Photo  I .   DrI I I Ing  rig
                                                          Photo 2.  Reserve pit and mud circulation tank
                                                          Photo 3.  Reserve  pit

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                Q.


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                                                           Photo 7.  Reserve  pit
            Photo 6.   Pump lines in reserve pit

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C-278

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ATTACHMENT B:  PERMITS
         C-279

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o
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 Fora 3160-3  *"
 (November 1983)
                              UNITED STATES
SUBMIT IN
 (Oth*r Inatructloc
    rererse side)
       oved.
      5ureau No. 1004-0136
Expires August 31, 1985
DEPARTMENT OF THE 1
BUREAU OF LAND MANAC
WTTDinF?
U < t.niWI\ 5. LEASE DESIGNATION AND SERIAL NO.
;EMENT . --- Sac. 021592
APPLICATION FOR PERMIT TO DRILL, DEEPEN, OR PLIKTBACK 9 -»»*.. *«««.<>. «,...«.
la. TTPE or woaK
DRJLL ffl DEEPEN [
b. TTPE Or WELL
OIL rn °AS r~i
WELL LAI WELL 1 	 1 OTHER
2. NAME Or OPERATOR
Shell California Production Inc.
3. ADORERS Or OPERATOR
P. 0. Box 11164 Bakersfield, CA 93389

H PLUG BACK D 7- BhIT ««1*«1. uui v>.i 1JID aulvIT „, iM,
Section 21, T31S, R22E,
--M..D.B.&.M.
14. DISTANCE IN- MILES) AND DIRECTION- rioW NEAREST TOWN OR POST OWCE*— 12. COCNTT OR PARISH 13. STATE
See attached road map " "- -Kern Calif.
IS. DISTANCE raOM PROPOSED* Tjn 1 f-,.— £..,+.
LOCATION TO NEAREST 1 OU TrOITI t3St
PROPEETT OR LEAER LINE. n. •, - „ 1 ,' „ „
(Alto to nearest drlg. unit line. If any) 16856 1 1 06
13. DISTANCE FROM raorosED LOCATION* en i f>nm
TO NEAREST WELL. DRILLING. COMPLETED.-10 ' ' UUI
OR ATPUtD FOR. ON THIS LEAM. PT. W6 1 1 50" 3 I
21. ELEVATIONS (Show wb«th«r DF. RT. GR, »«
5--22-S6



X* 1 C "3S
           OF APPRUVIL. IT ANT 1
                                                C-281
                                      *S<« Instructions Cn R
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C-282

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ATTACHMENT C:  CALIFORNIA DEPARTMENT OF HEALTH SERVICES'
          LIST OF DRILLING MUD ADDITIVES USED
             IN NONHAZARDOUS  MUDS  AND  FLUIDS
                          C-283

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C-284

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•MT Of CAUtt>«*«*-MtAlTM ANP Wnf AU AGENCY                                     IDMUND C. MOWN

)EPARTMENT  OF HEALTH SERVICES
4/744 P JTHETT
kCIAMSNTO. CA V3IU              Q
    32^-1789                 0705 RPR*9  85
                             TO:    EPS, WMS, WWTF              July 9> l982

                             FROM:  TOM COBNWELL

                             Still the current list per
                             Tracy.	'      	
                                                                    APR -04  1985
     TO:       Producers, Transporters, and Disposers  of
               Waste Drilling Muds and Fluids

     FROM:     Hazardous Waste Management Branch
               714 P Street, Room 523

     SUBJECT:  Identification of Nonhazardous Waste Drilling Muds  and  Fluids
     Waste drilling muds and fluids are listed in state hazardous waste  regulations
      (Section 66680, Chapter 30, Division A, Title 22,  California Administrative
     Code) as hazardous wastes if the muds or fluids contain hazardous materials.
     That listing does not take into account the likely dilution of hazardous  addi-
     tives during drilling operations.

     Since the time of the listing, the Department has  obtained from laboratory  test-
      Ing and from manufacturers more information about  the nature of drilling  fluid
     additives and their usage.

     The Information has made possible the development  of the enclosed list of chem-
      ical and material drilling fluid additives which the Department has concluded
      do not  render the waste muds and fluids hazardous  wastes.  Note that some chem-
      icals on the enclosure are listed In the regulations as hazardous wastes  (e.g.,
     phosphoric  acid and sodium hydroxide).  If these,  and other additives, are di-
      luted and used as recommended by the manufacturers, however,  they will not cause
      the waste muds and fluids to be considered hazardous wastes.

     Accordingly, persons producing, transporting, and disposing of waste drilling
      muds and fluids containing only the  listed additives may manage them as non-
      hazardous wastes, provided they do not contain substantial concentrations of
      toxic substances  from other sources  (e.g., toxic metal from geological depos-
      its encountered during drilling operations).  Drilling muds that contain addi-
      tives which are not included on the  list will continue to be considered haz-
      ardous  waste.  The Department will periodically revise the enclosed list as
      more  information  Is obtained.   If you wish to add a chemical  or material  to
      the  list,  please  send to the Department supporting data such as Material  Safe-
      ty Data Sheets, chemical compositions, toxic!ties, and concentrations used
      (e.g.,  Ibs/bbl).
                                            C-285
                                              I

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                                      -2-
Please note that all  waste drilling muds  and fluids,  hazardous  and nonhazardous,
must be disposed at sites  approved by  the Regional  Water Quality Control  Boards.

If you have any questions  on this  matter  please contact the Chemical  Support
Unit at 
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                    CALIFORNIA  DEPARTMENT OF HEALTH SERVICES
                      0      DRILLING  MUD ADDfTIVES
                 USED IN NONHAZARDOUS  DRILLING MUDS AND  FLUIDS3

                                    Hay  1982
 1.  Aluminum stearate (Aluminum tristearate)

 2.  Attapulglte clay

 3.  Bagasse (dried sugar cane)

 4.  -Barium sulfate

 5.  Bentonlte

 6.  Calcium carbonate

 7.  Causticized lignite (Sodium lignite)

 8.  Cellophane

 9.  Chrome free 1 ignosul fonate

10.  Cottonseed pellets

11.  Diamines and fatty acid amides

12.  Detergents

.13.  Ethylene oxide adducts of phenol  and nonylphenol

14.  Guar gum

15.  Hydroxyethyl cellulose

16.  Lecithin

17-  Lignite

18.  Magnesium oxide

19.  Methanol

20.  Mica                        .

21.  Morpholine polyethoxyethanol
 These additives will not a render a waste drilling mud or fluid hazardous when
 used according to manufacturer's specifications and provided no other nonlisted
 hazardous constituents are used.    C-28t

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Drilling Mud Additives                 -2-


                      Q



22.  Nut shells


23.  Paraformaldehyde


24.  Peptized bentonIte


25.  Phosphoric acid


26.  Polyacrylamide resin


27.  Polyanionic cellulosle polymer


28.  Polysaccharides


29.  Potassium chloride


30.  Potassium hydroxide (Caustic potash)


31.  Potassium sulfate


32.  Pregelatinized corn starch


33-  Quartz or Cristobalite


34.  Rice hulls


35.  Sawdust


36.  Shredded paper


37.  Sodium acid pyrophosphate


38.  Sodium bicarbonate (Bicarbonate of soda)


39-  Sodium carbonate (Soda ash)


40.  Sodium carboxy methyl cellulose


41.  Sodium chloride


42.  Sodium hexametaphosphate


43.  Sodium hydroxide  (Caustic soda)


44.  Sodium montmorllloni te clay


45.  Sodium polyacrylate


46.  Sodium tetraphosphate
                                     C-288
                                         I

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Drilling Mud Additives                 -3-
                  Q
47.  Starch

48.  Tetrasodium pyrophosphate

49.  Trlbutyl phosphate

50.  Vegetable and polymer fibers,  flakes,  and granules

51.  Vinyl acetate/Haleic anhydrie  copolymer

52.  Xanthan gum (XC polymer)
                                   C-289

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C-290

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ATTACHMENT D:  LABORATORY REPORT ON
  WELL  CUTTINGS  FROM  GORE  C  LEASE
                C-291

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C-292

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•••II •••---•
[ 	 ] 1 ZALCO LABURATORittD, IINIU.
/ L\ Analytical &. Consulting S
v_ ^
Shell California Production Inc.
P.O. Box 11164
Bakersfield, CA 93389-1164
Attention: Ray Ouelette
I}f=>n\/iof=»C3

Laboratory No: 4225-2
Date Received: 1-25-85
Date Reported: 2-28-85

til/, / J/
Sample Description: Midway Sunset Gore C7-5N Composite l/J^-/l O^jV/^^
Sample as received:
pH 7.74
~~
Moisture, wt. % 23.6
California Department of Health Services (CAM) revised 1-11-84

TTLC Total Cone.
mg/kg mg/kg
Cadmium, Cd 100 0.1
Chromium, Cr 2500/500 9.5
Cobalt, Co 8000 2.5
Copper, Cu 2500 7.5
Lead, Pb 1000 4.8
Nickel, Ni 2000 14.2
Silver, Ag 500 <0.3
Thallium, Tl 700 2.2
Zinc, Zn 5000 23
Barium, Ba 10,000 92 .
Beryllium, Be 75 0.2
Molybdenum-, Mo 3500 <2
Vanadium, V 2400 19
Antimony, Sb 500 <0.01
Arsenic, As 500 1.03
Mercury, Hg 20 <0.01
Selenium, Se 100 0.12
Fluoride, F 18,000 <10
TTLC - Total Threshold Limit Concentration
Extractable
STLC Concentration
mg/1 mg/1
1
560/5
80
25
5.0
20
5
7.0
250
100
0.75
350
24
15
5
0.2
1.0
180

STLC - Soluble Threshold Limit Concentration
WET - Waste Extraction Test. pH 5.0 Solution, 0.2 M Citrate Buffer.
All values are below the STLCs so that no

)
- RLP/sw
soluble testing is necessary.
Richard L. Penner
Chief Chemist

V zl^nQ Anmr-M in Av/«=n. 11= RsaL-oneafiealri Raliff-inoin <=?r^!^nH 	 S
                               [805]
3539

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COLORADO
     C-295

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C-296

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                         Sampling Report
                 Investigation of E-Vap, Limited
                        Greeley, Colorado
                          July 11, 1986
SITE INFORMATION

Site Selection

EPA specifically selected the E-Vap, Limited facility to obtain
technical information and analytical data regarding the regional
practice of using centralized pits for disposal of wastes from
multiple oil and/or gas sources.  More detailed information about
the rationale for selection of centralized disposal pits is
contained in Appendix B of the EPA Technical Report (EPA 530-
SW-87-005).

EPA worked cooperatively with the Colorado Department of Health
to identify and select the E-Vap, Limited facility.  No problems
were encountered arranging for sampling to be conducted on
July 11, 1986.

Site Location

E-Vap, Limited is located 7 miles southwest of Greeley, Colorado,
off County Road 54 connecting to State Route 257.  Figure 1 is a
map indicating the disposal site.

The site is operated by Travelers Insurance Company in Denver,
CO.  The contacting office has the following mailing address and
telephone number:

             5404 24th Street
             Greeley, CO 80634
             303-339-0929
             Contact Name: Robert Dragich

Attendees

Sampling of E-Vap,  Limited was performed by CENTEC Corporation
personnel on July 11, 1986.  The following is a list of people
present at the time of sampling:
     CENTEC Corp. (sample team):
     State Representatives:
Bruce Hoskins, Team Leader
Dewayne Buskey, Technician

Scott Winters, Geologist,  CO
  Dept. of Health
Stephen Pott,  Petroleum
  Engineer, CO Oil & Gas
  Conservation Commission
                              C-297

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Figure 1.  Location of E-Vap,  Limited,  Greeley,  Colorado
                        C-298

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     Operator Representative:      Robert Dragich, Operations
                                     Manager
                                   Kenneth Thrasher, Operator

     American Petroleum
       Institute Representatives:  George Holliday, Contracted
                                     Observer
                                   Alan Wilson,  Contracted Sample
                                     Team Member
                                   Earl Hinsley, Contracted
                                     Sample Team Member

Site Description

E-Vap, Limited is located in rural flatland; the depth to
groundwater is 51-75 feet, and the nearest surface water is 1/2-2
miles away.  There are no drinking water wells within a 1-mile
radius of the site.  The soil in this area is clay.  The climate
at this site is net evaporation.

This site is a commercial central pit facility for brine.  Annual
operation hours are 8780.  Proximity of clientele ranges in 0-50
mile radius from the facility.  The facility utilizes an
evaporation system for produced waters.  The facility accepts
produced water, completion fluids, and workover fluids trucked
from outside.  Maximum daily capacity of the facility is 5000
bbl.  Average daily influent is 2000 bbl.  Fluids are unloaded at
a dumping station and proceed to sludge skimmers.  The water then
flows through three consecutive oil-water separation tanks.
Saleable oil recovered is placed in oil storage tanks.  The water
is then placed into one of four evaporation, aeration ponds.
Equipment needed at the facility for this operation includes two
tank batteries, an artificial well head, a five-state skim
system, heater treater system, oil washing facility, and aeration
system with air compressors.  Capitol investment for this
equipment was $287,000.  The facility has 12 acres of evaporation
ponds.  The cost for pit construction was $450,000.  The total
cost for constructing the facility was $900,000.  Engineering and
consultant costs for pit treatment were $80,000.  Operational
labor costs are $15,000 per month.

Figure 2 is a schematic diagram of the disposal site.  Four
separate pits have been constructed for the site.  All pits are
constructed above grade.  The pits are lined with a 1.5-foot-
thick bentonite layer.  The purpose of the pits is for
evaporation of produced fluids.  Leak detection monitoring is
required.  There is a peripheral drain system that requires
monitoring four times a year.  The evaporation ponds are equipped
with a sprinkler system for aeration and to enhance fluid
evaporation.  The pits are also chemically treated with borax,
calcium hypochlorite, and potassium permanganate.  Monthly
chemical treatment costs are $3000.  On the day of sampling, the
liquid depth of the pond selected for sampling was 2.5 feet.  The
sludge depth was 2-3 inches.  The liquid depths of the remaining


                              C-299

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o
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to
O
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O   '"""
            Figure 2.   Schematic Diagram, E-Vap,

                       Limited

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pits were no greater than 1 foot and sludge depths of less than
1/2 foot.  The pits are constructed to be in operation for 15
years.  The individual pits are not fenced; however, the entire
site is fenced.  Photos 1 and 2 in Attachment A show the interior
of the truck dumping area.  Photo 3 shows the exterior of the
dumping area and the sludge skim tanks. Photos 4-9 show the four
evaporation ponds as seen from the top of one of the oil-water
separation tanks.

The influent is tested for its physical and chemical properties
prior to treatment.  The final disposition of the pit fluids is
evaporation.  The solids from the skim tanks are collected and
placed in a designated pit.  The final disposition of these
solids was unknown to site personnel.

Permits

A copy of the facility's permit was not available to the sample
team at the time of sampling.


SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).The following
is a description of site-specific sampling information and
activities.

Sample Point Locations

The samples collected at E-Vap, Limited consisted of one
supernatant sample and one sludge sample from the evaporation
pond closest to the dumping zone.  Figure 3 shows the sampling
locations within the evaporation pit.  This pit measured 395 feet
in length and 385 feet in width.  This evaporation pit was
selected for sampling over the other three because it was the
most recently active pond.  The other pits had not received
recent fluids and, as a result, had a substantially lower liquid
level due to evaporation.  Analysis of samples from any of the
other three pits would show analytes in concentrated form.  Prior
to sampling the pit and its contents had been treated.  This
treatment included aeration, addition of fresh water, and
addition of calcium hypochlorite.

Sample points were accessed by boat.  There were no discrepancies
between the actual and measured sample points caused by the
inaccessibility of the measured point.
                              C-301

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                                               _ 315"
o

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o
ro
                 185'
                                     Figure 3.  Sampled Evaporation Pond

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Sampling Methods and Equipment

To collect the samples, the pond was measured to identify the
four quadrants and to locate the center of each quadrant.  Liquid
sampling was conducted with the liquid thief from the boat;
Sludge sampling was conducted from the boa't using a Ponar dredge.
The coring tube was not used because of concern that the tube
might penetrate the bentonite clay liner in the pit.

After sampling was completed, the pit supernatant was tested
onsite for pH and free chlorine content.  The pH was found to be
8 and free chlorine was less than the lowest detectable limit of
0.2 ppm.
                             C-303

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C-304

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-305

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C-306

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Photo  1.  Truck unloading  zone
O

u>
o
                                                                Photo  2.   Interior  of  truck  unloading  zone
                                      Photo  3.   Exterior of  truck unloading zone and sludge

                                                skim tanks

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E-Vap, Ltd. evaporation ponds
       Ltd. evaporation ponds

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ATTACHMENT B:  PERMITS
        C-309

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C-310

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No permit specific to the operation
     of  this  site  is  available.
               C-311

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C-312

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KANSAS
  C-313

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C-314

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                         Sampling Report
                Investigation of Cindy Van Dyke's
                    Gentry Lease Well No. 2A
                    Montgomery County, Kansas
                          •July  2, 1986


SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA 530-SW-87-005).   In most cases,  site selection could
be made from a list of appropriate sites several days in advance
of the sampling team's arrival.  However, the Forest City Basin
in southeast Kansas is shallow, often requiring a single day for
drilling.  This situation of very quick drilling and completion
made it impossible to develop a list of sites at or near
completion for the scheduled sampling date of July 1, 1986.
Thus, arrangements were made with the Kansas Department of Health
and Environment to select a  site for sampling just prior to the
arrival of the sampling team.

On June 27, 1986, the Kansas Department of Health and Environment
notified the EPA contractor  that they could not participate in
sampling on July 1, 1986.  New plans were made to sample July 2,
1986, to accommodate their participation.  State officials put
the EPA contractor in direct communication with a drilling agent
who was planning a well for  that time period.

Since no list of sites was possible, the EPA contractor pursued
sampling arrangements with the drilling agent, Cindy Van Dyke,
for sampling July 2, 1986, at a site near Coffeyville, Kansas.
Site selection was considered random due to the nature of
southeastern Kansas drilling described above.  The EPA contractor
had no prior knowledge of the drilling site prior to its proposal
by a Kansas state official.

Site Location

The Gentry Lease Well No. 2A is located approximately 8 miles
southeast of Independence, KS via Highway 160 and a county road
located 2 miles west of highway 169 in Montgomery County.  Figure
1 is a map indicating the drilling site.  The full name and
mailing address for Cindy Van Dyke is:

          Cindy Van Dyke
          Route 1
          Coffeeville, KS  67337
          Main Office Contact:  Cindy Van Dyke
                        Phone:  316-948-6331
                              C-315

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                                                              oJr  -1
                                                               •—4*-:..  '.t
                                                         • •   --   ;  *i^
                                                        I ; »  ".r " pi-' "
                                                        -I-' •   [    tt  -
Figure 1.  Location of Cindy  Van Dyke's Gentry Lease Well #2A,
           Montgomery County,  Kansas
                             C-316

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Attendees

Sampling at the Gentry Lease site was performed by CENTEC
Corporation personnel on July 2, 1986.  Following is a list of
people present at the time of sampling:
    CENTEC Corp. (Sample Team):
    State Representatives:
                                 Bill Lane,  Technician
                                 Jamie Mclntyre,  Team Leader

                                  Steve Korf,  Environmental
                                    Geologist, Bureau of Oil
                                    Field and  Environmental
                                    Geology, Kansas  Corporation
                                    Commission, Southeast
                                    District Office

                                  Bill Augustine, Environmental
                                    Technician, Kansas
                                    Corporation Commission

    Operator Representatives:      None Present

    American Petroleum Institute
      Representatives:            George Holliday, Contracted
                                    Observer
                                  Alan Wilson, Contracted Sample
                                    Team Member
                                  Earl Hinsley, Contracted Sample
                                    Team Member

Several unsuccessful attempts  were made to contact the operator
the day of sampling.  Steve Korf said he would continue to try to
contact the operator after the sampling was completed.
Information about drilling operations at this  site was provided
by Steve Korf, and was largely based on local  industry practices.

Site Description

The Gentry Lease site is located in a rural, piedmont area.   The
climate at this site location  is net precipitation.   The soil is
described as clay with a layer of rich top soil.   The site is
located over the Mississippian formation of the Forrest City
basin.

The depth to the groundwater in the area was estimated to be
100 feet, given that the depth to the bottom of "usable" water is
150 feet (see drilling permit, Attachment B).   The nearest
surface water is the Verdigris River located one mile west of the
site.  Information about drinking water wells  located in the  area
was not available.

At the time of sampling, the site consisted of one oil well and
two reserve pits.  The drill rig had been removed from the site.
The well head consisted of a completion pipe rising  approximately
                              C-317

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20 feet out of the hole (Photos 4,  6,  and 7).   This pipe was not
cemented in place.  Gas could be heard and smelled coming from
the well.  Figure 2 is an approximate  schematic diagram of the
site, indicating the directions in  which photos were taken
(Attachment A).

Also at the site was an array of cuttings samples taken from
various depths reached during drilling.   These are shown in
Photos 9 and 10.

This site was an experimental oil or gas drilling site.  The well
was completed at 1/400 feet.   Drilling began on June 25, 1986 and
the well was completed June 27, 1986.

Drilling was accomplished using air rotary drilling, evidenced by
the cuttings pile located on the side  of the pit farthest from
the well head (Photo 1 and Figure 2).   It was  suggested that this
drilling technique would have included the use of natural
drilling muds, as this is common local practice.

Two unlined pits were constructed onsite to provide temporary
storage of drill cuttings, residual drilling muds from the
circulation system, and waste oil.   The pit contents were piped
from the drilling operation.   The pits were in use between
June 25 and June 27, 1986, and could contain fluids for 120 days,
in accordance with State requirements.

The pits were constructed below grade, in approximately
rectangular shapes.  The width of each pit was approximately the
width of a bulldozer blade.  Figure 2  shows the measured
dimensions obtained at the time of  sampling, based on the liquid
level in the pits at that time.  A  ditch connecting the two pits
allowed for mixing of the pit contents.

The purpose of the northern pit was to directly receive drill
cuttings from the rig.  This was apparent from the piles of
cuttings indicated in Figure 2.  The southern pit was used to
store drilling fluids, presumably drawn from the northern pit via
the small connecting ditch shown in Photos 2 and 5.

The depth of liquid in both pits was 1 foot, and the depth of the
sludge was 1/2 to 1 foot.  Both pits had a 1-inch layer of oil on
the surface.

Pit contents included 2,500 barrels or less of cuttings, drilling
fluids and waste water generated from drilling operations, and 1
to 2 barrels of waste oil.  Tank trucks storing diesel onsite
contained roughly 100 gallons prior to removal of the drilling
rig.

Disposal Practices

State representative Steve Korf suggested that the operator would
probably skim the oil layer off the surface of both pits and take

                               C-318

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               	d)	
           	0	
Figure 2.  Schematic Diagram of Drillina Site
                    C-319

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it to a recycling facility/ possibly located in nearby
Coffeeville, KS.  The remaining water would be hauled to an
injection well.  The state allows for solids to dry in reserve
pits for one year, followed by backfilling and leveling the
surface to grade.  Reseeding the area is usually left to the
discretion of the landowner.

Permits

A copy of the drilling permit secured by Cindy Van Dyke for the
Gentry Lease Well No. 2A is located in Attachment B.


SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).

Sample Point Locations

At the Gentry Lease site, the samples were defined as the
supernatant and solid contents of the waste material  in both
reserve pits.  This was done because the connecting ditch between
the two pits allowed for mixing of pit contents.

Sample points were identified based on measurements of pit
dimensions.  However, the asymmetry of the Gentry Lease pits did
not allow for placing sample points at the center of  measured
quadrants, as with rectangular pits.  Figure 2 indicates the
location of the sample points.

Sampling Methods and Equipment

To collect samples from the reserve pits, measurements were made
to identify four points evenly spaced within both pits.  The
measured points were marked by placing stakes along the sides of
the pit to facilitate locating sample points.

The sample points were accessed by boat.  The boat was pulled to
the measured sample points via one rope, and was anchored at that
point.  One sample team member worked in the boat while the other
stood on shore to steady the boat.

The first sample to be collected was the liquid composite.  The
thief was used to obtain this sample.  Care was taken not to
allow oil floating on the surface of the liquid to enter the
thief.
                               C-320

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The reserve pits were then sampled for sludge.   The dredge was
used to sample the sludge because the sludge was too liquid to be
retained by the coring device.   Two full dredges were obtained at
each point, yielding a total volume of approximately 5 gallons.
The solids were composited in a steel bucket.

The samples were tested onsite for pH after sampling was
completed.  The pH of both the liquid and sludge samples was 7.
                               C-321

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C-322

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                 C-323

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C-324

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                                                               ;Sp^iA:^
                                                               &&&3&s&m£
Photos 1,2,3. Easterly view of reserve pits

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Photo
Easterly view of pole extending from well
(pits In background)
                                                               Photo 5.  Southerly view of ditch between  pits
                               Photo 6.   Westerly  view of  north pit

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o

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to
Photo 8.  Northwesterly view  of  south  pit
          Photo 7.  Westerly  view  of  north  pit

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o

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CD
Photo 9.  Northeasterly v'ew of north pit -

          (formation samples In foreground)

                                                                         Photo 10.   Formation samples

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ATTACHMENT B:  PERMITS
          0329

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C-330

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 CARD MUST BE TYPED
                     6-25-86
Suiting Dale	

OPERATOR: Urea** t	7.?.?.$.
              Cl.ndy  V
          	Route"!
                                                     Stale of Kansas
                                       NOTICE OF INTENTION TO DRILL
                                                 (see rules on reverse side)
                                       	     API Number 15—
                                                                                   ';> '
                                                                                                CARD MUST BK SIGNED
                                         yew
              Cind
CONTRACTOR: Limu*
  Nl-,	Hok.a.t.
  Ci,y/*l«...Tjr.r.O»...KS.....673.64	      Domestic well
                                                                 $W  SW  $W   s_  12
                                                               • ••«i  •••**  •*T«*   din*•nn •
                                                               	3.3Q	
                                                               ...4.9.5.0.	
                                                                        (Note: Local* well oa
                                                               Nearest lease or unit boundary^
                                                               County	
                                                               Lease Nsme. .GW.tT.y	  Well #	2A	
                                                               Ground surface elevation ... .1 /. A	ferl MSL
                                                                                                                  X
                                                                                                  . s.  Rj...l.6...
                                                                                                 FL fma South Lin* of SrdU>«
                                                                                                  ft fnm EMI Line of Section
                                                                                                     rr*cnr >idc)
                                                                                                3 U
                                                                           within 330 feet:
                   SWD
Well Drilled For:
   £_ Oil
   1_ C-       _ by
   _ OWWO   _ Espl
If OWWO: «U •«« !•(• ••
 Operator
                             Well Class:
                             _ la/kU
                             __ Pool Esl.
                             JL WIMcat
                                           	Air
                                           	CaM*
.1.6...
.1.5.0.
                                                                                                        —yes    X	no
                                                                                                              l_ J
  OMpUott	  OM Total Depth	
I certify thai well will comply with KJ5.A. 55-101, et seq^, plus
Type Equipment:     Municipal well within one mile:
                    Depth to bottom of fresh water..
                    Depth to bottom of usable water
                    Surface pipe by Alternate:
                    Surface pipe planned to be set.
                           f r  r                           r
                    Conductor pipe required	fu .3	
                    Projected Total Depth	IHQ.O	feet
                    Formation	M.i$.$.1S* J.PJJ.1	
                lally plugfiiw hole 14 KCC specifications.
lur M'JC Use:
C4Hidurlur Pipe Required	f*tt; Minimum
Tbi» AulhuriialioB Expires
                                                      ace Pipe Required	..*..feet per
                                   PLUGGING PROPOSAL IF ABOVE IS D le A
T5i» pluKKing proposal will be reviewed and approved or revised at the time the district office is called prior to setting surface casing (call 7 a.m. to
5 p.m. workdays).
In plug (a ..A.4. P.P.	  feet depth with ,
2nd plug (it	  feet depth with .
                                                             J.9.
                                                                               s«s of ....
                                                                               >x( of
                                                        C-331

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C-332

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                         Sampling Report
         Investigation of American Energies Corporation's
                      Munsell F Well No.  1
                        Pendennis,  Kansas
                          July 7, 1986
SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA-530-SW-87-005).   This site was selected randomly from
a list of Dodge City Embayment drill sites (at or near
completion) developed by the Department of Health and Environment
at the request of EPA.  The list was transmitted via telephone to
the EPA contractor on June 27, 1986.  Site selection toolc place
during the telephone conversation.

Kansas state officials preferred to list the possible sample
sites in the manner shown below.   The EPA contractor had no
interest in the manner the particular sites were listed (by site
name, location, operator, permit number, API number, etc.) as
long as the site could be identified in detail upon selection.
Thus, the EPA contractor had minimal information which kept to a
minimum the amount of bias.   No other information was known about
the sites on the list at the time of selection.  Detailed
information was obtained only after selection of primary and
back-up sites.  The list consisted of five drill sites:

     1.  Hutchinson Oil - 91712 - Barton Co.
         Spud 6/25/86.

     2.  American Energy - 281527 - Gobe Co.
         Spud 6/24/86.

     3.  Striling Ltd. - 211131 - Gobe Co.
         Spud 6/24/86.

     4.  Pan Canadian Oil Co. - 12721 - Graham Co.
         Spud 6/26/86.

     5.  CFA Oil Co. - 351031 - Thomas Co.
         Spud 6/27/86.

As indicated above, the EPA contractor assigned numbers to the
members of the list as they were transmitted.  A random number
table was used to select the sample site.  No. 2 on the above
list (American Energy) was selected as the primary sample site.
Plans were made for sampling to be conducted July 7, 1986.  No. 1
on the above list (Hutchinson Oil) was tentatively selected as a
back-up site.  No back-up site was required.
                              C-333

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Site Location

Munsell F Well No. 1 is located 5.5 miles north of Pendennis,
Kansas.  Figure 1 is a map indicating the well site.

The site is operated by American Energies Corporation,  whose
mailing address and telephone number are:

             575 Fourth Financial Center
             Wichita, KS 67202
             316-263-5785
             Contact Name: Alan deGood

Attendees

Sampling of Munsell F Well No. 1 was performed by CENTEC
Corporation personnel on July 7, 1986.  The following is a list
of people present at the time of sampling:

    CENTEC Corp. (sample team):   Bruce Hoskins, Team Leader
                                  Dewayne Buskey, Technician

    State Representative:         Don Butcher, Inspector in
                                    Charge, Kansas Corporation
                                    Commission

    Operator Representative:      L. W. Jackson, Production
                                    Superintendent

    American Petroleum
      Institute Representative:   George Holiday, Contracted
                                    Observer

Site Description

Munsell F Well No. 1 is located within the Dodge City Embayment
in rural flatland; the depth to groundwater is 180 feet, and the
nearest surface water is over 2 miles away.  There is one
drinking water well within a 1/2-mile to 1-mile radius of the
well.  There are no drinking water wells within a 1/2-mile
radius.  The soil in this area is mostly shale.  The climate at
this site is net evaporation.

This site was an exploratory oil drilling site.  The well reached
a final depth of 4,370 feet on June 30, 1986.  The well was a dry
hole.  Drilling was accomplished with fresh-water bentonite muds.
No biocides were used during drilling.

Figure 2 is a schematic diagram of the drilling site.  Four
separate pits were constructed for the site: a reserve pit, a
fresh water pit, and two working pits.  The fresh water and
working pits were constructed below grade.  The reserve pit had
bermed sides.  All pits were unlined except the fresh water pit,
which had a plastic liner.  This was done to prevent the loss of


                              C-334

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Figure 1.  Location of Munsell F Well #1, Pendennis, Kansas
                       C-335

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          /
n

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00
en
                           Figure 2.  Munsell F Well  #1  Site  Schematic Diagram

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fresh water in the pit due to percolation into the ground.
Liquids placed into the unlined pits would percolate into the
ground.  The total cost of pit construction was unknown, but pit
costs at similar drilling sites are less than $1,000.  Photos 1
and 2 (Attachment A) show the drilling rig platform and the
doghouse.  Photos 3-7 show the working pits.  Photos 8 and 9 show
the particular working pit that was sampled.  Photo 10 shows the
dried reserve pit.

A mud recirculation system was used at this site.  The reserve
pit was designed for a one-time use; all drilling cuttings were
to be piped into the reserve pit at the completion of drilling
operations.  On the day of sampling, there was no supernatant in
the reserve pit.  There was 1/2 foot of supernatant in the
working pit along with 2 feet of sludge.  It was unknown what
quantity of drilling fluids the reserve pit received.  The
reserve pit received only drilling fluids.

Fifteen hundred gallons of diesel oil were stored at this
facility in tanks.  No waste diesel oil was generated.

Disposal Practices

At the completion of drilling, all cuttings were placed in the
reserve pit.  There was no treatment or testing of pit contents.
The pit contents were not moved for final disposition.  The
fluids were evaporated.  The dried pit solids were buried.  The
pit site would be reclaimed by the addition of new top soil, and
reseeded.  According to site personnel, there are records
available regarding the final disposition.

Permits

No facility permit was available to the sample team at the time
of sampling.


SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).The following
is a description of site-specific sampling information and
activities.

Sample Point Locations

The samples collected at Munsell F Well No. 1 consisted of one
supernatant and one sludge sample.  Originally, sampling was to
take place in the reserve pit.  The reserve pit was dry on the
sampling day.  Sampling took place in one of the working pits
that had a discrete liquid surface.  This working pit also still
had drilling fluids in it according to s.ite personnel.  Figure 3


                              C-337

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.\>    X
v

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shows the sampled pit and the location of the sample points.
Pour quadrants were established for sludge sampling.  The liquid
was not across the entire surface of the pit; therefore, liquid
sample points did not match sludge sample points.

Sample Methods and Equipment

The liquid was too shallow for thief sampling; the supernatant
was sampled from the boat with a stainless steel bucket.  Sludge
was collected using a stainless steel spoon; the solids were too
fluid to use the coring tube.  A sludge sample depth of 1 foot
below pit surface was achieved.

Due to time constraints, samples were held in refrigeration
overnight prior to laboratory shipment.
                             C-339

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C-340

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-341

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n
10

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Photo I.  Drilling platform
Photo 2.  Drilling platform and dog house
Photo 3.  Work Ing pits
                                      C-343
Photo 4.  Working pits

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                                                                Photo
 Working  pit
Photo 7.  Working pits
                                                               Photo
Sampled working pit

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-Ud eAjesey   '0|
                                                                                          04.0114

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C-346

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                      Reconnaissance Report
          Investigation  of  Ritchie  Exploration,  Inc.  and
       Crosswind  Petroleum,  Inc.'s  Keith  Garrett Well No.
                        Wakeeney,  Kansas
                           July  8,  1986
SITE INFORMATION

Site Selection

EPA conducted a reconnaissance site visit to gain further
information on drilling practices in the state of Kansas.  This
site was selected from active Dodge City Embayment drill sites
near Hayes, Kansas, that were accessible to the sampling team.
The Kansas Department of Health and Environment identified this
site at the request of EPA.  Site identification was transmitted
directly to the EPA contractor on July 8, 1986.

No back-up site was selected.  No problems were encountered
arranging for a site reconnaissance to be conducted July 9, 1986.
No back-up site was required.

Site Location

Keith Garrett Well No. 1 is located near Wakeeney, Kansas, 6
miles north on Route 283 from the junction of Route 283 and
Interstate 70, and 6.5 miles west on County Rd 422.  Figure 1 is
a map indicating the well site.

The site is operated by Ritchie Exploration, Inc. & Crosswind
Petroleum, Inc.; the mailing address and telephone number are:

               125 North Market
               No. 1000
               Wichita, KS 67202
               316-267-4375

Also hired as contractor was Duke Drilling Co., Inc. from Great
Bend, KS.

Attendees

Reconnaissance of Keith Garrett Well No. 1 was performed by
CENTEC Corporation personnel on July 8, 1986.  The following is a
list of people present at the time of reconnaissance:

    CENTEC Corp. (sample team):   Bruce Hoskins, Team Leader
                                  Dewayne Buskey, Technician

    State Representative:         Don Butcher, Inspector in
                                    Charge, Kansas Corporation
                                    Commission
                             C-365

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  JJtfAK I MfcN 1 OK 1 Hb IIS I tKlUK
     GEOLOGICAL SURVEY
07'30"
                                          ^~r\/
                                          ~.~ V:*.,-  \  V,
                                                   '^' r 12 -'--- V
                                 ^'^tW^^ifc

          Figure 1.  Location of Keith Garrett Well No. 1,
                  Wakeeney, Kansas
                             0366

-------
    Operator Representative:      Jeff Christian, Geologist

    American Petroleum
      Institute Representative:    George Holiday, Contracted
                                     Observer
Site Description

Keith Garrett Well No. 1 is located within the Dodge City
Embayment in rural flatland; the depth to groundwater is over 100
feet, and the nearest surface water is less than 1/2 mile away.
The soil in this area is mostly sand and loam.  The climate at
this site location is net evaporation.

This site was an exploratory oil drilling site.  The well reached
a final depth of 3,970 feet on the day of the reconnaissance.
The well was a dry hole.  Drilling was accomplished with
fresh-water muds.  No biocides were used during drilling.

Figure 2 is a schematic diagram of the drilling site.  Four
separate pits were constructed for the site: a reserve pit, a
fresh water pit, and two working pits connected by trenches.  The
fresh water and working pits were constructed below grade.  The
reserve pit had bermed sides.  All pits were unlined except the
fresh water pit, which had a plastic liner.  This was done to
prevent the loss of fresh water in the pit due to percolation
into the ground.  Liquids placed in the unlined pits would
percolate into the ground.  The total cost of pit construction
was $500.  Photos 1-3 (in Attachment A) show the drilling rig and
the diesel oil storage tanks.  Photos 4-6 show the working pits
and the trenches connecting them.  Photos 7-11 are the reserve
pit and its contents.  They show that a considerable amount of
trash was thrown into the reserve pit.  Photos 12 and 13 show the
reserve pit and the adjacent fresh water pit.  Photo 14 is a
closeup of the fresh water pit which was nearly completely dry.

A mud recirculation system was used at this site.  There was no
liquid mud storage.  The reserve pit received cuttings and
unrecirculated fluids once a day piped from the working pits.  On
the day of the reconnaissance,  there was a sludge depth of 1 foot
in the reserve pit.  There was no supernatant in the reserve
pit.  All remaining drilling fluids and cuttings were placed in
the reserve pit at the completion of drilling operations.  The
reserve pit received less than 2,500 bbl of drilling fluids and
cuttings.  The reserve pit also received trash.  No waste diesel
oil was generated at this site.

Five hundred gallons of diesel oil were stored at this facility
in diesel storage tanks.
                             C-367

-------
        3. j  WORKING  MOO ?tT
Figure 2.  Keith Garrett Well #1 Site  Schematic Diagram
                       0368

-------
Disposal Practices

At the completion of drilling, all drilling fluids and cuttings
were placed in the reserve pit.  There was no planned treatment
of the pit contents.  The reserve pit contents would not be moved
for final disposition.  The fluids were evaporated.  The dried
pit solids were buried.  The pit site was to be reclaimed by the
addition of new top soil, and reseeded.  According to site
personnel, there are records available regarding the final pit
disposition but were not available at the site.

Permits

The drilling of this well was authorized by the Kansas
Corporation Commission under API No. 15-195-21862.  A copy of
this permit is in Attachment B.
                             C-369

-------
C-370

-------
ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-371

-------
C-372

-------
 L.
Q
 O
 +-
 O
 .c
 0.
C-373
                                                          O)
                                                          a
                                                          v.
                                                          O
                                                          O
                                                          in
t.
a
o
•t-
o

-------
 Photo  6.   Working  pit  and  reserve pit
Photo 8.  Reserve pit

-------
li,  Photo  9.   Reserve pit
-4
ui
 Photo 10.  Reserve pit
  Photo  II.   Reserve  pit
Photo 12.  Reserve and fresh water  pits

-------
Photo 13.  Reserve and fresh water pits
Photo 14.  Fresh water pit

-------
ATTSCHMxiNT  B:   PERMITS
        0377

-------
00
r-
m
 I
U

-------
                                                                                                        CARD MUST DF SIGNED
Stirring D»te
                                          NOllvl  <>l  IMKN110N  IODKII.I.
                                                    (•». i i tilt \ tui I <* MIU')
                        .fi/2.7/.'!.':  ..                            \I-IN	•--  r,    ,
                          lUOHltl

                    ,....4767.
                                                   1 ''.'.'I.-;. Mr I •>' ;             .1.6.50	Kl. from South Un» of trttloo
  Addf,
         ?ct role urn,... Inc..    j .",
                                                             i
             ...J.aif..Christ i,j'.
  PbeM....3.16/.Z6.7.r.43.7rJ	
CONTRACTOR: Licew. «	!J91>')
  NMM..Dukje..Djr.illiiKj.  Cu.. ,.  i  i.. ,
  cnr/suM...jGrjeii.L..BGndT...K:;.. . o ,'.> M
Well Drilled For:               UVI] (.I..--.      I M.. 1 .,,.,.„.. ,,i
    V  Oil        	 SWD       _ l.if.,1.1        '..  •>!.. i u..M,,
   	CM       	 l«j            I-.-.M.I          \  »	
   	owwo    	t»pi       :•; w«u. .1           •••••
IfOWWO: »U veil infu .. (olt..v...
  Operator	
                            Ol.l'luul Ik-p
1 certify that well will comply *>iih K S. A. .'>">  IDl.ii-.  .. ri..•.«%. niu-.ll\  plu^^nii; ).i|li in K('<^ \j>rrilii .ni
For KCC Uwt
Cooductor Pipe Required ..
Thu Aothoriulion Expirri.
                               	(i<<. Mtttitiuiin ->.iit.MI* l*iiic  Miiiniii'i
                                /-.-.'.. ,-'*{ '   -'•'<•.
                                                                                                              .ree«PcrAI«.
                                                                  \,T,..,.-.I lit	<'...,.4,',.'. ,.'.•:.•.

                                                                            /'i '  ' '     / ^ &
                                                                             1 (    .  . t  !' '
                                                                                         , ..J.O   «»P.J:s  s. R». ..?.A..
 Thi» plugjin|propoi»| wi
 5 pja. worfcdajri).
 lit ping®	1240.
                                      iM.i'<:<;iN(. I'Koros.M. ii-  \iu>\ i  is  i> .1 A         HV^*-
                                  rtl*»tli>|>|>i»\iu» 111 .cum); surface cuing (c«ll 7 t.m. lo
 2nd plug @	Ifl H.O	   i,. i .
 Srdpluggji	23.0	  i.,,.
 4«hplug@	AO	   I,, i .
 Stbplug®	     I,,, ,
 (2) JUrhole with  	] U	  ,x.
                                                •|.ih >• I'll
                                               . Mill 1. l.ll
                                                                 . i.o
                                                                               ' I I .) ()   ...       	Ft. from tut Un« i
                                                                             (N.iir |JM  nr Mftl IM. Sr. lii.it I'Ul an rever«« ttil*...l	
                                                                  t.t..nml MI.I.i. r rletji,..,! .. i.1:; t ... 23 25.	feet MSL
                                                                  I>..mi-kin  uill uiilun '[.'III In-).                  	ytt     __no       f
                                                                  M.IIIU IJIA! urlt **tlmi **nr Itiilr                 	yri        no
                                                                  !>• jilli I.. Imlli.iii of frr«h u^lrr 	L20.'.	
                                                                  I', fill III ln.llo.ll of U »!.!<• V.JIIT	1.00(1 .'	
                                                                  '.iiil.i. < JIIJH- In  MlrniMlr*.                           I 	  ?X—
                                                                  S...I.I. r |.,|.i- pla	it I,. IK- »••!	2QjO.'.	

                                                                  «	<•	• I'M" '	'«»	
                                                                  I'n.j. il. .1  I..I..I Dij.lh	3'1 40	feel
                                                                  i-ori.,..i	  .   ..U;.u;<;..ot"..Kansas.-Ci-ty	
 NOTE: Agrcrmrnl brlwrrn ..(«•. ji.., .,...1 ,|,M, ,. i .,if,,. ....,.! .:  ,.t... »« m .m
 In Addition: Call ili^irui uffur *lin >.i II M i nl.. i |.ln(v. .1 •..  |	I"
                                                   i< .ill V . in  )'. '. p in

 Dutrict office u»c only.
Surface cuing of	 r,.,, ,,.( ,,,i|,
UlenUtC 1	or 2	 mirfa.r |>.|M M.I-. OM-I|
IheruU 2 cementing wm» cuinpl«-i,-,| („	
UU plugged	 |
-------
C-380

-------
                      Reconnaissance Report
         Investigation of Oil Producers,  Inc.  of Kansas'
                          Ott Well No.  2
                         Wakeeney, Kansas
                           July 9, 1986

SITE INFORMATION

Site Selection

EPA conducted a reconnaissance site visit to gain further
information on drilling practices in the state of Kansas.  This
site was selected from active Dodge City Embayment drill sites
near Hayes, Kansas, that were accessible to the sampling team.
The Kansas Department of Health and Environment identified this
site at the request of EPA.  Site identification was transmitted
directly to the EPA contractor on July 8, 1986.

No back-up site was selected.  No problems were encountered
arranging for a site reconnaissance to be conducted July 9, 1986.
No back-up site was required.

Site Location

Ott Well No. 2 is located near Wakeeney,  Kansas, 6 miles north on
Route 283 from the junction of Route 283 and Interstate 70, and 6
miles west on County Road 422.  Figure 1 is a map indicating the
well site.

The site is operated by Oil Producers,  Inc. of Kansas, whose
mailing address and telephone number are:

               PO Box 8647
               Wichita, KS 67208
               316-681-0231

Also hired as contractor is Western Kansas Drilling,  from Hays,
KS.

Attendees

Reconnaissance of Ott Well No. 2 was performed by CENTEC
Corporation personnel on July 9,  1986.   The following is a list
of people present at the time of reconnaissance:
    CENTEC Corp. (sample team)
    Operator Representatives:
Bruce Hoskins, Team Leader
Dewayne Buskey, Technician

John S. Weir, President, Oil
  Producers, Inc. of Kansas
Bill Shepard, Geologist
Rick Hughes, Service Engineer,
 Hughes Drilling Fluids
                             C-381

-------
    DEPARTMENT OF THE INTERIOR
        GEOLOGICAL SURVEY
  100*00'     <|«—£           «li
07'30"
                                        •!»
                                                    •17 S7'30"
                                                                             Owil OITY I I3SOOOI
                  Figure 1.   Location of Ott  Well  #2,  Wakeeney,  Kansas
                                               C-382

-------
     American  Petroleum
      Institute  Representative:    George Holiday, Contracted
                                    Observer

 Site Description

 Ott  Well No.  2  is  located within the Dodge City Embayment in
 rural flatland; the depth to groundwater is over 100 feet, and
 the  nearest surface water is less than 1/2 mile away.  The soil
 in this area  is mostly sand and loam.  The climate at this site
 location is net evaporation.

 This site was a developmental oil drilling site.  The well
 reached a final depth of 3,942 feet on the day of the
 reconnaissance.  The well was a dry hole.  Drilling was
 accomplished with  fresh-water spud muds: either bentonite or
 attapulgite in combination with fresh water, corn starch, cotton
 seed hulls, and paraformaldehyde as a biocide.  All mud
 components were supplied by Hughes Drilling Fluids of Houston,
 Texas.  Attachment C contains the specification sheets on the
 individual mud components as supplied by Hughes Drilling Fluids.

 Figure 2 is a schematic diagram of the drilling site.  Five
 separate pits were constructed for the site: a reserve pit, a
 fresh water pit, an overflow pit, a working pit (which resembled
 a trench rather than a pit), and a burn pit.  All pits were
 constructed below grade.  All pits were unlined except the fresh
 water pit, which had a plastic liner.  This was done to prevent
 the  loss of fresh water in the pit due to percolation into the
 ground.  Liquids placed in the unlined pits would percolate into
 the  ground.  The total cost of pit construction was $800.  In
 Attachment A is a series of photos (Photos 1-5) taken from the
 top  of the freshwater tank that show the different pits.  The
 largest pit by far was the reserve pit which measured 75 feet by
 75 feet.

A near 100 percent mud recirculation system was used at this
 site.  There was no liquid mud storage.  The reserve pit was
designed for a one-time use; all drilling fluids and cuttings
were  to be placed in the reserve pit at the completion of
drilling operations.  Any fluids that were removed during
drilling were placed in the overflow pit.  Photos 6-14 are
closeups of the working pit in sequence from the surface mud
ejection to the recirculation point.   Photo 15 is a closeup of
the overflow pit.   The reserve pit was to receive between 6,000
and  7,500 bbl of drilling fluids and cuttings.  The reserve pit
was to receive no other types of wastes.   No waste diesel oil was
generated.

Four thousand gallons of diesel oil were  stored at this facility
in a diesel storage tank.   The fresh water storage tank also
appeared to have a considerable amount of oil floating on the
surface.
                              C-383

-------
                                                                                    fs.
o

OJ
00
                GtWfRftTfiR
                    c
                                                   R  TAMK
                                                                               \WftTER
                                                                             Pn
                Figure  2.   Ott Well  #2 Drilling  Site Schematic
                            Diagram

-------
Disposal Practices

At the completion of drilling, all drilling fluids and cuttings
were placed in the reserve pit.  There was no planned treatment
of the pit contents.  The mud company, Hughes Drilling Fluids,
was to test the pit contents for pH, chlorides,  viscosity,  and
water loss.  The results of these tests were not available at the
drilling site.  The reserve pit contents would not be moved for
final disposition.  The fluids were evaporated.   The dried pit
solids were buried.  The pit site was reclaimed by the addition
of new top soil.  According to site personnel, there were no
records available regarding the final pit disposition.

Permits

Drilling at this site was authorized by the Kansas Corporation
Commission under API No. 15-195-21863.  A copy of this permit is
in Attachment B.
                             C-385

-------
C-386

-------
ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-387

-------
C-388

-------
 :Vr<>-^^'W
yvYfi'^w^

-------

I  Photo  6.   Working  and  mud recIrcuI at I on pit
LJ
VO
o
Photo 7.  Working and mud recIrcuI at Ion  pit

-------
OPhoto 8.
I
OJ
VO
Working and mud recircuI at I on pit
                                                                  Photo 9.  Working and mud  recIrcuI at Ion  pit

-------
36£-D

-------
O
OJ
                                                                   Photo
                                                                              Working
                                                                                      and mud rec.rcul
                                                                                                       atlon
                              r.clr<;

-------
                                                                                                                          ---v    •>
                                                                                                                          «.^-iK«rl;^*..-..-LiiW h. .4 /
<"!   Photo 14.   Working  and mud  rec I rcu I at I on pit
Photo  15.  Overflow pit
U)

-------
ATTACHMENT B:  PERMITS
         C-395

-------
C-396

-------
                                                      f, oh  I.N i i.r-, i K i,\ i < >  nun i.
                                                       (s.-r Mil,-, mi ri-M-iM- s,.
                             •loath     da)     >rar
   OPERATOR: Uc«n-*...BQ6i	
     N«n« ....Q.t.l. ..P.r.P.dw fi s xs.t.. .T.u.c. t.. .P f... K n n -•>..) ^
     Addr«.	?.,.P.,.
                                                                    Al'l NIHIIII. i  I',
                                                                                                                          ___ *"'
                                                                     SK   NW  ;;/9()*«--J-T.p...U.s.R,...24..   _Xwe.,
                                                                                . ,  •       	r-'l. from South Line of Section
                                                                    • •  • •          •  •     	 Fi. from E*u Line of Section
                                                                              (Ni.ii-  l.xji, »rll .MI Sr.ii.i.i |M»i oil reverse side)
CONTRACTOR: Llcens. *	c(iii
                        Signature of Ojieralor or Agenl
 »,-ni,-.l I,-,iv, „, „„,, iM.nn.ljry |i,lf .330
 (mini\          l'rci',0
 ir.iv, N.,,...  ..U^A	
 l.iiiiinil VIM I.,, ,- , 1,-v.ilnm	
                                                                                                                               .feet
Miniii ip.il H.-ll uiiliin line milr:
Siiil.i. >• |n|., |iv Ali.-in.it. :
IV|Hli in I...ll,,IM i,l I,, si, w.,i,.r	70
IK-plli i.i In,ll.mi ol us.iliU- w;urr .1000
.Siilf.i, r |'ip<- |il.iiiuc.l In IK- srl	2 0 0
                                                                                                               Well *.... 2	
                                                                                                               	feet MSL
                                                                                                                   	yes    	no
                                                                                                                   —yes    —no
  Due ,
  Kor KCC Use:
  Conductor Pipe Required	f,.ct;  Minimum Sin(j.Wi,,.- l<< .,IMI.-,
  This Authorization Expires	/.«?• . .<*. fa^	  Apmme.l II v
   1'cr  Gilbert   lli^.s
 This pluggi
 5 p.m. workdays).
                                              Off ii-c
                                     n.uuiiNC.  I'uorosAi  IF AIIOVI  is i> ,v \
                          revi..w,.,la,,,|appr(U<.,|,irl<.viv,,,.lM,,,	,,,,,..	  ,„	•«i.«Rsurl«-cCjsing(,-.||7fcm.u,
 is, plug V ...5.9.:.(.ak?.Y.':..Arbuck ^ ^^ ^	j s
     •   "   Vn* I*" *t*  i	  " *   '''  '*"**' *l**Pih wi(h	* /	
 3rd piuK &,.. 50... below_t i,__cibo_vo ,l}.i«.Uu a;,,,         I  no
 5th plug (»	
 (2) Ralhole with
                         15
                                         l.-i-l I,.K1.,.,I ,.,  i,,,.,|,,. „.,„   	        .  ,
                                              |   f>^    -  ('I ....... ,11.1, I .IVIIII. IV I I 11,1 1,1, ,| 1,1
                                                  ((•jll 7 .1.111. 10 rl |> Ml. »,,, |,,|.u s,
 District office use only:
                 »x-. ,,l  	
                 V \ V III
                 •-X-. ,,l
                 S»S I.I " "  «' -If
                 *»1 V l,| . .
                 ll'l Mouvrh,,!,- unit .j,.^,	L

                                          '  5
Arms-..	
Surface casing of	  f.-«-l M-I «iil,
Alternate 1	_or 2	surface pip.- v.j> us,-,|.
Alternate J cementing was completed i«	   ,,
Hole plugged	 19	
-------
C-398

-------
          ATTACHMENT  C:
MUD COMPONENT SPECIFICATION SHEETS
              C-399

-------
C-400

-------
S516012
               EMERGENCY TELEPHONE:   (713)680-3823

                      HUGHES DRILLING FLUIDS
                     10777 N.W. FRWY..STE 700
                         HOUSTON, TX 77092
                                               HEALTH   0
                                         FLAMMABILITY   1
                                           REACTIVITY   0
                                  PERSONAL PROTECTION   E
                           WHITE STARCH
               SECTION I - PRODUCT IDENTIFICATION
Synonyms
Formula
Corn starch
Variable
Chemical Family: Polysachlaride
CASf         :
Unit of Issue:
Application  :
Multiple
55 Ib. sack
Filtration
control
                             Warning
WARNING!  NUISANCE DUST I
eyes, skin and clothing.
         Avoid high concentration.  Minimize contact with
         Keep away from heat, sparks, and open flames.
SECTIC
COMPONENT
Starch
)N II - HAZARDOUS
PERCENT (%)
100
5 INGREDIENTS
TLV
2
10 mg/m
(total dust)

Reference
ACGIH, 1984-85
                   TRANSPORTATION INFORMATION
Classified as a hazardous material according to DOT(49 CFR 172):
Proper  shipping name: Not restricted
Hazard  Class         : Nonhazardous
Identification No.   : None
Labels  required      : None
IMCO class           : Nonhazardous
IATA class           : Nonhazardous
                                                  YES X NO
                SECTION III - PHYSICAL PROPERTIES
Appearance A color
Solubility in water
Boiling point
Evaporation rate
Vapor density
pH
White powder
Insoluble
N/A
N/A
N/A
5.0-7.0
Odor :
Melting point :
Vapor pressure (mm Hg):
% Volatile (by vol.) :
Specific gravity :
Odorless
N/A
N/A
8.0 (moisture)
1.5
         SECTION IV -  FIRE ft  EXPLOSION HAZARD  INFORMATION
 Flash point                 : N.D.         Autoignition temp  : 429 C
 Flammable limits (%  by vol.): N.D.         Decomposition temp: N.D.
 Extinguishing media          : Water, carbon  dioxide,  dry or chemical foam
 Fire ft explosion hazards    : Treat  as  flammable  dust when in the finely
                              divided and  suspended  state.
                                  C-401

-------
WHITE STARCH page 2
              SECTION V - HEALTH HAZARD INFORMATION
Routes of Entry:    Inhalation X   Ingestion	  Skin * Eye Contact	

Acute effects of overexposure: No data available.


First aid:  Eyes      :       }
            Skin .  _  -x       }
            Inhalation:       } None required.
            Ingestion :       }


Additional comments: Follow suggested precautions for nuisance dust.


                  SECTION VI - REACTIVITY DATA

Stability  YES(X)  NO( )        Undergoes Polymerizations  YES( )  NO(X)
Incompatible materials: Heat.


Hazardous decomposition products: None reported.


                SECTION VII - SPILL OR LEAK PROCEDURES
Keep dust to a minimum.Sweep into a waste container.
  	Waste Disposal	
Disposal  should be in accordance with federal, state and local regulations.
This material  is not listed as a hazardous substance, as defined in Section
101  (14)  of  the Comprehensive Environmental Response, Compensation and
Liability Act  (CERCLA) of 1980.

             SECTION VIII - PERSONAL PROTECTIVE EQUIPMENT
Wear cotton  gloves, safety glasses and particle dust mask for comfort.
Personal  Protection Index "E".
 	SECTION XI - SPECIAL PRECAUTIONS	

 Handling & storage: Store in a cool, dry area.  Keep dust to a minimum.

 Other regulatory agency  controls:



                                             Data Sheet Issued:   01/17/86
                                   C-402

-------
S441011
                EMERGENCY TELEPHONE  (713)680-3823

                      HUGHES DRILLING FLUIDS
                     10777 N.W. FRWY.,STE 700
                         HOUSTON, TX 77092
                                                                HEALTH
                                                          FLAMMABILITY
                                                            REACTIVITY
                                                   PERSONAL PROTECTION
                        STARCH PRESERVATIVE
               SECTION I - PRODUCT IDENTIFICATION
Synonyms
Formula
Chemical Family
               : Paraformaldehyde
               : C3HgO,
               : Aldehydes
     CASt         : 30525-89-4
     Unit of Issue: 50 Ib. sack
     Application  : Biocide
                             Warning
WARNING!  HARMFUL IF INHALED OR SWALLOWED.  Causes irritation.  CAUTION!
Combustible - Keep away from heat and flame.  Avoid breathing dust.  Use
only with adequate ventilation.  Avoid contact with eyes, skin and
clothing.
SECTION II - HAZARDOUS INGREDIENTS
COMPONENT
Paraformaldehyde
PERCENT (%)
>95
TWA
2 ppm
Reference
ACGIH
TRANSPORTATION INFORMATION
Classified as a hazardous material according to DOT(49 CFR 172); X YES
Proper shipping name: Paraformaldehyde
                     : ORM-A
                     : UN 2213
                     : None
                     : 4.l--Inflanunable solids
                     : Flammable solid
                                                                         NO
Hazard Class
Identification No.
Labels required
IMCO class
IATA class
                SECTION III - PHYSICAL PROPERTIES
Appearance  A color
                     White flakes
Solubility  in water:  0.17 g
Boiling point
Evaporation rate
Vapor  density
pH
                     Sublimes
                     N/A
                     N/A
                     N.D.
Odor                 : Pungent
Melting point        : Sublimes
Vapor pressure(mm Hg): 1 @ 86°F
% Volatile (by vol.) : 100
Specific gravity     : 1.46
                                                                      302°F
         SECTION  IV  - FIRE  * EXPLOSION HAZARD INFORMATION
                            : 158°F
Flash  point  (PMCC)           : 158F        Autoignition temp  :  572F
Flammable  limits  (% by vol.): Upper 73  Lower 7.0
Extinguishing media          : Water, carbon dioxide, dry or chemical foam
Fire * explosion  hazards     : Explosive hazard at high temperatures
                                  C-403

-------
STARCH PRESERVATIVE page 2
             SECTION V - HEALTH HAZARD INFORMATION
Routes of Entry:    Inhalation X   Ingestion X   Skin A Eye Contact X

Acute effects of overexposure: Corrosive.  Severely irritating to eyes and
respiratory tract.  Acute exposure results in pulmonary ademea, chronic
exposure irritates the skin/ producing sensitization and asthma.

First aid:  Eyes      : Flush with water.
            Skin      : Wash with soap and water.
            Inhalation: Remove to fresh air.
            Ingestion : DO NOT INDUCE VOMITING.  Seek immediate medical
                        attention.
Additional comments: Toxicity Data — Oral -Rat LD5n* 800 mg/kg
Skin-Rabbit LDQi 10,000 mg/kg
SECTION VI
- REACTIVITY DATA
Stability  YES(X)  NO( )        Undergoes Polymerization:  YES( )  NO(X)
Incompatible materials: Heat, strong oxidizers, peroxides, acids, ketones.
                        Reacts with water, releasing dangerous gases.

Hazardous decomposition products: Thermal decomposition products are
   hazardous and toxic-carbon dioxide and carbon monoxide.


                SECTION VII - SPILL OR LEAK PROCEDURES
Contain area of spill.Do not allow contact with moisture.Sweep into
container.  Dispose at licensed waste facility.  Reportable quantity-
1000 kg/454 Ibs..

                         Waste Disposal
Disposal should be in accordance with federal, state and local regulations
This material is listed as a hazardous substance, as defined in Section 10
(14) of the Comprehensive Environmental Response, Compensation Act (CERCLA
of 1980.

             SECTION VIII - PERSONAL PROTECTIVE EQUIPMENT
Avoid skin contact.Wear impervious clothing,including goggles,boots an
rubber gloves.  Wear vapor respirator when mixing product.  Personal
Protection Index "H".

                   SECTION XI - SPECIAL PRECAUTIONS

Handling * storage: Store in cool, dry area in air-tight drums.  Do not al
   low contact with moisture.  Keep away from heat, sparks and open flames

Other regulatory agency controls: Registry Toxic Chemicals Number RV 05400
   DOT:  49 CFR 172.101 Hazardous Materials Table.  Subject to additional
   labeling requirements of 49 CFR 172.402


                                             Data Sheet Issued:  01/17/86
                                  C-404

-------
S111011
                EMERGENCY TELEPHONE (713)680-3823

                      HUGHES DRILLING FLUIDS
                     10777 N.W. FRWY.,STE 700
                         HOUSTON, TX 77092
                                               HEALTH   1
                                         FLAMMABILITY   0
                                           REACTIVITY   0
                                  PERSONAL PROTECTION   E
                             CLOROGEL
               SECTION I - PRODUCT IDENTIFICATION
Synonyms       ;
Formula        :
Chemical Family:
Attapulgite
(OH2)4(OH)2Mg5Sig02 *4H20
Magnesium, Aluminum
Silicate
     CASf
                                                                -/b-4
     Unit of Issue:  50 Ib.  sack
     Application  :  Viscosifier
                             Warning
WARNING!  MAY BE HARMFUL IF INHALED OVER PROLONGED PERIOD AND MAY CAUSE
DELAYED LUNG INJURY.  Avoid breathing dust.  Use NIOSH/MSHA approved
respirator where TLV for crystalline silica may be exceeded.

               SECTION  II - HAZARDOUS INGREDIENTS
COMPONENT
Free silica
PERCENT (%)
1-3
TLV
10 mg/m
Reference
ACGIH
                   TRANSPORTATION  INFORMATION
Classified as  a hazardous material  according to DOT(49 CFR 172)
Proper  shipping name:  Not restricted
Hazard  Class         :  Nonhazardous
Labels  required      :  None
IMCO class           :  Nonhazardous
IATA class           :  Nonhazardous
                                                  YES X NO
                SECTION III - PHYSICAL PROPERTIES
Appearance  ft  color
Solubility  in water
Boiling point
Evaporation rate
Vapor density
PH
    Powder,tan
    Insoluble
    N/A
    N/A
    N/A
    N.D.
Odor
Melting point
Vapor pressure(mm Hg)
% Volatile (by vol.)
Specific gravity
Odorless
N/A
N.D.
16% moisture
2.29-2.36
(colloidal)
         SECTION IV - FIRE ft EXPLOSION HAZARD  INFORMATION
 Flash point                 :  N/A          Autoignition  temp  : N/A
 Flammable limits (% by vol.):  N/A          Decomposition temp: N/A
 Extinguishing media       '  :  Carbon  dioxide,  dry  or  chemical foam  & water
 Fire ft explosion hazards    :  None.
                                   C-405

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CLOROGEL page 2


              SECTION  V  -  HEALTH HAZARD  INFORMATION

Routes of Entry:     Inhalation X   Ingestion	  Skin ft Eye Contact	

Acute effects of overexposure: Prolonged and con'tinuous exposure to an
excessive concentration of dust may have an adverse"pulmonary effect.


First aid:    Eyes      :
              Skin      :             None required.
              Inhalation:
              Ingestion :


Additional comments: None


                  SECTION VI - REACTIVITY DATA

Stability  YES(X)  NO(  )        Undergoes Polymerization:  YES(  )  NO(X)
Incompatible materials: None.


Hazardous decomposition products: Does not decompose.
	SECTION VII - SPILL OR LEAK PROCEDURES
Sweep or vacuum up spilled material into a container for disposal.
                         Waste Disposal
Disposal  should  be  in  accordance with federal, state and local regulations.
This material  is not listed as a hazardous  substance, as defined in Sectior
101  (14)  of  the  Comprehensive, Environmental Response, Compensation, Lia-
bility  Act  (CERCLA) of  1980.

             SECTION VIII  - PERSONAL PROTECTIVE EQUIPMENT
Supply  adequate  mechanical ventilation.  Wear NIOSH approved particle  dust
mask and  cotton  gloves  for comfort.  Personal Protection Index "E".
 	SECTION XI  -  SPECIAL  PRECAUTIONS	

 Handling ft storage: Minimize dust  generation  and  exposure.

 Other regulatory agency controls:


                                              Data Sheet  Issued:   01/17/86
                                  C-406

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S110018
               EMERGENCY TELEPHONE (713)680-3823)

                      HUGHES DRILLING FLUIDS
                     10777 N.W. FRWY.,STE 700
                         HOUSTON, TX 77092
                                                 HEALTH   1
                                           FLAMMABILITY   0
                                             REACTIVITY   0
                                    PERSONAL PROTECTION   E
                              BENGEL
               SECTION I - PRODUCT IDENTIFICATION
Synonyms
Formula
:  Bentonite clay               CASf         : 1302-78-9
:  (OH)4Sig(Al3 34*Mg0 066)030  Onit of Issue: 50 & 100
Chemical Family: Aluminum Magnesium Silicate  Application
                                              Ib. sack,  bulk
                                            :  Viscosifier
                             Warning
WARNING!  MAY BE HARMFUL IF INHALED OVER PROLONGED PERIOD AND MAY CAUSE
DELAYED LUNG INJURY.  Avoid breathing dust.  Use NIOSH/MSHA approved
respirator where TLV for crystalline silica may be exceeded.
SECTION II - HAZARDOUS INGREDIENTS
COMPONENT
Silica
PERCENT (%)
3
TLV
3
10 mg/m
Reference
OSHA
TRANSPORTATION INFORMATION
Classified as a hazardous material according to DOT(49 CFR 172):
Proper shipping name: Not restricted
Hazard Class         : Nonhazardous
Identification No.   : None
Labels required      : None
IMCO class           : Nonhazardous
IATA class           : Nonhazardous
                                                    YES X NO
                SECTION III - PHYSICAL PROPERTIES
Appearance * color
Solubility in water
Boiling point
Evaporation rate
Vapor density
pH  (6% solution)
      Gray powder
      Insoluble
      N/A
      N/A
      N/A
      8-9
Melting point
Vapor pressure(mm Hg)
% Volatile (by vol.)
Specific gravity
N/A
N/A
10% moisture
1.70-2.65
        SECTION  IV - FIRE  * EXPLOSION HAZARD INFORMATION
Flash point
Flammable  limits  (% by vol.)
Extinguishing media
Fire ft explosion  hazards
               N.E.
               N.E.
     Autoignition temp : N.E.
     Decomposition temp: N.E.
             : Water,  carbon dioxide,  dry or chemical foam
             : None reported.
                                  C-407

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BENGEL page 2
              SECTION V  -  HEALTH  HAZARD  INFORMATION
Routes of Entry:     Inhalation X   Ingestion     Skin A Eye Contact

Acute effects of overexposure: No known danger.

Chronic effects of overexposure: Repeated or prolonged inhalation of dust
                                 may result in silicosis and/or related
                                 respiration ailments.

First aid:  Eyes      : Flush with water.
            Skin      : Wash with soap and water.
            Inhalation: Remove to fresh air.
            Ingestion : Drink water.  Induce vomiting.


Additional comments: Suggested precautions for nuisance dust are sufficient
                     to safeguard health.

                  SECTION VI - REACTIVITY DATA

Stability  YES(X)  NO( )        Undergoes Polymerization:  YES( )  NO(X)
Incompatible materials: Heat.


Hazardous decomposition products: None.
                SECTION VII - SPILL OR LEAK PROCEDURES
Sweep into a waste container.Dispose in land fill.
_^	             ^	Waste Disposal	
Disposal should be  in accordance with federal, state,and local
regulations.  This  product is not listed as a hazardous substance, as de-
fined in Section 101 (14) of the Comprehensive Environmental Response,
Compensation, Liability Act (CERCLA), of 1980.

             SECTION VIII - PERSONAL PROTECTIVE EQUIPMENT
Wear cotton gloves, safety glasses, and particle dust mask for comfort.
Personal Protection Index "E".
	SECTION XI - SPECIAL PRECAUTIONS	

Handling  A storage: Keep dust to a minimum.  Keep away from heat, open
                    flame or electrical sparks.

Other  regulatory agency controls: FDA:  Safe designation 21 CFR  582.1155


                                             Data Sheet Issued:   01/17/86
                                   C-408

-------
S551211
               EMERGENCY  TELEPHONE:   (713)680-3823

                      HUGHES DRILLING FLUIDS
                     10777 N.W. FRWY.,STE 700
                         HOUSTON, TX 77092
                                                 HEALTH
                                           FLAMMABILITY
                                             REACTIVITY
                                    PERSONAL PROTECTION
                              _0_
                              B
                         COTTON SEED HULLS
               SECTION I - PRODUCT IDENTIFICATION
Synonyms
Formula
:  Cottonseed Hulls
:  Variable
Chemical Family: Cellulose
CAS}         : Multiple
Unit of Issue: Multiple
Application  : Lost circulation
               material
                             Warninc
WARNING!  NUISANCE DUST!  Avoid high dust concentration.  Minimize contact
with eyes, skin, and clothing.  Keep away from heat, sparks, and open
flame.
SECTION II - HAZARDOUS INGREDIENTS
COMPONENT
Cellulose
PERCENT (%)
100
TLV
3
10 mg/m
Reference
ACGIH (Nuisance dust)
TRANSPORTATION INFORMATION
Classified as a hazardous material according to DOT(49 CFR 172); X YES
Proper shipping name: Cottonseed Hulls
Hazard Class         : ORM-C
Identification No.   : None
Labels required      : None
IMCO class           : None
IATA class           : None
                                                          NO
SECTION III - PHYSICAL PROPERTIES
Appearance & color
Solubility in water
Boiling point
Evaporation rate
Vapor density
pH
Brown hulls
Insoluble
N/A
N/A
N/A
N/A
Odor
Melting point
Vapor pressure (mm Hg)
% Volatile (by vol.)
Specific gravity
: Odorless
: N/A
: N/A
: N/A
: N.D.
SECTION IV - FIRE * EXPLOSION HAZARD INFORMATION
Flash point                  : N.D.         Autoignition temp  : N.D.
Flammable  limits  (% by vol.): N.D.         Decomposition temp: N.D.
Extinguishing media          : Water, carbon dioxide, dry or chemical foam
Fire * explosion  hazards     : Treat as flammable dust when in the suspended
                              state.
                                  C-409

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COTTONSEED HULLS page 2
              SECTION V - HEALTH HAZARD  INFORMATION
Routes of Entry:     Inhalation X   Ingestion	  Skin ft Eye Contact	

Acute effects of overexposure:  Mo data available.


First aid:  Eyes      :
            Skin      :        None required.
            Inhalation:
            Ingestion :


Additional comments: Follow suggested precautions for nuisance dust.


                  SECTION VI -  REACTIVITY DATA

Stability  YES(X)  NO( )        Undergoes Polymerization:  YES( )  NO(X)
Incompatible materials: Heat, oxidizing agents.


Hazardous decomposition products: None reported.



                SECTION VII - SPILL OR LEAK PROCEDURES
Keep dust to a minimum.Sweep  into a waste container.
                         Waste Disposal
Disposal should be in accordance with federal, state and local regulations.
This material is not listed as a hazardous material, as defined in Section
101 (14) of the Comprehensive, Environmental Response,  Compensation,
Liability Act (CERCLA) of 1980.

             SECTION VIII - PERSONAL PROTECTIVE EQUIPMENT
Wear cotton gloves and particle dust mask for comfort.Personal Protection
Index "B".
	SECTION XI - SPECIAL PRECAUTIONS	

Handling ft storage: Store in a cool, dry area.  Keep dust to a minimum.

Other regulatory agency controls: DOT:  Hazardous Materials Table 49
                                  C?R 172.101


                                             Data Sheet Issued:  01/17/86
                                  C-410

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KENTUCKY
   C-411

-------
C-412

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                         Sampling Report
           Investigation of Maverick Production, Inc.
                    Glassco Lease Well No.  1
                   Henderson County, Kentucky
                         August 21,  1986
SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA 530-SW-87-005).  This site was selected randomly from
a list of Illinois Basin drill sites developed by the Department
of Mines and Minerals, at the request of EPA.  The list was
transmitted via telephone to the EPA contractor on August 18,
1986.  Randomization and selection took place during the
telephone conversation.

The EPA contractor had no interest in the manner the particular
sites were listed (by site name, location, operator, permit
number, API number,  etc.) as long as the site could be identified
in detail upon selection.  Thus, the EPA contractor had minimal
information which kept to a minimum the amount of bias.  No other
information was known about the sites on the list at the time of
selection.  Detailed information was obtained only after
selection of primary and back-up sites.

The Department of Mines and Minerals listed the possible sample
sites by permit number and status, as shown below.  The list
consisted of nine drill sites in the Illinois Basin:

     1.  Permit No.  73145, pits open testing on it 8/18/86

     2.  Permit 73146, plugged dry hole, pit still open

     3.  J. F. Smith #14, Empire Oil and Gas.  Casing set,
         waiting on cable tools.

     4.  Kit Industries, Green Valley Farm Supply.  Dry
         hole, pits still open.

     5.  Maverick Production #3, Crapston Lewis.  Casing
         set, cable tools on for testing.

     6.  Maverick £1, Glassco.  Logging well now, will know
         more later.

     7.  South Coast Oil Company, II Wheatley.  Drilling
         now, anticipate finishing by Friday or Saturday.
                              C-413

-------
     8.  D. K. Parker, #1A McDowell 73266.  Started
         Saturday, surface casing set, expect to finish by
         Friday or Saturday.

     9.  Texas Gas, Midland Gas Field, Peabody Coal Company
         acreage.  At total depth, mud rig.

As indicated above, the EPA contractor assigned numbers to the
members of the list as they were transmitted.  A random number
table was used to select the primary and back-up sample sites.
The randomly-selected primary site was No. 6 on the above list
(Maverick tl Glassco).  No. 2 on the above list (Permit 73146)
was selected as a back-up site in the event the primary site was
inaccessible or inappropriate.

Further inquiry identified the primary sample site as Maverick
Petroleum Company's Glassco Lease Well No. 1, in Henderson
County, Kentucky.  No problems were encountered in arranging
sampling for August 21, 1986.

The back-up site was identified as C&L Resources Development #2
Gertrude Buchanan well, owned by Frank Cox.  The back-up site was
not required.

Site Location

The location of the Glassco Lease Well No. 1 is approximately 1
mile west of the intersection of County Road 351 and Tillotson .
Road, and approximately 8 miles east of the Pennyrile and Audubon
Parkways in Henderson County, KY.  Figure 1 is a map indicating
the drilling site.  The full name and mailing address for
Maverick Production is:

          Maverick Production, Incorporated
          Route 3,  P.O. Box- 238-A
          Henderson, KY  42420
          Main Office Contact:  Otis Walker, President
                        Phone:  502-521-6022

Attendees

Sampling at the Glassco Lease site was performed by CENTEC
Corporation personnel on August 21, 1986.  Following is a list of
people present at the time of sampling:

    CENTEC Corp.  (Sample Team):   Jim Kourmadas, Technician
                                  Jamie Mclntyre, Team Leader
                              C-414

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Figure 1.  Location of Maverick Production, Inc.'s
           Glassco Lease Well No. 1, Henderson County,
           Kentucky
                        C-415

-------
    State Representatives:
    Operator Representative:
    American Petroleum Institute
      Representatives:
Joe Lander, Inspection
Supervisor, Department of Mines
  and Minerals, Oil and Gas
  Division

George Bradel, Environmental
  Engineer Chief, Natural
  Resources and Environmental
  Protection Cabinet

Otis Walker, President
Terry Walker, Geologist
George Holliday, Contracted
  Observer
Alan Willson, Contracted Sample
  Team Member
Kyle Hodges, Contracted Sample
  Team Member
Site Description
The Glassco Lease site is located in a rural,  piedmont area.   The
climate at this site location is net precipitation.   The soil is
described as clay.  The site is located over the Illinois basin.
The formation was not specified by the operator.  Figure 2 is a
survey of the exact location of the hole.

The depth to the groundwater in the area is 58 feet.   The nearest
surface water is Lick Creek located less than 1/4 mile from the
site.  There are no drinking water wells located within a 1-mile
radius of the site because all residences in the vicinity use the
county water system.

At the time of sampling,  the site consisted of two mud
circulation pits, one settling pit, and one reserve pit.  The
drilling equipment had been disassembled but was still at the
site, as shown in Photos  11 and 12.  Figure 3 is an approximate
schematic diagram of the  site, indicating the directions in which
photos were taken (Attachment A).

This site was an exploratory oil drilling site.  Drilling began
on August 14, 1986 and was halted August 18, 1986. The depth was
2,400 feet when drilling  was stopped.  The well proved to be a
dry hole.

Drilling was accomplished with a Quebracho mud and a  lime mud.
Other additives included  caustic soda and Magcobar Gel
(bentonite).  The Brant Mud Company located in Henderson, KY was
used to run the drilling  mud program.
                             C-416

-------
                                WELL LOCATION  PLAT
                  MAVERICK PRODUCTION INC.  - TOMMY GLASSCO NO. 1
   OPERATOR -
   FARM
   COUNTY
   TOPO SHEET
   DATE
   SCALE
                                                     Maverick Production  Inc.
                                                     Tommy Classco
                                                     Henderson
                                                     Spottsville
                                                     7/16/86
                                                     1" - 200* —
                                                               CARTER COORDINATES
                                                                  13-P-2S
                                                               750 FSL,  200 PEL
                                                               Elevation » 409.S feet
I HEREBY CERTIFY that the above plat is  accurate
and correct  and satisfies the requirements of
805 KAR 1:0$9 to the best^of ay knowledge and belief.
          Eeve A. Likins
         (502) 826-4330
     UKiHS i :iOi;«AVE
    uo; .1. c';..:.. .,:;I::T
       p o. i.n- •'?.'•:
    rnC'JOM. M.-ih':- Ky «2420
                                 STATE o? AeiTiiCi

                                                                             '
\  S. A. UKJSS
      2352
   RCGIST«r.lD
           Figure  2.   Survey of Well Location  (size of
                          copy  has been  reduced)
                                        C-417

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Figure 3.  Schematic Diagram of Drilling Site
                    C-418

-------
One unlined reserve pit was constructed onsite to provide
temporary storage of drill cuttings, fresh water, drilling mud,
cement, and produced brine.   The operator stated that the
drilling muds were vacuumed into the reserve pit from the mud
circulation pits.  The drill cuttings were piped to the reserve
pit from the drilling operation.

The average depth of liquid in the reserve pit was 1/2 foot, and
the average depth of the sludge was 1 foot.  Photo 1 shows that
the reserve pit was never filled enough to cover the bottom
completely.

Two pits were constructed for use as mud circulation pits.
Photo 7 shows these pits and the channel that connects them.
Photos 8 and 10 include the settling pit constructed north of the
circulation pits.   All four pits onsite were constructed below
grade.

The mud circulation pits had been treated prior to the time of
sampling.  During drilling, caustic soda was added to neutralize
the mud to a pH of 7.  The entire contents of the pits were
treated, and half of the contents were "jetted" over to the
reserve pit.

Approximately 200 gallons of diesel were stored onsite in tanks
during drilling.  The operator estimated that approximately 5
gallons of waste oil had been disposed of in the circulation pits
when a diesel engine developed an injector leak.  Another source
of waste oil was rotary chain lubricant used onsite.

Disposal Practices

The operator would not take any steps to restore the site until
after the corn in the surrounding field had been harvested, in
order to minimize the crop loss.  The harvest was expected to
take place in October.

The liquid in the pit was to be removed from the site by truck,
although the ultimate disposition of the liquid was not
identified by the operator.  The company used for hauling waste
liquids from the site was Russell's Tank Service, located in
Pleasant Ridge, KY.  The solids would remain in the pit, and the
pit would be backfilled.  The area would be restored according to
recommendations of the Agricultural Soil Conservation Service, a
state-funded service performed by the University of Kentucky.

Permits

A copy of the drilling permit secured by Maverick Production,
Inc. for the Glassco Lease Well No. 1 is located in Attachment B.
                              C-419

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SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).

Sample Point Locations

At the Glassco Lease site, the samples were defined as the
supernatant and solid contents of the waste material in the
reserve pit.

The sample points were obtained by standing on the side of the
pit and reaching in with the sampling equipment.   A boat was not
used for sampling because there was not enough liquid surface in
the reserve pit to float on. There was some discrepancy between
actual and measured sample points due to the inaccessibility of
the measured points.  Figure 3 indicates the measured sample
points as well as the actual sample points from which the pit
samples were composited.

In addition to the pit samples, a drilling mud sample was
collected from the eastern mud circulating pit.  The circulation
pits were connected by the channel shown in Photo 9, so their
contents were assumed to be approximately the same.  The eastern
pit was chosen for its lack of surface debris.

Sampling Methods and Equipment

To collect samples from the reserve pit, the pit was measured to
identify the four quadrants shown in Figure 3, and to locate the
center of each quadrant.  The measured points were marked with
stakes to facilitate locating sample points.

The first sample to be collected was the liquid composite.  The
thief was used by threading the gaging tape through a pipe,
attaching the thief to the end of the tape, and extending the
pipe over the surface of the liquid as far as the sampler could
safely reach.  Care was taken not to allow oil floating on the
surface of the liquid to enter the thief.  The liquid from each
sample point was composited in a 5-gallon carboy.

The reserve pit was then sampled for sludge.  The dredge was used
to sample the sludge because the sludge was not deep enough and
was too liquid to be retained by the coring device.  Two full
dredges were obtained at each sample point, yielding a total
volume of approximately 4 gallons.  The solids were composited in
a 5-gallon steel bucket.

To collect the drilling mud sample, a clean, 1-gallon glass jar
was dipped into the eastern mud circulation pit,  shown on the
right in Photo 9.  This was a grab sample rather than a composite
sample.
                              C-420

-------
The pH of both the reserve pit sludge sample and the drilling mud
sample was measured onsite after sampling was completed.   The pH
was 7 for both samples.
                             C-421

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                C-423

-------
C-424

-------
n
      Photos  t,2,3.   Northerly view of drill site
to
Ul

-------
         .-•^"^T..~i •:\..l'^-.:„-*,i;^'%-"
Photos  4.5.   North  end  of reserve pit
                            Photo 6.   Southwesterly  view of  reserve pit
                                                 C-426

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   Photo  7.   Southerly  view  of  mud  circulation  pits and
*••            connecting  drainage ditches
10
-j.
                                                                          Photo 9.  Northerly view of connection
                                                                                    between mud circulation  pits
   Photo 8.   Southwesterly view of mud circulation pits
             with settling pit In foreground

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 Photo  10.   SettlIng pit
O
I
*>.
to
00
Photo 11.  Northeasterly  view  across  drill  site

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Photo 13.   Surface of sludge  In. reserve pit
Photo 14.  Surface of liquid In circulation pit

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0430

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ATTACHMENT B:  PERMITS
        C-431

-------
C-432

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   COMMONWEALTH OF KENTUCKY
  DEPARTMENT OF MINES AND MINERALS  P.O. Box 690, Lexington, Kentucky 40586
                       DIVISION OF OIL AND GAS  (606)257-3812
              AUTHORITY TO DRILL, DEEPEN, OR REOPEN A WELL
                                          Fee Account No: 786-94
                                          Samples Required:
                                          Type of Bond:
                                          Elevation:        4O9.5O
                                          Proposed Total Depth @  2535
 Permit No:  73198
 Datelssued: 28-Jul-198A
 Formation:  ST  GENEVIEVE  LS
 County:    HENDERSON
 Deepest Fresh Water @    35O
 Quadrangle: SPOTTSVILLE
     This is the authority under the 1960 Oil and Gas Conservation Act. effective June 15, 1960, and the Rules
                           and Regulations of this Division, for
MAVERICK PROD*  INC
RT 3  BOX 238-A
HENDERSON  KY  4242O
 to drill a well on the below described premises.   Location of well to be 13  P 25
0750   _FS1_    0200   PEL                 Said well is number 1
 and lessor is GLASSCOr  TOMMY
                                                                             m

This permit expires one year from the date of issuance unless drilling operations have commenced, prior thereto. A
completion report and drillers log and electric log, if run, and plugging affidavit if plugged must be furnished to the Oil
and Gas Division within 90 days of completion of drilling operations, in compliance with the laws of the Commonwealth
of Kentucky. Fresh water protection casing must be cemented to the surface or removed at the completion of the drilling
operation.  •
     THIS PERMIT MUST BE POSTED AT THE WELL SITE BEFORE DRILLING COMMENCES.
This well is permitted only for the purpose of  OIL
CALL THE INSPECTOR AT LEAST ONE DAY IN ADVANCE OF DRILLING COMMENCEMENT AND/OR
PLUGGING. TO OBTAIN PLUGGING INSTRUCTIONS FROM THE INSPECTOR YOU MUST IDENTIFY THE
WELL BY PERMIT NUMBER AND PROVIDE THE WELL LOG FOR THE INSPECTOR.
Inspector   JAMES  M  BRYARS  JR
         ROUTE  2r  BOX 474-D
         HENDERSON  KY 4242O
Home Phone:
     5O2 82A  O397
                                          Mobile Phone:
                                         ooo ooo  oooo
                            INSPECTOR'S COPY

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C-434

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                         Sampling Report
               Investigation of Ecus Corporation's
                Gamblin Lease Production Facility
                     Hopkins County,  Kentucky
                         August 22, 1986


SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document  in Appendix B of the EPA Technical
Report  (EPA 530-SW-87-005).  This site was selected randomly from
a computerized list of 2,454 Illinois Basin production sites
developed by the Madisonville Office of Water, and the Department
of Mines and Minerals, at the request of EPA.  The list was
transmitted via overnight mail to the EPA contractor on August
18, 1986. Randomization and selection took place immediately.

The EPA contractor had no interest in the manner the particular
sites were listed (by site name, location, operator, permit
number, API number, etc.) as long as the site could be identified
in detail upon selection.  Thus, the EPA contractor had minimal
information which kept to a minimum the amount of bias.  No other
information was known about the sites on the list at the time of
selection.  Detailed information was obtained only after
selection of primary and back-up sites.

The Department of Mines and Minerals listed the possible sample
sites by registration number, by status, by operator,  by
lease/field name, by type of well, by production rates, and by
discharge type.  The EPA contractor assigned numbers to the
members of the list as they were transmitted.  A random number
table was used to select the primary and back-up sample sites.
The randomly-selected primary site was Ecus Corporation's Gamblin
Lease Production Facility in Hopkins County, Kentucky.  A second
site, the J/H Oil Company's Bettie Moss Heirs Moss Road facility,
was selected as a back-up sampling location in the event the
primary site was inaccessible or inappropriate.

Site Location

The Ecus Gamblin Lease production facility is located
approximately 2 miles west of Earlington, KY via County Road
1337, and 1 mile south of County Road 1337.  Figure 1  is a map
indicating the production facility site.  The full name and
mailing address for Ecus Corporation is:

          Ecus Corporation
          212 Main Street
          Mt. Vernon, Indiana
                              C-435

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Figure 1.  Location of Ecus Corporation's Gamblin Lease Production
           Facility, Hopkins County, Kentucky
                                C-436

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          Main Office Contact:  Lloyd Quinn
                           Ph:  812-838-4819

Attendees

Sampling at the Gamblin Lease production site was performed by
CENTEC Corporation personnel on August 22, 1986.  Following is a
list of people present at the time of sampling:
    CENTEC Corp. (Sample Team):
    State Representatives:
    Operator Representative:
    American Petroleum Institute
      Representatives:
Jim Kourmadas/ Technician
Jamie Mclntyre, Team Leader

Joe Lander, Inspection
  Supervisor, Department of
Mines and Minerals, Oil and
  Gas Division
George Bradel, Environmental
  Engineer Chief, Natural
  Resources and Environmental
  Protection Cabinet

Kenneth Paul, Production
  Superintendent
George Holliday, Contracted
  Observer
Alan Willson, Contracted Sample
  Team Member
Kyle Hodges, Contracted Sample
  Team Member
Site Description

The Gamblin Lease production facility is located in a rural,
piedmont area.  The climate at this site location is net
precipitation.  The soil is described as clay.  Wells serviced by
this facility are completed in the Jackson Sand formation of the
Illinois basin.

The depth to groundwater in the area is between 40 and 100 feet.
The nearest surface water is a creek located 300 feet from the
site.  The nearest drinking water wells are between 1/2 and
1 mile from the site.

The site consists of two oil stock tanks, one brine tank, and one
free water knockout, all shown in Photo 1 (Attachment A).  Figure
2 is an approximate schematic diagram of the facility, indicating
the directions in which photos were taken.

The brine tank and the free water knockout are cleaned twice per
year.  The stock tanks are emptied once per year.  Oil is
separated from the resulting tank bottoms and sold.  The final
                              C-437

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      \
     N
Figure 2.  Schematic Diagram of Production Facility
                        C-438

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disposition of the tank bottoms was not specified by the
operator.

At the time of sampling, there were three producing oil wells
being serviced by this facility.   These were Gamblin Well Nos.
2, 4, and 5.  The location of these wells is shown in Figure 3.
The average depth of these wells was 1,835 feet.  They each
produced less than 10 barrels of oil per day.  At the time of
sampling, each well produced the following amounts of water:
Well No. 2 produced 10 bbls/day, Well No. 4 produced 15 bbls/day,
and Well No. 5 produced 25 bbls/day.  The produced water from
these wells is reinjected into three injection wells to enhance
production on the Gamblin lease.

Chemical treatment of the wells includes the following products:

     o    Nalco Chemical #4910 (Visco Corrosion
          Inhibitor), average usage 3 gallons per week.

     o    Nalco Chemical #3930 (Visco Corrosion
          Inhibitor), average usage 15 gallons per
          month.

     o    Nalco Chemical #1153 (Visco Biocide), average
          usage 18 gallons per month, put into brine
          tank.

Photo 11 shows the storage area for chemicals used onsite.

Disposal Practices

The produced water from wells at the Ecus Corp. Gamblin lease is
reinjected to enhance production in the area.  Photos 5, 6, and 7
show the meters and filters for the three injection wells,
located in a pump shed northeast of the tank battery.

Permits

The operator states that "the wells in this water flood are being
operated by Authorization of Underground Injection by Rule."
Therefore, no copies of permits specific to the operation of the
production facility were available to the sample team at the time
of sampling.
SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).
                              C-439

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            \     A.C Gomblin
            '   MULLENAX a SHARP
            I
       •m«>M*vT
                                              WWfOSCO WATCMFLOOO PATTERN
                                                    SUGAR CREEK FIELD   '   '
                                                •  MOMIN8 COUNTY. KCNTUCKY  .
                                                       MAkl • !*• «4«'
                                            OATt
                                            OATt
                                                      MEVIKDtr
DATE
OATt
JAMES A LEWIS
 ENGINEERING
    INC.
Figure 3.   Location of Wells Serviced  by Ecus Corporation's
             Gamblin  Lease  Production Facility
                                C-440

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Sample Point Locations

One fluid composite sample was collected from a sample port in
the brine tank shown in Photo 9.  Figure 2 indicates the sample
point from which the fluid sample was composited.

In addition to the produced water sample, a tank bottoms sample
was obtained from the brine tank.

Sampling Methods and Equipment

The fluid sample was collected through a pipe located approxi-
mately 8 inches from the bottom of the brine tank.  Photos 8 and
9 show the sample point.  The sample was collected in a 5-gallon
carboy.

The tank bottoms sample was collected by dropping the dredge
through an opening in the top of the brine tank.  The solids
contained a considerable amount of oil.  Conditions on the top of
the tank were hot and slippery, and eventually became too
dangerous to continue sampling.  The dredge brought up very
little sample with each drop into the tank, so the total volume
of solids collected was approximately 2 gallons.

Tests for the pH and free chlorine content of the fluid sample
were conducted onsite after sampling was completed.  The pH of
the fluid sample was 7, and its free chlorine content was less
than 0.2 ppm (i.e., none detected).  The pH of the tank bottom
sample was also 7.
                               C-441

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C-442

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                 C-443

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C-444

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o
 I
ut
Photo 1.  Westerly view of production tankage
                       Photos 2.3.  Westerly view of  production  tankage

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0  Photo 4.  Brine flow Hne exlt.ng
Photo 5.  Two sides of pomp
          well heads
                            house wall.; showing Injection
      „„*„ -,   MtTTTnn three" U lect Ion wells. Inside

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O  Photo  8.   Liquid  sample  point  at  brine  tank
                                                                      Photo  9.   Liquid  sample  point  at  brine tank
                                                                          ^:.C. ..  -. .-^ ' —"•"•~^ •  -'iir*-^^ •' -l-
   Photo 10.   Sampler preparing to take tank bottoms
              sample from brine tank
                                                                     Photo 11.  Treatment chemical drums at production site

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C-448

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ATTACHMENT B:  PERMITS
          C-449

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n
 i
iU
en
o

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No permit specific to the operation
     of  this  site  is  available.
                C-451

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C-452

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LOUISIANNA
     C-453

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C-454

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                         Sampling Report
                         Investigation of
         FMP Operating Company's S/L 195 No. 2 Oil Well
                  Plaquemines Parish, Louisiana
                         June  14,  1986


SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA 530-SW-87-005).  This site was selected randomly from
a list of Gulf Coast Salt Dome Basin drill sites (at or near
completion) developed by the Louisiana Department of Natural
Resources Office of Conservation for EPA.  The list was
transmitted via telephone to the EPA contractor on June 10,
1986.  Site selection took place during the telephone
conversation.

Louisiana state officials preferred to list the possible sample
sites by location (rather than by operator).  The EPA contractor
had no interest in the manner the particular sites were listed
(by site name, location, operator, permit number, API number,
etc.) as long as the site could be identified in detail upon
selection.  Thus, the EPA contractor had minimal information
which kept to a minimum the amount of bias.  No other information
was known about the sites on the list at the time of selection.
Detailed information was obtained only after selection of primary
and back-up sites.  The list consisted of six coastal drilling
sites:

               1.  St. Bernard
               2.  Cameron
               3.  Quarantine Bay
               4.  Lake Washington
               5.  St. Mary
               6.  Cameron

As indicated above,  the EPA contractor assigned numbers to the
members of the list as they were transmitted.  A random number
table was used to select the primary and back-up sample sites.
Quarantine Bay was selected as the primary sample site.  St. Mary
was selected as a back-up site should sampling at Quarantine Bay
prove inaccessible or inappropriate.

Further inquiry indicated that the Quarantine Bay site was being
operated by FMP Operating Company at their S/L 195 No. 2 Oil Well
in Plaquemines Parish, Louisiana.  Their status was described as
being very near completion during the desired sample time frame.
Plans were made for sampling to be conducted June 14, 1986.  The
back-up site was not required.
                              C-455

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Site Location

The FMP Operating Company's S/L 195 No. 2 oil well is located
approximately 2 miles north of Buras, LA, in Quarantine Bay.
Figure 1 is a map indicating the well site.  Figure 2 is a
drawing indicating the exact surveyed locations of the surface
and bottom hole.  The full name and mailing address for FMP
Operating Co. is:

          Freeport-McMoRan and Partners (FMP) Operating Co.
          A Limited Partnership
          McMoRan Oil and Gas Co., Managing General Partner
          McMoRan Exploration Co., A Division of McMoRan Oil and
            Gas Co.
          P.O. Box 60009
          New Orleans, LA  70160
          Main Office Ph.: 504-582-4000
          Main Office Contact: Doug Vrooman, Chief Engineer
                               Ph: 504-582-4662

Attendees

Sampling at the FMP Operating Co.  S/L 195 No. 2 well was
performed by CENTEC Corporation personnel on June 14, 1986.
Following is a list of people present at the time of sampling:
     CENTEC Corp. (sample team):
     EPA Representative:
     State Representative:
     Operator Representative:
     Drilling Contractor
       Representative:
Bill Lane, Technician
Jamie Mclntyre, Team Leader
Kerri Kennedy, Project
  Manager

Susan de Nagy, Office of Water,
  Project Officer

Shile McCarty, Conservation
  Enforcement Agent, Dept. of
  Natural Resources, Office
  of Conservation

Gavin Barefield, Drilling
  Foreman
John Hall, Rig Supervisor
     American Petroleum
       Institute Representatives:  George  Holliday,  Contracted
                                    Observer
                                  Lloyd Deuel,  Contracted Sample
                                    Team  Member
                                  Allan Wilson, Contracted Sample
                                    Team  Member
                              C-456

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- ^tlpPfpS%=
                                            VT TOMCAT!
                                            .ATlTUM M* LC
    Figure 1.  Location of FMP's S/L 195 #2 Well, Plaquemines
             Parish, Louisiana
                       C-457

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        UJ
        CO
        CO
LJ
CO
              30
 * I «
                            19
                             54
                               STATE  OF LOUISIANA

                               PEL-   L'  '"

                                     INC. LEASE**
                                                                                3  K5S
                                                      56
                                           s.c. a «^
                                           STftlCA"
                                                     -•'          —r     ~r
                                                     2   ..-.--.-.- -  ••T-^'yj-   •;
                                                     I                   i:


                                                     v  /. :._:..';'cr.u.7 ^/


                                           	\. "*»  —'.'• ^X
                                           HE8. MO. 4348
CH t C K F O BV     a^^^^^^^^1""^     ftJAB^ * •»  K.   "^^^^^^^^^•^^^•^^"•IMI^™^^ ^^"™*™^'-fc^'illl*ll^^^^""«
                                   HOOMA.^.^^^
                                                                         A - (498
               Figure  2.   Survey
                                                               (size of
                                       C-458

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The drilling contractor for this well was Atlantic Pacific Marine
Corporation  (AMPC).  A copy of a vendor list, provided by FMP
Operating Co., is  located in Attachment C.

Site Description

The S/L 195 No. 2  well is located in a rural, coastal area.  The
climate at this site location is net precipitation.  At the time
of sampling, the site consisted of the APMC Drilling Rig No. 12,
a cargo barge, and a drilling waste barge moored to the east side
of the rig.  Figure 3 is a view of the west side of the rig, and
Figure 4 is a plan view of the main deck.  Both these figures
were provided by FMP Operating Co.

The site is located in an oyster bed area within Quarantine Bay,
and is therefore accessible only by boat, or as indicated in
Figure 3, by helicopter.  Photo 6 was taken from a boat that was
leaving the drilling site after sampling was completed.  Water
depth at the site  is 5 to 8 feet.

This site was a developmental oil drilling site.  The well was
planned to be completed at 13,850 feet, and its depth the day of
sampling was 13,827 feet.  Drilling began April 13, 1986 and was
estimated to be completed by June 15, 1986.

Drilling was accomplished with three fresh water base muds.
These are summarized in the table below:

             Mud Type            Depth Range (ft)

             Spud  Mud                0 -  6,000

             Lignosulfonate      6,000 - 12,332

             Lime               12,332 - 15,021

The change from spud mud to lignosulfonate mud was gradual.  When
drilling reached 12,332 feet, approximately 1,516 barrels of
ligno-sulfonate mud were taken to a Francis Drilling Fluids, LTD
mud storage facility, and replaced with approximately 1,592
barrels of lime mud.  The address of Francis Drilling Fluids
follows:

          Francis Drilling Fluids, LTD
          PO Box 1694
          Crowley, LA  70527
          (318)  783-8685

The lime mud was used when a region of abnormal pressure
containing C02 was reached.   It was explained that lime muds
resist thickening  in the presence of C02, and that a higher
weight mud is necessary in abnormally high pressure.  The lime
mud in use at the time of sampling had been measured to have a
weight of 14.7 pounds per gallon.  Copies of mud reports for each


                              C-459

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H-
•X!
C

(D

u>
 (D
 Ul
 ri-

 cn
 H-
 a
 ro
 H-
 CD
 3
 -2

 70

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i
•u
a\
                               Figure 4.   Overhead View of Drilling Ria

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mud type/ provided by the drilling fluid contractor,  IMCO, are
located in Attachment D.

Drilling took longer than expected because a pipe broke at 11/600
feet.  It was originally estimated that drilling would take about
40 days.  The broken pipe put the drilling schedule three weeks
behind, since it was necessary to drill a new hole.  This was
accomplished by partially backing up the hole and sidetracking
around the original hole.

Tanks storing diesel onsite contained 19,320 gallons  at the time
of sampling.  An exact amount of waste motor oil to be generated
by completion date could not be given at the time.

The barge containing drilling wastes to be sampled by the CENTEC
team served as temporary storage of fresh water, deck drainage,
and cuttings with residual drilling mud that left the mud
circulation system via shale shaker, desilter, and desander.
Figure 5 illustrates the position of the barge in relation to the
drilling rig.  The barge was partitioned into four quadrants of
equal size.  The quadrants contained liquid and sludge waste in
various amounts, received via pipe from the mud circulation
system located on the main deck of the rig.  Photo 2  shows the
CENTEC sample team taking a core sample from the southeast
quadrant of the barge.  This photo also shows the shale shaker
and cuttings line located on the overhead platform behind the
yellow railing.

Disposal Practices

Newpark Waste Treatment Systems, Inc. was the contractor hired to
receive and process the drilling waste barges as they were filled
and brought to the nearest treatment facility.  Price lists for
the waste handling services provided by Newpark are located in
Attachment E.

The drilling waste that was in the barge at the time  of sampling
was the fourth barge-load to be filled since drilling began April
13, 1986.  The first three barges were received at the Newpark
facility on April 17, 26, and May 15, 1986, each holding volumes
of 1,610, 1,369, and 1,366 barrels, respectively.

Two barges were kept in service so that as one barge  was being
emptied at the treatment facility the other was being filled at
the rig.

Permits

Copies of construction and drilling permits secured by FMP
Operating Co. are located in Attachment B.  It should be noted
that the Pel-Tex Oil Company, Inc., appearing on the  construction
permit as the applicant, has been acquired by Freeport-McMoRan
Oil and Gas Co., and therefore does not appear on later
documents.
                              C-462

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           N
             RI6
" AM PC  RIG, NO. 12
                          Pl_ATTZ*K

                                •  \'?.
4
                                         I
                                      BARGE"
              DRILLIN6
                BARGE:
                                                          BOATS
Figure  5.   Schematic of Drilling Waste Barge

                    C-463

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-SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).

Sample Point Locations

At the Quarantine Bay site, the samples were defined as the
supernatant and solid contents of the waste material in the
holding barge.  Figure 5 indicates the sample points from which
the barge samples were composited.  As shown in Photo 2, the
sample points were reached by standing on a 2-foot ledge around
the barge and reaching into the quadrants with the sample
equipment.

In addition to the barge samples, drilling mud samples were
collected from points located before and after the drilled hole.
The first mud sample was taken from the holding tank from which
mud was pumped down hole.  The second was taken from the shale
shaker effluent as it reentered the circulation system after
coming back up the hole.

Sampling Methods and Equipment

The first sample to be collected was the sludge composite.  To
collect this sample, the barge was measured to identify the
center of each quadrant.  The sides of the barge were marked with
tape to facilitate locating center points.  The coring device was
used with a 5-foot extension rod attached.  The sample was taken
by extending the coring device over the quadrant along one
measured axis as a second person sited the device's distance from
center along the perpendicular axis.  When the end of the device
had reached center, the second person signaled the sampler to
insert the device at that point.  The device usually went into
the sludge at a 30"-45* angle (Photo 3).

The barge quadrants were sampled in counterclockwise order,
beginning with the southeast section.  The first sludge cores
were two-thirds full (about 2/3 quart), but each successive
quadrant was more difficult to sample.  By the fourth quadrant,
three glass core sleeves had broken, and the teflon sleeve was
not retaining sludge long enough to get it to the steel bucket.
The difficulties with sampling were attributed to the hard-packed
consistency of the sludge, presumably high in sand content.  The
last quadrant was finally sampled using the dredge.  The sludge
was composited in a 5-gallon steel bucket.

Next, the barge was sampled for liquid.  The thief was used by
threading the gaging tape through a. pipe, attaching the thief to
the end of the tape, and extending the pipe over the quadrant in
                              C-464

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the same manner as the coring device,  until the thief was located
over the center point.  One sampler lowered the thief into the
liquid, and a second sampler pulled the string allowing the
sample to enter the thief.   Photos 4 and 5 show samplers taking
thief samples from the northwest quadrant.  A problem was
encountered in the first (southeast) quadrant when it was
discovered there were only 2-3 inches  of liquid over the sludge.
To sample this quadrant, a clean 1-quart glass jar was lowered
over the side of the barge and held by hand as it filled.  The
liquid from each quadrant was composited in a 5-gallon carboy.

The drilling mud samples were also collected by holding clean
1-quart jars in the streams located prior to the hole and exiting
the shale shaker after the hole.  These were grab samples, not
composites.

The pH of the barge samples was measured after sampling was
completed.  Both the liquid and the sludge samples had a pH of
10.

The samples were preserved with ice and held overnight prior to
the day of shipment.  This was necessary because of time
constraints encountered on the day of  sampling.
                              C-465

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C-466

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                 C-467

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C-46fi

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  Photo  I.  Approaching  drilling  rig  from  the  west
O
I
ID
Photo 2.  Core sampling southeast quadrant  of  drilling

          waste barge
                                                                                        - - f~^s*»

                                   Photo  3.   Core  sampling  southeast quadrant of drilling

                                             waste barge

-------
n
i
•*>.
  Photo 4.
Liquid sampling northwest quadrant of barge
                                                     Photo  5.   Liquid  sampling northwest
                                                                                         quadrant

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ATTACHMENT B:  PERMITS
          C-471

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C-472

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FOMM MO ILK
STATE OF LOUISIANA
OFFICE OF CONSERVATION
           ATT
Send To	Hev Orleana/12
                      (            '.VEIL RLE COPY           (

                          PERMIT TO DRILL FOR MINERALS
    N»     Ser*203552  API  #1707523380
                                              REPERMIT
                                              iMarch 6, 1986
                                                                  PERMIT	$200.00  I
                                                                  Multiple Zone Processing
Porish	


Operator.
           Plaquq"t n**a   038
FJ.U  South Quarantine Bay  7563
           FMP Operating Company. Ltd Ptn  2071
           P. Q. Box  6QQOg
City & stat.   ffev Orleans.  LA  70160
Well Nam,    SL 195  ffO. g	
LQgat,on      Sec —. T19S,  R17B
           N Ilr°lt2'53"  E  7190.92' fr USC&GS "OSTRICA".  PBHL; 2580' N 7803*E
           of surf.  (Repermt-SerteQing-Eamired. ]_X=2.578.850.00
                                 JPTDJ15.000'
                COMMISSIONER
                                  Any and a.3T
Ani}iir«ii -CM' c? J* Coni»'vaiion Otder 	
                                                                  < ,-
                                                                      1^0801
                                      C-473

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                     APPLICATJON FOR CfcWCTlON PEWIT
                  PLAOUEHJHES PARISH DEPARTMENT OF PEWITS
  RICIIPT "a.         w-                 PIRMT No.
  BATH    Vftm        _        PERMIT PKS       itnn.nn
  ZONING BHTRICTt               .           PERMIT CLERK!
  APPLICANT    M-T«JK Oil Company,lnc.        Anpggss  MOO Intarflrat PUia
  PHONE H0i    <713) €58-8284	          Houston. Ttm 77002
  Typt of Construction:  Coaaaroial          In dm trial    *     Saiamic,
  DESCRIPTION or PROPOSED MORX-
                 >»n for oil  t att  • »1nlB«l
  LOCATION Of PIOPOSID WORK:
           AoprenlMttlv ? n<1«s northtrlv of Bur»s. Louisiana
  BASE OP OPERATION:
       <1) Location:    Pel-Tax Oil Coapany, Inc.
       (2) Fhona No. at Location:   1-318-237-1654
       (3) Mailing addrata  at  location:  PO Box 891. Scott. La.  70583
       (4) A»tnt in chargt  at  baaa o'f oparation: Pat Angers
  PROPERTY OWNER OR LEASE OWNER:      State of Louisiana	 ,_..
                   (Attach a copy of aatborizatioit froa property owner or Uut
 ESTIMATED COST:  S   a.OOP.000 4
 CONTRACTOR:          Unknown «t th-it
            Addraaa:.	
            Phona No.
       THIS APPLICATION WILL NOT BE CONSIDERED UNLESS ALL QUESTIONS ON
       THE APPLICATION AND ANNEX "B" ARE COMPLETED AND A  COMPLETE SET
       OP PLANS AND SPECIFICATIONS OF THE PROPOSED WORK ARE ATTACHED.
        ; . THIS OFFICE HUSt BE NOTICED NO LESS THAN* 24 HOURS PRIOR TO.THE*
          TIME YOUR EQUIPMENT IS. MOVED TO THE JOB SITE.
                    y'=*   * OWE            AGENT ORUe>/ESENTATIVE
-------
                                  ANN!/ *•
                                         *"
           (IF MORI IFACI It MII&I9, ATTACH ANOTHtR IHItT OF PA»«)


1.  Uit rafter aod typo of «a*ta MviBg equipment to to ueed ia .propoeett
    work. (land or vater, fit*, h.p.,  draft, bucket lisa, ton&|«, been ln(tb)

    I • w*n bucket dredge
.   U»t a\ab«r nd t7P« of b«r|«i to b
   (•!«•.  draft,  aad type of u»«)

   During drilling >  1 » 300 HP tug
                   2 • 40' x 110 deck btrges
                                               la propoaod works
3.  Uit ftiobor  »d  trp*  of work boat*  and cufi to bo u«*d ia prepovad work: ,
    (aixo. draft, Boriapow«r of aach)

    Vc win use 2  - 600 HP tugs to nove rig ind 1 300 HP tug to service H?


4.  Drillia$  oparatim:   (loeaeioa,  dapeh of drilliaf, la&d or water rig)

     (•rge rig • Proposed depth • -15,000'


S.  Method  aod route of eraaaeortiag aquipamt to location:
     (if watar route, attach plat ahowiag propoead route in rad)

     He will enter from touth it OstHc* locks end u»e channel ecross Quarantine
     Bay a* shown  on plat.

«.  Attach  drawtag  ehovinj propoead location of rig and accessory buildingt.
    oil pits, aod any  other related structures, sbowint the  distance freos
    euch  structures  to highways , levees, draiaage cattail, buildings, or  any
    other public iaprovemants .
        Please see attached plats
 7.  If this becoaas  a  production wall,  show method of  atorage and traas-
    pertation of raw materials.
          PUts attached

 I.   Other information:
               SPECiriCATIOKS OR COSOITIOSS OF PERMIT APPROVAL:
•APPROVED     /
                            HATE
ACEIR OR «£WSINTAT:VE
                                         C-475
                                                   Or—.

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C-476

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ATTACHMENT C:  VENDOR LIST
            C-477

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C-478

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                             FMP Operating  Company,
                             a Limited Partnership
                                  MEC Division

                                    S/L 195  12
                          Plaquemines Pariah, Louialana
                                    T19S  R17E
                                  AFE *  12442
                                    VENDOR LIST

 1.   DRILLING CONTRACTOR  -  Atlantic Pacific Marine  - Houma - (504)  868-5330

 2.   BITS  -  Hughes  - Houma  - (504)  872-0414

           "  Security - Venice -  (504) 534-2327

           -  Smith - Belle Chaaae -  (504) 392-2487

           -  Reed -  Harvey - (504) 394-1259

 3.   CASING  CREWS - International Hammers - Houma  - (504)  872-6892

 4.   CEMENT  & CEMENT'G SERVICE - Halliburton  -  Venice -  (504)  534-2386

 5.   CENTRIFUGE - Brandt  -  Houma -  (504) 876-7112

 6.   CHOKE - Drilco - Houma -  (504) 868-6510

 7.   DIRECTIONAL DRILLING - Helmer  - Gretna - (504)  524-9769

 8.   DRILLING JARS  - Dailey Oil Tool - Houaa  -  (504) 873-7788

 9.   FISHING SERVICES - Tri-State - Houma - (504)  876-1097

10.   FLOAT EQUIPMENT - Davis Lynch  - Houma  -  (504)  868-4510

11.   HEVI-WATE - Colony Rentals  - Gretna -  (504) 524-9769

12.   LOGGING - Schlumberger - Lafayette  -  (318) 261-8104

13.   MUD CLEANER -  Brandt - Provided with Rig

14.   MUD SERVICES - IMCO  -  Venice - (504) 368-2622

15.   MULTI-SHOT - Sperry  Sun - Harvey -  (504) 393-9810

16.   RENTAL  EQUIPMENT - Patterson Rentals - Venice - (504) 534-2627

17.    STABILIZERS -  LOR -  Lafayette  - (318)  232-4245 (17j)

                 -  Helmer - Gretna  - (504)  524-9769 (12t & 8J)

18.    SURVEYOR - Morris Hebert  - Houma - (504)  879-2731

19.    SUPPLIES - Continental Emseo - Venice  -  (504) 534-2389

20.    TUGS &  BARGES  -  C-Craft - LaRoae -  (50A) 392-7980

21.   WELL HEADS -  Cameron - Harvey  - (504)  366-4528

22.    WELL HEAD PREHEATING - Heat Treating  Int'l - Gretna - (504) 363-0550

-------
C-480

-------
ATTACHMENT D:  MUD REPORTS
           C-481

-------
C-482

-------
             IMCO Services    g
                 A Halliburton Company
             MM N. Conn* Dr. PO. So< TWOS
             HouXw, TX 77327 A/C 713MM300
                                                                            DRILLING MUD REPORT NO.
                                                                            COUNTY0RARISH OR OFFSHORE  STATE/PROVINCE
OPERATOR
REPORT FOR
                                                                                                         SECTION. TOWNSHIP. RANGE
WELL NAME AND NO.
                                                       OR BLOCK NO..
     DRILLING ASSEMBLY
                                    CASINO
                                    MUDVOLUME(BBL)
                                                                                             CIRCULATION DATA
BIT SIZE
           TYPE
                     JET SIZE
                                     iURFACE
                                                  HOLE
                                                              PITS
                                                                            PUMP SIZE
                                                                                                     IN.
                                                                                                         ANNULAR VEL (ft/mln)
DRILL PIPE
SIZE
           TYPE
                     LENGTH
                                  INTERMEDIATE
                                                  TOTAL CIRCULATING VOLUME
                                                          SVL
                                                         GE   WEI
                                                                            PUMP MAKE, MODEL
                                                                                              ASSUMED
                                                                                                         CIRCULATION
                                                                                                         PRESSURE (BSD
DRILL PIPE
           TYPE
                    LENGTH
                 INTERMEDIATE
                    ln.»  	 It.
                                                  IN STORAGE   WEIGHT
                                                                            bbV»tk
                                                                                                  MWtnln
                                                                                                         BOTTOMS
)RILL COLLAR SIZE
                     LENGTH
                               PRODUCTION OR LINER
                                    m. •       n.
                                                  MUD TYPE
                                                     JLJl
                                                                                        TOTAL CIRC
                                                                                                  o*l/min
 •mpto From
 im« Stmpte Taken
 owlln* Tamp«ratu(« (*F)
       l/(PPO)
                                         MUD PROPERTIES
                                                                               MUD PROPERTY SPECIFICATIONS
                                      U F.L. H/PIT
                                       /Kg
                                 D F.L. D PIT
                                                            WEIGHT
                                                                                   VISCOSITY
                                                                                                          FILTRATE
                                                                               RECOMMENDED TOUR TREATMENT
                                                            IMCO
 light
C id Point (lb/100 ftt
  I Strength (lb/100 ft1) 10 »«CHO mm
                                       /  /j
  rats API (cm«/30 mln)
   HTHP Filtrste (Ctrl'/So mln) 9
   • Thickness (32nd In. API/NTHP)
   da Content (•/, By Von 11 calculated I/retort
                                                                                         .REMARKS
   ild Content (% by Vol) OllftVatef
   J Content (% by Vol)
   lylens Blue Capselty
     H  Strtp  f/Meter
   Unity Mud |P»>
    Inlty Filtrate (Pf/Mf)
    de(mg/L)
                                                                      SOLIQS EQUIPMENT RUN LAST 24 HOURS (Please Fill In)
                                                                 «MA*CO .1

                                                                 SHAKER «*
                                                                 MUO Cl EANER
                                                                        mesh
                                                                        mesh
                                                                                                CENTRIFUGE
                                                                                                DESANOER _
                                                                                                DESIITER
                                                                                                                         » 'no
                                                                                                                          10
     <0
                                                                                                      HHP.

                                                                                                          CRITICAL VfLOCITY

                                                                                                      DP _____   DC	
                             6*3363
                                                                                                      EQUIVALENT CIRC DENSITY
                                                                                                      Csfl.
                                                                                                      Shoe	  TO	
                                      PHONE
                                                       WAREHOUSE PHONE  DAILY COST
                                                                                                     CUMULATIVE COST
      MOR
      1 REV. 4-S4
      IN US.A
                     t-M SOU
                             NOTICE ANY OPINION ANOOR RECOMMENDATION. EXPRESSED ORALLV OR WRITTEN HEREIN. HAS BEEN PREPARED CAflEFULLV AND
                             MAY BE US«O IF TH6 USHt SO B.ECTS YOHei». NO RCPRCSENTATION OR WARRANTY IS MADE BY OURSELVES OR OUR ACEN T S AS TO
                             ITS CORRECTNESS OB OOMPUETENES& AMD NO LIAONJTY IS ASSUMED FOR ANY DAMAGES RESULTING FROM THE \Kf n* uuc

-------
            IMCQ Services
            «9»*ongiMAU.ieo*T>'»C<>'n« Ttmo«r»tu'»   (f)
                          M. O«T
                                                             WEIGHT
                                                         VISCOSITY
                                                                                                        FILTRATE
                                                                          RECOMMENDED TOUR TREATMENT
Otpih (ft)
                                    Q  IMCO BAR
                  Dlib/euft) O$ogr
                                    Q  IMCO GEL
Funnel Vucotity (s*c/qt) API 9
                                     D  IMCO BR1NEGEL
Pl»ttie Vitcoiity ep 9
                                     Q  IMCORO-111
  wiri Point (lb/100ft2)
                                     D  IMCOVC-10
Get Strtnqth Ob/100 ft2) 10 Me/10 min
                                     D  »MCO THIN
Filtrate API (cm3/30 mm)
                                         CAUSTIC
API HTHP Filtrate (cm3/30 mm) 9
C»kA Thickneis (32nd in. API/HTHP)
                                     D
Solids Content M by Vol)  D cileulmed Qtetort
                                                          REMARKS
Liquid Content {% by Vol) Oil/Watef
Sand Content (% by Vol)
 Metnylene Blue Capacity
 ygigg
 pH O Strip
Alkalinity Mud n Img/L)
                                                                            CRITICAL VELOCITY


                                                                         DP	DC
                                                                         EQUIVALENT CIRC DENSITY
 CLOSING
 IMVtNTOHY
              ^  l4»
m \w \wr
               &&
                                               ^ HI-SP SHAKER

                                               3 MUD CLEANER
                                                    0DESANOER

                                                    ^DESILTEH
                   D CENTRIFU

                   C OEGASSth
                           *7yV
                                  PHONE
                                                    WAREHOUSE PHONE
                                                                          DAILY COST
                                                                                                    CUMULATIVE COST
                               NOTICE- ANY OPINION AND'OR KECOMMENOATION. EXPRESSED ORALLY OR WRITTEN HEREIN. MM HEN PREl-AfUn » AHr.«ui- v
                               MAY BE USED IP THE USCR SO ELECTS. HOWEVER. NO REPRESENTATION Ol» (WARRANTY is MADE »Y OJRSEI.VES an (»u'< A. ,f \Ts
                               ITS CORRECTNESS OR COMPLETENESS. A>0 I»O LIAeiLlTY IS ASSUMED POP ANY lAMAGf 5 MEilll 'IN(i PROM THP USI- 1)1 SA-f

-------
                                                                        DRILLING MUD REPORT NO.
                                                                                                   DEPTH
                                                                                             PR ESENTjlv l
                                                                         COUNTyJWUlSH OR OFPSHORE    STATE/PHJ»VI\CF
                                       MUD PROPERTIES
                                               MUD PROPERTY SPECIFICATIONS
implt From
                                      Q PH.
                                            rPIT
 a Swnplt Taken
>wlin« T«mp«r«(ur*
                    Q P.C. D PIT
                                                           WEIGHT
                                                                                 VISCOSITY
                                                                                                      FILTRATE
                                                                        RECOMMENDED TOUR TREATMENT
pth (ft)
O
                                          BAR
 ijht    elppg}  Ddb/cuft) Otpgr
                                D   IMCO GEL
   l Viscosity (s«c/qt> API 9
                                D   IMCOBRINEGEL
 Hie VJSCQSiCV CO 9
                                Q   IMCORD-111
 Id Paint (Ib/100ft2)
                                D   IMCO VC-10
 Strength lib/100 ft2) 10 »c/10 min
                                D   IMCO THIN
 rat* API (em3/30 mm)
                                Q   CAUSTIC
  HTHP Pil|r»t« (an3/30 min) 9
                                a
  l Thicknws (32nd in. API/HTHP)
  it Content (% by Voll  Q calculated {/retort
                                                     REMARKS
  id Content (% by Voll Oil/W»t»r
  I Content 1% by Vol)
  ylene Blue Capacity
  3 Strip S^eter 9
  inity Mud (Pm)
  inity Filtrate (Pf/Mf)
   late Alkalinity Filtrate IP]/Pz)
   de (mq/L)
   Hardness as Calcium (mg/L)
                                                                                 BIT HYDRAULICS
                                                           HHP
                                                 HHPB
                                   .HSIB
                                                                          CRITICAL VELOCITY

                                                                       DP	DC
                                                                      EQUIVALENT CIRC DENSITY
                                   SSS
                              37S
                                                                       H HI-SP SHAKER    (HOESANOER    n CENTRIFUGE
                                                                         WUD CLEANER   5/DESILTER     G DEGASSEH
     ATOR
      HEV. 0411 JOM
     IN II.5.A
                                PHONE
                     WAREHOUSE PHONE
          DAILY COST
                                                                                                CUMULATIVE COST
NOTICE ANV OPINION ANt»OR RICOMMINDATION. fXPRESSEO ORALLY OR WRITTEN HEREIN, HAS SEEN ffU'f.flU) CAHrni. , v AM.
MAY |( USED IP THE USER SO ELECTS HOWEVER, NO REPRSSENTATIO11; OR WAORANTV « MADE BV OUflSRI vrj JH .).i^< •.;><.'' A. i.
ITS CORRECTNiSS OR COMPLETENESS, ANO NO LIABILITY IS ASSUMED 'OR AMY fJAMAOf S RESUI TIMR rnOM Tt'E ur.F Ol

-------
C-486

-------
ATTACHMENT E:  PRICE LISTS FOR
   WASTE  HANDLING FACILITY
             C-487

-------
C-488

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                                   NEWPARK WASTE TREATMENT SYSTEMS, INC
                         GULF COAST PRICE LIST
                        EFFECTIVE JANUARY 1,1986
 PRICE LIST FOR DISPOSAL OF NON-HAZARDOUS OILFIELD WASTE AND SERVICES AT NEWPARICS
 GULF COAST FACILITIES. ALL PRICES ARE F. O. B. CLOSEST PROCESSING FACILITY.
 NON-HAZARDOUS OILFIELD WASTE                     PER BARREL
 WATER BASE MUD WASTE (A)                           (1) $ 7.50
 WATER BASE CUTTINGS                               (2)
 OIL BASE MUD WASTE (B)                              (1)   9.75
 OIL BASE CUTTINGS                                  (2)
 PRODUCTION  PIT AND TANK SLUDGES                       10.75
 PRODUCED SAND AND SOLIDS                             10.75
 PRODUCED SAND AND SOLIDS IN 55 GALLON DRUM            55.00/DR
 PRODUCED FORMATION FRESH WATER
          AND RING LEVEE WATER                        5.00
(A) WATER BASE MUD WASTE-WASH WATER                  $ 5.00
(B) OIL BASE MUD WASTE-WASH WATER                       6.00
(1) ALL MUD WASTE PRICES ARE BASED ON £ 30% SOLIDS BY
   VOLUME. WATER BASE MUD WASTE CONTAMINATED WITH
   GREATER THAN 10% OIL BY VOLUME WILL BE CHARGED AT
   OIL BASE MUD WASTE PRICES.
(2) CUTTINGS AND NON-PUMPABLE MUD WASTE WILL BE
   PRICED ON SOLIDS CONTENT, PRICES AVAILABLE UPON
   APPLICATION.

EQUIPMENT AND SERVICES RATES                     PER HOUR
SUPERVISOR              '                         (3)
OPERATOR
HELPER
PUMPING EQUIPMENT
CRANE WITH OPERATOR (4)
CRANE WITH OPERATOR CLAMBUCKET OPERATION
BOBCAT WITH  OPERATOR
AIR COMPRESSOR - (300 CFM) (FUEL INCLUDED)
DETERGENT- DEGREASER

(3) A SUPERVISOR CHARGE WILL APPLY TO ALL RECEIVING
   AND CLEANING ACTIVITIES AT NEWPARK DOCKS.
(4) NIGHTTIME AND WEEKEND CALL OUT RATES WILL BE CHARGED AT SOME FACILITIES.

BOAT TANK AND BARGE CLEANING WILL BE CHARGED AT PREVAILING RATES PLUS 20%.
TERMS: NET 30 DAYS FROM RECEIPT OF MATERIAL
TAXES: WILL BE ADDED WHEN APPLICABLE
$ 25.00
  20.00
  15.00
  60.00
 125.00
 150.00
  70.00
175.00/DAY
   5.00/GALLON
                                    C-489

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                                  NEWPARK WASTE TREATMENT SYSTEMS, INC
                      SOLIDS ADJUSTMENT CHART
                         FOR SOLIDS ABOVE 30%

THIS CHART SHOULD BE USED WHEN ADJUSTING PRICE FOR MUDS OR CUTTINGS WITH
SOLIDS CONTENT ABOVE 30% BY VOLUME.

EXAMPLE: OIL BASE MUD WASTE, 40% SOLIDS
CALCULATION: PRICE ADJUSTMENT
            1$9.00 x 1.327) X ACTUAL VOLUME
            $11.94 X ACTUAL VOLUME
31%
32%
33%
34%
35%
36%
37%
38%
39%
40%
41%
42%
43%
44%
45%
46%
47%
48%
49%
50%
1.033
1.066
1.099
1.132
1.165
1.198
1.231
1.264
1.297
1.327
1.360
1.393
1.426
1.459
1.492
1.525
1.558
1.591
1.624
1.657
51%
52%
53%
54%
55%
56%
57%
58%
59%
60%
61%
62%
63%
64%
65%
66%
67%
68%
69%
70%
1.690
1.723
1.756
1.789
1.822
1.855
1.897
1.932
1.966
2.00
2.033
2.066
2.099
2.132
2.165
2.198
2.231
2.264
2.297
2.327
' 1 /1 /85 OIL BASE MUD WASTE PRICE PER BARREL
                                   C-490

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                                   NEWPARK WASTE TREATMENT SYSTEMS, INC
                    SCHEDULE OF FREIGHT CHARGES
                          EFFECTIVE JANUARY 1,1986

        THE FOLLOWING SCHEDULE OF FREIGHT CHARGES APPLIES TO WASTE MATERIAL
        RECEIVED AT ONE OF NEWPARICS COASTAL COLLECTION POINTS AND
        TRANSPORTED BY BARGE TO THE COMPANY'S NEAREST TREATMENT FACILITY.
RECEIVING POINT
NEAREST TREATMENT
      FACILITY
  FREIGHT CHARGES TO THE
NEAREST TREATMENT FACILITY
VENICE. LA
MORGAN CITY, LA
INTRACOASTAL, LA
SABINE.TX
GALVESTON, TX
PORT O'CON NOR, TX
INGLESIDE.TX
   VENICE, LA
   VENICE, LA
   VENICE, LA
   INGLESIDE.TX
   INGLESIDE, TX
   INGLESIDE.TX
   INGLESIDE.TX
          $  0/BBL
            .95/BBL
           1.50/BBL
            .95/BBL
            .75/BBL
            .50/BBL
             0/BBL
                                   C-491

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C-492

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                          Sampling  Report
    Investigation of Sun Exploration and Production Company's
           Sweetbay  and Bateman  Lake  Tank  Battery No.  2
                    St. Mary Parish,  Louisiana
                          June 16, 1986


SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report  (EPA 530-SW-87-005).  This site was selected randomly from
a list of active coastal Gulf Coast Salt Dome Basin production
sites developed by the Louisiana Department of Natural Resources
Office of Conservation at the request of EPA.  The list was
transmitted via telephone to the EPA contractor on June 13,
1986.  Randomization and site selection took place during the
telephone conversation.

Louisiana state officials listed the possible sample sites by
location, operator,  and tank battery.  The EPA contractor had no
interest in the manner the particular sites were listed (by site
name, location, operator, permit number, API number, etc.) as
long as the site could be identified in detail upon selection.
Thus, the EPA contractor had minimal information which kept to a
minimum the amount of bias.  No other information was known about
the sites on the list at the time of selection.  Detailed
information was obtained only after selection of primary and
back-up sites.  The  list consisted of ten coastal production
sites:

          1.  Sun -  Bateman Lake
          2.  Chevron - Romere Pass
          3.  Texaco -  Lake Washington, 212A
          4.  Chevron - Quarantine Bay, Tank Battery #2
          5.  Shell  - West Empire,  Lease 3603
          6.  Texaco - Venice Buras Levee Dist. Tank Battery
          7.  Texaco - Venice, C. L.  Johnson Tank Battery
          8.  Shell  - E. Mississippi River
          9.  Texaco - Lake Washington Tank Battery SL 1464
         10.  Chevron - W. Delta Block 83

As indicated above,  the EPA contractor assigned numbers to the
members of the list  as they were transmitted.  A random number
table was used to select the primary and back-up sample sites.
The randomly-selected primary site was No. 1 on the above list
(Sun - Bateman Lake).  No. 7 on the above list (Texaco - Venice,
C. L. Johnson Tank Battery)  was selected as a back-up site in the
event the primary site was inaccessible or inappropriate.

Further inquiry identified the primary sample site as Sun
Exploration and Production Company's  Sweetbay and Bateman Lake


                              C-493

-------
Tank Battery No. 2 in St.  Mary Parish,  Louisiana.   No problems
were encountered in arranging sampling  for June 16, 1986.  The
back-up site was not required.

Site Location

The Sun E&P Sweetbay and Bateman Lake Tank Battery No. 2
production facility is located approximately 2 miles south of
Morgan City, LA via the Atchafalaya River in St. Mary Parish, and
approximately 31 miles southwest of the Mississippi River.
Figure 1 is a map indicating the production facility site.  The
full name and mailing address for Sun Exploration and Production
Company is:

          Sun Exploration and Production Company
          Gulf Coast District
          P.O. Box 31570-C
          Lafayette, LA  70503
          Main Office Ph.: 318-988-4870
          Main Office Contact: Richard  Spell, District
                               Environmental Coordinator
Attendees

Sampling at the Sun E&P Sweetbay and Bateman Lake Tank Battery
No. 2 production site was performed by CENTEC Corporation
personnel on June 16, 1986.  Following is a list of people
present at the time of sampling:
     CENTEC Corp. (sample team):
     EPA Representatives:
     State Representative:
Kerri Kennedy, Project
  Manager
Jamie Mclntyre, Sample Team
  Leader
Bill Lane, Technician

Susan de Nagy, Office of Water,
  Project Officer
Mitch Dubensky, Office of
  Analysis and Evaluation
Richard Montgomery, Aquatic
  Biologist, EPA Environmental
  Research Laboratory, Gulf
  Breeze

Carrol Wascom, Assistant
  Director, Injection and
  Mining Division, Office
  of Conservation, Department
  of Natural Resources
                               C-494

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                                  I SUN EXPLORATION AND PRODUCTION CO
                                     Quit Coast District - L«f«y»tt». L/l
Figure 1.   Location of Sweetbay  and Bateman Lake Tank
            Battery #2, St. Mary  Parish,  Louisiana  "
                            C-495

-------
     Operator Representatives:     Richard Spell,  District
                                    Environmental Coordinator
                                  Clarence Toupe, Production
                                    Engineer
                                  Melvin Childers, Lease Operator

     American Petroleum
       Institute Representatives:  George Holliday, Contracted
                                    Observer
                                  Lloyd Deuel,  Contracted Sample
                                    Team Member
                                  Allan Wilson, Contracted Sample
                                    Team Member

     Other Observers:              Gary Petrazzuolo, Technical
                                    Resources,  Inc.
                                  Lynn Bowler,  Technical
                                    Resources,  Inc.


Site Description

The Sun E&P production facility is located in a rural coastal
area.  The climate at  this site location is net precipitation.
The facility sits on a wooden platform constructed over a marsh
(see photos, Attachment A).

The site consists of one gun barrel, two oil stock tanks, one
brine tank, two heater-treaters, and other related process units
(Photos 2, 3, 4).  Figure 2 is an approximate schematic diagram
of the facility, indicating the directions in which photos were
taken.  Figure 3 is a  flow diagram of the production system,
provided by Sun E&P.

The schedules for cleaning tanks on the site are not rigorous,
but are different for  each type.  The gun barrel is cleaned every
3 to 5 years.  The production tanks are cleaned every 3 years,
although the bottoms from these tanks are circulated to a
heater-treater and back to the gun barrel on a daily basis.  The
heater-treaters are cleaned every 1 to 2 years, the last
time being 6 months prior to EPA's sampling visit.  The brine
tank is skimmed occasionally to remove the oil layer that builds
up, but is seldom cleaned thoroughly.  The oil layer had been
skimmed from the brine tank some time within the 30 days prior  to
EPA's sampling visit.   It was not known when the brine tank had
last been thoroughly cleaned.

The facility treats incoming oil and water by adding an emulsion
breaker and scale inhibitor to the system prior to the gun
barrel.  Photos 8 and 9 show the location of a drum containing
"Tretolite" demulsifier.  The demulsifier is added at a daily
rate of 1 gallon per 100 barrels of fluid treated.  The scale
inhibitor is added at  a daily rate of 1/2 gallon per 100 barrels
treated.


                               C-496

-------
n

>tk
vo
                              M
                                     Oil
                                  r— i
                                    t_J
A
1
                                    \t/
                                                                             j»r««*SS<«
-------
        <>—.
        •* MM



        <^
vo

00
~-±
              ' "L-jr.
 i
-|-h«4J
                                           >^-—
                                _.i--LwL.
                   l[_!rsr.	»«4..


                  £
                  1
                                             •T
                                          !-'r»='n
         l 1
                        1 . 1
                             Figure 3.  Flow Diaaram of Tank Battery No.  2

-------
At the time of sampling, there was one producing oil well and two
producing gas wells feeding  into Tank Battery No. 2, although one
gas well was temporarily closed.  Collectively, these wells
produce daily quantities of  100 barrels of oil, 2 million
standard cubic feet of gas,  and 640 barrels of produced water.
Attachment C includes a copy of meter readings from the Lease
Automatic Custody Transfer  (LACT) unit for the first half of June
1986, showing a daily production average of 99 barrels of oil.
Also included in Attachment  C is another report from the LACT
unit, showing the percentage of oil leaving the facility that is
basic sediment and water (BS and W).

Disposal Practices

As shown in Photos 6 and 7,  the produced water is ultimately
disposed of by discharging directly to the surrounding coastal
waters.  Samples are taken from the influent and effluent of the
brine tank each month, in accordance with the discharge permit.
Solids from the bottom of the brine tank are vacuumed into a
barge and hauled offsite.  However, details of the final
disposition of the solids were not available at the time of
sampling.

Permits

The Sun E&P Co. Sweetbay and Bateman Lake Tank Battery No. 2
processes incoming oil and gas from State Lease No. 1337.
Attachment B contains a copy of a letter from the Louisiana
Department of Environmental  Quality informing production
facilities of the need to submit permit applications  with regard
to recent changes in State pollution control regulations.
Following the DEQ letter is  a copy of Sun's response letter and
one page of the attachments  that identify the location and
quantity of Sun's produced water discharges.


SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report  (EPA 530-SW-87-005).

Sample Point Locations

At the Sun E&P site, one fluid composite sample was collected
from the discharge line from a produced water holding tank.
Figure 2 indicates the sample point from which the fluid sample
was composited.
                              C-499

-------
Sampling Methods and Equipment

The fluid sample from the tank discharge was collected through a
4-inch-diameter pipe extending from the side of the tank, about 3
feet from the top of the tank (Photo 6).  The sample was
collected in a 1-gallon glass bottle held under the flowing
discharge/ then transferred to a 5-gallon carboy.  Photo 5 shows
a sampler carrying a filled 1-gallon bottle away from the
discharge point.

The 5-gallon carboy containing the tank discharge sample was
transported offsite to the CENTEC van where it was separated into
appropriate sample bottles.

The pH of the fluid sample was tested after sampling was
completed.  The pH of this sample was 7.
                               C-500

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                 C-501

-------
C-502

-------
Photos 2,3,4.  Production tankage

-------
                     I/**"? •<
                                / --
                                             -. —' j  -'  I j f\  f*r y^ <|t.
Photo 5.   Liquid sampling
                                                                           Photo 6.  Side  view of produbed  fluid
                                                                                     tank  dIscharge     ;

-------
                            «
                            L.
                            O
                            •»-
                            O
                            .e
                            a.
       E

       3
       L.
       a
       o
       o

       •^
       o
       «
       •o
       CO

       o
       •*-
       o
       ^
       a.
C-505

-------
vo
o
in
 i
o

-------
ATTACHMENT B:  PERMITS
          C-507

-------
C-508

-------
PATRICIA L. NORTON                  OFFICE OF WATER RESOURCES                  J. DALE GIVENS
    SECRETARY                                                              ASSISTANT SECRETARY
                                                                     APR 211986
  Gentlemen:

  Re:  Notification of  EXISTING Oil and Gas Production Facilities

  This is  to  notify you of alternative water discharge permit application
  procedures  for existing facilities.

  The  Louisiana Water  Pollution Control Regulations, which became
  effective November 20, 1985, require that operators of existing
  unpermitted discharging facilities submit a complete permit application
  for  each such facility within 180 days of the effective date of the
  regulations. All state permits issued prior to January 1, 1980 shall
  expire one  year from the effective date of the regulations. State
  permits  Issued after January 1, 1980 shall expire six years after their
  effective date. All  applications for permit renewal must be submitted
  at least 180 days prior to the expiration date.

  We are currently developing a general permit for oil and gas
  production  facilities. The attached optional permit application form
  will serve  to satisfy the notification requirements for existing
  facilities  as outlined in the Louisiana Water Pollution Control
  Regualtions.  The application package should include a transmittal
  letter and  the attached application form and certification statement.
                                         0509
      NATURAL RESOURCES BUILDING • P.O. BOX 44066 • BATON ROUGE, LOUISIANA 70804 • PHONE (504) 342-6363

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                                                                             Sun Production
                                                                             Operations Division
                                                                             GuK Coast District
                                                                             Sun Exploration and
                                                                             Production Company
              Maw 15  IQflfi                                                   3639 Ambassador Cattery Pi
              nay ia, i?ou                                                   POBox3i570C
                                                                             LafayetreLATOSO: 1570
                                                                             3189884870

              Mr. J. Dale Givens, Assistant Secretary
              Office of Water Resources
              P.O. Box 44091
              Baton Rouge, La.  70804

              RE:  Water Discharge Permit Applications  for Existing Facilities

              Dear Mr. Givens:

                   Enclosed are  permit applications for  the existing discharges
              from facilities operated by  Sun Exploration and Production Company,
              Gulf  Coast District,  Lafayette, Louisiana.   Included in  this
              application are  two gas processing  plants, seven discharges  of
              comingled  produced  water  and  deck  drainage,  three  sewage
              discharges, seven  deck  drainage  discharges, and  eighty-two  storm
              water discharges,   these discharges  are  detailed on  the  attached
              notification forms.

                   We did  not have  enough time  to complete  the  sampling and
              analyses of  our produced water discharges  and  receiving waters.
              this information will be submitted  in about a week.

                                                  Very truly yours,
                                                   i chard A.  Spe11
                                                 District Environmental Coordinator
              RS/wd
C f'  •- ,
                                              c-5io

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 I
Ui
                    Qp«r«tor Sun Exploration I Production Co.
                            Addr«ti  P.O.  Box 31570C
                                   l«fayi.tte. la.  70503
                    Fttld  Bateman/Sweetbav T.ak«   F»rt«li
LOUISIANA  KMtTMBIT OP MVIRONMMTAL QUAUTT
        orricE or HATER RESOURCES
  EXISTING OIL  AMD CAS PRODUCTION PACIUTB
            HOTiriCAnOH POM
                                                          St- -  M» ru


PACIUTT
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LOCATION (1)

UTITUOE
KUMBBR OP PACIUTIES THAT ONll
DISCHARGE STORM HATE* (3)

urns in ic

SEC.

TS

R

TTPB OP DISCHARGE
PROD.
HATER


STORM
HATER



SDUGE

OTHER (SPECIF!)


RECEIflNS
HATER
RECEIVING
HATER
CHLORIDES
(PPT) (2)
PRODUCED
HATER
CHLORIDES
(PIT) (2)
PRODUCED
HATER
TOUIME
(BPD)(2)

8 niles SSW of Moraan Citv
UST EACH PACIUTT WITH HSCBAIICES IN ADDITION TO STORM HATER " '"" " " 	 	 	 	
Bateman Lake
Battery I


Bateman Lake
Battery II


29*35'
27"


29*35'
57"


91 12'
58.5


91 14'
45"



IS


S/L
1337
ST
3035

17S



17S



IDE



12E



X



X



X



X


















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at the
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Atchafalaya
River









DISCHARGE POINT LOCATIONS IMNTIPIED ON ATTACHED MAP (2) THIS MTA IS ONLT NECESSARY IP PROniC D HATER IS "DISCHARGED
'•"> GIVE GENERAL LOCATION OF FIELD








100




125


DEO-OC-02 LHU

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C-512

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ATTACHMENT C:  LEASE AUTOMATIC CUSTODY
     TRANSFER (LACT) UNIT REPORTS
                 C-513

-------
C-514

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Batman Uta U.

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                         Sampling Report
   Investigation of Mobil Oil's Bayou Blue Production Facility
                  Iberville Parish, Louisiana
                         June 17,  1986


SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA 530-SW-87-005).   This site was selected randomly from
a list of active upland Gulf Coast Salt Dome production sites
developed by the Louisiana Department of Natural Resources Office
of Conservation at the request of EPA.   The list was transmitted
via telephone to the EPA contractor on June 11, 1986.
Randomization and site selection took place during the telephone
conversation.

The EPA contractor had no interest in the manner the particular
sites were listed (by site name,  location, operator, permit
number, API number,  etc.)  as long as the site could be identified
in detail upon selection.   Thus,  the EPA contractor had minimal
information which kept to a minimum the amount of bias.  No other
information was known about the sites on the list at the time of
selection.  Detailed information was obtained only after
selection of primary and back-up sites.

Louisiana state officials listed the possible sample sites by
operator and specific location.   For simplicity of selection, the
list was transmitted using only operator names.  The list
consisted of ten upland production sites:

          1.  Superior Oil
          2.  Amoco  Production
          3.  Eenova
          4.  Union  - Texas Petroleum
          5.  Chevron
          6.  Evergreen Energy
          7.  Lakeshore Petroleum
          8.  Republic Mineral Corporation
          9.  Celeron
         10.  Shell

As indicated above,  the EPA contractor assigned numbers to the
members of the list  as they were transmitted.  A random number
table was used to select the primary and back-up sample sites.
The randomly-selected primary site was No. 1 on the above list,
Superior Oil.  No. 7 on the above list (Lakeshore Petroleum)  was
selected as a back-up site in the event the primary site was
inaccessible or inappropriate.
                               C-517

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Further inquiry identified the primary sample site as the
Superior Oil Company Bayou Blue site in Iberville Parish.  The
production facility was currently operated by Mobil Oil Company.
No problems were encountered in arranging sampling for June 14,
1986.  The back-up site was not required.

Site Location

The Mobil Oil Bayou Blue production facility is located
approximately 8 miles south of Grosse Tete, LA via Highways 77
and 386 in Iberville Parish, and approximately 11 miles west of
the Mississippi River.  Figure 1 is a map indicating the
production facility site.  The full name and mailing address for
Mobil Oil is:

          Mobil Oil Exploration and Producing Southeast Inc.
          Onshore Division
          3861 Ambassador Caffery Parkway
          P.O. Box 51108
          Lafayette, LA  70505
          Main Office Ph.: 318-988-5200
          Main Office Contact: James Green, Environmental and
                               Regulatory Engineer
                               Ph: 318-988-5691

It should be noted that the Superior Oil Co., named on a sign
appearing in Photo 1, was acquired by Mobil Oil.

Attendees

Sampling at the Mobil Oil Bayou Blue production site was
performed by CENTEC Corporation personnel and EPA personnel on
June 17, 1986.  Following is a list of people present at the time
of sampling:

     CENTEC Corp.:                Kerri Kennedy,  Project Manager*

     EPA Representatives:         William Telliard, Chief, Energy
                                    and Mining Industries Branch,
                                    Industrial Technology
                                    Division, Office of Water*
                                  Susan de Nagy,  Office of Water,
                                    Project Officer
                                  Dan Derkics, Chief, Large
                                    Volumes Section
*Indicates sample team member.  This site was sampled
 concurrently with a drill site in Pointe Coupee Parish,  LA where
 another CENTEC Corp. team was sampling.
                              C-518

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 BAYOU GOULA
SCO. 37 TIOS RISC
          o»
        Figure 1.   Location of Mobil Oil's Bayou Blue Production
                    Facility, Iberville  Parish,  Louisiana
                                    C-519

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     State Representative:
     Operator Representatives:
     American Petroleum
       Institute Representative:
     Other Observer:
Site Description
Carrol Wascom, Assistant
  Director, Injection and
  Mining Division, Office
  of Conservation, Department
  of Natural Resources

James Martin, Environmental and
  Regulatory Manager
Ory Persick, Production Foreman

George Holliday, Contracted
  Observer

Robert Cooper, Interstate Oil
  Compact Commission
The Mobil Oil Bayou Blue production facility is located in a
rural, flatland area.  The climate at this site location is net
precipitation.  The soil is described as sandy loam.

The depth to the groundwater in the area is between 500 and 600
feet.  The nearest surface water is a stream located less than
1/2-mile from the site.  There is one potable water well located
on the site.

The site consists of two heater-treaters, one gun barrel, one
free water knock-out, four oil stock tanks, and two brine tanks
(Photo 2).  Figure 2 is an approximate schematic diagram of the
facility, indicating the directions in which photos were taken
(Attachment A).  Figure 3 is a flow diagram of the production
system, provided by Mobil.  With the exception of the stock and
brine tanks, each vessel is cleaned at least once every 12
months.  The stock and brine tanks are cleaned only when
necessary.

The facility treats incoming oil and water by adding an emulsion
breaker to the line entering the gunbarrel.  This line carries
the water phase effluent from the free water knockout (Figure 3).

At the time of sampling, there were 41 producing oil wells out of
103 drilled in the Bayou Blue Lease, with 12 or more wells being
shut-in.  All wells in this field are strippers.  During the
month of June 1986, these wells produced total quantities of
24,660 barrels of oil, and 299,211 barrels of produced water.
The producing wells range in depth from 1,300 to 7,000 feet.

Less than 100,000 standard cubic feet of gas were also produced
from the Bayou Blue field at the time of sampling.  Photo 4 shows
the dehydrating equipment used to process incoming gas.  Most of
the gas produced from the Bayou Blue field is used on site.
                              C-520

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                      --*—«•—*—»-—x -~x—x—«
P/Pf
                                                      AR£A
      ISJECTIOM
        W5LL
         PUhP
BRINE:
TAMKS
STOCK  TANKS
                                                        FvJKO :

                                                        MT;
            Figure 2.  Schematic Diagram of Production Facility
                                   C-521

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 Disposal  Practices

 As  illustrated  in Figure  2,  the produced water  is  ultimately
 disposed  of  in  two  injection wells  located onsite.   Solids
 collected when  tanks  are  cleaned are  taken to Reliable Production
 Service,  Inc.,  a commercial  waste treatment  facility where  solid
 wastes  are land farmed, as dictated by  state regulations. The
 address for  Reliable  is

          Reliable  Production Service,  Inc.
          PO Box 176
          Livonia,  LA 70755
          504-637-2381 or 504-638-8146
 Permits

 The production facility operates two injection wells.  The serial
 numbers and names of these wells are SN 063271-Schwing No. 59,
 and SN 064731-Schwing No. 62.  The issuing authority for
 injection well serial numbers is the Louisiana Department of
 Natural Resources.  No operating permits were available for
 copying at the time of sampling.


 SAMPLING INFORMATION

 Sampling efforts at this site followed the sampling procedures
 and protocols for field sampling as outlined by the Sampling Plan
 and Sampling Quality Assurance/Quality Control Plan in Appendix G
 of the EPA Technical Report (EPA 530-SW-87-005).

 Sample Point Locations

 At the Bayou Blue site, two fluid samples were collected.  One of
 the samples was taken from the discharge line of the pump that
 feeds the injection wells, and the other sample was taken from
 the free water knockout effluent before emulsion breaker is
 added.  Figures 2 and 3 indicate the sample points from which the
 fluid samples were collected.

 Sampling Methods and Equipment

 The fluid sample from the pump discharge was collected through a
 sample port consisting of a tube and stopcock.  This sample was
 composited in a 5-gallon carboy.  The pump house is visible in
 Photo 3, at the end of the row of tanks.

 The 5-gallon carboy containing the pump discharge sample was
 transported offsite to the CENTEC van where it was separated into
 appropriate sample bottles.

As shown in Photos 5 and 6,  the fluid sample from the free water
knockout was collected through a tube and stopcock that tapped
                              C-523

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the discharge line.  This sample was added to the schedule by the
project officer onsite.  The sample was collected directly into
sample bottles.

The pH of the sample collected from the pump discharge was
measured after sampling was completed.   The pH of this sample
was 7.
                              C-524

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                 C-525

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C-526

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tn
K)
    Photo  t.   Sign  in  front of skim tank
Photo 2.  Northerly view of production site
   Photo 3.  Northerly  view  of  stock  and  brine  tanks  and
             pump house
Photo 4.  Gas processing equipment

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n

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to
GO
                                                            Photo 6.  Liquid sampling at  FWKO
          Photo  5.   FWKO  and sample tube In water

                     I Ine

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                                                        Photo 8.  Incoming pipelines
          Photo  7.   Northeasterly view of gun

                    barrel  (right)

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C-530

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ATTACHMENT B:  PERMITS
          C-531

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C-532

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No permit specific to the operation
     of  this  site  is  available.
               C-533

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C-534

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                         Sampling Report
     Investigation  of  Westland  Oil  Development  Corporation's
                Joseph Earl  Bajoie  No.  1  Oil Well
                 Pointe Coupee  Parish,  Louisiana
                         June  17,  1986
SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report  (EPA 530-SW-87-005). This site was selected randomly from
a list of upland drill sites (at or near completion) in the Gulf
Coast Salt Dome Basin developed by the Louisiana Department of
Natural Resources Office of Conservation at the request of EPA.
The list was transmitted via telephone to the EPA contractor on
June 10, 1986.  Randomization and site selection were conducted
during the telephone conversation.

The EPA contractor had no interest in the manner the particular
sites were listed (by site name, location, operator, permit
number, API number,  etc.) as long as the site could be identified
in detail upon selection.  Thus, the EPA contractor had minimal
information which kept to a minimum the amount of bias.  No other
information was known about the sites on the list at the time of
selection.  Detailed information was obtained only after
selection of primary and back-up sites.

The list used for selection of this site consisted of field names
(each containing an active drill site) for selection purposes.
The field names were assigned numbers as they were transmitted as
shown below:

          1.  Anse La Butte
          2.  Eunice
          3.  Irene
          4.  Profit Island
          5.  Perry Point

A random number table was used to select the primary and back-up
sample sites.  No. 2 on the above list (Eunice) was selected as
the primary site.  In case the primary site was inaccessible or
inappropriate, No. 4 on the above list (Profit .Island)  was
selected as the back-up site.  On further investigation, the
Eunice site had already completed operations.  Wastes had been
injected in to the well annulus for disposal.  Thus the back-up
site was sampled.

Further inquiry with the Office of Conservation identified the
back-up site as Westland Oil Development Corporation's Joseph
Earl Bajoie No. 1 Oil Well in Pointe Coupee Parish.  Arrangements
were made for sampling be conducted on June 14, 1986.


                              C-535

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Site Location

The Joseph Earl Bajoie No. 1 oil well is located approximately 1
mile southeast of the intersection of Highways 414 and 415 in
Pointe Coupee Parish/ Louisiana.  Figure 1 is a map indicating
the well site.  The full name and mailing address for Westland
Oil is:

          Westland Oil and Development Corporation
          P.O. Box 900
          Montgomery, Texas  77536
          Main Office Ph.: 409-582-6464
          Main Office Contact: H.P. Goodrich

Attendees

Sampling at the Joseph Earl Bajoie No. 1 oil well was performed
by CENTEC Corporation personnel on June 17,  1986.  Following is a
list of people present at the time of sampling:
     CENTEC Corp. (sample team):
     EPA Representatives:
     State Representatives:
     Operator Representatives
Kerri Kennedy, Project Manager
Jamie Mclntyre, Sample Team
  Leader
Bill Lane, Technician

William Telliard, Chief, Energy
  and Mining Industries Branch,
  Industrial Technology Div.
  Office of Water
Susan de Nagy, Office of Water,
  Project Officer
Dan Derkics, Section Chief,
  Office of Solid Waste
Mitch Dubensky, Office of
  Analysis and Evaluation
Rob Franke, Office of Solid
  Waste, Region VI

Carrol Wascom, Assistant
  Director, Injection and
  Mining Division, Office
  of Conservation, Department
  of Natural Resources
Shile McCarty, Enforcement
  Agent, Office of
  Conservation, Department of
  Natural Resources

Kenny Bland
                               C-536

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 o

 Ol
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Drilling Contractor
  Representative:
                                  Gary Workman, Drilling Super-
                                    intendent, Land Rigs, Penrod
                                    Drilling Company
     American Petroleum
       Institute Representatives: George Holliday, Contracted
                                    Observer
                                  Lloyd Deuel, Contracted Sample
                                    Team Member
                                  Allan Wilson, Contracted Sample
                                    Team Member
Other Observer:
Site Description
                                  Robert Cooper, Interstate Oil
                                    Compact Commission
Figure 2 is a diagram of the exact surveyed location of the
Joseph Earl Bajoie No. 1 oil well, which is located in a rural,
flatland area.  The climate at this site location is net
precipitation.  The soil in the area is a layer of rich topsoil
over clay.  The depth to groundwater is between 0 and 25 feet,
and the nearest surface water is a creek located northwest of the
site.  The nearest drinking water well is approximately 1.5 miles
from the site.

At the time of sampling, the site consisted of the Penrod
Drilling Rig No. 28 and two pits.  The entire site and the road
leading to it were covered with a wood plank deck, visible in
Photos 2 and 8.  The area surrounding the site was wooded.  The
road leading to the site was cut through corn fields.  Access to
the road from the highway was blocked by a locked gate.  Figure 3
is an approximate schematic diagram of the site location, indi-
cating the directions in which photos were taken (Attachment A) .

This site was a developmental oil drilling site.  The well was
drilled to 16,800 feet at the time of sampling.  Drilling began
May 5, 1986 and was estimated to be completed by mid-July, 1986.

The following table summarizes the drilling muds used to drill
the well to a total depth of 18,820 feet:
                              C-538

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     -Tu  £
                                   _  Y^« 3 7 fc
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                      76
                   9963
WV'//-. S     «v-»t» «*

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                                  Figure 3.  Schematic  of  Drilling Site

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     Mud Type                                Depth  (feet)

Spud Mud:
     o Native fresh water mud with
       bentonite, lime, and sodium
       bicarbonate additives                     0 -  9,000

     o Barite and lignite added              9,000 - 10,500

Oil-Emulsion Mud:
     o Additives included diesel
       oil, barite, water, and
       emulsifying chemicals (oil-to-
       water ratio maintained at 85/15)     10,500 - 18,820

Copies of the mud logs were considered confidential by the
operator.

The two pits at the site are shown in Photo 3, 4 and 5.  The
reserve pit is the one to the right of the levee in this photo,
and the emergency pit is to the left.  The reserve pit was
considerably more full than the emergency pit, and had a sheen on
its surface (Photos 14 and 15).  The emergency pit was said to
contain only rain water and wash water.  The intended use of the
emergency pit was to take up overflow from the reserve pit.  A
pipe buried in the dividing levee (Photo 5 and Figure 3) served
to direct any overflow from the reserve pit to the emergency pit.

The reserve pit was designed for the temporary storage of drill
cuttings and residual drilling mud that left the mud circulation
system.  Photo 4 shows the cuttings line through which drill
cuttings were piped to the pit.  The pit was constructed slightly
below grade with bermed sides built up above grade, giving a
total depth of 11 feet.  The depth of the liquid in the pit at
the time of sampling was 5 to 6 feet, and the sludge depth was 3
to 4 feet.

Disposal Practices

The supernatant liquid in the reserve pit was intermittently
reinjected down hole between depths of 4,000 and 7,000 feet.  The
hole was constructed with 13 3/8-inch casing to 4,000 feet
cemented to the surface, and 9 5/8-inch casing between 7,000 and
15,312 feet cemented back to 7,000 feet.  This left the zone
between 4,000 and 7,000 feet open for reinjection.   At the time
of sampling, a pump was turned on and removed approximately
6 inches of depth from the pit.  The recent loss of liquid is
evident in Photo 12,  on the side of the pit just above the
surface.

The liquid would be vacuumed up and hauled off site to a
treatment facility in the event that the liquid could not be
reinjected any longer.  This was considered a last resort measure
due to its high cost (roughly between $70,000 and $100,000) as
                              0541

-------
compared with that of reinjection (roughly $10,000).  No liquid
had been hauled off site as of the time of sampling.

At the end of their use, both pits were to be closed by removing
all the liquid and allowing the solids to dry as much as
possible, land farming the solids, and leveling the pit to grade.
These procedures are based on an agreement between the operator
and the landowner.

Permits

A copy of the drilling permit secured by Westland Oil Development
Corporation is located in Attachment B.


SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-S7-005).

Sample Point Locations

At the Westland site,  the samples were defined as the supernatant
and solid contents of the waste material in the reserve pit.

EPA personnel and CENTEC sample team members declined to sign a
release form required by the operator for entering the pit in a
boat.  Therefore, the sample points were obtained by standing
inside the bermed edge of the pit and reaching in with the sample
equipment, as shown in Photos 12, 14, and 15.  There was some
discrepancy between actual and measured sample points due to the
inaccessibility of the measured points.  Sample point locations
were ultimately directed onsite by the Project Officer.  Figure 4
indicates the measured sample points as well as the actual sample
points from which the pit samples were composited.

Sampling Methods and Equipment

To collect samples from the reserve pit, the pit was measured to
identify the mid-points of each side.  The measured points were
marked with stakes to facilitate locating sample points.

The first sample to be collected was the liquid composite.  The
thief was used by threading the gaging tape through a pipe,
attaching the thief to the end of the tape, and extending the
pipe over the surface of the liquid as far as the sampler could
safely reach.  One sampler lowered the thief into the liquid, and
a second sampler pulled the string allowing the sample to enter
the thief.  The liquid from each sample point was composited in a
5-gallon carboy.
                              C-542

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                                           D
Figure 4.  Measured vs. Actual Sample Points in Reserve Pit
                          C-543

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The reserve pit was then sampled for sludge.   First,  the coring
device was used with two 5-foot extension rods attached.  The
sample was taken by extending the coring device as far into the
pit as safely possible.  Photo 12 shows a sampler using the
coring device, and Photo 13 shows the sample  obtained from that
point.  The coring device was used only once,  however, because
the sludge was too dense to enter the glass core sleeve without
breaking it.  The dredge was used on the remaining sample points,
as shown in Photo 14.  The solids were composited in the steel
bucket shown in Photo 13.

Both the liquid and sludge samples were tested for pH after
sampling was completed.  The pH was 8 for both samples.
                              C-544

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                 C-545

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C-546

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o
I
at
Photo 2.  Southerly view away from reserve pit
        Photos 3,4,5.   Emergency  and  reserve  pits  viewed  from  drilling  rig

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  Photo 6.   Easterly  view across emergency pit
                                                                 Photo  7.   Westerly view of dike and emergency  pit
D
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               Photos  9,10.   Stick pile  and  drainage  pond
O
I
                                  Photo II.  Diversion ditch behind trailers

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                           ?£/m^-- \ jj-> • iT.^ ^^>fe»^ *

                           - v«.*3*»\».7Mri.—-. .^jji^.ui.tiCiA.c^',1, -j,^
Photo 13.  Core sample In steel  bucket
         Photo 12.  Core sampling In south corner

                  of  reserve  pit

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Photo J4.
                        ...  ,.  south  corner  o,
                                                               Photo  15.

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C-552

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ATTACHMENT B:  PERMITS
         C-553

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C-554

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                       {               V/5LL FtLS COPY
FOflM MO 13.ft
STiTE cc LC.J!SlV,A               PERMIT TO DRILL FOR MINERALS         PERMIT      $200.00
OFFICE OF CONSERVATION                                                    Multiple Zone Processing
          ATT
Send To	IT9V OlTlfmn3/2	P«t»  MflTTh 27,  IS
      ^    Serd(20376l    A"'  ^1707720376
          Pointa  Coupoo   039 _ PI.M  Profit  TBlagd   7558
Operotor _ WffB'tlflTvli ^H D^y^lTr"ff°T^ Corp*   ^379
                   y 8328
G»y & ^tnt»  Matairlo,  LA  70009
Weii Nnmg  Joseph Earl Bajola  ]?o.  1
Locot.cn
          Fr HW/q  of Sflti  Q9, go E alg Sea line 1233.51 *5  th S Q  RA for
         -387^08'  to loo.	
      	Pm-l8,8QOJ
/• ne •-•' R-.-erw.if c' &" f 0 *0 ConT-eion	TUSC-

                  COMMlSSlONCM
                                                            ISSUING AUTMOWITY   '] Q ^1   *1 "7
                                   C-555

-------
C-556

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MICHIGAN
    0557

-------
C-558

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                         Sampling Report
      Investigation of Wolverine Gas and Oil Company,  Inc.'s
              Hanover 7 Central Production Facility
                    Jackson County, Michigan
                          July 29,  1986
SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA 530-SW-87-005).  This site was selected randomly from
a list of active Michigan Basin production sites developed by the
Michigan Department of Natural Resources at the request of EPA.
The list was transmitted via telephone to the EPA contractor on
July 22, 1986.  Randomization and site selection took place
during the telephone conversation.

The EPA contractor had no interest in the manner the particular
sites were listed (by site name, location, operator, permit
number, API number, etc.) as long as the site could be identified
in detail upon selection.  Thus, the EPA contractor had minimal
information which kept to a minimum the amount of bias.  No other
information was known about the sites on the list at the time of
selection.  Detailed information was obtained only after
selection of primary and back-up sites.

The Department of Natural Resources listed the possible sample
sites by permit number.  The list consisted of ten sites:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
32780
4054
16795
39084
38001
38503
29468
29469
30594
37916
As indicated above, the EPA contractor assigned numbers to the
members of the list as they were transmitted.  A random number
table was used to select the primary and back-up sample sites.
The randomly-selected primary site was No. 4 on the above list
(permit no. 39084).  No. 2 on the above list (permit no. 4054)
was selected as a back-up site in the event the primary site was
inaccessible or inappropriate.

Further inquiry identified the primary sample site as the
Wolverine Oil and Gas Company, Incorporated's Gorham 3-7 well in


                               C-559

-------
Hanover Township of Jackson County, Michigan.    No problems were
encountered in arranging sampling for July 29, 1986.

The back-up site was identified a Harry E. Tope's Joseph E. Reed
No. 4 well in Buckeye Township of Gladwin County.  The back-up
site was not required.

Site Location

The Wolverine Hanover 7 production facility is located
approximately 300 feet northeast of the intersection of Grover
and Fowler Roads in Hanover Township, Jackson  County, MI.  Fig-
ure 1 is a map indicating the production facility site.  The full
name and mailing address for Wolverine is:

          Wolverine Gas and Oil Company, Inc.
          (Controlled by Star, Inc.)
          One Riverfront Plaza
          55 Campau, N.W.
          Grand Rapids, MI  49503
          Main Office Ph.:     616-458-1150
          Main Office Contact: Ron Suckle (works for Star, Inc.)
                               Ph: 616-946-7111

Attendees

Sampling at the Hanover 7 production facility  was performed by
CENTEC Corporation personnel on July 29, 1986.  Following is a
list of people present at the time of sampling:

     CENTEC Corp. (sample team):  Jamie Mclntyre, Sample Team
                                    Leader
                                  Bill Lane, Technician

     State Representative:        Dave Davis,  Geologist, Michigan
                                    Geological Survey Division,
                                    Rose Lake  Field Office

     Operator Representative:     Paul Whitham, Field Engineer
                                    (Star, Inc.)

     American Petroleum Institute
       Representatives:           George Holliday, Contracted
                                    Observer
                                  Lloyd Deuel, Contracted Sample
                                    Team Member
                                  Amy Crum, Contracted Sample
                                    Team Member
                               C-560

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EATON
              Figure  1.   Location of  Wolverine Gas and Oil Company's
                         Gorham Lease Production Facility, Jackson
                         County,  Michigan
                                     C-561

-------
Site Description

The Hanover 7 production facility is located in rural flatland.
The climate at this site location is net precipitation.  The soil
is described as a layer of top soil over clay and sand, and there
are marshes in the vicinity of the site.  Wells serviced by this
facility are completed in the Black River formation of the
Michigan basin. -

The depth to groundwater in the area is estimated to be 90 feet.
The nearest surface water is a creek located between 1/2 and 2
miles from the site.  The nearest drinking water wells are
associated with farms within a 1/2-mile radius of the site.

At the time of sampling, the site consisted of three oil stock
tanks, one brine tank, four heater-treaters, and other related
process equipment, shown in Photo 1.  Figure 2 is an approximate
schematic diagram of the facility, indicating the directions in
which photos were taken.  Figure 3 is a flow diagram of the
facility, provided by the operator.

All the equipment at the facility was new, and had been in use
only 6 months at the time of sampling.  Therefore, a cleaning
schedule for the equipment had not been established as yet.

Treatment chemicals used onsite include demulsifiers and parafin
dispersants.  Approximately 16 gallons per month of "CMR-5"
(demulsifier)  is used at the four heater-treaters (4 gallons/
treater).  Approximately 15 gallons per month of either "PD-100"
or "WGH-123A-4272" (parafin dispersants) are used in the
flowline.  No corrosion or scale inhibitors are used at this
facility.

At the.time of sampling, there were five producing oil wells
within a 1-mile radius serviced by this facility.  These wells
were producing approximately 400 barrels of produced water per
day, at that time.  One of these wells, Gorham No. 3-7, was
feeding into the second heater-treater from the right in Photo 1.
The oil and water are piped from the heater-treaters to the
appropriate tanks, shown in Photo 4.

The Gorham Well No. 3-7, shown in Photo 9, produced oil at a rate
of 100 barrels per day at the time of sampling.  The well had
been recently completed at approximately 4,600 feet.

Disposal Practices

At the time of sampling, the produced water in the brine tank was
hauled by truck to "Dean Center's" disposal well in Jackson
County, MI.  The name of the company used to haul the brine is
Joslin, Inc.,  located in South Boardman, MI.
                               C-562

-------
 \
N
                                     ^US
    Figure 2.   Schematic  Diagram of Production Facility
                           C-563

-------
 FLOWLINE
       ^
FLOWLINE
FLOWLINE
 FLOWUNE A " C 5
/•^ '"r *
9  55
            Sf
     *1
     El
            n
FLOWLINE /T^  r J
              N
              s

-------
The operator later submitted that the produced water is now
disposed of in the Savage Well No. 2-18A, which was drilled and
completed in October, 1986.

Permits

No permits specific to the operations of the production facility
were made available to the sample team at the time of sampling.
However, the operator later submitted a copy of a letter from the
Region 5 EPA, indicating that Wolverine had applied for a salt
water disposal well permit.  A copy of this letter is located in
Attachment B.

A copy of the drilling permit secured by Wolverine for drilling
the Gorham Well No. 3-7 also is located in Attachment B.
SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).

Sample Point Locations

At the Hanover 7 site, one fluid composite sample was collected
from a sample port in the heater-treater that services Gorham
Well No. 3-7.  Figure 2 indicates the sample point from which the
fluid sample was composited.

Sampling Methods and Equipment

The fluid sample from the heater-treater was collected through a
valve in a sight glass located in the lower half of the tank, as
shown in Photos 7 and 8.  The sample was collected in a 1-gallon
glass bottle held under the flowing discharge, then transferred
to a 5-gallon carboy.  The small amount of oil present in the
sample was removed by "topping-off" the carboy with produced
water until the oil layer had overflowed down the sides of the
carboy.  This was done over a plastic bag to keep the liquids
contained.

Tests for the pH and free chlorine content of the fluid sample
were conducted onsite after sampling was completed.  The pH was
7, and the free chlorine content was less than 0.2 ppm (the
lowest detectable limit).
                               C-565

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C-566

-------
ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                 C-567

-------
C-568

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    Photo 1.  Full view of production site
                                                                    Photo 2.   Southerly view of four heater-treaters
n
 I
U1
a\
vo
                                  Photo 3.  Southerly view of four heater-treaters

-------
  Photo 4.  Northerly view  of  stocK  tanks
n
I
en
-j
o
Photo 5.  Southwesterly view of heater-treater  that

          was sampled

-------
 Photo 7.  Inside heater-treater that MBS sampled
n
I
in
Photo 8.  Sampler showing how and where sample was taken

          (not actually sampling)
                                  Photo 9.  Well No. 3-7 (west of production site)

-------
C-572

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ATTACHMENT B:  PERMITS
          C-573

-------
C-574

-------
J"i~O *J ~' OEP*GEOLOGlCAL SURVEY DIVISION
LANSING. MICHIGAN 46909
PERMIT TO
gj DRILL O DEEPEN fj REWORK Q OPERATE
GRANTED UNDER PROVISIONS OF
Act 61. P.A. 1939. as amended Q Act 31S- P-A- 1959- as amended
(M.C.L. 319.1 to 319.27) (M.C.L. 319.211 to 319.236)
Violation of and/or non-compliance with the provisions
of the acts and conditions of permit may result in penalties.
Permit is issued based upon the attached stipulations which are
hereby incorporated in its entirety by reference.
ELL NAME WELL NO.
•orhara <-*3-7
"~*3SrjC4' - ]
DATE ISSUED
6/24/35
TYPE OF WELL
Oil and or Gas
Rotary
Wolverine Gas & 011 Co
1037 Trust Bldg
40 Pearle N.W.
Grand Rapids, HI 49503
—. -'- . u _
EXPIRES 	 	 	
6/24/35
TARGET FORMATION 	 • 	 • 	 -i
- - ' Black R1vor
INTENDED DEPTH 	 • 	 —
4600'
.. Inc.

     FOOT AGES.
     of SW  frc.'J* SW frc'% Sec. 7, T4S, R2W; Hanover Tte>,, Jacfcson Co.
  ft. from South  and 342 ft. from West line  of quarter section
  ft. from South  and 34"3 ft. from Eajt line  of drilling unit
O 0. SIZE WT./FT. • .
11-3/4" 42#
8-5/8" 24#
5-1/2" 15. 5#
CASING AND SEALING REQUIREMENTS
CASING
GRADE CONDITION DEPTH
H-40
K-55
K-55
New
Hew
New
4I01 ,
4GOO
CEMENT
SACKS
C to S
150+
as needed
WOC. (MRS )
12
12
^^^ I
  "NOTICE AIJD REQUIREMENTS FOR SOURCES OF HATER AND WATER WELLS USED III CONJUNCTION
  WITH OIL AMD GAS OR MINERAL WELL DRILLING, AND OPERATIONS", December 1, 1984 1s
  made part of and a  condition of this permit.
  Strip topsoll In coltlvated field prior to constructln?cut and fill pad.
  Place pits along western side of location in  highest ground..jf-
  Construct earthen dikes around perimeter of drill  pad.^,
6 TO BE NOTIFIED BEFORE ORILLINS/QgEPENlNG STARTS
                                                   BY
»t Lansing Field Office  517-373-1233                  Hilton A.  Gere, Jr., Permit Coordinator
                                     PAGE 1 of   PAGE(S)                    517-373-9290
                                                            FOR TH£ SUPERVISOR C* WELLSfjn'.FPAL V.E...5
                                          C-575
                                                                                       a», i 1,4

-------
    APPttCATION FOR  PERMIT TO  DRILL OR-BSEPEN
         A WELL  FOR  OIL, GAS,  BRINE  DISPOSAL,
 HYDROCARBON STORAGE OR SECONDARY RECOyERY
           Under Authority  'of Act 61,  P.A. of 1939,  As Amended
                                                  i? M*AIL TO:
                                              STATE OF MICHIGAN
                                    DEPARTMENT OF NATURAL RESOURCES
                                         GEOLOGICAL  SURVEY DIVISION
                                        Box 30028,  Lansing, Michigan 48909
                 SEE INSTRUCTIONS ON REVERSE SIDE
                                   2. H Fed. Employer Went. No. |  D  Soc. Security No.
                                         38-1710995
j App«c*<«>n lor permit to drill lor-
_ Oil and     .-,  Brine       ._.  Hydrocarbon     Secondary
1AJ or Gas     LJ  Disposal     I—I  Storage	LJ  Recovery
                4 Application to: (no lee required)
                .1.       /»,  Ravis* /
                    Deepen
                                                                   Application
                                                                                c*neel •
                                                                                Transfer
                                                      S. Ft* enclosed
                                                      E  No    D  Yes  $
6 Do prior permits enisl lor this well'
D No   S  Yes  { D Drilled D  Termin'd
7 List eecft permit number
           39084
    LOCATE WELL AND OUTLINE UNIT
     ON SECTION PLAT — 640 ACRES
  I. Applicant: (name each "owner" as they are bonded)

     WOLVERINE GAS  & OIL CO.,  INC.
                                                (616)458-1150
9. Mama: (operator only il more than one "owner")                      Phone:

    1037 TRUST BLDG., 40 PEARL  N.W.,  GRAND RAPIDS, MI 49503
                                      10. Leaae or well name: (be tmel aa possible)
                                          GORHAM
                                                                                             Well number
                                                              3-7
                                          WILLIAM WORTH
                                      12. Address:                                                Phone-
                                          606  S.  THOMPSON ROAD, JACKSON, MI 49201
                                      13. Surface location deaenptien (See* instructions, nem 4)
                                          S  l/&af SW fro?3.  1/4 ofs^nfrc'l 1/4
                                      14. Township
                                          HANOVER
                                                       County
                                                       JACKSON
                                      li. Bottom note location description il directional anil (See instructions, item 5)

                                          SAME AS S.L.    Mot       * Section        T.
                                      It. Tawnsmp
                                          SAME AS S.L.
                                                       County
 17. LOCATE WELL IN TWO DIRECTIONS PROM NEAREST LINES OF QUARTER SECTION AND ORILUNQ UNIT. (See instructions. Items 4 4 5|

   *****     330      . H— .«,«.  SOUTH        	.	....   .„„ 343        ..	 WEST
                    _lt. from (N/S


b.  Location- _SAME_AS-J5n,lram (N/S)
   Drilling
^.  o»t.      330
                                             . Line at quarter section.   AND


                                             _ Line ol quarter section   AND
                                         . It rrom (E/W)_


                                         .It. from (E/W)_
                                                             . Line ot quarter section


                                                             . Line ol quarter section
                        horn (N/SI_SQUTH_
                                                .Line ol flnihng unit  AND
                             343
                                                                               .It. Iron IE/W)
                                                     ESST
                                                                                                    . Line ol drilling unit.
 It. Drilling contractor:
                                                                                                 Telephone.
1f. Kind of ICM
Me (Aota'y- CAO*«. eomtwution)
ROTARY
20 Mtenoed oeptn
4600'
BLACK RIVER
22. la sour oH or gas aapeeted?
E No | D Yd. :>, new




Depth
*\0&Q
^y.Au_'.
<*ouu




CEMENT
Sacka
C to S
L> to A
is need




WAj&(nnvl
13-
I7_
ed^.,




25 Sena correspondence ana permit to Address
MUD
wt.







Via.








       LIDSCO.  INC..  P.O. BOX 174, TRAVERSE  CITY, MI  49685-0174
                          LEAVE tUUKK
                            PermR
?
                                         t -I i^l 11
                    2S"TO DRILL

                    D  TO DEEPEN
                                                            26 Name ol applicant s agent (Print)

                                                             JANTS T..  BSTRBAM
                                                                   Pnone

                                                    C616"! Q.41-7628
                                                                   Date
                                                               10/02/85
          FOR CASHIER'S USE ONLY. OO NOT WRITE IN T
                        t *
                                                    C"576
                           White — Lansing tile
                        2  Canary — Cashier copy
                        3  Blue — District review
                                                logteal Survey U*a> Only
                                                     4 Pmk — Region review
                                                     S Goldenrod — District Ine i»
                                                     6. Grej«n —• Applicant tile (»/(

-------
            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                   REGION 5
                           230 SOUTH DEARBORN ST.
                            CHICAGO, ILLINOIS 60604
                                                               1CM.Y TO THE ATTENTION OF:

November 12,  1986

CERTIFIED MAIL
RETURN RECEIPT REQUESTED                                     5WD-TUB-9

Mr. S1d Jansma
Wolverine Gas and 011  Co.
 1  Riverfront Plaza
55 Campau, North West
Grand Rapids, Michigan 49503

Re:  Draft Permit IMI-075-20-0006

Dear Mr. Jansma:

In accordance with Federal  Underground  Injection Control Program
permitting procedures, enclosed  1s a copy  of  the draft permit for the
salt water disposal well, Savage I2-18A (EPA  Permit IMI-075-2D-0006)  1n
Jackson County, Michigan.

According to Federal Regulation  40 CFR  124.10(b) a public notice of the
preparation of a draft permit shall allow  at  least 30 days for public
comment.  At the end of the public comment period you will be notified  if
any significant changes 1n the draft permit are required.  If no major
changes are made, the  permit  will  be Issued.


Sincerely yours,
 Valerie J. Jones .Acting Chief
 Underground injection Control  Section

 Enclosure

 cc:   R. Thomas Segal1. Michigan DNR
      Charles Brown, EEI
                                 C-577

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C-578

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                          Sampling Report
    Investigation of Sun Exploration and Production Company's
                   Cameron Lease Well No.  1-10
                    Gladwin County,  Michigan
                          July 30,  1986


SITE INFORMATION

Site Selection

This site was randomly selected by EPA as  described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA 530-SW-87-005).  This site was selected randomly from
a list of Michigan Basin drill sites (at or near completion)
developed by the Michigan Department of Natural Resources at the
request of EPA.  The list was transmitted  via telephone to the
EPA contractor on July 21, 1986.  Randomization and site
selection took place during the telephone  conversation.

The EPA contractor had no interest  in the  manner the particular
sites were listed (by site name, location, operator, permit
number, API number,  etc.) as long as the site could be identified
in detail upon selection.  Thus, the EPA contractor had minimal
information which kept to a minimum the amount of bias.  No other
information was known about the sites on the list at the time of
selection.  Detailed information was obtained only after
selection of primary and back-up sites.

The Department of Natural Resources listed the possible sample
sites by operator and county.   Their source for the list of drill
sites was the weekly Michigan Oil and Gas  News, which gives
weekly rig locations.   The list consisted  of seventeen Michigan
Basin drill sites:

          1.  Livingston Co. - Terra Energy
          2.  Livingston Co. - Dart Oil and Gas Corporation
          3.  Barry Co. - Allexco
          4.  Arenac Co. - Amoco
          5.  Arenac Co. - Benchley
          6.  Crawford Co. - Onion  Oil Company
          7.  Gladwin Co. - Sun Exploration and Production
                Company
          8.  Ogemaw Co. - Marathon Oil
          9.  Roscommons Co. - Federated National Resources
               Corporation
         10.  Manistee Co. - Preston Oil Company
         11.  New Aygo Co. - Wolverine Oil and Gas Company
         12.  New Aygo Co. - Wolverine Oil and Gas
               Company/Pet rosta r
         13.  Osceola Co. - H. L. Brown
         14.  Osceola Co. - Tetrostar
         15.  Alpena Co. - H.  L. Brown
         16.  Otsego Co. - Mosdacher/Scandia


                               C-579

-------
         17.  Tresque Isle Co. - Trend Well Oil Corporation

As indicated above, the EPA contractor assigned numbers to the
members of the list as they were transmitted.  A random number
table was used to select the primary and back-up sample sites.
The randomly-selected primary site was No.  7 on the above list
(Gladwin Co. - Sun Exploration and Production Company).  No. 17
on the above list  (Tresque Isle Co. - Trend Well Oil Corporation)
was selected as a back-up site in the event the primary site was
inaccessible or inappropriate.

Further inquiry identified the primary sample site as Sun
Exploration and Production Company's Cameron Lease Well No. 1-10,
in Gladwin County, Michigan.  No problems were encountered in
arranging sampling for July 30, 1986.  The back-up site was not
required.

Site Location

Cameron Well No. 1-10 is located approximately 300 feet northwest
of the intersection of Kerswill and McCollough Roads in Grout
Township in Gladwin County, MI.  Figure 1 is a map indicating the
drilling site.  The full name and mailing address for Sun
Exploration and Production is:

          Sun Exploration and Production Company
          1320 Waldo
          P.O. Box 999
          Midland, MI  48640
          Main Office Contact:  Mark Dalton
                          Northern District Environmental
                          Coordinator
                     Phone:  517-839-5831

Attendees

Sampling at the Cameron Lease site was performed by CENTEC
Corporation personnel on July 30, 1986.  Following is a list of
people present at the time of sampling:

     CENTEC Corp.  (Sample Team):  Bill Lane, Technician
                                  Jamie Mclntyre, Team Leader

     State Representative:        Jim Skipper, Geologist,
                                    Michigan Geological
                                    Survey Division, Mt. Pleasant
                                    District Office

     Operator Representatives:    Mark Dalton, District
                                    Environmental Coordinator
                                  Mike Fandell, Health and Safety
                                    Coordinator
                                  Clayborn Hunter, Drilling
                                    Foreman

                               C-580

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            +
Figure 1.  Location of Sun Exploration and Production Company's
           Cameron Lease Well #1-10, Gladwin County,-Michigan
                            C-581

-------
    American Petroleum
      Institute Representatives:   George Holliday, Contracted
                                    Observer
                                  Lloyd Deuel, Contracted Sample
                                    Team Member
                                  Amy Crum, Contracted Sample
                                    Team Member

Site Description

The Cameron Lease site is characterized as rural, flatland.  The
climate at this site location is  net precipitation.  The soil is
described as a red clay bed under loam.  The well was completed
in the Prairie du Chien formation in the Michigan basin.

The depth to the groundwater in the area is between 26 and 50
feet.  The nearest surface water  is a swamp less than 1/2 mile
from the site.  The nearest drinking water wells are associated
with seven houses within a 1/2 mile radius of the site.

At the time of sampling, the site consisted of one drilling well
and one reserve pit.  The drilling rig, Bigard Drilling Company's
Rig No. 18, is shown in Photos 1, 2, and 3.  There were several
trailers onsite serving as offices and living quarters for the
crew.  These were all situated on the side of the rig opposite
the pit.  Figure 2 is an approximate schematic diagram of the
site, indicating the directions in which photos were taken
(Attachment A).

This site was an exploratory drilling site.  Total depth of the
well was reached at 12,700 feet.   Total depth had been permitted
for 13,000 feet.  Drilling began  on April 27, 1986 and total
depth was reached on July 24, 1986.  A date for completion of the
well was unknown because the crew was waiting for further orders.
Mud was being circulated, but all other activities had been
halted.

Drilling was accomplished with a  spud mud, followed by a lime
mud.  At the time of sampling, a  polymer mud was being circulated
with saturated brine.

One lined pit was constructed onsite to provide temporary storage
of drill cuttings, residual drilling muds from the circulation
system, waste crude oil, and miscellaneous trash.  The operator
suggested that there would also be considerable amounts of salts
in the pit, due to the nature of  the formations they had drilled
into.  The pit contents were piped from the mud circulation
system, as shown in Photos 5, 9,  and 13.  The pit was in use as
of April 27, 1986, and was expected to be out of service some
time in August 1986.

Construction requirements of the  pit included a 20-millimeter PVC
liner, clearly visible in Photo 10.  The sides of the pit were


                               C-582

-------
Figure 2.  Schematic Diagram of Drilling Site
                    C-583

-------
required to have a three-to-one slope, and the depth could be no
less than 4 feet above the top of the groundwater in the area.

At the time of sampling, the average depth of liquid in the pit
was 2 feet, and the average depth of the sludge was approximately
7 feet.  These quantities were estimated by the operator.

Pit contents included an estimated 1,700 to 2,200 barrels of
cuttings, drilling fluids, and wastewater (deck drainage)
generated from drilling operations.  In addition, an unspecified
amount of cement had gone to the pit when the surface pipe was
cemented in place.

A tank storing diesel onsite could hold a volume of 21,000
gallons.  The volume of diesel onsite at the time of sampling was
2,500 gallons.  The operator estimated that less than one gallon
of waste oil had been generated onsite and put in the pit.

Disposal Practices

The operator stated that liquid from the pit was removed by
vacuum truck three times per week, and taken to "a variety of EPA
approved disposal wells."  Time did not permit collecting a list
of these disposal wells.  Two companies that had been used to
haul pit fluid to disposal wells included KalCon and Seiler
Companies.  Copies of invoices for the hauling services provided
by these companies are located in Attachment C.

Solids would remain in the pit, to be encapsulated by turning the
apron of the PVC liner into the pit, covering the pile with a
second PVC liner, and backfilling the pit.  The site would be
restored to its original grade, but further restoration would
depend on the ultimate disposition of the well.

Permits

Sun Exploration and Production Co. secured permits to drill, and
later to deepen, the Cameron Lease Well No. 1-10 in Gladwin
County, Michigan.  Copies of these permits are located in
Attachment B.
SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).
                               C-584

-------
Sample Point Locations

At the Cameron Lease site, the samples were defined as the
supernatant and solid contents of the waste material in the
reserve pit.  Figure 2 shows the locations of the sample points.

In addition to the pit samples, a drilling mud sample was
collected from the mud circulating area.  The sample was taken
from the flowing effluent shown in Photo 11 leaving the first
shale shaker in the system.  The shaker that was sampled is
visible in Photo 1 at the far left end of the mud tank, directly
above the cuttings pile in the pit.

Sampling Methods and Equipment

To collect samples from the reserve pit, the pit was measured to
identify the four quadrants shown in Figure 2, and to locate the
center of each quadrant.  The measured points were marked with
stakes to facilitate locating sample points.

The sample points were accessed by boat.  The boat was paddled to
the measured sample points and held in place with two anchors.

The first sample to be collected was the liquid composite.  The
thief was used to obtain this sample.

The reserve pit was then sampled for sludge.  The dredge was used
to sample the sludge because the coring device could have
possibly punctured the lining of the pit.  Photo 6 shows samplers
tossing the dredge from the boat in the northwest corner of the
pit.  Two full dredges were obtained at each quadrant, yielding a
total volume of approximately 5 gallons.  The solids were
composited in a 5-gallon steel bucket.

To collect the drilling mud sample, a clean 1-gallon glass jar
was held under the flow leaving the shale shaker shown in
Photo 10.  This was a grab sample rather than a composite sample.

Tests for the pH and free chlorine content of the pit samples
were conducted onsite after sampling was completed.  The pH of
both pit samples was 7.  The free chlorine test, which is only
performed on liquid samples, was immeasurable, but caused the
liquid to bubble out of the test cell.  The apparent chemical
reaction caused by this test was reported to the receiving
laboratories.

After sampling was completed, the samples were split with Sun
Exploration and Production Company.  This occurred at the request
of Sun representative, Mark Dalton, and at the direction of Mr.
William Telliard, EPA Project Quality Assurance Officer.  Bottles
for the split samples were supplied by the API sample team.  Each
sample bottle given to Sun was filled, labeled, and signed by
CENTEC sampler, Jamie Mclntyre.  A copy of the Chain of Custody
form used for these samples is located in Attachment D.


                               C-585

-------
The samples were preserved with ice and held overnight  prior to
the day of shipment.   This was necessary because  of  time
contraints encountered on the day of sampling.
                               C-586

-------
ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                  C-587

-------
C-588

-------
 Photos 1.2,3.  Westerly view of drill site
O
 I
m
CO
                                                    II
                                   Photo 4.   Samplers  In  southwest  corner  of  reserve pit

-------
Photo 5.  Samplers In southwest corner of reserve pit
Photo 6.  Samplers roovlnq toward northwest corner of
          reserve pit
                                                                 Photo 8.  Samplers next to cuttings pile  In southwest

-------
           Easterly  view  across south end of reserve pit
          Shale shaker (upper left) and cuttings pile
Photo II.  Effluent from shale shaker
Photo 12.  Effluent from shale shaker with API samplers
           In background

-------
$     Photo  ,3.   Cuttings  line  positioned over  reserve pit
                                                                          Photo 14.  Cyclone(s) located over mud
                                                                                     reclrculatlon tank(s)

-------
ATTACHMENT B:  PERMITS
          C-593

-------
C-594

-------
STATE OF MICHIGAN
DEPARTMENT OF NATURAL RESOURCES
O fl Q y GEOLOGICAL SURVEY DIVISION
L. \J J / BOX 30028
LANSING. MICHIGAN 48909
PERMIT TO

jgl DRILL Q DEEPEN Q REWORK Q OPERATE
GRANTED UNDER PROVISIONS OF
XX Act 61. PA. 1939. as amended Q Act 315, P.A. 1969. as amended
(M.C.L. 319.1 to 319.27) (M.C.L. 319.211 to 319.236)
Violation of and/or non-compliance with the provisions
ol the acts and conditions of permit may result in penalties.
rhis permit includes as requirements all the operations and methods
proposed by the applicant, unless rejected or titered by the ONR, and
along with the attached stipulations are incorporated in its entirety by
reference.
WELL NAME WELL NO.
' Cameron '1-10
LOCATION AND FOOTAGCS
•*~ "IWlo.,,
•39772 1-30-86
CANCEL ANO TRANSFER ISSUED

DEEPENING PERMIT


PERMIT EXPIRES
1-30-87
ISSUED TO


011 and or G as
FORMATION
Prairie du rMen
DEPTH

'I? 200'
KINO OF TOOLS
Rotary


6un Exploration^ Production Co.
Box 999
1320 Waldo Rd


Midland MI 48640


SPt SPs SBt Section 10, T18N, R2W, Grout Twp. €ladw1n Co.
330 ft. from South and 330 ft. from East line of quarter section
330 ft from South and 330 ft. from East line
ofd drilling unit
CASINO AND SEALING REQUIREMENTS
CASING
00 SIZE WT/FT. GRADE CONDITION DEPTH
24" .5" Wall PE New
16" 75* K-55 New
100'+
700 '"
10-3/4" 51-60.7* L-80 & SS-95 ,". New "6450*
7-5/8' 26.4-39* L-80 New
5' 15* N-80 New
*If no abnormal pressures 1n the A2 or Al Carts
* 9200-10300'
* 12200'

CEMENT
SACKS WOC (MRS)

600 12
1900 16
600 24
"300 24
or sloughing shale problems In the Utica .
Shale are encountered, then the 9-1/2* hole size will be reduced to 8-1/2" and a 5-1/2" long
string will be run Instead of the 7-5/8* Intermediate casing & 5" Uner.
1. HYDROGEN SULFIOE (M GUIDELINES APPLY. SEE NO. 10 ON REVERSE 8IESIDE OF THE PERMIT.
2. Materials expected to be exposed to H2S environments oust meet the standards for
resistance to sulffde stress cracking outlined 1n the NACE Standard
MR-01-75, "Sulflde
Stress Resistant Metallic Material for 011 Field Equipment*. 1978 revision.
3. Reserve pit 1s to be located north of well.
4. Mt. Pleasant office Is to be notified prior

ICE TO BE NOTIFIED BEFORE DRILLING/DEEPENING STARTS
t. Pleasant Field Office 517-773-9965
PAGE 1 ol



to encapsulation of pit.

BY ]' -Y <•' /
Rex TefertHler
PAGE(S)
FOR THE SUPERVISOR


i
t
7!3~"
517-373-9TBST COORDINATOR
OF WELLS/MINgRAL WELLS
1
C-595
                                                PR 7700
                                               O... •»;•€

-------
    APPLICATION FOR  PERMIT TO  DRILL OR DEEPEN.
         A WELL FOR OIL,  GAS,  BRINE DISPOSAL,
  HYDROCARBON STORAGE OR SECONDARY RECOVERY
           Under Authority of Act  61, P.A.  of 1939. As Amended
                                                                           0
                                                                                                \J n.WM.1  r. IV r I I
                                                                                                                R 7207
                                                                                                              Rev 2/81
                                                          MAIL TO:
                                                    STATE OF MICHIGAN
                                          DEPARTMENT OF NATURAL RESOURCES
                                              GEOLOGICAL SURVEY DIVISION
                                             Box 30028, Lansing,  Michigan  48909
                 SEE INSTRUCTIONS ON REVERSE SIDE ->•
                 ace inamuunuraa

 3 Acoi'canon lor permit to drill for
 -,  Oil and     _-.  Srme       _  Hydrocarbon    Secondary
 -jt  Of Gas	U  Disposal     U  Storage     I—I Recovery
 6 Do prior permits exist for tfiis weft9              "
 _X  No    Q  Yes  I D  Drilled D Termmd
                                                     4 Application to  (no lee required)
                                                                  Revise        Cancel and
                                                     I—J  Deepen I—I Application  I—I  Transfer
                                                                        2 £] Fed. Employer Ident. No. | G  Soc. Security No.
                                                                           23-1743284
                                                          5 Fee enclosed
                                                          D  No   G3  Yes  S  100.00
  List tacn permit number
    LOCATE WELL AND OUTLINE UNIT
     ON  SECTION PLAT —640 ACRES
 W



~~

—




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• "m «
                                     a Applicant, (name each owner" at tney are bonded)
                                       Sun Exploration and Production  Company
                                      9 Address, (operator only if more than on* "owner')
                                       Box 999 -  1320  Waldo Rd., Midland,   MI  48640   (517)  839-5800
                                      10. LMM or wott nvrw. (tM bntf as possiblt)
                                        Cameron       	
                                                                                           Well number-
                                                                                           1-10
                                      n. Surface owner:
                                        Alex  Acres
                                      12. Addraaa.                                               Phone
                                        4789  W. Cedar.  Gladwin. MI   48624   (517) 426-7969
                                     13. Surlac* location description (Sa* instructions, item 4)

                                          SE   *ol   SE    *"'  SE   *Sect.on   1Q    T   18N       «  2W
                                      14 Township
                                        Grout
                                                                                           County
                                                                                      G1adwi n
                                      15. Bottom note location description ,f directional dnfl (See instructions, item S\
                                               V. of          V. ol       V. Section         T
                                      18 Township
                                                                                            County
 •' LOCATE WELL IN TWO DIRECTIONS FROM NEAREST LINES Of QUARTER SECTION AND DRILLING UNIT. (See instructions, items 445)

           330	n from img)  SOUth	Line ol quarter section.  AND    330	ft. from is/w>  EdSt
  Surface
a Location
   Bot Hole
D  Location .

   Drilling

 c  'Jntt 	
                     .n. from IK'S).
           330
                     . ft. from (N/SI-
South
. Una ol quarter section  AND .


	Line of dnllmg unit   AND
                                                                             .It. Irom (E/W)_
330
                                                                              . ft Irom (E/W)
East
_ Lin* of quarter section


_ Line of quarter section


  ... Line of drilling unit.
 18 Drilling contractor
    Not yet awarded
                                                                                               T*i«phon*.
19. Kind of tools (Rotary, cable, comom.iiooi
Rotary
20. IMwndwJ d*ptn
az.zoo1
21. Inlenaed farmaoan
'rairie du Chi en
22. Is sour 0*1 or o«s •«p«ct*d?
n NO | c Y., QQ' 10 300
i??nn-
Lf_nn ahnnrm
"countered,
QeoL Form
be drivi
GL Drif
"F" Sal-
Niag-Tri
PdC
L! pressi
:hen the
BK Ola.
rn
: 20"
: 14-3/4
pnt. 9-1
6-1/2"
ires in
9-1/2"
CASINO
O.D. Size
24"
16"
10-3/4
2" 7-5/.
5"
he A2 o
ole siz
Wty R. — Grade — CondlUon
0.5" wall - Pt - new
75# K-55 new
1 51-60. 7# L-80 & SS-<
i" 26.4-39# L80 new"ty
15? N-80 new >
• Al Carbs or slouqhlr
>will be reduced to i
Depth
±1UU'
7UU1
5 6450'
M-lOSOf
12200'
g shale
.-1/2" ar
« send eorr.spono.nc. .no B.,m,t t0 Address run nstead of the /-b/«" i ntenned
CEMENT
Secka
—
600
1900
1 600
300
jrobier
d a 5-
iate ce
W.O£Qn,;
—
12
16
9/1
2<


is in •
12" 1c
isir
MUD
Wt.
--
a./
R VI
) ?-1
J.2-:
ie Ut
iq st
VI*.
—
50
n ? rt
Q S '
0.8 •
resn
ring
W.
--
NC
R I
0-f
0-'
RT
W1
ig & b" Uner.
   Sun  Exploration and Production  Company  - Box 999 -  1320  Waldo Rd., Midland,  MI   48640

Date Issued
.L" if '%**

Permit

-------
  2397
       STATE Of M»CT«^_.
DEPARTMENT OF NATURAL RESOURCB9  _.
   GEOLOGICAL SURVEY DIVISION
          BOX 30028
     LANSING. MICHIGAN 46909
                   PERMIT  TO
                             OPERATE
  Q DRILL .3 DEEPEN  Q REWORK
             GRANTED UNDER PROVISIONS OF
  Act 61. P.A. 1939. as amended   O Act 315. P.A. 1969, as amended
  (M.C.L. 319.1 to 319.27)          (M.C.L 319.211 to 319.236)
       Violation of and/or non-compliance witn the  provisions
    of the acts and conditions of permit may result in penalties.
  fhis permit includes as requirements all the operations and methods
  proposed by the applicant, unless rejected or altered by the DNR. and
  along with the attached stipulations are incorporated  in its entirety by
  reference.	
PCKMIT ISSUED
39772 7/11/86
CANCEL AND TRANSFER ISSUED
DEEPENING PERMIT
2302
PERMIT EXPIRES
7/11/87
Tff 6 OF WCLL
Oil or Gas
FORMATION
Prairie du
Chi en
DEPTH
13,000'
KINO OF TOOLS
Rotary
WELL NAME
 Cameron
                                         1-10
                                         ISSUED TO
                                           Sun Exploration and Production Company
                                           Box 999
                                           1320 Waldo Rd.
                                           Midland, HI   48640
LOCATION AND FOOTAGES
 SZk  S&t SEH.  Sec. 10, T18U, R2W,  Grout Twp., Gladwln Co.
 330  ft.  from  South and  330 ft.  from East  line of  quarter section.
 330  ft.  from  South and  330 ft.  from East  line of  drilling  unit.
                                  CASING
                               QRAOE
                             CASINO AND SEALING REQUIREMENTS

                                    CONDITION          DEPTH
 5 1/2"
   Conductor
   750             K-55            New
   51-60.7*       L-80 & SS-95   New
   Deepen to 13,000'
   17-20*         N-SO            Hew
                                                                100'
                                                                700'
                                                                6450*

                                                                13,000'
600
1900

1700
WOC (HHS|


12
16

48
 1.  HYDROGEN SULPIDE  (H2S) GUIBELXHES APPLY.  SEE NO. 10 021 REVERSE SICE OF THE PERMIT.
 2.  Materials  expected  to be exposed to H2S environments must meet  the standards for
     resistance to sulfide stress cracking outlined in the RACE Standard MR-01-75,  "Sulflde
     Stress Resistant Metallic Material for Oil Field Equipment", 197S revision.
 3.  Reserve pit la to be located north of veil.
 4.  Mt. Pleasant office Is to be notified prior  to encapsulation of pit.

 fFlCE TO BE NOTIFIED 8EFOBE OBILLINO/DEEPENINO STARTS

 Mt. Pleasant Field Office 517-773-9965
                                                          BY   '   •"
                                                          David II.  Bechler  for
                                                                             -/'/  /'•  &'•+-••'
                                                                              PERMIT COORDINATOR
                              PAGE i of
                                                      PAGE(S) Hex Tefertiller        517-334-6974
                                                                    FOR THE SUPERVISOR OF WELLS/MINERAL WELLS
                                         cinccno
                                                              oem iiRPMFMT!1?
                                                                                                  PR rzoo
                                                                                                 R«v. 7/85
                                                  C-597

-------
   APPLICATION  FOR  PERMIT  TO:
                                                                                    REWORK OR  G OPERATE A WELL
                           MAIL TO
          MICHIGAN DEPARTMENT  OF  NATURAL RESOURCES
                  GEOLOGICAL SURVEY  DIVISION
               BOX 30028. ^ANSING.  MICHIGAN 48909
                                           •','/
                                          /

        AND/OR FALSIFICATION OF THIS INFORMATION
MAY RESULT IN FINES AND/OR IMPRISONMENT.
                                                                                    BY AUTHORITY OF:
                                                             la   " Act 61. PA  1939  as amended
                                                                y. Oil & Gas
                                                                ~ Snne Disposal
                                                                C Hydrocarbon  Storage
                                                                C Seconday Recovery
  A=r''Cation to  (no fee required it permit is valid)
    -^**
              Revise Application  ~ Cancel and Transfer C Convert to II
                                                                                              10
~ Act 315. PA
__ Disposal
^_ Brine
~ Test Well Type

H Single
                                                                                                              19ii9 as amended
                                                                                                                 _ Storage
                                                                                                                    Blanket
                                                                    3 Fee enclosed
                                                                      5C No   C Yes
                                                                                    4  Do prior permits exist7
                                                                                      ^ No  5£ Yes ij( Drilled  H Abandoned/Terminated
 5 i_is: each permit number
    39772
   Surety Bond-
   X Blanket  ~ Single Well
                                       6. Fed. Employer Idem. No  or Soc.  Security No.
                                             23-1743284
                        6. i_ Attached
                          X On File
                                         9. Bond No.
                                            8074-71-81
                                                          10. Bond Amount
                                                           $50.000.00
    Applicant  (name each  owner  as they are  bonded)
   Sun  Exploration and  Production  Company
 *2 Address- (operator only  if more Man one owner")
                                                             Phone:
   Box 999  - 1320  Waldo  Rd..  Midland,  MT   4flfi4n   (si?)
 13  Lease or  well name:  |Se as  brief as possible)
  - Cameron                 	
                                                            Well  number:
                                                               1-10
 1-  Surface owner
   Alex Acres
 i5  Address
   4789  W. Cedar.  Gladwin. MI   48624
                                                             Phone
                                                        (517)  426-7969
                                                                                             LOCATE WELL AND OUTLINE UNIT
                                                                                             ON SECTION  PLAT - 640 ACRES
                                                                                                           N
                                                                                          W
15  Surface location (See instructions)
  SE    * ^E   * of   SE   *
                                 sec.
                                                18N   R-2W
                                                             Township
                                                                 Grout
                                                                                    County

                                                                                        GTatlvdn
    Bottom hole locaron if directional dnll (See instructions)

         'i        Y« Of        '* of Sec.       T.
                                                             Township
                                                                                               County
                                                      R.
13  LOCATE WELL IN TWO DIRECTIONS FROM NEAREST UNES OF QUARTER SECTION AND DRILLING UNIT. (See instructions)


              330	ft. from (MfS) SOUth	Line of quarter section.   Ann    330	ft. from (E/W) __EaSi— Line of quarter secttor


              	ft. from (N/S)	Line of quarter section.   AND	It .from (E/W) 	Line of cuarter sectior


                                     SOUth	Line of drilling unit.   Ann     330	ft. from (E/W)    EjSt     Line ot drilling um
   Surface
 3  Location:.

   Bot. Hole
 s  Location- .
   Drillmg
 c  Unit-
                        _ft. from
1 9 Drilling
contractor
RinarH
Hr*l 111 nfl
Cn
20.
Kind of tools (Rotary,
Rotary
cable.
combination)
21
Is sour oil
D No
or gas expected''
BE Yes
72. Blriwout control diagram enclosed
C No £ Yes
 23  Blowout control (Detail equipment type. size. mm. rating,  testing, choke manifold,  etc. See instructions)

   See attached
 2-  intended Total  Depth
.  c13,000'
                        25. Formation at Total Depth
                          Prairie du  CM en
                                               26. Producing Formation
                                                      PrairMo  Hn  fhion
                                                                             27. Objective Pool or Field
                                                                                    Prairie du Chien
                                PROPOSED DRILLING, CASING, CEMENTING AND SEALING PROGRAM
HOLE
Depth
100'
?nn'
6450'



13000'
Geol Form
Drift
pi nn' ft
"F" Salt



PdC 9-1
Bit Dia.
Drive
?r>"
14-3/4



/2"» R-
CASING
0.0. Size
24"
1«"
10-3/4



I/?" S-l
Wt./Ft. — Grade — Condition
Conductor
?«;# \(.^ new
51-60. n L-80 & SS-95
new
Dppppn t.n 13,nnn'
PHP
/?" 17-?n< N.RO npw
Depth
inn1
700'
6450'



i ^nnn •
CEMENT
Sacks
~ ^
500
1
-------
ATTACHMENT C:  INVOICES FOR PIT FLUID
           HAULING  SERVICES
                 C-599

-------
C-600

-------
      -*•
                           ALBION, MICH. 49224     June  30

                     In Account With
                                       -.«M-

          SE1LER TANK TRUCK SERVICE;' INC.
                       Fully Insured
P.O. Box 364  Albion, Michigan 49224   Phone Area 517629-4810
                                                                                             DS
                                               CS  40382
                                                                               N2   88279
                                                                            PLEASE REMIT TO:
                                                                               MB Unit
                                                                               No. 9384
                                                                               Milwaukee, Wl. 53201

June
June
June
June


June
June










-





21
21
21
21


23
23














-
Lease: Camercn 1-10 '
Field Ticket * 1508 7 hrs
Field Ticket £ 1630 7 hrs
Field Ticket * 1098 9*« hrs
Field Ticket #812 9% hrs
Furnished Transport and Cceratcr to
haul brine
to rig.
33 hrs 3951.75
.* - -.- . .• 	 .. O^Gcount
Field Ticket * 313 10*$ hrs
Field Ticket * 1S30 11 hrs
Furnished Transport and Operator to
haul oit water to Oisccsai.
213* hrs §551.75
Discount
Disposal Charce 9£0 bbl @.25C
Total



i








o crElYED
RBV**1**^-
* Hor«M»OUM
i JUL051SS3 ••
torn 	 .w-- 	
JATNC f IAI» TW* 	 • 	 —

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t



S1707
(? 165


$1112
(S 107
5 245
















76
00)


63
50)
OC






















f-2792





















G9











             TERMS: Our FINANCE CHARGE on accounts ovw 30 day* i* a fixed amount of 1V, % p«r month which is 18% ANNUAL PERCENTAGE RATE.
Accounts Due In 30 Days

-------
                                     /*LBION, MICH. 49224.
                                      V- ' • -
                                                                                                .198
                                In Account With

                     SEILER TANK TRUCK  SERVICE, INC.
                                 Fully-Insured
            P.O. Box 364  Albion, Michigan 49224   Phone Area 517629-4810
Sun S::T? Lcrati. en
                                                                        8S921
P.O. 3cx 599
Midland, MI  43640
                       CS-403C2
                                                               PLEASE REMIT TO:
                                                                   MB Unit
                                                                   No.  9384
                                                                   Milwaukee, Wl. 53201

Auo
Auc
Auc
.iUC
Auc
AUC
Auc
.AUC
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12
13
9
9
10
10
11
12.
12
12
13
i j
13














-
i _ 1
Lease: Cameron 1-1*0
Field Ticket i 2459 6 hr
Field Ticket if 2465 3 hr
Field Ticket f 1957 2h hr
Field Ticket 7 24S5- 5 hr
Field Ticket i 24S5- 15 hr
Field Ticket * 2545- 4*5 hr
Field Tickec * 251S 5 hr
Fielc Ticxec :.f 2s 19 11 hr
Field Ticket #-2490 5 hr
k'leiti Ticket w 24^5 2*5 hr
Field Ticket # 2491 5 hr
^'ieic vic.cec s £
-------
                                              ALBION, MICH. 49224      ^UCUS -  2.3

                                        In Account With

                              SE1LER  TANK TRUCK SERVICE, INC.
                                          Fully Insured
                    P.O. Box 364   Albion, Michigan 49224  Phone Area 517 629-4810
                                                                                  193	
Sun ":;
                        tion. ."
          P.O. Zcx 99S
          I lid land, t-:i   45640
                           CS-40332
N2  '86937
                                                                        PLEASE  REMIT TO:
                                                                           MB Unit
                                                                           No.  9334
                                                                           Milwaukee, Wl. 53201

>.uc














^
4





20




















Lease: Car.ercn 1— 19 	
Field Ticket •? 1215
ITurnished 70 bbL Tanden Vac Truck and
Operator tc ;.aul pit watar to cispcsaJL.
3 hrs §545.00
Discciaal. Cliarrs
ISO bbL 3.25*
Total






^







RcCtiVtD
K.~';~T: '.'.anti
ftiw 9 7 1986
..• . "is r\
rn STCO VI.U.T- J _
rvr N-i ' •' "" • ° — 	 r^=:
>.





314^
3 37






-






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.






00
5G






















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50















           TERMS: Our FINANCE CHARGE on oCEOunts ov»r 30 day* if a (lx«d amount of 1 Vt % per month which it 18% ANNUAL PERCENTAGE RATE.
xounti Due In 30 Days                           C-603

-------
                                                       ALBION. MICH. 49224	

                                                 In Account With

                                     SE1LER TANK TRUCK SERVICE, INC.
                                                  Fully Insured
                          P. O. Box 364  Albion, Michigan 49224   Phone Area 517 629-4810
                                                                                       CttCCeTi.-=r
                                                                                              <3 / i • j o
                                                                                   PLEASE  REMIT TO:
                                                                                       MB Unit
                                                                                       No.  9384
                                                                                       Milwaukee, Wl. 53201
                                           c.Truj. ndrci '. I*er.  rr-  -^.-j
                                                                   Tctai
                 TERMS: Our FINANCE CHARGE on accounts ov«r 30 daypiiatfvgd amount of 1". % pw month which is 18% ANNUAL PERCENTAGi
All Accounts Due In 30 Days                               ^

-------
           CCrSSTaUCTiON  S23VJC2
mJm ^^» V» 4»«3» VE^^ Via/ JL» «fc PC BOX 41 KAUASXA. MICHIGAN 49646 PHONE (616) 258-9134
eiw«« «»v,cs • "O«o luaAiM . MMMIWUNCI • .XCAV.TINO EMAN HOOERHEIDB JI. DENNIS HOCERHE1DE
OOZXK MKVICC • IOUVMCNT MAMBUMO • MIDI HUI
OIL. fltUO TDUCKINa • MPT1C STSTIMS
™« STJN- PRODUCT^?; COMPANY ^ * M ^HOR.ZEO .,,„ ^ ^
««-,, P.O. BOX 999
<"!TYll5TiT* MIDLAND. 'H

r OWE |
S/^/Sfi

5/Ob/36

5/06/o6

5/06/36

5/06/3S

5/07/86

3/07/36

S/Oo/86

3/oa/ae

5/09/S6




/" \ rKv) * LOCATION Crt:-[£'»GM 1-10
/XW
10
A 4453"
OEsaumoN. I PRICE L AMOUNE .-•• 1
* ^ nniras v/TA>nra» -rav B«rf?n T)I?*:T!?VII Trs* TISOQ
5.00 HOURS W/TANKER TPJC. HAULED 2a7 SSL 3RT>^ TN'TO LOCATT
:\.ra PUT
3. 00 HOUIIS '•„'
r" T^JKS Ts.. "US^'O^f;^ Tfy 40;"1'1
/T^t'KZS TV -VU'FD 130 l^L 1?^O'-: Vr^^VF ^7
TO ?. dOLDE^ 41 S-.JO r*. TO«P»nVO 7^' &»«7
3.00 SOUltS "»
PIT TO
2.00 HO'JSS W
/T^IKER TI1K. 'ULTLHD 130 33L '.JATSR j?^CII 1ES.
F-FOLOrZIAI.' .>! S'iO (?. T'OnffMTtfli^ TCTC ?"56i?
/TAiTER T!TC. --4nLffD 130 33^ «RT-.V T-TTO T,nr\TT
r CF. SODfTJTW^ TRK 7^fi7
S.SO ««oL-3 :;/?4i-fitKTi r.^- BATT:*T» 7-.-1 r.sr. ^VT^TT T»rrc 5JAr
TA^rKS FOR. RIG H. RJDEJJISH^ TC^ 4-63
5.00 HOUP.S >T
/T.V'TSI T\Jv •iATJTj'T) 4Q'"< ii'H' TTCT"!' t*r*'"T '5T>Ar>
T^,r *OR STJ CF wo^i^rr^^ -jx: •'37-'
r; Afl iiAir^c '..'

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v,, ,n

44 •s '("i

.,.. .

<•- -.-.
. ^ ^ , -.

KAUASKA CONSTRUCTION SERVICE INC. 2% AFTER 30 DAYS
                                 INVOICE
C-605

-------
CHAN* MMVICC • "0*0 BUHDUM • M«KT«NANC«
    OOZtH HMVICI • IOUWMCMT MAMOUM • MIDI MIX
         OH. Pl«L0 TBUCKINO • MPTIC SVSTWMS
                                                     POBOX48     KALKASKA, MICHIGAN 49646    PHONE (616) 258-9134
                                                              EMAN HOGWHE10E J«.        DENNIS HOGERHEIDE
S '•'"" • •«-
a,Tlrr vcfl ^. (e
,./T,.._r.t, ^J. ,..)lf
PRVrr ,,vfl ,.,T ,n






	 	 . — • -.„ 	
\ .%;-»..-..--..
,
^--
* — ".
1 "AY ._.-> -.-:...- 	

DESCHIPTiar*- . _ 	 ...
. HAULED 420 33L t«Hi:fE I!JTO LOC.
±JS^ TCK l^Oil
„, lsn ^RT pTi-TATira nnr rn rm
r, ,?Wi,.,,I..n Trt- 7,r,,,
ITTrn ,<7 .rt,( 9l-..aTra 70 ......^
-T,rjiB^. Trr <;,,i
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viwjif.q^ T,-nr ^iqh













^^^^^^^^^^^^^^^^B
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l^^^^^T^^^^^3]
470. rO

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-^ ,A

i-,7 np.

'.',A 4r.


1 <'< 4 TK











                                       KALKASKA CONSTRUCTION SERVICE INC
                                                                                                     AFTER 30 DAYS
                                                                                                       INVOICE
                                                      C-606

-------
                                                 XALXA5XA   COrsST^UCTiCiS   ScSVlCS  INC
                                                  POBOX4«    -KAIKASXA, MICHIGAN 49644     PHONE (616) 1 i8-9134
      C*AN« M*v,ci •  «a«a ~W..MO . ..A.NT.NAMCI . KCAVATWO         EMAN HOGERHEIDE JR.      DENNIS HOGSRHEID6
          OQSIt SVftVICI • KOUIPMCWr HAMOLIMO • ftVOI MIX
               on. fimuo mucxma • MPTIC SYSTVMS
SOIOTO   .


ADDRESS   .

CITY & STATS.
              SUN  PRODUCTION  COMPANY
P.O. 30X 999
          VT  4:
.nfiAft      / a*  \(
                                                  AUTHORED   gOB ACgLm
                                   LOCATION  CAI-iERAOM 1-10
                                (7
                                                                                             A  4551

DATE I
5/13/86

6/13/86

5/16/H6

S/1S/8*

6/Ui/S*

«/!7/rtfi





1






DESCRIPTION.- .... - - PMICE- , - . U, -•; - MMOUmr^H
^'/TANKER TPJt. •r,'AI7T."'D 1 SS RRL BST?i'P OUT 0" PTT TO OT^Pfl^VT.
AT 1 )<< PrT> URT n im'TASW^ rnr ST?7
^/TAirscss. T=b;. KAITLSTJ PTTUATSR OUT OF PTT TO ^TSPO^AT.
70.1 «T. .71.^7-
'.T/TA\--?. T^K.. rr.Afrr..--n w
4<50 8UT. AT 1.13 ?T
v ^RT. (r cnnP-iTwi rr..- 40^7
-,7^?. r»rrr HP PKTI nn

5A.43

^ &,

•>«/ Ort


, ^ K,









                                   KALKASKA CONSTRUCTION SERVICE INC
                                                                                          2% AFTER 30 DAYS
                                                                                           INVOICE
                                                 C-607

-------
                                                    PO8OX4*     KALKASKA, MICHIGAN 49646      PHONE (616) 258-9134

ow* SCMVICI . IKJAO muiuiiHO » .MW.TIJ.A..CE  • «xe*WATiNa           EMAN HOGERHEIDE JR.        DENNIS HOGERHEIOE
     OOZXK HHVICI « tOOI^XBMT MAMOUMO » »«OI M«     .   .  •
          on. n«u> TKUCXIHO •  MFTIC sv«n»m   '
^ 	 SUN PRCDUCTTOM COMPAQ 7^ ID -, AUTHORED JIM SM1TH/3bB ACSLS7
	 P.O. SO'-C 999 ° A^Or^ ""4/V LOCATION CAMERON 1-10
ADDRESS 	 k-iv ^ -'OVQl

A 455
| OATE. |T - QESCHIPTIONi- . . - . - |^_ PWCE- : jfc.-r.-j. AMQUNr «
fi/^n/^fi

6/21/G6

6/21/36

R/-Q/8S

T/21/S6

fi/?7/flfi


7/Ol/Hh

7/,V/«ft

7/iT^/A^
sS*s^
c . .^
\
\
i
\ ,
i!/TAvnft? T-JTT. KAT,I m i "?n n:u Ti-'T'ja'rrR nnr rn
F. KOLDC"^,' rfi SVD n*. RiisHONf:'* rr? -i^s
5.00 HOURS W/VAC. TSK. HAULED 160 BBL SRIIffi DITO LOCATION
(a. FASR) TCK 6294
, r,n ..„,„<. C/TV^V-, T,,- j.^m -»r,n UT:T qa^rr T-W, Tr."r-,
^..n PTIT .,^0 -,n!,r PTT, rir pnn..TTC.n ,^ /|CV)Q
2. CO ^O!ri?s '."/TiNiTra TP."_ HArn.Tm t^n RTIT. rtPT'-nr rn Trtr^T^nv
r, ,TNS,0i!r^ Trr 771i
0/ nn ,rf.1T,q :T/T,,r~, -^., 3AT^.im inn anr. «T,!P r^,-. a*r.
Fno .,..TT,T,Tf: .., r-r.wMrt frv 7335
..;/T i._ri.,, T-,.r ^iITTKTy ^rn ,.,,. OTWA.Bl_ „,...
^rsyTjV.. prr -,.r „ .:nTnP.,4ft jjt ,,-T, ^ Hnrtir>fT«-j>
TT< 1"S.'?I
9/TiVS"'-""'? TT?tT triTTT '"1 ARH UBT pTTT^jlT^ • "5V {_("»/"•
B,?c^,f.,, SZZ~^ 	 > ^
^^X./T^.v,, „,. „,.,„„ ,,« £lr ^r-TlTSp .,^ ,«c
x^T^> 7 ,V". -4v «i v-n (T> an«wr^ rrv 7^x
r\H •* \
V » r--- A^n unr pTTTT^-nrs1 ^^77 T_-">r
.^ _^gfi»r ...^.^^j, c^ -r .^p^-^, ,.^. 10,.,3
,V^' ^
-------
                                              PO8OX4J     KAUCASKA, MICHIGAN 49646     PHONE (616) 253-9134

OIAN. M»VIC*  . »o«o .u,u>««a • «««T.H«HC« . «O.VAT,N«         EMAN HOGSRHSIOE J«.       DENNIS HOGERHEIOE
     OO2ZR SCRVICS • (QUIPMINT H«MOUMd • MCDI MIX
         on. ntiD muCKiNa • MPTIC svsnus
        P.O. BOX 999
                                                              AUTHORIZED
                                                                  BY	
                                                   BOB
                                       IOCATION    CAMERON 1-10
        '•IIDLAJrD, J^
43640
                                                                                             A   4555
OAT& | nscJiipnanfc" •-,-. {:--.-.> o««-c - |_^, ... ftMfnmF^...- ^
7/11/86

7/14/86

7/14/36

7/14/86

7/14/36














W/TASKSH T*X. HAULED 450 BBL PITWATER OFF LOCATIO
TO PL. fiOT.DFMAM #1 SWD <"R. 5TJSHONG} TCX 7347
7.00 SOURS W/TAHKER TRK. HAULED 300 BBL BRINE INTO LOCAIO
tOR DRILLING RIG (R. BUSHON-G) TCX 7349
W/TAJKER TRK. HAULED iso BBL PITCATER OFF LOCATIO
TO F. HOLDEMAS #1 SOT (R. BOSHOHGDTCK 7348
3.50 HOURS W/TA«KE2 TRK. HAULED 150 BBL BRIME INTO LOG.
FOR URILLIITO RIG. (J. RODEHISH) TCX 6373
y/TAITKER TRK. HAULED 300 BBL PITOATEB. OFF LOG.
TO F. HOLDEMAN #1 SOT (J. RQDENISH) TCK 6374



^\
^t.^ \
^?^\&* \
(^ ^^ ,^ ]
\ ,\\ ^ ' **^ ,
\ ^., ^^
\ ^^^^
\ ^^^


t 1.18
PER BBL.
I 55.40

r i.is

55.40

lilS



TOTAL



\
^





531.00

387.50

177.00

193.90

354.00



1,643.70










                               KAIXASKA CONSTRUCTION SERVICE INC.
                                                                                          2% AFTER 30 DAYS
                                                                                               INVOICE
                                              C-609

-------
                                                                     CwiSiTxi-CTiCiS   Si.tviCi
A«« s«»wic« •  «OAO •UIUJINO • -*I«T«NA«C«
   OOZ*» MMVICI  • IQumUHT HAMQUNO • ««0I MIX
       on. ri*\a THUCKIMO • seme SYSTEMS
                                                     POBOX4C     KA1.KASKA, MICHIGAN 49644     PHONE (616) 258-9134
                                                              EMAN HOGE*HEIO« J«.        DENNIS HOGERHEIOE
SOIOTO
AOORESS  -
CITY & STATE-
                                                                     AUTHORIZED BQB ACKLEY
        P.O.  BOX  999
        :HDLAI-iD.  MI  46640    i .-
LOCATION    CA2-JERAOH   1-10
                                                                                            A   45c
| OATE- - I1-' - •' ' OkbCJUWIOJ*.-
7/17/86

7/24/G6

7/25/36

7/25/86

'7/25/86














r.m / "** A ^TIT^I *T*VTT P A 1 ^ ^T) A *^ H
-rtKT. PTTVATTTTJ n
. --.--• . - |. , .-- MICE ..... (. ..-AMOUNT.
rn- rn KZX TRK. HAULSD 150
#1 S*«D fR. BUSiiOi'G)
SBL PITwATER OUT TO F. HOLCEJiAN
TCK 11112

33L PITWATES OUT TO F. SDUJEMAJT
TCX 5^05

BBL PIWATER OUT TO F. HOLDS-IAN
TCK 12642

BBL PiriATES. OUT TO F. KOLDEMAN
TCK 12120













R-gcTTvl
HorU«»« uU»Ut
JUL 5 1 1981
.„_.- VSSffffiO
p>v kirT IJ.TSS r.SAN _
	

i .ifi ,

1.18

1.18

1.18

1.13


TOTAL




D

i
	 .
. — =1


-^ r*

531.00

1 77 . ",.->

177.00

177.00


1,59"?. DO











                                       KAUASKA CONSTRUCTION SERVICE INC.
                                                                                                  2<* AFTER 30 DAY!
                                                                                                       INVOICI
                                                       0610

-------
                                                  XAUA5XA  CCiMSVaUCTiCN  S2HV3C2  INC
                                                   PO BOX 4«    KAU ASK A. MICHIGAN 49646    PHONE (6161 25 S-9134

      CMMM MKVICI • HOAO funjHNO • MAiMT«HA»c« . Mc*v*TiNa         fMAN HOGE8HEIOE JR.       DENNIS HOGS8HE1DE
          OOZER MHVIC* • COUII>MwAPTlTH WATER
TROH OP5N TOP TA1*!^, ',T ^-r TtTTO TIFCX7VP ^TT
^n. STAMPED TCK lZu«m
2.50 HOiniS U/TAKJCS3 TRK. START5:t) -.O.AbTrCr; i/ATKB FSnM" T>TTr
HAD 40-50 BBL ON. '/HEN S^'JT 3PHM. RETiniMSn Tm? N'FXT
DAY TO CONTIITCE ('A. •'?usHo•^;«^ TCT:-; •'sng
9 tf/TAwKER TSK. iA.'JvSp 600 BSL ?TT7ATFT? OFV TO sTJTl
^.T. fcor^TT *'•?•! rrr-: 1-5^4?








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TOTAT






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•:D 	
7c1^ MO

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.... 	 r
~U i
.«
86
!
_J_l
                                    KALKASKA CONSTRUCTION SERVICE INC.
                                                                  -.'	 ._ - --  1% AFTER 30DAYS
                                                                                             INVOICE
                                                   C-611

-------
                                                                                   Si.SViCi   i.SC.
                                              POBOX4*     KALKASKA. MICHIGAN 49646     PHONE (616) 258-9134
CXANI SCMVICI  • ftOAO •IHLDINO • MAWTONANC*  • IXCAVATINC         EMAN HOGERHEIDE JR
    OOZIK MMVICf • (QUm««NT HANOUMS * MDI MIX
DENNIS HOGcRHEIDE
OIL ^I*»-D TWUCKIWO • SCPTIC SY3TCM3
,„„,„ SUN PXOBUCTIOM COMPANY ,— x P\ A1
P.O. BOX 999 / \ ^^ LC
THORIZED CLAY30RN HUNTER
CATION cvno** is 10
mv.«A« ;ji^LA^n. :-ti 456413 	 (_./ . . —
I naxfe. .--*••
•J/04/.36

•}/05/86




















L:---. - -- ..--.• . DBCfllPTlQNw „ ........ ......... .,,......- ,
2.*;/TAiiKZa TRK. EA'JL'zD PIT:;AT5K TO DISPOSAL 150 S3L .J
(?.. SUSHON'G^ TCK 5514
3.50 HOURS W/TA:33H T3K. HAUL2D «'ATZ?. OUTGO? GAS BUSTER
3UC1CZD O'JT OP2S TOP TANK ix)'^ TO "TO. TCP^m OrT
VAT2A FSO:-! PIT. TIAUL2D TO ST«)
"/TAl^KEK TRX. HAULS 1 "..CAD PITfoATSR TO DTS?OSAL 15033'
DISPOSAL F2E OS 1ST LOAD 150 33L fl








	 	 - t r-f-^T-.
\ '• •:•'•*
1 -. /x a v»*J«J
i AVJU J ° u
\ -""^TTB 	 ' ""
j r^-f^j:!!!.'.- J- """ "


— pwce -
1.13
i-'i.A dou
50.00


^ 1 1
-------
                                                       .XA5.CA  CONSTRUCTION   ScSVlCa   INC.


                                                   POBOX4<     KALXASXA, MICHIGAN 49646     PHONE (616) 258-9134

       e»«N« um.ee - «OAO .U,U>.N« . «.«T«NA«ee • excAv»T,«o         EMAN HOGERHEIDE JR.       DENNIS HOGEUHEIOE
           OOZCH sewvice • lOumwCNT MAMOUWO • ncoi MIX
               on. rmui mjocina * seme STSTWMS
SOIDTO  _


MJO«SS  .


CITY & STATE.
                SUi: PRODUCTION COZ1PXNT
          999
                                                   AUTHORIZED   .-~
                                                      BY	  '
                      LOCATION   cjui£Ro:;  1-10
MDLAI.T). MI   4,°S40
\Cr
                                                                                                 A   4566
OAIE. . . . DESCRIPTION**- . . PRICE- • K ----- fffffPUt™^ 	 1
h/U!/3'>


C/21/S5


S/21/U6




•J/L.i/36


o/t3/u6


d/:s/u&






4.50 rtOUT<3 V/TAC. T7C\. OAULZD 40 ddL FilrlSKT/ATER I:7TO LOC
TO GUM uT ;rLT; IN BRINE TAIfK, SUCIO^J CUT GO dBL ^"U2
^"D BLO:» Ii,TO A2S22VE PIT (D. 3TA1-IPER) TCK 11154
4.00 "CJ33 ,./7AC. lid;. ilAULZD GC tlL "^£jU;:ATKS. TO GTUi
ill? ..-'.ITJ Il< 37.1!l£ 7AV.K, LIAULcD Oi'F UO 3aL PITTv'ATSl TO
i}Tjr":iSAi. (if. 3T^.^E?.^ TCK Ilio7
5.50 iOuL->S w/'/AC. "ISA. LOADED 40 5BL "/iijiSii'.'ATSi Ai.15 \jl~Ai
i:;TO OT-Eil V\c. Ti^' Vi** «•• rs
111 AXU Aj :^--J.A J- '.ii-L, T.x .-CiJ LV/U& 1C ortU
(o. :TA:T?..-C) 'cr' inea
j.5J iroucis -V/TAC. -;-.tx. '^^HKJ LIIJEH A:.-D «-&.u:i -:••• PATCI
rL^r Sli/a 07 ^I.-iir.. SUCKED vf T;ArER F7.CT.1 vJT SIDE
lu^ULZi TO S"3 (K. S'JSHOKG) TCK 1124t;
2.00 auL'iiS '-f/VAC. T-'Jal, SUCiGD LT 10 3£L '.-i&ZZZ. I'XO.-i PIT
«'iilj«i FTL-IXO PIT, liAULZD TO J"-"t) ^R. ^USHC ••'}
^ p-^
L'Ucs. L.^^-ri ....... r p.
^ 	 k £ i, c 1 V E D
UICPOS*-!. fiZZ Nar'ht n:-»rf.-t 120 &feU y

ou, - 1—
KMif A^KA^CDNStlTf f^TlQW-WB /ICE INC
fAT NOT UTSa tM*N 	 	
42.95


ftZ.95


D 42.95




42.95


4Z.05


42.95


.50
TOTAL

H3..M,


171.20


236.23




193. iU


•? ~ 2 •> ••>


05.90


6'J.O'J
1.176.7-

2% AFTER 30 DAYS
                                                                                              INVOICE
                                                  C-613

-------
vo
 I

-------
ATTACHMENT D:  CHAIN OF CUSTODY FORM FOR
   SAMPLES SPLIT WITH SUN E&P COMPANY
                  C-615

-------
o
o\
o\

-------
imiKlcr OR FACILITY
                                      SAMPLER
                                                                         SAMPLE
                                                                                                         Sun E&P Compc
                                                          PRESERVATION
Name:
Address:
FIELD: M};
                                      Address: c
                                              H
                                      Signature:
                                                       . /fTufyre-

                                                       A»*l«c 3«r   PROPERTY NO:
SAHPIE
NUMBER
              LOCATION
                                DATE
TIME
 SAMPLE TYPE
GRAB/COMP/OTHER
  NO. OF
CONTAINERS
ANALYSIS
REQUIRED
REHARKS
  1
                                                                  «
                                                                                   f «^
RELINQUISHED BY (Signature)
2/
                               RECEIVED BY (Signature)
                                                            DATE
                              TIME
SHIPPED VIA:.
DATE: 	
FROM: 	
TO:
                          BILL NO:
                                ADDITIONAL REMARKS:
                                                                                            r^rf
                                                                                          ****/ p+'^jm-rUtttt^ .
SHIPPED VIA:
DATE:	
FROM:	
TO: 	

Form No.
                         BILL NO:
                                                                                ALL ANALYSIS PERFORMED BY EPA

                                                                                APPROVED PROCEDURES


                                                                                D YES    [] NO

-------
C-618

-------
                         Sampling Report
            Investigation of Powell Production, Inc.'s
                Savarino and Stoll Well No. 6-21
                   Hillsdale County, Michigan
                          July 31,  1986
SITE INFORMATION

Site Selection

This site was randomly selected by EPA as described in the
sampling strategy document in Appendix B of the EPA Technical
Report (EPA 530-SW-87-005).   This site was selected randomly from
a list of active Michigan Basin drill sites developed by the
Michigan Department of Natural Resources at the request of EPA.
The list was transmitted via telephone to the EPA contractor on
July 21, 1986.  Randomization and site selection took place
during the telephone conversation.

The EPA contractor had no interest in the manner the particular
sites were listed (by site name, location, operator, permit
number, API number, etc.) as long as the site could be identified
in detail upon selection.  Thus, the EPA contractor had minimal
information which kept to a minimum the amount of bias.  No other
information was known about the sites on the list at the time of
selection.  Detailed information was obtained only after
selection of primary and back-up sites.

The Department of Natural Resources listed the possible sample
sites by operator and county.  The list consisted of four sites:

          1.  Hillsdale Co.  - Powell Production
          2.  Hillsdale Co.  - Patrick Petroleum
          3.  Jackson Co. - Adolf Roszeki
          4.  Otsego Co. - Northern Michigan Oil and Land
               Company

As indicated above, the EPA contractor assigned numbers to the
members of the list as they were transmitted.  A random number
table was used to select the primary and back-up sample sites.
The randomly-selected primary site was No. 2 on the above list
(Hillsdale Co. - Patrick Petroleum).  No. 3 on the above list
(Jackson Co. - Adolf Roszeki) was selected as a back-up site in
the event the primary site was inaccessible or inappropriate.

Further inquiry identified the primary sample site as the Powell
Production lease in Moscow Township near Jonesville, Michigan.
Further inquiry indicated that the well was not near completion,
so the site was considered inappropriate for sampling.

The operator of the back-up site remained inaccessible during the
scheduling period.  Although EPA contacted the operator one day


                               C-619

-------
prior to sampling, arrangements could not be made in time for
sampling on July 31, 1986.

A second back-up site was selected by a coin toss.  The No. 1
site above (Hillsdale County - Powell Production) was selected.
Further inquiry identified the sample site as Powell Production
Incorporated's Savarino and Stoll Well No. 6-21.   No problems
were encountered in arranging sampling for July 31, 1986.

Site Location

Savarino and Stoll Well No. 6-21 is located approximately 3,000
feet northwest of the intersection of Dennings and Sterling Roads
in Moscow Township in Hillsdale County, MI.  Figure 1 is a map
indicating the drilling site.  The full name and  mailing address
for Powell Production is:

          Powell Production, Incorporated
          404 East Chicago Street
          P.O. Box 184
          Jonesville, MI 49250
          Main Office Contact:  Mike Nichols
                                Vice President of Lands
                        Phone:  517-849-2727

Attendees

Sampling at the Savarino and Stoll Lease site was performed by
CENTEC Corporation personnel on July 31, 1986. Following is a
list of people present at the time of sampling:

     CENTEC Corp. (Sample Team):  Bill Lane, Technician
                                  Jamie Mclntyre, Team Leader

     State Representative:        Dave Davis, Geologist, Michigan
                                    Geological Survey Division,
                                  Rose Lake Field Office

     Operator Representative:     Mike Nichols, Vice President of
                                    Lands

    American Petroleum
      Institute Representatives:  George Holliday, Contracted
                                    Observer
                                  Lloyd Deuel, Contracted Sample
                                    Team Member
                                  Amy Crum, Contracted Sample
                                    Team Member

Operator representative Mike Nichols arrived at the site at
approximately 2:00 p.m., after sampling was completed.  He stayed
long enough to provide detailed information about drilling
activities.
                               C-620

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CO ; JACKSON
                               ...     7
                         B—sjL._.-te:__ii._A..L-v—4
                                                                         CO
Figure 1.   Location of Powell Production, Inc.'s Savarino
            and Stoll Well #6-21,  Hillsdale County, Michigan
                             C-621

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Site Description

The Savarino and Stoll Lease site is located in rural flatland.
The climate at this site location is net precipitation.  The soil
is described as a red clay bed under loam.   The operator said
that a layer of "Marshal Sandstone" was reached at 385 feet
downhole.  The well was completed in the Glenwood section of the
Prairie du Chieh formation in the Michigan  basin.  The operator
also called this the "St. Peter Sandstone."   Figure 2 is a
survey of the exact location of the well.

This well was one of approximately 70 wells that were producing
in the Stoney Point field at the time of sampling.  The wells in
this field range in depth between 4,200 feet and 4,600 feet.

The depth to the groundwater in the area is between 70 and 80
feet.  The nearest surface water is Goose Lake, 4 miles east of
the site.  The nearest drinking water wells are associated with
nineteen residences within a 1-mile radius  of the site.

At the time of sampling, the site consisted of one reserve pit.
The drill rig and all associated equipment  had been removed from
the site.  The well head, located approximately 50 feet east of
the pit, is shown in Photo 4.  Figure 3 is  an approximate
schematic diagram of the site, indicating the directions in which
photos were taken (Attachment A).

This site was a developmental oil drilling  site.  The well was
completed at 4,360 feet.  Drilling began on July 10, 1986 and
total depth was reached on July 19, 1986.

Drilling was accomplished with a fresh-water mud, a polymer mud,
and finally a saltwater mud.  The following table summarizes the
products used during drilling:
  Depth (ft}
   0 -  385
Mud Type
Fresh-water
  385 - 3600   Polymer
 3600 - 4360   Saltwater
Constituents/quantity

8.3 Ib-fresh water/800 barrels
Montmorilonite (bentonite)/5,600 Ibs
Sodium carbonate/50 Ibs
Sodium hydroxide/100 Ibs
Shredded newspaper/100 Ibs

8.3 Ib-fresh water/800 barrels
Milo-gel (cornstarch)/700 Ibs
Salt-gel (atopulgite clay)/1000 Ibs
Quick Seal (cellophane and
  straw)/100 Ibs
Floxite (flocculent and wetting
  agent)/6 Ibs

400 barrels of polymer mud were
  replaced with 400 barrels of
  10.4 Ib-salt brine
                               C-622

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                   ^—
                   $8*11 H0catt0n
                     POWELL PRODUCTION, INCORPORATED

   Well Name and Number:  Savarino - Stoll, 6-21

   Location:  Southeast 1/4 of Northeast 1/4 of Southeast 1/4 of Section 21,
   Town 5 South, Range 2 West, Moscow Township, Hillsdale County, Michigan.
  ETAsr-UesT 14 bus SECTION ai^
                                              . * WORTH UUITLJUE
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        SOUTH la LmeSecnaa2( * SOOTH
11 Pruduction, Incorporated
East Chicago Road
sville, Michigan  49250
9, 1986
-62
                                                      . /• FARM-)
                                                      • w     *^
                                                                   111
                                                                   -2
                                                                  -J

                                                                   to

                                                                  ffi
                                       William A. Worth, L.L.S.  #19009
                      Figure 2.  Survey of Well  Site

                                  C-623

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O J
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Chlorine was added to the fresh water before it was mixed into
the mud system.

The operator stated that a "slight loss of drilling fluid"
occurred during drilling in the Niagara formation, between depths
of 2,350 and 2,850 feet.  The operator estimated that not more
than 150 barrels of fluid were lost over three days of drilling.

One lined pit was constructed onsite to provide temporary storage
of drill cuttings, residual drilling muds from the circulation
system, and miscellaneous trash.  The pit contents were piped
from the mud circulation system over the apron of the pit liner.
The pit was in use as of July 10, 1986, and was out of service as
of July 19, 1986.

Construction requirements of the pit included a 20-millimeter PVC
liner, clearly visible in Photo 2.  The sides of the pit were
required to have a three-to-one slope, and the depth could be no
less than 4 feet above the top of the groundwater in the area.
The operator used Everett Sparks Excavation in Jonesville, MI to
construct this pit.

The average depth of liquid in the pit was 2 feet, and the
average depth of the sludge was 1 foot.  The distance from ground
level to the surface of the liquid was approximately 5 feet.

During the drilling operation, diesel was stored onsite in tanks,
although the operator could not estimate the quantity used during
drilling.

Disposal Practices

The liquid in the pit was to be vacuumed into a truck and hauled
to "Dean Center's" saltwater disposal well in Jackson County, MI.

Solids would remain in the pit, to be encapsulated by turning the
apron of the PVC liner into the pit, covering the pile with a
second PVC liner, and backfilling the pit.  Prior to closing the
pit, a decision would be made whether to stabilize the solids
with kiln dust in order to make it a firmer mass.  This is done
to prevent the soil over the pit from sinking in the following
years.  The site would be restored to its original grade,
including adding fertilizer and top soil.

Permits

A copy of the drilling permit secured by Powell Production, Inc.
to drill the Savarino and Stoll Well No. 6-21 is located in
Attachment B.
                               C-625

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SAMPLING INFORMATION

Sampling efforts at this site followed the sampling procedures
and protocols for field sampling as outlined by the Sampling Plan
and Sampling Quality Assurance/Quality Control Plan in Appendix G
of the EPA Technical Report (EPA 530-SW-87-005).

Sample Point Locations

At the Savarino and Stoll Lease site,  the samples were defined as
the supernatant and solid contents of  the waste material in the
reserve pit.

The operator did not permit the sample team to enter the pit in a
boat.  Therefore, the sample points were obtained by standing on
the side of the pit and reaching in with the sample equipment, as
shown in Photos 5 and 6. There was some discrepancy between
actual and measured sample points due  to the inaccessibility of
the measured points.  Figure 3 indicates the measured sample
points as well as the actual sample points from which the pit
samples were composited.

Sampling Methods and Equipment

To collect samples from the reserve pit, the pit was measured to
identify the four quadrants shown in Figure 3, and to locate the
center of each quadrant.  The measured points were marked with
stakes to facilitate locating sample points.

The first sample to be collected was the liquid composite.  The
thief was used by threading the gaging tape through a pipe,
attaching the thief to the end of the  tape, and extending the
pipe over the surface of the liquid as far as the sampler could
safely reach.  One sampler lowered the thief into the liquid, and
a second sampler pulled the string allowing the sample to enter
the thief.  The liquid from each sample point was composited in a
5-gallon carboy.

The reserve pit was then sampled for sludge.  The dredge was used
to sample the sludge because the coring device could have
possibly punctured the lining of the pit.  Photo 5 shows samplers
tossing the dredge from the east side  of the pit.  Two full
dredges were obtained at each sample point, yielding a total
volume of approximately 4 gallons.  The solids were composited in
a 5-gallon steel bucket.

The liquid and sludge samples were tested for pH after sampling
was completed.  The pH was 7 for both  samples.  The liquid was
also tested for its free chlorine content.  The result of the
test was immeasurable because the liquid bubbled out of the test
cell.  The apparent chemical reaction  caused by this test was
reported to the receiving laboratories.
                               C-626

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ATTACHMENT A:  PHOTO DOCUMENTATION OF
         SAMPLING ACTIVITIES
                 C-627

-------
C-628

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I   Photo 1,  Southwesterly  view of  reserve pit
                                                                  Photo 2.   Southerly  view of reserve pit
                                                                                                         *^-&-.--.-v.-.^.»:... ••^sai&ii'
Photo 3.  Northerly  view of reserve pit
                                                                     Photo 4.  Well head  with  reserve pit In background

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C-630

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o
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to
   Photo  8.
Large -.pudd.e" at  southeast  corner of p,t
                                                      Photo  9.
                                                                Bags of unused drj,,|flg  ro(jd
                                 Photo  !0.   Unused  bag of -Magcog.l

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C-632

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ATTACHMENT B:  PERMITS
          C-633

-------
C-634

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                                                       DRILL  G  DEEPEN
                                                                                  REWORK  OR  C OPERATE  A  WELL
                          MAIL TO:
         MICHIGAN DEPARTMENT OF NATURAL RESQUflCES   U»
                 GEOLOGICAL SURVEY DIVISION
              BOX 30028.  *ANSING. MICHIGAN 48909

   NON-SUBMISSION AND/OR FALSIFICATION OF THIS INFORMATION
          MAY RESULT IN  FINES ANO/OR IMPRISONMENT
                                                                                 BY AUTHORITY OF:
                                                                 ACI Si  PA  1939. » amended
                                                                 On  4 G*s
                                                                 Brine Ouoosal
                                                                 Hyotoca'Oon  Storage
                                                                 Secondly Recovery
                                                                                           IB
                                                         ACI 31S  PA >9o9. as a«r«nOed
                                                         Disposal         SioiaM«
                                                         Brine
                                                         Test Welt Type
                                                                                                 Smg'e
                                                                                                                SUnkai
2 Application 10: (no fee requirea il permit is »ana)
   .  Deepen ~ Revise Application ^ Cancel and Transler
                                                  Convert 10
                                                                    Fee enclosed:
                                                                    i; No   £  Yes
                                         4  Qo  prior permits ••lit''
                                            X No  !1 Yt»  ". Drilled
      tacTi permit
  Surely Band-
   X Blannet
              Single Well
                                       6. Fed. Employer Iflem  No or Sac. Security No.
                                         38-2390443
                            Attacned
                               File
9. Bond NO.
  #4506292
                                             10.  Bond Amount.
                                             S50.000.00
   Applicant: (name eacn  owner  at tney  are oorxleO)
    Powell  Production,  Inc.
                                                                             .      _^
                                                                          RELE.VEP
   Address: (operatoToniy \l mere man one "owner")
    404  E.  Chicago  St., P.O.  Box  184
    Jpnesville,  Michigan   49250
                                                           Phone:
                                                           (517)  849- (aw lake
'3. Lease or we* name: (Oe aa anel aa posnoie>
    SavarinoLStoll
                                                           # 6-21
   Surla
  David  L.  Stoll  and  Edith Stoll
'5. Address:
  R.  R.  13   Loogootee,  Indiana   47553
                                                                                          LOCATE WELL AND  OUTLINE UNIT
                                                                                           ON SECTION PLAT  - s irOm . 3Mj»out control (Detail •outworn type. sit*, mm. rating, leaong. CMM
  See  attached Form R  7200-1-S1
   intended Total Oeptn
     4360'
                       29. Formation at Total Oeptn
                        Prairie du  Chien
      28.
       Trenton-Slack  River
                                                              27. Ooteowe Pool or FWM
                                                                Stoney Point
                               PROPOSED ORILUNQ,  CASINO. CEMENTING AND SEAUNO PROGRAM
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   $end correipondenc* ind permit to:     Address
   hn R.  Powell  404  E.  Chicago St., P.O.  BOX  184,  Jonesville, Michigan   49250   (517)  849-2727

/ Ptrmn
&\
.-.__ —
FOR CASHIER'S
FOR ONfl USE ONLY
Date issued
	 ^«rfk«.
USE ONLY. OO NOT WRITE

Numoer
^LV2± 	
IN THIS SPACE
30. Appfccxdon Pr*0"*^ 8yt (Pwit) Pftonti
Michael P. Nichols (517) 849-2727
"^Mtf?l?^7fcjffi£?
1 M* '700-1
                                                      —    C-635   	

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