MANAGEMENT OF WASTES FROM CRUDE
OIL AND NATURAL GAS
EXPLORATION, DEVELOPMENT,
AND PRODUCTION ON ALASKA'S
NORTH SLOPE

Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, D.C.

June, 1989

* * * DRAFT * * *

-------
TABLE 07 CONTENTS

Page

CHAPTER 1. INTRODUCTION 		1-1

1.1	PURPOSE AND SCOPE OF THIS SERIES

OF STUDIES 		1-3

1.2	DESCRIPTION OF THE OIL AND GAS

INDUSTRY 		1-5

1.2.1	Exploration and Development
Operations 		1-5

1.2.2	Production Operations 		1-7

1.2.3	North Slope Environment 		1-10

1.2.4	Operators on the North Slope ..	1-12

1.2.5	Waste Management on the

North Slope 		1-13

1.3	OUTLINE OF THIS REPORT		1-15

CHAPTER 2. ALASKA REGULATORY AND ENFORCEMENT

PROGRAMS 			2-1

2.1	ALASKA DEPARTMENT OF ENVIRONMENTAL
CONSERVATION 		2-1

2.1.1	Solid Waste Program				2-3

2.1.2	Water Quality Program		2-6

2.1.3	Hazardous Waste Program 		2-8

2.1.4	Other ADEC Programs 		2-10

2.1.5	ADEC Implementation		2-11

2.2	OTHER STATE AGENCIES 		2-20

2.2.1	Alaska Oil and Gas

Conservation Commission 		2-20

2.2.2	Alaska Department of

Natural Resources 		2-22

2.2.3	Alaska Department of Fish

and Game		2-22

* * * 6/89 DRAFT * * *

-------
ii

TABLE OF CONTENTS (continued)

Page

2.3	FEDERAL AGENCIES 		2-23

2.3.1	United States Army Corps

of Engineers 		2-23

2.3.2	United States Environmental
Protection Agency, Region X ...	2-24

2.4	ANALYTICAL FRAMEWORK FOR SITE

VISIT CASE STUDIES 		2-27

CHAPTER 3. SITE VISITS 		3-1

3.1	CLASSIFICATION OF OIL AND GAS
PRODUCTION-RELATED FACILITIES 		3-1

3.2	SELECTION AND OBSERVATION OF SITES ...	3-3

3.3	PRODUCTION AND OPERATION FACILITIES ..	3-8

3.3.1	Drillsites 		3-8

3.3.2	Crude Oil Topping Units		3-20

3.3.3	Gathering centers 		3-22

3.4	WASTE MANAGEMENT FACILITIES 		3-24

3.4.1	Used Drum Facilities 		3-24

3.4.2	Hazardous Waste Storage

Facilities 		3-29

3.4.3	Oily Waste Injection

Facilities 		3-30

3.4.4	Recycling Facilities 		3-35

3.4.5	Oily Waste Pits 		3-36

3.4.6	Abandoned or Closed Landfills

and Disposal Pits 		3-36

3.4.7	Landfill 		3-41

3.4.8	Municipal Incinerator 		3-49

3.5 SERVICE COMPANIES 		3-49

* * * 6/89 DRAFT * * *

-------
iii

TABLE OF CONTENTS (continued)

Sags

CHAPTER 4. TENTATIVE CONCLUSIONS 	 4-1

APPENDIX A MISCELLANEOUS SITE VISITS 	 A-l

APPENDIX B SUMMARY OP RECENT FACILITY INSPECTIONS .... B-l

REFERENCES 	 R-l

* * *

6/89 DRAFT * * *

-------
iv

TABLE OF EXHIBITS

Page

EXHIBIT 2-1: AGENCY RESPONSIBILITIES ON THE NORTH

SLOPE 	 2-2

EXHIBIT 2-2: ALASKA DEPARTMENT OF ENVIRONMENTAL

CONSERVATION, NORTH SLOPE OPERATIONS 	 2-13

EXHIBIT 3-1: NORTH SLOPE FACILITIES VISITED			 3-4

EXHIBIT 3-2: OVERVIEW OF NORTH SLOPE PRODUCTION

FACILITIES VISITED 	 3-9

EXHIBIT 3-3: OVERVIEW OF NORTH SLOPE WASTE

MANAGEMENT FACILITIES VISITED 	 3-25

EXHIBIT 3-4: OVERVIEW OF NORTH SLOPE SERVICE

COMPANIES VISITED 	 3-50

* * *

6/89 DRAFT * * *

-------
CHAPTER 1. INTRODUCTION

Under Section 3001(b)(2)(A) of the Resource Conservation
and Recovery Act (RCRA), Congress temporarily exempted
"drilling fluids, produced waters, and other wastes associated
with the exploration, development, or production of crude oil
or natural gasn from regulation as hazardous waste. Congress
also required the U.S. Environmental Protection Agency (EPA or
the Agency) to study these wastes and submit a report to
Congress evaluating the status of their management. (RCRA
Section 8002(m).) In December of 19S7, the Agency submitted to
Congress its report titled "Management of Wastes from the
Exploration, Development, and Production of Crude Oil, Natural
Gas, and Geothermal Energy."

After conducting public hearings on the Report to Congress
and analyzing the comments, EPA determined that regulation of
drilling fluids, produced waters, and other wastes associated
with the exploration, development, and production of crude oil
and natural gas as hazardous waste (i.e., under Subtitle c of
RCRA) was not warranted. (53 Federal Register 25446, July 6,
1988.) This determination was based on data that EPA gathered
and evaluated in the Report to Congress, including data on
three key factors pertaining to wastes from the exploration,
development, and production of oil and gas:

(1)	The characteristics, management practices, and
resulting impacts of these wastes on human
health and the environment;

(2)	The adequacy of existing State and Federal
regulatory programs? and

(3)	The economic impacts of any additional
regulatory controls on industry.

In considering the first factor. EPA found that a wide
variety of management practices are utilized for these wastes.
Oil and gas wastes originate in diverse ecologic settings and
contain a wide variety of toxic constituents and, as a result,
appropriate waste management practices vary throughout the
nation. EPA documented 62 damage cases resulting from the
management of these wastes and found that these damages were
often caused by violations of existing state and Federal
requirements.

With respect to the second factor. EPA found that existing
State and Federal regulations are generally adequate to control
the management of oil and gas wastes. This finding was based

1 RCRA Section 8002(m) required EPA to analyze these factors
in the Report to Congress.

* * * 6/89 DRAFT * * *

-------
1-2

on several types of analyses, including (1) an evaluation of
the regulatory requirements in the 13 major oil- and gas-
producing States, and (2) quantitative risk modeling, which
indicated that oil and gas wastes managed in accordance with
existing requirements rarely pose a threat to human health and
the environment. Although existing regulations are generally
adequate, EPA recognized that certain regulatory gaps do exist
and that enforcement of existing regulations is inadequate in
some States. For example, some states have insufficient
controls on the use of landfarming, roadspreading, pit
construction, and surface water discharge practices. Some
States lack sufficient controls for central disposal and
treatment facilities and for associated wastes. On the
Federal level, existing Federal standards under Subtitle D of
RCRA provide general environmental performance standards for
disposal of solid wastes, but these standards do not address
fully the specific concerns posed by oil and gas wastes. (53
Federal Register 25455.)

EPA's analysis of the third factor found that regulating
oil and gas wastes as hazardous wastes was impractical and
unnecessary to protect human health and the environment, in
addition, such regulation would cause a severe adverse economic
impact on the oil and gas industry; significantly reduce
domestic oil and gas production; severely strain the hazardous
waste treatment, storage, and disposal capacity in the short-
term; and substantially increase the permitting burden for
State and Federal hazardous waste programs.

While determining that regulation of oil and gas
exploration, development, and production wastes under RCRA
Subtitle C was not warranted, EPA did find that improvements in
existing State and Federal programs were warranted. To this
end, EPA adopted a three-pronged strategy to:

(1) Improve Federal programs under existing

authorities in Subtitle D of RCRA, the Clean
Water Act (CWA), and the Safe Drinking Water Act
(SDWA);

2	This evaluation focused mainly on the scope of program
requirements, rather than on the effectiveness of the requirements
as they are implemented and enforced in the field.

3	Associated wastes are those wastes other than produced
water, drilling muds and cutting, and rigwash that are intrinsic
to exploration, development, and production of crude oil and
natural gas. (53 Federal Register 25446.)

* * * 6/89 DRAFT * * *

-------
1-3

(2)	Work with States to encourage changes in their
regulations and enforcement to improve some
programs; and

(3)	Work with Congress to develop any additional
statutory authorities that may be required. (53
Federal Register 25447.)

1.1 PURPOSE AND SCOPS 07 THIS SERIES OF STUDIES

In executing this strategy, EPA is conducting a series of
studies of the field-level implementation of State programs
governing the solid waste (as defined by 40 CFR Part 261)
management practices associated with oil and gas exploration,
development, and production operations in several States. The
primary purpose of the studies is to evaluate the objectives,
level of implementation, and enforcement of State regulatory
programs. This effort initiates the first two prongs of EPA's
three-part strategy. The studies represent a first step in:

(1)	Determining the necessary scope of an EPA
regulatory program; and

(2)	Assisting States in improving their programs.

EPA will use the results of this.project to engage in
dialogue with the States regarding improvements that can be
made in State oil and gas waste management programs. For
example, EPA will direct the analysis and findings of this
effort to the Interstate Oil Compact Commission (IOCC), which
is an association of oil and gas producing states. EPA has
funded an IOCC panel to lead an effort, which will involve a
wide range of interest groups such as industry, environmental
groups, and state environmental and oil and gas commission
representatives, that will use the information gathered by EPA
to develop guidelines for State oil and gas waste management
regulations.

This report, and the others to follow, will also support
the development of RCRA Subtitle D guidelines applicable to
wastes from crude oil and natural gas exploration, development,
and production activities. The report will supplement
information gathered for the Report to Congress on current
industry practices and will assist in providing EPA with a
basis for identifying waste management practices that need
regulating. For example, the project will gather information
on fragile or sensitive environments, such as the North Slope
of Alaska, that can be used to craft specially tailored
standards as needed.

* * * 6/89 DRAFT * * *

-------
1-4

The studies will also facilitate a dialogue between EPA
and industry concerning voluntary improvements in industry
waste management practices. One forum for such dialogue will
be the IOCC effort funded by EPA.

Finally, the field-level evaluations of State programs
will gather data relevant to existing Federal programs. For
example, during the site visits conducted for each study, EPA
gathered data on the implementation of applicable Federal
regulatory programs. These observations have addressed not
only the implementation of the RCRA hazardous waste program4,
but also the SDWA injection control program and the CWA
National Pollutant Discharge Elimination System (NPDES)
program. Rather than ignoring non-RCRA information, EPA will
compile the facts and, where appropriate, take follow-up
actions.

This report on the North Slope of Alaska is one in the
series of planned Agency studies of State programs. The
series will cover a wide range of States and oil and gas
producing regions. The reports will use a case-study approach
to discover the strengths and weaknesses of State programs.

Each report will contain case studies of individual sites that
were visited by EPA personnel or its contractors. The case
studies and State program evaluations will be based on:

•	Site visit reports;

•	Reviews of State statutes, regulations,
policies, and permits and their implementation
and enforcement; and

•	Available facility histories, including readily
available knowledge about existing and past
waste management practices, results of prior
inspections, any enforcement actions, and
relevant correspondence between the regulatory
agency and the facility owner or operator.

These case studies will build on information collected for
the Report to Congress and Regulatory Determination to better
understand current oil and gas industry practices and to
identify and analyze gaps in existing State programs. As
identified in the Regulatory Determination, gaps in some States
include insufficient controls on use of landfarming,
roadspreading, pit construction, and surface water discharge
practices and insufficient regulations for central disposal and

4 Wastes from activities that are not intrinsic although
related to crude oil and natural gas exploration are not exempt
from regulation under Subtitle C.

* * * 6/89 DRAFT * * *

-------
1-5

treatment facilities and associated wastes. (53 Federal
Register 25446.)

1.2 DESCRIPTION OF THE OIL AND GAS INDUSTRY5

The oil and gas industry is as varied as it is large.

Some aspects of exploration, development, and production can
change markedly from region to region and State to state, well
depths range from as little as 30 to 50 feet to over 30,000
feet. Pennsylvania has been producing oil for 120 years;

Alaska for only about 20. Production from a single well can
vary from a high of 11,500 barrels per day (the 1985 average
for wells on the Alaska North Slope) to less than 10 barrels
per day for many thousands of "stripper" wells located around
the country.

This section provides background information on this
diverse industry. It focuses on the regulation and management
of wastes from exploration, development, and production
activities in the United States generally and on the North
Slope of Alaska specifically. It is organized in the following
order:

•	Exploration and development activities;

•	Production activities, including "downhole" and
surface operations;

•	National waste volume estimates;

•	North Slope environment;

•	Operators on the North Slope; and

•	Waste generation on the North Slope.

This background knowledge is essential for understanding
subsequent chapters that discuss specific types of facilities,
wastes, and waste management practices.

1.2.X Exploration and Development operations

Although geological and geophysical studies provide
information concerning potential accumulations of petroleum,
exploratory drilling is the only method of confirming the
presence of petroleum. The majority of exploratory wells are
"dry" and must be plugged and abandoned. When an exploratory

5 The discussion of the national oil and gas industry is
excerpted from the EPA Report to Congress, Volume 1, pp. Il-i to
11-16.

* * * fi/89 DRAPT * * *

-------
1-6

well does reveal a commercial deposit, many development wells
are typically needed to extract oil or gas from that reservoir.
Exploratory and development wells are mechanically similar and
generate similar wastes. To bring a field into production,
however, development wells generate wastes associated with well
completion and stimulation, as is discussed below.

Rotary drilling, the predominant method used today, safely
controls high-pressure oil/gas/water flows and allows
simultaneous drilling of the well and removal of cuttings,
making it possible to drill wells over 30,000 feet deep. Well
casing is periodically cemented into the hole, providing a
uniform and stable conduit for the drill stem as it drills
deeper into the hole. The casing also seals freshwater
aquifers, high-pressure zones, and other troublesome
formations.

Most rotary drilling operations employ a circulation
system using a water- or oil-based fluid which is called "mud"
because of its appearance. The mud is pumped down the hollow
drill pipe and across the face of the bit to lubricate and
remove cuttings. The mud and cuttings are then pumped back up
through the annular space between the drill pipe and the walls
of the hole or casing. Mud is generally mixed with a weighting
agent, such as barite, and other additives, that help it serve
several other important functions such as stabilizing the
wellbore, counterbalancing any high-pressure zones in the
formations being drilled, and alleviating problems downhole.

Cuttings are removed at the surface and deposited in a
"reserve pit," which is excavated or constructed next to the
drilling rig. The reclaimed drilling mud is often recirculated
back to the well. Drilling mud must be disposed when excess
mud is collected, when changing downhole conditions require an
entirely new mud formulation, or when the well is abandoned.
The reserve pit is generally used for this purpose. If the
well is a dry hole, the drilling mud may be disposed in the
well upon abandonment.

Potential oil and gas producing zones are commonly
measured and analyzed (or logged) during drilling, a process
that typically generates no waste. If hydrocarbons appear to
be present, a drill stem test can identify many of their
characteristics. When the test is completed, formation fluids
collected in the drill pipe must be disposed. If tests detect
commercial quantities of oil and gas, the well must be prepared
for production or "completed." "Cased hole" completions, the
most common type, are performed as follows:

• First, production casing is run into the hole
and cemented permanently in place.

* * * 6/89 DRAFT * * *

-------
1-7

•	Second, one or more strings of production tubing
are set in the hole; productive intervals are
isolated with packers; and surface equipment is
installed.

•	Finally a gun or explosive charge perforates the
production casing and petroleum begins to flow
into the well.

During these completion operations, drilling fluid in the
well may be modified or replaced by specialized fluids to
control the flow from the formation. A typical completion
fluid consists of a brine solution modified with petroleum
products, resins, polymers, and other chemical additives. When
the well is produced initially, the completion fluid may be
reclaimed or treated as a waste product that must be disposed.
For long-term corrosion protection, a packer fluid is placed in
the casing/tubing annulus.

Following well completion, oil or gas in the surrounding
formations frequently is not under sufficient pressure to flow
freely into the well. Operators use a variety of stimulation
techniques to correct this condition and increase oil flow,
including acidizing and hydraulic fracturing. Other
specialized fluids may be pumped down a production well to
enhance its yield. These can include corrosion inhibitors,
surfactants, friction reducers, complexing agents, and cleanup
additives. Although the formation may retain some of these
fluids, most are returned to the surface when the well is
initially produced or are slowly released over time. These
fluids may require disposal, independent of disposal associated
with produced water.

Service companies supply operators with the variety of
oil-field chemicals used in exploration and development
operations, as well as production operations. These firms
typically store the chemicals in 55-gallon drums at their own
facilities. Wastes generated by the use of these chemicals,
including empty drums,' drum rinsate, and other RCRA hazardous
and non-hazardous wastes, must be disposed.

1.2.2 Production Operations

Production operations generally include all activities
associated with the recovery of petroleum from geologic
formations. They can be divided into activities associated
with (1) downhole operations and (2) surface operations.

Downhole Operations involve primary, secondary, and
tertiary recovery and workovers.

* * * 6/89 DRAFT * * *

-------
1-8

•	Primary recovery refers to the initial
production of oil or gas from a reservoir by
using natural pressure or artificial lift
methods, such as surface or subsurface pumps and
gas lift. Most reservoirs are capable of
producing oil and gas by primary recovery
methods alone, but this ability declines over
the life of the well.

•	Eventually, virtually all wells employ some form
of secondary recovery, typically injecting gas
or liquid into the reservoir to maintain
pressure within the producing formation. The
most common secondary recovery method is
waterflooding, that is, injecting treated fresh
water, seawater, or produced water into the
formation through a separate well or wells.

•	Tertiary recovery refers to the recovery of the
last portion of the oil that can be economically
produced. Chemical, physical, and thermal
recovery methods are available and may be used
in combination. When oil eventually reaches a
production well, injected gases or fluids from
secondary and tertiary recovery operations may
be dissolved or carried in formation oil or
water, or simply mixed with them. Their removal
is discussed below in conjunction with surface
production operations.

•	workovers, another aspect of downhole production
operations, restore or increase production from
wells whose flows are inhibited by downhole
mechanical failures or blockages, such as sand
or paraffin deposits. Fluids circulated into
the well for this purpose are similar to
completion fluids, described earlier. When the
well is put back into production, the workover
fluid may be reclaimed or disposed.

Surface production operations generally include collecting
the produced fluids (oil, gas, gas liquids, and water) from a
well or group of wells at a gathering center, separating and
treating the produced fluids, disposing wastes from the
gathering center operations, and piping the petroleum and
natural gas to distribution facilities.

As producing reservoirs are depleted, their water/oil
ratios may increase steeply. New wells may produce little if
any water; some stripper wells may produce more than 100
barrels of water for every barrel of oil, particularly if the
wells are subject to waterflooding operations. Virtually all

* * * fi/89 DRAFT * * *

-------
1-9

of this water must be removed before the product can be
transferred to a pipeline. The oil may also contain completion
or workover fluids, stimulation fluids, or other chemicals
(e.g., biocides, fungicides).

Some oil/water mixtures may separate easily by gravity,
but others may exist as fine emulsions that do not separate
easily. Where settling is possible, it is done in tanks.

Where emulsions are difficult to break, heat is usually applied
in "heater treaters." Whichever method is used, crude oil
flows from the final separator to stock tanks. The sludges and
liquids that settle out of the oil as tank bottoms throughout
the separation process must be collected and discarded along
with the separated water.

The largest volume production waste, produced water,6
flows from separators into storage tanks. It is highly saline.
(Seawater is 35,000 ppm chlorides. Produced water can range
from 5,000 ppm to 180,000 ppm chlorides.) Most produced water
is injected down disposal wells or enhanced recovery wells.
Produced water is also discharged to tidal areas, surface
streams, and storage pits or used for agricultural or other
beneficial use. If produced water is injected down a disposal
well or an enhanced recovery well, it may be treated to remove
solids, which are also disposed.

Tank bottoms are periodically removed from production
vessels. Tank bottoms are usually hauled away from the
production site for disposal. Occasionally, if the bottoms
contain enough fluid, they are disposed with produced water.

Waste crude oil may also be generated at a production
site. If crude oil becomes contaminated with chemicals or is
skimmed from surface impoundments, it is usually reclaimed.

Soil and gravel contaminated by crude oil as a result of normal
field operations and occasional leaks and spills require

disposal.

Separating natural gas from crude oil, gas liquids,
entrained solids, and other impurities requires different
techniques than separating oil/water mixtures. These
separation processes are usually conducted in a gas processing
plant, but they can also occur in the field. Crude oil, gas
liquids, some free water, and entrained solids can be removed
in conventional separation vessels. Additional water may be
removed' by any of several dehydration processes, frequently
through using glycol, a liquid desiccant, or various solid
desiccants. Although these separation media can generally be

6 As defined by EPA, produced water is not a waste when used
for enhanced recovery.

* * * 6/89 DRAFT * * *

-------
1-10

regenerated and reused, they eventually lose their
effectiveness and must be disposed.

Both crude oil and natural gas may contain the highly
toxic gas hydrogen sulfide, which is an exempt waste. (Eight
hundred ppm in air is lethal to humans and represents an
occupational hazard, but not an ambient air toxics threat to
human health off-site.) At plants where hydrogen sulfide is
removed from natural gas, sulfur dioxide (S02) release results.
Hydrogen sulfide dissolved in crude oil does not pose any
danger, but when it is produced at the wellhead in gaseous
form, it poses serious occupational risks through possible
leaks or blowouts. These risks are also present later in the
production process when then hydrogen sulfide is separated out
in various "sweetening" processes.

1.2.3 North Slope Environment

Alaska's North Slope is 250 miles north of the Arctic
Circle and extends 600 miles along the northern coast of Alaska
from the Canadian border west to the Chukchi Sea. It is up to
200 miles wide and stretches from the Brook's Range north to
the edge of the continental shelf in the Arctic Ocean. The
North Slope is part of a thick sedimentary belt extending about
1,500 miles along the northern edge of North America, known as
the Arctic Coastal Plain. (The Petroleum Publishing Co. 1974.)
With an average precipitation of only 6 inches of snow per
year, the North Slope is technically a desert. (Cargo and
Mallory 1977.) The outstanding factors making the North Slope
region unique in the context of energy development are the
existence of extremely cold weather, the unusual pattern of
daylight, the presence of permafrost, and the remoteness of the
area.

The coastal plain of the North Slope is nearly flat and
featureless. Surface elevations rise gradually from 10 feet
near the coast to between 50 and 65 feet near the southern
boundary. The few natural forms that stand above the coastal
plain are small pingos 30 feet or less in height. (Polar
Research Board et al. 1982.)

The North Slope area is permanently frozen to a depth that
reaches to over 1,000 feet in some places. The upper few
meters of this sand and gravel sedimentary layer contain the
greatest quantities of ice. (Polar Research Board et al.
1982.) The active zone is that part of the permafrost that
thaws during the summer months.

7 Pingos are low hills or mounds forced up by hydrostatic
pressure in an area underlain by permafrost.

* * * 6/89 DRAFT * * *

-------
1-11

A two-season cycle dominates the climate of the North
Slope: A prolonged winter and a brief summer. Winter lasts
for about 9 months of the year, during which frigid
temperatures of about -20*C are common and little or no
sunlight rises above the horizon, summer lasts for two or
three months, during which temperatures average about 7*C and
sunlight is almost constant. (Polar Research Board et al. -
1982.) Breakup, the beginning of summer, commences in late May
or early June. During this period of the year, when melting
ice and snow cause large quantities of water to accumulate on
the surface of the frozen tundra, oil and gas waste management
practices on the North Slope are most critical. Melting snow
and ice can cause overflow of pits, and flowing water can cause
erosive damage. Any substance leaked into the surrounding
tundra can be spread by water over a large area.

Surface water is the primary source of water for life on
the North Slope. Human communities in this region also obtain
their water almost solely from surface water. (BLM 1978.)

During the summer months, much of the land area (25-30 percent
of the surface) is covered with surface water, in the form of
thaw lakes. (Polar Research Board et al. 1982.) Thaw lakes
are created by melting of the ground surface or ice wedges.

They are generally less than 7 feet deep and often freeze solid
by late winter, limiting fish to seasonal usage. (Alaska
Department of Fish and Game 1988.)

The permanently frozen soil, or permafrost, that covers
the North Slope region, is overlain by a fragile mat of
vegetation to form a treeless landscape known as tundra.

Mosses, lichens, wildflowers are among the types of vegetation
present, whose vegetative mat serves as a natural insulator for
the permafrost. Removal of the vegetative cover greatly
increases the depth of the active zone. (Sowers 1979.)

The native vegetation has proven to be sensitive to
industrial activity. Dust plumes that can be generated from
oil drilling operation, mining activities, and truck traffic
during the snow-free summer period affect the vegetation.

(Polar Research Board et al. 1982.) Thus, North Slope roads
are watered to control the dust. Roadsides, drilling pads, and
ground denuded by road construction and mining revegetate very
slowly in the Arctic. (Polar Research Board et al. 1982.)

In developing energy production and associated activities
on the North Slope, the unique and harsh environment has
demanded innovative engineering techniques. All drilling rigs
and production facilities where people work must be enclosed,
insulated, and heated. Structures such as buildings, roads,
and runways must be insulated from permafrost or else thawing
will occur and cause structural failure. (Sowers 1979.) As a
result, most facilities are built upon a gravel layer at least

* * * 6/89 DRAFT * * *

-------
1-12

five feet thick to help insulate the permafrost from the
activities above. For example,

•	Drilling and production operations are built on
gravel pads; (Petroleum Publishing Co. 1974.)

•	Many buildings have gravel floors;

•	An extensive gravel road network ties together
numerous gravel drill pads, storage areas, and
production facilities; (Polar Research Board et
al. 1982.)

•	Shallow offshore islands are sometimes built
with gravel and connected to shore with gravel
causeways; and

•	Reserve Pits and other land disposal facilities
are constructed with gravel.

The existence of permafrost creates the unique opportunity
to use "freezeback" as a means of closing waste pits or
landfills. Freezeback is a closure method whereby wastes are
left in place and covered with gravel, and the frigid
temperatures and proximity to permafrost freeze and thereby
contain the wastes. Freezeback is not appropriate in all
locations on the North Slope because the depth of the
permafrost is not uniform. For example, rivers and other local
conditions may increase the depth to the permafrost and prevent
wastes from remaining frozen year-round.

1.2.4 Operators on the North Slope

Standard and ARCO are the two major onshore oil and gas
production, drilling, and exploration operators on the North
Slope. However, Conoco operates the Milne Point field, and
Exxon and Chevron have drilled exploratory wells in the Prudhoe
Bay production area. In addition to onshore production,
several large operators have production facilities immediately
offshore from the Prudhoe Bay area. (This study does not
address offshore facilities.)

Dozens of independent service companies supply the entire
North Slope oil and gas industry, both onshore and offshore,
with a variety of oil field services. They supply oilfield
operators with chemicals including cleaning solvents, corrosion
inhibitors, antifreeze, emulsion breakers, surfactants, acids,
bases, biocides, and prescription formulations as well as
lubricants, drilling fluids, drilling muds, and completion and
workover fluids. Many of the service companies generate
unused, discarded product and spent chemicals, some of which

* * * 6/89 DRAFT * * *

-------
1-13

are subject to hazardous waste regulations under RCRA Subtitle
C.

1.2.5 Waste Management on the North slope

Subsurface Injection. The wastes produced in the greatest
volume on the North Slope are produced water, reserve pit
fluids, hydrostatic testing fluids, and excavation dewatering
fluids. Subsurface injection of produced water wastes is a
common form of disposal. Produced water, the largest volume of
waste (e.g., more than 924 million gallons in December 1987),
is primarily reinjected in a waterflood program for enhanced
recovery. Injection has occurred in both shallow non-
hydrocarbon bearing zones and deep hydrocarbon bearing geologic
zones. At the end of 1987, 355 enhanced recovery wells were
reinjecting produced water back into the hydrocarbon bearing
formations. Before the waterflood program started in 1981,
most produced water was disposed through dedicated shallow zone
injection wells. (ADEC 1988v.)

Shallow zone dedicated waste injection wells dispose
produced waters and various wastes from the large gathering
centers and oil/gas/water separation centers. Wastes are
injected into shallow zones through annular disposal (i.e.,
disposal through the annulus or space between the casing and
the tubing in a well) and through dedicated waste injection
wells, such as those at the Prudhoe Bay Unit Pad 3 injection
facility. Although the disposal depth has been as shallow as
1,000 feet, the typical onshore disposal depth is between 2,000
and 4,000 feet. In 1986, 116,000 gallons of liquid waste were
disposed through the annuli of 171 wells. In 1987, 74,400
gallons of waste were disposed through the annuli of 89 wells.
(ADEC 1988v.)

Surface Disposal. Until 1988, the Alaska Department of
Environmental Conservation (ADEC) allowed several methods of
surface disposal of wastes on the North Slope including:

•	Discharge of reserve pit fluids to the tundra.

Prior to the 1988 summer season, discharge to
the tundra under permit from ADEC was the most
common method of disposing reserve pit fluids.

During the 1986 season, a record volume of
64,568,520 gallons of reserve pit fluids were
discharged to the tundra. (ADEC 1988v.)

•	Discharge of reserve pit fluid bv road watering.

Until 1988, road watering was also a widespread
practice on the North Slope. ADEC first issued
a permit allowing on-road disposal of reserve
pit fluids in 1985. In 1987 and 1988, ADEC
issued permits that authorized the disposal of

* * * 6/89 DRAPT * * *

-------
1-14

36,924,594 gallons and 26,540,346 gallons,
respectively. During the 1988 summer season,

North Slope operators did not dispose of reserve
pit fluids through road watering. (ADEC 1988v.)

•	Disposal of hydrostatic testing fluids. ADEC
has allowed the discharge of water used as a
hydrostatic test fluid to the tundra and roads.
The largest discharge of hydrostatic testing
fluids during ADEC's years of record occurred in
1985 when ARCO and Conoco discharged 13,941,560
gallons. North Slope operators have recently
discontinued these discharges. (ADEC I988v.)

Currently. ADEC's policy is to not issue new permits for such
discharges, and North Slope operators with existing permits
have apparently discontinued such practices. (ADEC 1988v.)
However, on October 4, 1988, ARCO applied to EPA Region X for a
fieldwide NPDES permit for the Kuparuk field to resume disposal
of reserve pit fluids and hydrostatic test fluids through
roadwatering. (ARCO 1988i.)

other waste Management Facilities. As is discussed in
detail in Chapter 3, wastes generated on the North Slope are
also managed at a variety of other waste management facilities,
including the following:

•	Used drum facilities that store, rinse, and
crush empty drums?

•	Three interim status hazardous waste storage
facilities?

•	Recycling facilities that reclaim oily wastes,
such as lubricating oils, workover wastes,
pigging wastes, and diesel oil used in
hydrostatic testing?

•	A landfill operated by the North Slope Borough
that has:

An oily waste pit that disposes
various wastes from production
operators and service companies,
including oily solids from reserve
pits used in production operations?
and

A solid waste pit that disposes
domestic garbage, building materials,
used machinery, incinerator ash,

* * * 6/89 DRAFT * * *

-------
1-15

crushed drums, and a variety of
industrial wastes;

•	A municipal incinerator that accepts domestic
garbage and some industrial wastes (e.g.,
filters from a gatherihg center); and

•	Small waste oil burners, operated by some
service companies, that dispose oily, liquid
waste.

Also, North Slope operators have reported that they ship
limited quantities of hazardous waste to the lower 48 states
for treatment or disposal.

1.3 OUTLINE OF THIS RESORT

The remainder of this report is organized into three
chapters:

Chapter 2 provides an overview of the State and

Federal programs that regulate oil and gas
waste management activities on the North
Slope of Alaska;

Chapter 3 characterizes the oil and gas facilities

and waste management practices on the North
Slope and presents case studies of each of
the sites visited in preparing this report;
and

Chapter 4 draws tentative conclusions about the
effectiveness of Alaska's regulatory
programs as indicated by the case studies
of field-level performance.

In addition, an appendix presents supplementary information.

* * *

6/89 DRAPT * * *

-------
CHAPTER 2. ALASKA REGULATORY AMD ENFORCEMENT PROGRAMS

Several State and Federal agencies regulate the management
of wastes generated by oil and gas operations on the North
Slope of Alaska.1 (See Exhibit 2-1.) This chapter identifies
these agencies, describes their programs governing North Slope
facilities, and presents a framework for evaluating the state
regulatory programs based on their field-level effectiveness.
This chapter is organized as follows:

Section 2.1 describes the major responsibilities of
the Alaska Department of Environmental
Conservation (ADEC) for North Slope oil
and gas facilities; ADEC's solid waste,
water quality, hazardous waste, and
other regulatory programs; and its
inspection and enforcement resources and
procedures.

Section 2.2 identifies other relevant State agencies
and briefly summarizes their programs.

Section 2.3 identifies relevant Federal agencies and
briefly summarizes their programs.

Section 2.4 presents the framework for evaluating
State programs based on their
effectiveness at the facility.level.

2.1 ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION

ADEC is the State's primary pollution control agency. The
Department regulates waste management practices at all major
exploration, development, and production facilities on the
North Slope. ADEC has regulatory and permitting responsibility
for:

•	Solid waste disposal;

•	Water quality, including wastewater discharges
from oil and gas drilling and production
operations;

•	Hazardous waste transportation, storage,
treatment, and disposal; and

1 Although local agencies may regulate certain waste
management practices on the North Slope, this report does not
address these regulatory programs.

* * * 6/89 DRAFT * * *

-------
Exhibit 2-1
AGENCY EES POSSIBILITIES OK THE WXTU SLOPE

STATE

ALASKA DEPARTMENT OP EMTOOHMEMTAL COW SERVAT I OH

•	PrlMrjr enforcer of wast* uiM|ซMnt requireatents at oil
and |at facilities

•	Ratulatat solid wait* disposal facilities, wastewater
diachargea, air amleaions, hazardous waste, and surface
ollint

•	Permits and lnapecta aurface facilities associated with
Cleas II injection wella

ALASKA DEPARTMENT OP NATURAL RESOURCES

•	Iasuaa aurfaca and aubaurface oil and |a' leases on State
lands

•	Approves plans for oil and gaa operations on State lands

•	Inspects oil field operations and abandonoenta

ALASKA OIL AND GAS CONSERVATION COMMISSION

e Regulatea oil and gaa production, priauirlly to conaerve
reeerves

•	Regulates Class II injection wella

•	Perot ta production and injection wella

•	Regulatea plugging and abandouaent of wella

ALASKA DEPARTMENT OF FISH AND GAME

•	Haa Jurisdiction over the use of surface watere on the
North Slope as regards wildlife and aquatic management

•	Permits energy-related activltlea within apeclal arees

(e.g., critical fish habitat)	to

I

•	Typically refera problema with waate management	N)
facilities to ADEC

UNITED STATES ARMY CORPS OF ENGINEERS

•	Penite dredge or fill ectivitlea in navigable watere
(including wetlands), including building of roada, pada,
and cauaewaya on the North Slope

•	Authorizea dredge or fill ectivitlea that obstruct
navigable waters

U.S. EHV. PROTECTION AGENCY REGION X

•	Coordlnstes with ADEC to menege the NPDES program under
the Clea Water Act

•	Regulatea all injection wella other than Class II wells
on the North Slope

•	Regulates hazardoua waste under RCRA Subtitle C

-------
2-3

• Other environmental protection programs (e.g.,
air contaminant emissions, surface oiling, and
oil and hazardous substance releases).

These programs and ADEC's permitting, inspection, and
enforcement approach are described in more detail below.

2.1.1 Solid Waste Program

The Alaska Department of Environmental Conservation
regulates the transportation, storage, treatment, and disposal
of solid waste under the Environmental Conservation Law (AS
46.03) and the Solid Waste Management Regulations (18 AAC 60).
The regulations broadly define solid waste to include solid,
liquid, semi-solid, and contained gaseous wastes. Produced
water that is injected for enhanced recovery is not a waste
because it is beneficially recycled. Industrial discharges
subject to permits under Section 404 of the Clean Water Act
(see Section 2.3.1) are specifically exempted from regulation
as a solid waste.

Drilling wastes are a special category of solid wastes.
They are defined as

wastes associated with the exploration, development,
or production of crude oil, natural gas, or
geothermal energy, including drilling muds, cuttings,
hydrocarbons, brine, acid, sand, and emulsions or
mixtures of fluids produced from and unique to the
operation or maintenance of a well, whether naturally
occurring or added for the operation or productivity
of the well; 'drilling wastes' includes only wastes
described in this paragraph which are derived
intrinsically from primary field operations, produced
from a well, and removed at the drill site or removed
at a crude oil production facility by crude oil or
wastewater treatment process before custody transfer
of the crude oil. (18 AAC 910(19).)

Drilling wastes are further defined to exclude spent solvents
and oils from equipment maintenance activities, discarded
chemical products, or fuels; these wastes may be regulated as
hazardous wastes. (Solid wastes that are regulated as
hazardous waste under RCRA Subtitle C are subject to the rules
described in Section 2.1.3.)

2 Produced waters on the North Slope contain approximately
20,000 mg/1 total dissolved solids (TDS), approximately 20 mg/i
suspended solids, and 20-250 mg/1 hydrocarbons. Produced water
also may contain varying amounts of volatile organic compounds,
such as benzene, toluene, and xylene.

* * * 6/89 DRAPT * • *

-------
2-4

The solid waste regulations apply to owners and operators
of solid waste disposal facilities, which include reserve pits,
pigging pits, oily waste injection facilities, landfills, and
oily waste pits. A facility owner or operator must obtain a
permit to dispose of solid waste or to construct, modify, or
operate the facility. The permit application must include,
among other items, a detailed site map; a description of the
types, estimated quantities, and sources of wastes to be
disposed; an evaluation of leachate potential; a monitoring
plan; and a closure plan. A disposal facility with a
containment structure located in permafrost must meet, among
various requirements, the following general performance
standard: "ensure that the wastes do not cause thawing of the
permafrost, and if containment is accomplished by freezeback,
ensure that the wastes do not thaw after closure." (18 AAC
60.410(d)(4).)

In 1987, ADEC promulgated additional solid waste
regulations that apply specifically to reserve pits and other
facilities that dispose drilling wastes. (18 AAC 60, Article
5.) These regulations distinguish between existing and new
facilities. Owners and operators of existing facilities that
continue to dispose drilling wastes are subject to several
requirements, including:

•	Submitting an application to ADEC within 180
days after September 20, 1987 that includes a
site plan, a fluid management plan, a monitoring
plan, and an anticipated date of closure;

•	Taking corrective action to correct damage,
prevent release, and cleanup improper disposal
when the need is indicated by visual monitoring
or ADEC inspection;

•	Responding to changes in water quality near the
facility; and

•	Submitting a closure plan one year before
closure.

Owners and operators of new facilities that dispose of
drilling fluids are subject to more stringent regulations,
which, if enforced, promise to improve waste management
practices on the North Slope. These requirements include the
following:

3 New facilities are those for which construction began on or
after September 20, 1987.

* * * 6/89 DRAFT * * *

-------
2-5

Liner Requirements

•	A single or double liner.

Containment Standards

•	Freezeback with no free liquid hydrocarbons if
the facility does not use an optional fluid
management plan;4

•	A barrier berm (i.e., an above-ground
containment structure) if the facility does not
have a fluid management plan and if no drinking
water source or population center exists within
1,000 feet; or

•	A reinforced barrier berm (i.e., a barrier berm
with a liner) if the facility has a fluid
management plan and if a drinking water source
or population center exists within 1,000 feet.

Monitoring Standards

•	Site inspection;

•	Surface water or active thaw monitoring; and

•	Thermistors if freezeback is employed.

Under these new rules, ADEC pi ems to authorize the
disposal of oil-based drilling muds in new reserve pits.

ADEC's current policy is to not allow the disposal of these
wastes in existing, unlined reserved pits. Neither the general
solid waste disposal regulations nor the special regulations
for drilling wastes require the facility owner or operator or
the waste generator to test the wastes prior to disposal.

In addition to disposal facilities, these new drilling
waste regulations require a person who intends to store
drilling wastes during a drilling operation to submit a plan
(rather than a solid waste disposal permit application) to ADEC
that:

4 A fluid management plan is defined to mean the "use of snow
removal or any dewatering practice to keep to a minimum the
hydrostatic head of fluids and drilling wastes in a containment
structure, and includes approved disposal of liquid wastes in an
injection well or by other approved discharges to the land and
water of the State." (18 AAC 60.910(24).)

* * * 6/89 DRAPT * * *

-------
2-6

•	Describes the storage container and the methods
used to prevent any discharges;

•	Certifies that the wastes will be removed from
the site within one year; and

•	Specifies the location of ultimate disposal.

2.1.2 Water Quality Program

ADEC regulates water quality under the Environmental
Conservation Law through two sets of regulations, the Alaska
Water Quality Standards (18 AAC 70) and the Wastewater Disposal
Regulations (18 AAC 72). The statute authorizes ADEC to
prevent and abate the pollution of the waters of the State and
empowers ADEC to meet this goal, among other means, by
developing a comprehensive plan for water pollution control
adopting water quality and purity standards, and issuing waste
disposal permits. ADEC water quality regulations establish
water quality criteria for different water uses. These
regulations also prohibit persons from discharging any waste or
substance into waters of the state without treating and
controlling the discharge to ensure that the quality of the
receiving water meets the water quality standards. To prevent
the violation of these water quality standards, the State solid
waste regulations require a disposal facility owner or operator
to take corrective action when a change in water quality is
detected at the facility boundary or within 50 feet of the
designated portion of the facility.

ADEC requires persons discharging wastewaters from oil and
gas production into waters or onto land of the State to have a
permit. ADEC may specify in a permit the terms and conditions
under which waste material may be disposed, including
operating, monitoring, inspection, sampling, access to records
reporting, and bonding requirements. Prior to 1988, ADEC '
issued permits for discharge of reserve pit effluent to the
tundra and to roadways for dust control, in addition, until
recently ADEC has allowed the discharge of water used as
hydrostatic testing fluid to the tundra and roads.

Discharge of Reserve Pits to the Tundra. Prior to the
1988 summer season, discharge to the tundra under an ADEC
permit was the most common method of disposal of reserve pit
fluids. According to ADEC, general permits for reserve pit
dewatering require characterization of pit fluids and establish

5 If EPA issues a National Pollutant Discharge Elimination
System (NPDES) permit that ADEC has certified, ADEC may waive its
permitting requirements.

* * * 6/89 DRAFT * * *

-------
2-7

effluent limitations and monitoring and reporting requirements.
Effluent limitations include the following:

Constituent	Effluent Limitation

COD	200 mg/1

salinity	3 ppt

settle-able solids	0.2 mg/1

oil and grease	15 mg/1

total aromatic hydrocarbons	10 mg/1

pH	6.5 to 8.5

ADEC has compiled a list of approximately 25 reserve pits
referred to as the "Problem Pit List." ADEC has documented
spillage, leaking, breaching, or overtopping at these problem
pits. Currently, North Slope operators have ceased all
dewatering of the reserve pits onto the tundra and efforts have
begun to line leaking reserve pits, repair breached berms
around reserve pits, and close out several of the problem Dits
(ADEC, 1987e.)	" '

Discharges to the tundra and to roadways on the North
Slope have recently ceased. While ADEC is apparently not
presently granting permits for these discharges, the present
regulations authorize ADEC to issue them in the future. Also
because permits are issued for a term of up to five years, some
existing permits may still allow these discharges.

Discharge of Reserve Pit Fluids to Road*. Road watering
to suppress dust is a widespread practice at North Slope oil
production facilities. Road watering with freshwater is a
sound means of suppressing dust, which, as noted earlier, is
harmful to tundra vegetation. Water from local rivers, lakes
or flooded mine sites is used for road watering. Until 1988 '
reserve pit fluids were also discharged under ADEC permits onto
roads for the same purpose. According to ADEC, the fate of
contaminants in the reserve pit fluids after they are applied
to roadbeds is not known at thxs txme. Some possible fates of
pollutants include attenuation in the roadbed, washing or
leaching from the roadbed to the surrounding environment or
escape in road dust to the environment. ADEC issued permits
allowing on-road disposal from 1985 to 1987. During the 1988
summer season, North Slope operators did not dispose of reserve

6 Parts per thousand.

* * * 6/89 DRAFT * * *

-------
2-8

pit fluids through road watering. (ADEC 1988v.) However, in
October 1988 ARCO applied to EPA Region X for an NPDES permit
to dispose reserve pit fluids through road watering in the
Kuparuk Field.

Disposal Of Hydrostatic Testing Fluids. Several types of
fluids are used in hydrostatic testing of pipelines and
vessels, including freshwater, saltwater, methanol, glycols,
and diesel. ADEC has allowed the discharge of water used as a
test fluid to the tundra and roads. The largest volume of
hydrostatic testing fluids discharged during ADEC's years of
record occurred during 1985 when ARCO and Conoco discharged
13,941,560 gallons. North Slope operators have recently
discontinued these discharges. (ADEC 1988v.) However, ARCO's
aforementioned NPDES permit application requests authorization
to resume these discharges through road watering. (ARCO
1988i.)

2.1.3 Hazardous Waste Program

The Alaska Department of Environmental Conservation
regulates hazardous waste under the Environmental Conservation
Law and the Hazardous Waste Management Regulations (18 AAC 62).
The statute directs the Department to take all actions
necessary to obtain EPA authorization to administer the State
program in lieu of the Federal program. Although the
Department has adopted hazardous waste regulations that
incorporate by reference EPA hazardous waste regulations
codified as of July, 1986, the State has not received program
authorization from EPA. As a result, EPA, Region X also
regulates hazardous waste in Alaska under Subtitle C of the
Federal Resource Conservation and Recovery Act.

Because the Alaska rules incorporate the Federal males,
the two programs have similar requirements. Neither program
regulates "drilling fluids, produced waters, and other wastes
associated with the exploration, development, or production of
crude oil or natural gas."7 However, as stated by EPA in the
Regulatory Determination of July 6, 1988, the following types
of wastes are not included in the exemption and therefore are
subject to hazardous waste regulations as listed or
"characteristic wastes (53 Federal Register 25454):

7 AS 46 03.299(b) exempted from hazardous waste regulation
the wastes associated with the exploration, development, or
production of crude oil and natural gas until EPA's Report to
Conaress under RCRA Section 8002 (m) is completed. Since the Report
hM been completed, the Department has the authority to terminate
ซ amend the exemption after considering the findings of the
Report.

k * * 6/89 DRAFT * * *

-------
2-9

•	Unused fracturing fluids or acids;

•	Gas plant cooling tower cleaning wastes;

•	Painting wastes;

•	Oil and gas service company wastes, such as
empty drums, drum rinsate, vacuum truck rinsate,
sandblast media, painting wastes, spent
solvents, spilled chemicals, and waste acids;

•	Vacuum truck and drum rinsate from trucks and
drums transporting or containing non-exempt
waste;

•	Refinery wastes;

•	Liquid and solid wastes generated by crude oil
and tank bottom reclaimers;

•	Used equipment lubrication oils;

•	Waste compressor oil, filters, and blowdown;

•	Used hydraulic fluids;

•	Waste solvents;

•	Waste in transportation pipeline-related pits;

•	Caustic or acid cleaners;

•	Boiler cleaning wastes;

•	Boiler refractory bricks;

•	Boiler scrubber fluids, sludges, and ash;

•	Incinerator ash;

•	Laboratory wastes;

•	Sanitary wastes;

•	pesticide wastes;

•	Radioactive tracer wastes; and

•	Drums, insulation, and miscellaneous solids.

Both programs establish technical and permitting standards for
hazardous waste treatment, storage, and disposal facilities.

* * * 6/89 DRAFT * * *

-------
2-10

Both programs also regulate, but do not permit, generators and
transporters of hazardous waste. The major difference between
the two sets of regulations is that the Alaska rules do not
include Federal regulations promulgated since July l, 1986.

2.1.4 Other ADEC Programs

Air Contaminant Emissions

ADEC regulates air quality under the Environmental
Conservation Law and the Air Quality Control Regulations (18
AAC 50). The statute authorizes the Department to establish
air pollution control regulations necessary to prevent, abate
or control air pollution, and to require permits for	'

construction, installation, or modification of new air
contamination sources. Local governments may establish ADEC-
approved air emissions control programs. The ADEC Air Quality
Control Regulations establish ambient air quality standards
air emission limitations, monitoring requirements, and permit
procedures. The regulations do not establish any specific
standards for oil and gas extraction operations, but rather
employ a "blanket standard" for most industrial processes and
fuel burning equipment. According to ADEC, no State or Federal
air quality regulations apply to waste oil burners with a
rating of less than 1 million BTU/hour; the service company
incinerators and waste oil burners on the North Slope are rated
below this level.

Surface oiling

ADEC regulates surface oiling under the Alaska oil and
Hazardous Substance Releases Law (AS 46.08} and the Alaska oil
and Hazardous Substances Pollution Control Regulations (18 AAC
75). The regulations prohibit any person from discharging oil
or other petroleum residues onto the lands of the state without
a surface oiling permit. In reviewing a permit application,
ADEC considers the potential effects on adjacent water and
vegetation, the actual need for oiling, the weather conditions
at the time of oiling, and the effects on the environment.

ADEC uses its discretion to require analysis of the oil for
polychlorinated biphenyls (PCBs), total volatile aromatics
total halogenated volatile organics, and lead. In the past,
wastewaters from reserve pits that contain oil were used for
oiling? however, this activity has been stopped. No road
oiling has occurred since 1987, and ADEC, as a policy matter
no longer issues such permits on the North Slope. {ADEC '
1988V.)

Oil Soills and Hazardous Substance Release

ADEC is responsible for ensuring that oil spills to the
water or lands of the State are properly reported and cleaned

* * * 6/89 DRAFT • * *

-------
2-11

up, as mandated by the tinder the Alaska oil Pollution Control
Lav (AS 46.04), the Alaska Oil and Hazardous Substance Releases
Law (AS 46.09), and the Alaska Oil and Hazardous Substances
Pollution Control Regulations (18 AAC 75). The regulations
require the person in charge or the operator of a facility that
discharges oil or other hazardous substances to the water or
land of Alaska to report the spill to the central office or the
appropriate regional office of ADEC. The person responsible
for a discharge of a hazardous substance other than oil must
notify ADEC as soon as he or she has knowledge of the
discharge. The person responsible for a discharge of oil must
notify ADEC within seven days of knowledge of the discharge or
within a shorter time period if the discharge meets specified
criteria (e.g., spill volume, size of sheen or surface water,
and sludge deposited beneath the surface of the water).

Under Alaska statutes:

•	"A person who causes a release of a hazardous
substance shall make reasonable efforts to
contain and clean up the hazardous substance
promptly after.learning of the release."

(AS 46.09.020.)

•	Similarly, "[a] person who is causing or
permitting the discharge of oil shall
immediately contain and clean up the discharge."
(AS 46.04.010.) (Further research is needed to
determine how the courts interpret these
provisions. For example, it is uncertain
whether a person that purchased contaminated
property could be held liable for continuing
hazardous substance releases on the property.

Under the Federal Comprehensive Environmental
Response, Compensation, and Liability Act, the
new owner could be liable for the cleanup.)

If a responsible person fails to undertake adequate
containment or cleanup activities, ADEC may undertake such
activities and recover its costs. The State may aiso seek to
impose civil and criminal penalties for the pollution and
liability for restoration costs. Finally, "a person owning or
having control over a hazardous substance which enters in or
upon the water, surface or subsurface lands of the state is
strictly liable, without regard to fault, for the damages to
persons or property, public or private, caused by the entry."
(AS 46.03.822.)

2.1.5 ADEC Implementation

This section briefly describes how ADEC implements its
statutory and regulatory authority. Four topics are addressed:

* * * fi/89 DRAFT * * *

-------
2-12

(1)	ADEC's organizational structure and resources as
they relate to the North Slope;

(2)	The permitting process for the regulatory
programs described above?

(3)	ADEC's procedures for targetting, conducting,
and following up inspections; and

(4)	The State's enforcement procedures and
authority.

Organization and Resources

The Alaska Department of Environmental Conservation is
comprised of four divisions. (See Exhibit 2-2.) The largest
division, with approximately 145 personnel, is the Division of
Environmental Quality; the other three, with a combined total
of approximately 108 personnel, are the Division of
Environmental Health, the Division of Facility Construction and
Operation, and the Division of Administrative Services.

The Division of Environmental Quality is responsible for
applying solid waste, hazardous waste, air, water, and other
environmental regulations mandated by the Environmental
Conservation Law and several other statutes. The Division has
three central program offices (i.e., Air, Water, and
Monitoring) and three regional offices. Only one other
division, the Division of Environmental Health, has regional
offices. These offices are, however, relatively small compared
to the regional offices of the Division of Environmental
Quality, which combined have approximately 70 personnel.8

The Northern Regional Office is split into three groups
the Placer Mining Office, the Program Management Office, and'
the District Management Office, which performs the field
duties. The Program Management office is divided into
functional groups, two of which are Hazardous Waste and Solid
Waste groups, each staffed by one person. The District
Management office is divided into four districts, including The
North Slope District, which, in 1986, was staffed with four
field positions and one staff person. (These estimates agree
with numbers reported by ADEC in August, 1987, indicating that
the North Slope District had four field personnel supported by
two program officials concerned with hazardous and solid
waste.)

8 All estimates for numbers of personnel are based on
organizational charts approved by ADEC in October, 1986.

* * * 6/89 DRAFT * * *

-------
2-13

Exhibit 2-2

ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION,
NORTH SLOPE OPERATIONS

Commissioner

Administrative
Services

Environmental
Health

Environmental
Quality

Facility Construction i
and Operation

Program Offlcea
(Air, Water, and
Monitoring)

South Central and

-j South Eastern ,
I Region Offlcea

Northern Region	j

Environmental Cons. Manager j

Clerical Staff
2 Personnel

(Source: ADEC Organizational Charts Revised and Approved
October, 1986)

* * * 6/89 DRAFT * * *

-------
2-14

The North Slope District's field staff has many
responsibilities.9 Their primary responsibilities regarding
oil and gas production facilities are to:

•	Review plans and permit applications for oil and
gas exploration, production, and transport
operations;

•	Conduct field monitoring to locate, identify,
analyze, and report sources of pollution;

•	Investigate violations, including sampling
polluted media, compiling legal materials,
interfacing with the regulated community, and
possibly meeting with State attorneys for
further enforcement; and

•	Provide technical assistance and represent
ADEC's interests to citizens, municipalities,
industry, and other agencies, meeting
approximately monthly with village leaders,
private citizens, the Alaska Department of
Transportation, and USEPA; weekly with members
of ADNR, ADFG, and the North Slope Borough; and
daily with members of the oil and oil field
service industry.

These officials, however, do not concentrate solely on oil
and gas operations. In cooperation with other government
officials, they may review plans and permits for the
exploration and extraction of minerals, the construction of
highways, military installations, and public utilities, and the
commencement of commercial hunting and fishing. They also
inspect these activities and investigate potential problems.
These field staff necessarily must be familiar with solid
waste, water quality, wastewater discharge, hazardous waste,
air, and other regulations. As an additional constraint,
because these North Slope District staff are headquartered in
Fairbanks, they must spend considerable time traveling between
the region headquarters and the Deadhorse office. (As is
discussed in Chapter 4, EPA believes that ADEC needs additional
staff to have a sufficient regulatory and enforcement program
on the North Slope.)

Details concerning the duties of the North Slope field
positions are taken from Personnel Description Questionnaires
completed by ADEC personnel in 1984.

* * * 6/89 DRAFT * * *

-------
2-15

Permitting Process

As indicated above, ADEC programs are implemented through
a permitting process. The Alaska Environmental Conservation
Law and subsequent regulations are sometimes broad and
nonspecific. The strength of the regulatory program,
therefore, may depend largely on the site-specific terms and
conditions of permit for diverse facilities and related
implementation activities. The importance of the permits makes
the role of ADEC field staff and other personnel who evaluate
applications and write, permits crucial elements in the
regulatory program.

ADEC issues a wide range of permits on the North Slope.
As described in Sections 2.1.1-2.1.4 of this report, ADEC
issues permits for many types of solid waste disposal
facilities: wastewater discharges including disposal in
injection wells (see also Section 2.2.1), discharges to the
tundra, and discharge by road spreading; air contaminant
emissions; and surface oiling.

Permit applications for solid waste disposal, wastewater
disposal, or construction or modification of a treatment
facility on the North Slope must be sent to ADEC's Northern
Regional Office or the Headquarters Office at least 60 days
prior to commencement of discharge operations or construction
or modification of a treatment works. Applications for air
contaminant emissions must be sent to either the regional or
central office at least 30 days prior to commencement of
regulated activities. Although ADEC is currently not issuing
these permits, a permit application for surface oiling on the
North Slope must be sent directly to the Northern Regional
Office at least five days prior to commencement of the
discharge operation. An application for renewal of an ADEC
permit must be filed at least 30 days before the expiration of
the current permit.

A permit application must be submitted on forms prescribed
by either ADEC or EPA and, among other requirements, must
identify the quantity and type of waste material to be disposed
and the proposed method of disposal or discharge. During the
application review period, ADEC may conduct a site visit or
otherwise gather additional information. Additional
information may be submitted by the commissioners of Fish and
Game and the Departments of Natural Resources, Commerce and
Economic Development, and Health and Social Services, all to
whom ADEC must send application copies. ADEC may deny or
approve a permit when approving a permit. ADEC has the
discretion, based on the available information and any other
agency's comments, to attach specific terms and conditions
directed at avoiding pollution or implementing other policies.

* * * 6/89 DRAPT * * *

-------
2-16

Persons seeking multiple permits for the start of a
project from several State and Federal agencies may follow a
procedure designed to simplify the permitting process. This
procedure, found in The Environmental Procedure Coordination
Law (AS 46.35), allows the applicant to submit a master
application to ADEC requesting all necessary permits. ADEC
will forward copies of the application to all necessary local,
State, or Federal agencies, who may decide whether they will
require a permit for the operation, and who, in the case of an
affirmative response, must send ADEC a copy of their permit
application form. ADEC will send a package containing all the
interested agencies' forms to the applicant; the applicant must
return the completed applications to ADEC; and ADEC will send
the forms to the respective agencies.

Permits are valid for a fixed term not to exceed 5 years,
after which a permit must be renewed. Older permits often will
have less stringent requirements than new permits for the same
type of facility because some new, more stringent regulations
are not imposed retroactively. Updating these permits to
include recent regulatory changes is generally possible only
through the permit renewal process.

Inspections

One of the key responsibilities of ADEC field staff is to
inspect oil and gas extraction operations on the North Slope.
The North Slope District of ADEC apparently allocates
inspection resources by using an informal targeting procedure
that relies on the following types of information:

•	Referrals from other agencies, when other
agencies, such as the Alaska Departments of
Natural Resources or Fish and Game, observe
potential violations during inspections of
extraction operations, permit reviews, or
related studies they often notify ADEC. When
ADEC is notified of a problem on the North
Slope, its field staff will generally make an
inspection while working out of the Deadhorse
office.

•	site history. ADEC inspectors may decide to
visit a site based on prior knowledge of
problems or a perceived potential for problems
at a facility. These inspections may be follow-
up inspections to confirm that violations have
been remedied or may be routine inspections at
facilities that have a high potential for
serious violations (e.g., at the previous
inspection the reserve pits were full).

* * * 6/89 DRAFT * * *

-------
2-17

*	Permit applicatiqr)^. Inspections may be made in
response to permit applications by industry
(e.g., for wastewater discharge or construction
or modification of waste management facilities).
Although these inspections are intended to focus
on the facilities and/or activities to be
permitted, field staff often take these
opportunities to inspect entire facilities.

*	Atrial r3
-------
2-18

If an ADEC inspector discovers a violation, the inspector
usually notifies the owner or operator informally as soon as
possible. Upon return from the inspection, the inspector will
send the owner or operator both an inspection form that relates
the findings of the inspection and a letter that informs the
party of a notice of violation (NOV). Based on a review of
about 10 notices issued for the North Slope facilities visited
by EPA in preparing this report, these documents generally:

•	Describe the violation;

•	Request reports from the responsible party
stating how the problem will be corrected; and

•	identify potential penalties.

Typically the owner or operator will respond with a letter
notifying ADEC what action will be taken. If ADEC determines
that the proposed response is insufficient, the parties will
discuss the situation until an agreement is reached (or ADEC
begins enforcement proceedings). The owner or operator will
then remedy the violation. ADEC may undertake a follow-up
inspection to ensure that all approved actions have been taken.

ADEC staff are also responsible for inspecting hazardous
waste generators and treatment, storage, and disposal
facilities on the North Slope. ADEC commitments related to
inspection of these facilities are established in a Memorandum
of Understanding (MOU) with EPA. An MOU is developed each year
with EPA Region X based on the RCRA Implementation Plan and
Operating Year Guidance (RIP). Recent inspections by ADEC and
EPA of facilities discussed in Chapter 3 are summarized in
Appendix B. If inspections reveal violations, ADEC issues
NOVs. EPA Region X is responsible for enforcement actions that
require issuance of orders.

Enforcement

When violations of statutes, regulations, or permit
conditions are identified, ADEC may take formal enforcement
action under the following three-step process specified in the
Environmental Conservation Law (AS 46.03) and ADEC regulations
(18 AAC 95).

(1) Wotice of intent to issue a compliance order.

If the initial enforcement activities are
unsuccessful in obtaining compliance, ADEC can
issue a notice of intent to issue a compliance
order, signed by the Deputy Commissioner of
ADEC, that:

* * * 6/89 DRAFT * * *

-------
2-19

Describes the conduct causing the
violation and the basis for such
determination;

Identifies the statute, regulation,
order, or permit that was violated;

Requests the responsible party to
prepare a detailed report specifying
the corrective measures that have been
or will be taken; and

Describes the potential subsequent
enforcement procedures and
noncompliance penalties.

(2)	Compliance order. After reviewing the report
from the responsible party, if submitted, and
reviewing the case record, the Deputy
Commissioner may issue a compliance order. The
responsible party has a right to a hearing on
this order.

(3)	Attorney General enforcement of a compliance
order. The State Attorney General is
responsible for enforcing compliance orders in
court. The Attorney General has discretion
about whether, how, and when to proceed with
these cases.

Significant ADEC personnel time and resources are required
to write notices and orders and prepare cases for the State
attorneys. Although ADEC can forward these cases to the
State's Attorney General for resolution in court, the Attorney
General reportedly has pursued only one instance of
noncompliance through the courts, in the case involving North
Slope Salvage, Inc. which is described in Section 3.5.

Persons who violate State statutes, regulations, permits,
orders, etc. may be subject to civil and criminal penalties and

The 10 notices of violation that were reviewed for this
report appear to contain most, but not all of the regulatorv
requirements for a notice of intent to file a compliance order
established by 18 AAC 95.010. For example, the NOVs lacked a
statement of intent to file a compliance order or a description of
the compliance order procedures. Thus, to be able to issue
enforcement order, ADEC apparently must file a separate notice of
intent subsequent to a standard notice of violation.

* * * 6/89 DRAFT * * *

-------
2-20

injunctions. For example, the State may impose civil
penalties in the amount of up to $100,000 for an initial
violation and $5,000/day or, for violation of radiation or
hazardous waste requirements, $10,000/day for each day of
violation. Generally, the courts may award civil damages for
compensatory and remedial purposes only and not for punitive
purposes, except to deter future noncompliance. (AS
40.03.760.) Finally, the Department may order immediate
actions to halt activities that pose imminent or present danger
or would result in irreversible or irreparable damage to the
natural resources or the environment. (AS 46.03.820.)

2.2 OTHER STATS AGENCIES

Although ADEC is the State's primary pollution control
agency, several other State agencies also regulate wastes
generated from oil and gas exploration, development, and
production on the North Slope. This section describes the
responsibilities of these agencies:

•	Alaska Oil and Gas Conservation Commission
(AOGCC);

•	Alaska Department of Natural Resources (ADNR);
and

•	Alaska Department of Fish and Game (ADFG).

Although the responsibilities of ADEC and other state agencies
overlap significantly, EPA has concentrated its information
gathering for this report on the primary State agency, ADEC
and therefore possesses less information on the other agencies
or the official and informal interactions among all the
involved agencies.

2.2.1 AlasXa Oil and Gas Conservation Commission

The AOGCC regulates oil and gas production in Alaska with
the primary objective of reducing the waste of these resources
The Commission also regulates Class II injection wells, which '
the oil and gas industry uses to reinject produced water and
other liquids for enhanced recovery, to store hydrocarbons and
to dispose wastewaters from oil and gas extraction operations

11 Further research is needed to clarify whether ADEC,
administratively, or the Attorney General, judicially, is
authorized to seek such penalties and injunctions. The statute
authorizing the sanctions does not directly address the matter.

* * * 6/89 DRAFT * * *

-------
2-21

AOGCC regulates oil and gas production under the Oil and
Gas Conservation Act (AS 31.05) and the Oil and Gas
Conservation Commission regulations (20 AAC 25). The
regulations govern drilling, abandonment and plugging,
reporting, annular injection, and production practices.

Through bonding requirements, well operators are required to
demonstrate assurance that funds will be available to pay for
proper well maintenance, repair, and abandonment. The
regulations also set forth requirements for detection
monitoring, emergency planning, and personnel training with
respect to hydrogen sulfide gas prevention and detection at
production wells. In addition, the rules address the
construction and closure of reserve pits. For example, they
require "special precautions" to be taken to ensure that
reserve pits are impervious and are closed "in a condition that
does not constitute a hazard to ground water." (20 AAC
25.047.)

AOGCC also regulates class II underground injection wells
under the Oil and Gas Conservation Act, which authorizes the
Commission to "take all actions necessary to allow the state to
acquire primary enforcement responsibility" under the Federal
Safe Drinking Water Act. The State has received this
enforcement responsibility from EPA for Class II wells, while
EPA retains responsibility for regulating other classes of
injection wells. (See Section 2.3.2 for a discussion of the
other classes of injection wells.)

The Oil and Gas Conservation Commission requires each
operator of an injection well to obtain a permit. Permit
applications must include, among other items, a survey plat, a
description of the formation into which fluids will be
injected, a description of the well casing, a characterization
of the fluid to be injected, an estimation of the amount of
fluid to be injected, and evidence that the proposed disposal
well will not initiate or propagate fractures that will enable
the fluids to migrate. For all Class II wells drilled or
converted to injection wells after April, 1986, the operator
has the burden of demonstrating the mechanical integrity before
operation can begin and monthly thereafter, thereby ensuring
that the proposed injection will not allow injected fluid to
migrate into sources of freshwater.

Many of the requirements for injection wells are the same
as those for oil and gas production wells, including the
permitting procedures and the rules for plugging, abandonment,
and bonding. The actual injection of wastewater into a well
for disposal, however, requires an ADEC wastewater discharge
permit.

The commission is authorized to adopt orders and take
other actions to implement its responsibilities, including:

* * * 6/89 DRAFT * * *

-------
2-22

•	Conducting on-site inspections to ensure
compliance;

•	Ordering remedial work or other action to be
taken as deemed necessary; and

•	Entering into an agreement with the Alaska
Department of Natural Resources concerning the
collection of information from regulated
persons.

Persons who willfully violate the statute, regulations, or
orders of the Commission may be fined not more than $1,000 per
day. Penalties are recoverable by suit filed by the State
Attorney General. In addition, the Commission may seek
injunctive relief for continuing violations.

AOGCC is headed by three Commissioners appointed by the
Governor. As of January, 1987, the Commission employed a staff
of twenty: two petroleum geologists, six petroleum engineers,
three petroleum inspectors, and nine miscellaneous support
staff. 2 The 1987 EPA Report to Congress stated that the
Commission has eight enforcement positions for the entire
State.

2.2.2 Alaska Department of Natural Resources

The Alaska Department of Natural Resources (ADNR) issues
surface and subsurface oil and gas leases on State land. ADNR
is the leaseholder (landlord) for all oil and gas leases
currently held by North Slope operations. These ADNR leases
include provisions for environmental protection, which may
significantly overlap ADEC and AOGCC requirements. For
example, under 11 AAC 83.158, the plan of operations submitted
by lessees must contain information on:

•	The location and design of solid waste sites
(e.g., reserve pits);

•	Plans for rehabilitating the affected leased
area; and

•	A description of operating procedures designed
to prevent or minimize adverse effects on
natural resources and other uses of the leased
and adjacent area.

12 All estimates for numbers of personnel are based on
organizational charts approved by AOGCC in January 1987.

* * * 6/89 DRAFT * * *

-------
2-23

ADNR also inspects oil and gas operations and abandonments. If
ADNR detects or suspects a violation of waste management
regulations, it generally refers the matter to ADEC. Finally,
ADNR leases State land to service companies on the North Slope.

2.2.3 Alaska Department of Fish and Same

The Alaska Department of Fish and Game (ADFG) has
jurisdiction over the use of surface waters as regards wildlife
and aquatic habitat management, especially the habitat of
anadromous fish. (5 AAC 95.) The Department issues permits
for energy exploration, development, production, or associated
activities within "special areas," namely, State game refuges,
State game sanctuaries, and State fish and game critical
habitat areas. ADFG may issue a notice of violation to persons
who affect or destroy such habitat (see, e.g., the case of the
Sag River Mine Site C, discussed in the Appendix, where river
waters that were considered habitat for anadromous fish were
diverted to flood the open pit mine). More often, the
Department refers problems with contamination from a waste
management facility to ADEC.

2.3 FEDERAL AGENCIES

The U.S. Army Corps of Engineers and the U.S.

Environmental Protection Agency have major responsibilities for
regulating wastes management activities on the North Slope of
Alaska. In other parts of the nation, additional Federal
agencies are involved.

2.3.1 united states Army Corps of Engineers

The Army Corps of Engineers has jurisdiction over
activities that affect the waters of the U.S., including
wetlands. The Corps of Engineers issues permits for the
discharge of fill material into any navigable waters, under
Clean Water Act Section 404. Because all extraction operations
on the North Slope are located in designated wetlands, persons
who construct any pad, road, or causeway on the North Slope
must obtain a Section 404 permit. The Corps has required that
all pit constructed on the North Slope be rendered impermeable
and has concluded that permafrost alone is not a sufficient
barrier. As a result, the Corps required, as of August 1986
that	'

hydrocarbons discharged into relief pits, flare pits
or reserve pits shall be removed and properly	'

disposed of as soon as practicable during the winter
but before spring breakup and within 72 hours of
discovery during periods of thaw. (U.S. Army corps
of Engineers 1986.)

* * * 6/89 DRAFT * * *

-------
2-24

For every Section 404 permit application, the Corps must
notify the U.S. Fish and Wildlife Service and EPA. EPA has
authority to veto permits approved by the Corps.

An applicant for a Section 404 permit must provide the
Corps of Engineers with a Water Quality Certification prepared
by the ADEC indicating that any discharge from the operation
will comply with the applicable provisions of the Clean Water
Act. This certification sets forth effluent limitations and
monitoring requirements necessary to ensure that the applicant
will meet Federal and any applicable State requirements. These
and any other standards become permit conditions.

In addition, the Corps of Engineers is responsible for
authorizing any dredge or fill activity that obstructs
navigable waters. Regarding North Slope operations, the Corps
regulates any islands and associated causeways built using
dredge and fill operations. For example, the Corps has issued
a permit for Standard's Endicott project, which is built on a
gravel causeway that extends approximately 5 miles from the
shore into the Arctic Ocean.

The applicability of CWA Section 404 on the North Slope is
currently the subject of ligation filed by the Natural
Resources Defense Council (NRDC) against ARCO. (Natural
Resources Defense Council 1988.) NRDC claims that reserve pit
leakage and seepage violate existing Section 404 permits. NRDC
also claims that such leakage and seepage as well as discharges
of reserve pit fluids to the tundra or roads violate the CWA
because they are unpermitted discharges of pollutants to
surface waters.

2.3.2 United states Environmental Protection Agency,
Region X

The Region X office of EPA is responsible for several
programs on the North Slope of Alaska, including:

•	Wastewater discharges to surface water under the
National Pollutant Discharge Elimination System
(NPDES) program of the Clean Water Act (CWA);

•	Discharges of wastewater through injection
wells, other than Class II wells, under the
Underground Injection Control (UIC) program of
the Safe Drinking Water Act;

•	Hazardous waste management under Subtitle C of
the Resource Conservation and Recovery Act; and

•	Review of Clean Water Act Section 404 dredge and
fill permit actions by the Corps of Engineers.

* * * 6/89 DRA7T * * *

-------
2-25

In addition, EPA has the authority to order, conduct, and
recover the costs of the cleanup of releases of hazardous
substances under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) and of releases to
navigable waters of petroleum and certain hazardous substances
under CWA, Section 311.

EPA, Region X administers the NPDES program in Alaska,
coordinating its efforts with AOEC, who must prepare Water
Quality Certifications, as discussed above. The NPDES program
requires a permit to discharge any pollutant into surface
waters. Any North Slope discharges into coastal or offshore
waters must meet Section 403 guidelines mandated for preventing
degradation of those offshore waters as well as effluent
limitations presented in the NPDES regulations (40 CFR Part
435). The NPDES regulations, however, prohibit discharges to
onshore waters of wastewater pollutants from exploration,
drilling, or production of oil.

As of February 1989, EPA had issued three NPDES permits
for major point source discharges on the North Slope of Alaska:
two permits for seawater treatment plants and one combined
permit for sewage, seawater, and mud and cutting release into
coastal waters on the North Slope from the Endicott project.
In addition, on October 24, 1988, ARCO applied for an NPDES
permit that would apply to all discharges for its entire
Kuparuk field operations. ARCO's application was accompanied
by a request that EPA determine whether disposal of reserve pit
fluids through roadwatering is subject to NPDES permitting.

EPA also regulates the disposal of wastewater through
injection wells. Under the UIC program, EPA regulates five
different classes of injection wells, with the class
designation based on the use of the well.

•	nass I injection wells are usually designed and
permitted for the disposal of RCRA hazardous
waste, although a Class I well can be permitted
for non-hazardous waste. As of February 1989,
there were no Class I wells permitted in Alaska,
although a permit application was pending with
EPA Region X for Class I status for the Prudhoe
Bay Unit Pad 3 injection facility.

•	As discussed in Section 2.2.1 of this report
regarding AOGCC, Alaska has primacy for
regulating class II wells only, which are used
by the oil and gas industry for enhanced
recovery, disposal, and storage of hydrocarbons.

. r-|agg hi. IV. and V wells are mineral

extraction wells, CERCLA remedial activity

* * * 6/89 DRAFT * * *

-------
2-26

hazardous waste disposal wells, and all other
wells, respectively, which are not relevant to
oil and gas production on the North Slope.

EPA, in addition, retains responsibility in Alaska for
enforcing the Federal hazardous waste regulations. EPA may
authorize States to enforce their own rules in lieu of the
Federal program if the state rules are at least as stringent as
the Federal rules. EPA has not delegated such authority to
Alaska. The State has, however, promulgated hazardous waste
regulations and is presently enforcing them in cooperation with
EPA. As noted earlier, the Federal and State hazardous waste
regulations do not apply to many wastes generated in the
exploration, development, and production of crude oil and
natural gas. According to the Regulatory Determination the
Agency considers the following wastes as exempt from regulation
as hazardous wastes:

Produced water? drilling fluid; drill cuttings;
rigwash; drilling fluids and cutting from offshore
operations disposed of onshore; well completion,
treatment, and stimulation fluids; basic sediment and
water and other tank bottoms from storage facilities
that hold product and exempt waste; accumulated
materials such as hydrocarbons, solids, sand, and
emulsion from production separators, fluid treating
vessels, and production impoundments; pit sludges and
contaminated bottoms from storage or disposal of
exempt wastes; workover wastes; gas plant dehydration
wastes, including glycol-based compounds, glycol
filters, filter media, backwash, and molecular
sieves; gas plant sweetening wastes for sulfur
removal, including amines, amine filters, amine
filter media, backwash, precipitated amine sludge,
iron sponge, and hydrogen sulfide scrubber liquid'and
sludge; cooling tower blowdown; spent filters, filter
media, and backwash (assuming the filter itself is
not hazardous and the residue in it is from an exempt
waste stream); packing fluids; produced sand; pipe
scale, hydrocarbon solids, hydrates, and other
deposits removed from piping and equipment prior to
transportation; hydrocarbon-bearing soil; pigging
wastes from gathering lines; wastes from subsurface
gas storage and retrieval, except for the nonexempt
wastes listed below [see Section 2.1.3 of this
report]; constituents removed from produced water
before it is injected or otherwise disposed of;
liquid hydrocarbons removed from the production
stream but not from oil refining; gases from the
production stream such as hydrogen sulfide and carbon
dioxide, and volatilized hydrocarbons; materials
ejected from a producing well during the process

* * * 6/89 DRAFT * * *

-------
2-27

known as blowdown; waste crude from primary field
operation and production; and light organics
volatilized from exempt wastes in reserve pits or
impoundments or production equipment. (53 Federal
Register, 25453-54.)

Subtitle D of RCRA applies to all non-hazardous solid
wastes and establishes broad, general guidelines for their
disposal. EPA does not have enforcement authority under
Subtitle D. Thus, ADEC, not EPA, is responsible for regulating
solid waste disposal facilities in Alaska.

2.4 ANALYTICAL FRAMEWORK FOR SITE 7ISIT CASS STUDIES

Site visits, which are described in the next chapter were
the primary source of data for evaluating the field-level'
effectiveness of regulatory programs on the North Slope. Using
the analytical framework presented in this section, Chapter 4
draws several broad conclusions from this site visit
information.

The site visits, which were arranged with industry and
ADEC assistance, enabled EPA to observe conditions and waste
management practices at a broad cross section of sites on the
North Slope.

•	EPA asked industry to choose sites that would
represent typical waste management technologies
and to provide personnel with expertise in the
processes utilized at the various facilities.

Industry selected 13 production and waste
management facilities.

•	EPA asked ADEC to select sites that would
illustrate technical and regulatory problems or
innovations. The Department selected an
additional 11 production and waste management
sites and 12 service companies.

Both ADEC and EPA believe that the 36 facilities selected
effectively illustrate the range of waste management practices
on the North Slope. Although the selection procedure did not
produce a random or statistically representative sample all
facilities in certain categories were visited (e.g., the onlv
commercial disposal site was visited).	y

EPA visited the North Slope sites in the critical summer
month of June, when the tundra thaws, and in August. Agencv
activities at each site included making and recording
observations and questioning facility personnel over a period
of up to several hours. EPA also subsequently gathered readily

* * * 6/89 DRAFT * * *

-------
2-28

available information concerning each site and its regulatory
history from ADEC and industry. However, EPA did not conduct
additional studies or analyses. For example, EPA did not study
the impact of observed discharges to the environment; analyze
the nature, use, and vulnerability of the tundra; or review
site activities during other seasons.

The Program Evaluation Framework

The data produced by the site visit methodology are used
to evaluate the field-level effectiveness of North Slope
regulatory programs under an analytical framework that
categorizes the factors that contribute to a successful program
into three areas: (1) resources; (2) authority and
enforcement; and (3) institutional arrangements. For each
factor, a series of questions delineates the framework for
analysis.

1.

•	Are adequate personnel available?

•	Are resources carefully targeted?
Authority and Enforcement

•	What regulations, authorities, and
enforcement programs are being employed at
any particular site or activity?

•	Are inspection and enforcement programs
sufficient to identify violations and
obtain compliance in a timely manner?

•	Do authorities, regulations, and
enforcement programs result in adequate
pollution prevention, mitigation, and
corrective action activities?

3. Institutional Arrangements

•	How do Federal and State agencies
cooperate?

•	How do institutional interactions affect
the effectiveness of the environmental
protection programs?

•	Are jurisdictional responsibilities clear?

* * * 6/89 DRAFT * * *

-------
2-29

• Does duplication exist? If so, how does it
influence the effectiveness of the
environmental protection program?

The site visit and program information collected to date
is sufficient for a preliminary review and analysis that
responds to all the questions listed above. Building the
analysis of the study's site visits around this framework
yields useful findings and conclusions that set the stage for
the State of Alaska, EPA, other Federal agencies, and industry
to improve the environmental management of oil production and
waste management related facilities.

* * *

6/89 DRAFT * * *

-------
CHAPTER 3. SITE VZSZT8

This chapter is organized into five sections. Section 3.1
classifies the types of North Slope sites selected for
observation. Section 3.2 discusses how each facility was
selected and visited. Sections 3.3 to 3.5 present brief case
studies for all sites, which are divided into three major
classes, as described below. These case studies are based on
EPA observations made at each site and a summary of the
compliance status at individual sites as indicated by
information obtained from the Alaska Department of
Environmental Conservation (ADEC) and industry. EPA's
conclusions, as appropriate, concerning State programs and each
site, including EPA's suggestions for possible further actions
related to each site, are presented at the end of each
subcategory of facilities. Chapter 4 presents EPA's overall

conclusions.

3.1 CLASSIFICATION OP OIL AND GAS PRODUCTION-RELATED

FACILITIES

Oil and gas wastes" are managed at three primary types of
oil and gas production-related facilities on the North Slope:

•	Production and operations facilities;

9 Off-site waste management facilities; and

•	Service company facilities.

These three facility categories are further divided into
subcategories of sites visited. (The names of the facilities
in each subcategory that were visited and available data on the
total number of North Slope facilities m each subcategory are
presented in Section 3.2.)

Production Facilities

. n-rmsites. Drillsites consist of a series of
production wells surrounding a reserve pit used
for waste containment.

. ir"—""-. ""ters. ^hiring centers (also
rofsjrxBd to 21s flow stations)	tne

oil/gas/water emulsion.

•	rr-nrfg nil taping unit. One crude oil topping
unit refines fuel from crude oil for use in the
vehicles and diesel engines on the North Slope.

Waste Management Facilities

TT—j 1rTT1 facilities. These facilities store,
rinse, and crush oii-field chemical drums.

* * * 6/89 DRAFT * * *

-------
3-2

•	Hazardous waste storage facility. The hazardous
waste storage facility visited is one of three
RCRA interim status facilities on the North
Slope. It stores miscellaneous non-exempt
wastes in 55-gallon drums contained in overpack
drums prior to treatment or disposal in the
lower 48 states.

•	Qilv waste injection facilities. The existing
oily waste injection facilities on the North
Slope are Class II injection wells used for the
permanent disposal of non-miscible oily wastes
and other liquid wastes.

•	Recycling facilities. Recycling centers
separate oil-miscible wastes from non-miscible
wastes and return the oil-miscible wastes to the
crude oil stream. Non-miscible wastes are
injected down class II disposal wells.

•	Qilv waste pits. Oily waste pits accept oily
sludges and solids that are not disposed by
underground injection or recycled.

•	Abandoned or closed landfills or disposal pits.
Closed or abandoned oily waste pits include
those pits that received oily solids and sludges
from a number of generating sites.

•	landfill. The Oxbow landfill, the only active
landfill on the North Slope, is used for the
disposal of exempt industrial waste, including
sludges and solid waste that are not injected or
recycled. In addition, the landfill disposes
municipal waste and incinerator ash from the
North Slope Borough Incinerator.

•	Municipal incinerator. The municipal
incinerator accepts municipal and industrial
wastes from numerous sources in the North Slope
Borough. (This facility was not visited, but is
included to complete the picture of major North
Slope facilities.)

Service company Facilities

•	Service company sites. Service companies
construct their own facilities on land leased
from the State. Service companies supply
production operators with a variety of oil field
chemicals, including solvents, corrosion
inhibitors, antifreeze, emulsion breakers,

* * * 6/89 DRAFT * * *

-------
3-3

acids, bases, biocides, lubricants, drilling
fluids, drilling muds, completion, and workover
fluids and a range of services.

The appendix describes a sewage treatment plant and two
mine sites that are not part of any of these three categories,
but were visited by EPA to obtain additional background
information on the range of facility operations relating to oil
and gas production on the North Slope.

3.2 8ELECTX0N AND OBSERVATION OF SITES

After completing and publishing the Report to Congress,
"Management of Wastes from the Exploration, Development, and
Production of Crude Oil, Natural Gas, and Geothermal Energy,"
the Agency determined that it needed additional information on
the generation, characterization, and management of associated
wastes generated by the exploration, development, and
production of crude oil and natural gas. In addition, EPA
desired supplementary information on the implementation of
State regulatory programs as illustrated by actual field
practices. EPA decided to collect this type of information
primarily through a series of field trips to several major oil
and gas producing States to observe first hand the generation
and management of associated wastes and the implementation of
State regulatory programs. (See Chapter 1 for a further
discussion of the purposes of this report.)

In preparing to visit facilities on Alaska's North Slope,
EPA arranged to spend equal time with industry and ADEC to
observe a variety of sites and discuss specific waste
management practices. EPA requested that industry choose sites
that would represent typical waste management technology and to
provide personnel with expertise in the processes utilized at
the various facilities. EPA requested that ADEC select sites
that would illustrate technical and regulatory problems or
innovations. EPA requested to visit production sites, off-site
waste management facilities, and service companies.

•	Industry selected 4 production facilities and 7
waste management facilities; and

•	ADEC selected an additional 5 production
facilities, 6 waste management sites, and 13
service company facilities.

Exhibit 3-1 identifies the facilities visited in each category,
the organization that selected the site, and the
representativeness of the selected facilities to other
facilities on the North Slope in the same category.

* * * 6/89 DRAFT * * *

-------
3-4

Exhibit 3—1
NORTH SLOPE FACILITIES VISITED

Facility 2-.it.,.
Category selected Facility

Agency or
Company
Responsible
for
Selection

Visited
by EPA
Contractor

Visited
by EPA
Staff

PBOPOCTlOff JX.ITIBS







?rinfiite8 A1100 Drillsite 3-0

ARCO

X

X

ARCO Drillsite 4

ADEC

X



ARCO Pad 14

AOEC

X



Standard's * Pad

Standard

X



Standard's G Pad

ADEC

X

X

Standard's J Pad

ADEC

X



Endicott Facility

ADEC

X

X

of this facility subcategory, seven w
observed.

facilities are atypical
active drillsites were

fiTiiri. oil ARCO Crud* Oil

?ฃฃ?ป;" Toppin9 ปnซ

ARCO

X





This unit is the only topping unit on the North Slope.
Gathering Center 3	Standard

Gathering

Centera

The selected facility is one of the six active gathering centers on
the North Slope.

Used Drum
FaciUtltf

ARCO Materials and
Used Drum Storage
Area

Sante Fe Pad Drum
Cleaning and Crushing
Facility

ARCO

Standard

EPA does not have information on file indicating the total number of
used drum storage and disposal facilities on the North Slope.

* * * 6/89 DRAPT * * *

-------
3-5

Exhibit 3-1 (continued)

NORTH SLOPE FACILITIES VISITED

Agency or
Company

Responsible Visited	Visited

Facility	for	by EPA	by ilT

Category	Selected Facility	Selection Contractor Staff

WASTB MMasamiT FACILITIES fcontinued!

Hazardous Standard Hazardous	Standard	X

Waste	Waste Storage Site

Storage

Facilities

This site is one of three hazardous waste storage facilities on the
North Slope.

Oily Waste Kuparuk Oily Waste	ARCO	X

Injection Injection Facility

Facilities

Prudhoe Bay Unit	Standard	X	x

Pad 3 Oily Waste

Facility

EPA does not have information on file indicating the total number of
oily waste injection facilities on the North Slope.

FogycUna Kuparuk Oily Waste	ARCO	X

Facilities Recycling Facility

EPA does not have information on file indicating the total number of
recycling facilities on the North Slope.

oilv waste Prudhoe Bay Unit	Standard	X

Pits	Pad 3 Oily Waste

Facility

Oxbow Oily Waste Pit	ADEC	X

The selected facilities are the only two oily waste pits on the North

Slope

Abandoned	Old Surfcote Landfill ADEC	X

gg

Landfills	Standard's East Dock	ADEC	X

2ฃ	Pits

Disposal

Pits	Pingut Pit	ADEC	X

EPA does not have information on file indicating "the total numbe
abandoned or closed disposal pits on the North Slope.	umoer of

* * * 6/89 DRAFT * * *

-------
3-6

Exhibit 3-1 (continued)
NORTH SLOPE FACILITIES VISITED

Facility
Category

Selected Facility

Agency or
Company
Responsible

for
Selection

Visited
by EPA
Contractor

Visited
by EPA
Staff

WMCT MANAGEMENT FACILITIES

Landfill	Oxbow Landfill	ADEC	X

This facility is the only landfill on the North Slope.

Municipal North Slope Municipal ADEC
Inslngrrtpg Incinerator

This facility is the only municipal incinerator on the North Slope.

SERVICE
rnMPAimtS

Frahley Site

Oeadhorse Hotel Lease
Tract

Aurora North Fuel

B.J. Titan Oil Field
Services

Forward Alaska
Service

North Slope Salvage
Site

Child's Pad
Oowell Schluoberger

Schlumberger Offshore
Services Pad

N.L. Baroid
Halliburton
Peak Service Company
Veco

ADEC
ADEC

ADEC
ADEC

ADEC

ADEC

ADEC
ADEC
ADEC

ADEC
ADEC
ADEC
ADEC

X
X

X
X

X

X
X
X

X
X
X
X

T

troa Aama not have information on file indicating the total number of
service company sites on the North Slope.

1 This facility was not visited by EPA during June 1988. It represents
the only major type of off-site oil and gas waste management facility on the

North Slope that EPA did not visit.

* * * 6/89 DRAFT * * *

-------
3-7

An official with EPA's Office of Solid Waste, Special
Wastes Branch, toured the North Slope oil fields in the fall of

1987.	Information from this trip was used to guide the efforts
of later visits by EPA contractors and staff, on June 14-17,

1988,	two employees of an EPA contractor toured North Slope oil
production and waiste management facilities. The contractor
employees were accompanied by Standard Alaska and ARCO
personnel on June 14 and 15 and by ADEC officials on June 16
and 17. In August of 1988, another official with EPA's Office
of Solid Waste, Special Waste Branch, briefly toured the North
Slope oil fields with both industry personnel and ADEC
personnel while in Alaska participating in a separate study.
EPA (i.e., EPA staff and EPA contractor employees) toured each
of the selected facilities (except the North Slope Municipal
Incinerator), taking photographs and notes on observations and
questions asked of State and industry representatives
concerning the generation and characterization of wastes and
waste management practices. This document incorporates EPA's
observations during these visits and information obtained after
the visits from ADEC and industry.

After the site visits, EPA completed trip notes, prepared
photograph captions, and drafted a preliminary site visit
report, and requested regulatory compliance information from
ADEC on the sites visited. State and industry personnel
reviewed the first draft and incorporated their comments into a
second draft report that State personnel reviewed.

Subsequently, EPA expanded the scope of the analysis to include
evaluating State regulatory programs, which necessitated
gathering further information from readily available sources.

EPA designed the process of selecting sites to obtain
information on a variety of facilities that represent a cross-
section of waste management activities undertaken in the course
of oil and gas production. The selected sites also provide a
reasonable basis for identifying the major strengths and
weaknesses of the State's regulatory and enforcement programs.
For certain classes of facilities that contain few facilities,
such as oil waste pits, landfills, recycling facilities, and
hazardous waste storage facilities, all or a majority of the
total number of facilities on the North Slope were visited.
(See Exhibit 3-1.) For other classes, a small or unknown
portion of the facilities in the class were visited.
Nevertheless, in some of these cases, such as the 7 production
sites visited out of a total of over 100 sites, EPA has no
reason to believe that the visited sites are atypical in their
waste management practices or in the State's program

activities.

* * * 6/89 DRAFT * * *

-------
3-8

3.3 PRODUCTION AMD OPERATION FACILITIES

This report covers three types of productions and
operations facilities:

•	Drillsites?

•	Gathering Center; and

•	Crude Oil Topping Unit.

Exhibit 3-2 summarizes the primary activities conducted at
each facility visited and provides an overview of waste
management practices associated with each facility. Each of
the facilities visited by EPA is discussed below.

3.3.1 Drillsites

EPA visited 7 of the more than 100 active drillsites in
this subcategory. Typical North Slope drillsites consist of
production and enhanced recovery wells placed around the
perimeter of a large, unlined reserve pit. Gathering lines run
over and around the reserve pit. Drilling operations generate
large quantities of waste, including drilling muds, cuttings,
and produced water. Other fluids generated at these facilities
include well worlcover and completion fluids, consisting of
biocides, corrosion inhibitors, resins, polymers, solvents, and
brine, as well as truck rinsates, crude oil, and rig
wastewater. These wastes are typically stored in reserve pits,
which are drained when excess fluids accumulate. Pit
dewatering has been accomplished by direct discharge to the
tundra, although this practice recently ceased. Pit fluids can
also be disposed by subsurface injection and discharge to tidal
areas.

New ARCO Drill	at Pad 3-0 - KUParufc Field

The new ARCO drill site has a gravel pad with two unlined,
below-grade reserve pits. Drilling and workover rigs were on-
site at the time of the visit. One pit was receiving wastes
and the other was under construction. According to ARCO
personnel interviewed during the site visit, wells are drilled
on this site to develop the existing field, typically to a
depth of approximately 6,500 feet. This site represents ARCO's
first use of below-grade (instead of above-grade) reserve pits
at a production drill site on the North Slope.' Both ADEC and
the industry believe that below-grade reserve pits will reduce
seeping of reserve pit waste onto the tundra and will minimize
the breaching of pit berms during breakup. According to ARCO
personnel interviewed during the site visit, ARCO plans to use

2 Below-grade reserve pits are excavated below the around
surface.	y a

* * * 6/89 DRAFT * * *

-------
Exhibit 3-2

OVERVIEW Of KKTH SLOPE PBODUCTION FACILITIES VISITED*

SELECTED FACILITIES
Production Fecilltlea
Drlllaltea
ARCO Drlllslte 3-0

STATUS

Active

ACTIVITIES

ป
ป
ป

ARCO Drlllslte *

Active

Development dri1Ling of production walls
•round en unllned, below-grede raaarva pit.

Production of cruda oil, natural gas, and
producad watar from aariaa of walla
surrounding an unllnad gravel, above-grade
raaarva pit.

WASTE MANAGEMENT

ARCO Pad H

Actlva

Production of cruda oil, natural gas, and
producad watar from aariaa of walls
surrounding an unlinad gravel, above-grade
raaarva pit. Also, a pigging pit and a
relief pit are located on-site.

ป
ป
ป

Standard's I Pad

Actlva

Production of crude oil, natural gas, and
produced watar from series of wells
surrounding an unllnad gravel, above-grade
reserve pit.

Drilling wastes are deposited In reeerve
pit. At closure, process wastewaters will
be decanted and disposed on-site down
annulus of producing wells. Solids will be
convered with overburden and frozen in
place. Completion fluids are contained in
tanks and disposed off-site.

Produced water and natural gas are
separated from oil at gathering center and
reinjected for enhanced recovery. Other
process wsstewatars are contained in
reserve pit or disposed In Cless II
injection well or through snnular disposal.
Solida are left In place in reserve pit or
removed end disposed et Pad 3 or Oxbow Oily
Haata Pit. Development drilling weataa are
placed in reserve pit and may be left In
place or removed to Oxbow Oily Haate Pit.

Producad water and natural gas are
separated from oil et gathering center and
reinjected for enhanced recovery. Other
process wastewaters are conteined in
reserve pit or disposed In Cless II
injection well or through snnular disposal.
Solids are left in place in reserve pit or
removed and disposed at Pad 3 or Oxbow Oily
Waste Pit. Pigging wastes sre deposited in
pigging pit and eventuelly removed and
transported off-site. Relief pit is used
during "upset" of facility in which
emergency storage of produced fluids is
required. Development drilling wastes are
placed in reserve pit and may be left in
place or removed to Oxbow Oily Waste Pit.

Produced water and natural gas are
separated from oil at gathering canter and
reinjected for enhanced recovery. Other
process wastewaters are contained in
reserve pit or disposed in Cless II
injection well or through annular disposal.
Solids are left in place in reserve pit or
removed and disposed st Psd 3 or Oxbow Oily
Waste Pit. Development drilling wastes are
placed in reserve pit and nay be left in
place or removed to Oxbow Oily Waste Pit.

Ca>

I

lO

* This exhibit is based on limited Information from site visits and selected written materials collected primarily In 1988 from ADEC
and facility operators.

-------
Exhibit 3-2 (caotinuad)

OVEKVIQi QT HKTH SLOPE PBODUCTIOI FACILITIES VISITED

SELECTED FACILITIES
Standard's G Pad

STATUS

Actlva

ACTIVITIES

ป
ป
ป

Standard'! J Pad

Actlva

ป
ป
ป

Endlcott Pad Facility

ARCO Cruda Oil Topping
Unit

Standard's Gathering
Cantar

Actlva

Actlva

Actlva

Production of cruda oil, natural gas, and
produced water froa *arias of walls
surrounding an unllnad gravel, above-grade
reaarva pit.

WASTE HAHAGEMEMT

Production of cruda oil, natural gas, and
produced watar frost sarlas of walla
surrounding an unllnad graval, abova-grada
rasarva pit.

Cruda oil and natural gas production
facility constructed on graval Island in
Arctic Ocaan connected to ahora by 3-mlla
long graval cauaeway. Facility contains
120 producing walls.

Small raflnsry that braaks tha dieael
fraction froa tha cruda oil.

Gatharlng cantar racalvas all producad
flulda from production walls.
Oll/gss/watar ara saparatad. Oil and gas
ara ralnjactad for anhancad recovery and
cruda Is sant down pipeline.

Producad water and natural gas ara
aaparatad froa oil at gathering cantar and
reinjected tor enhanced recovery. Other
procaas waatawetara are contelned In
reaerve pit or dlapoaed in Claas II
injection wall or through annular diapossl.
Solids ara left in piece in reserve pit or
removed and disposed at Pad 3 or Oxbow Oily
Haste Pit. Developsent drilling weatas ara
placed in reserve pit and may ba left In
place or raaoved to Oxbow Oily Haata Pit.

Producad watar and natural gaa ara
separated froa oil at gathering center and
reinjected for enhanced recovery. Other
proceaa waetewatera are contelned In
reaerve pit or diepoeed in Class II
injection well or through annular diaposal.
Solids ara left in place In reserve pit or
ramovad and dlapoaed at Pad 3 or Oxbow Oily
Haste Pit. Development drilling waates are
placed in reserve pit and nay be left In
piece or removed to Oxbow Oily Hssta Pit.

NPDES-permitted dlacharge to Arctic Ocean
for liquid and solid wastes, except oil-
besed drilling muds and cuttings. Oily
liquid wsstes are Injected at Pad 3. Oily
aludges are removed and dlapoaed at Pad 3
or Oxbow Oily Waste Pit.

Vessel bottoms and heat exchange bundle
aludges sre disposed st Ped 3 Oily Heste
Pit. Process wsstewaters ara disposed at
Pad 3 Oily Waate Injection facility.
Precipitates and sludges from vessel
cleanouts ere dlspossd et the Pad 3 Oily
Haste Pit or tha Oxbow Oily Haste Pit.
Filters used in the gethering center srs
incinerated at the North Slope Borough
Incinerator.

U>
I

H
O

-------
3-11

below-grade reserve pits on several new drillsites in Kuparuk
over the next few drilling seasons.

During drilling of production wells at this drill site,
ARCO discharges drilling mud and cuttings to the below-grade
reserve pit. After drilling is completed, ARCO plans to inject
the liquids in the reserve pit down the annulus of a completed
well and cover the solids with overburden, which are then to be
frozen in place inside the pit using a method referred to as
"freezeback.w ARCO also plans to drill additional production
wells around each reserve pit and install production piping
around the pit perimeter. This new type of reserve pit
configuration will allow easier removal of solids from the pit,
should the need arise prior to closure. Production piping at
older reserve pits was frequently constructed directly over the
pit, making it difficult to remove the remaining solids.

At the time of the site visit, EPA observed that ARCO was
constructing a new reserve pit. This reserve pit was partially
lined with a styrofoam material to insulate the exposed
permafrost. (Exposed permafrost will melt during the summer
season, and when thawed may cause subsidence.) ARCO plans to
dispose of this insulation material in the Oxbow landfill
following the summer drilling season. Overburden from
excavation of both pits was stacked on one edge of the drill
site. ARCO plans to use this overburden to close the reserve
pits.

In addition to the drilling rig, a workover rig was
operating at the time of the site visit. This workover rig was
being used to complete a well and bring it into production.
Steel tanks containing the cement and brine solution used in
the well completion were located adjacent to the workover rig.
Additional steel tanks used to store displaced fluids generated
from the borehole and waste fluids generated from completion
and workover operations were also located near the rig. ARCO
disposes wastes generated during completion and workover
operations at this site in the Kuparuk oily waste injection
facility, the Kuparuk recycling center, the Prudhoe Bay Unit
Pad 3 oily waste disposal well and pit, and the Oxbow landfill.
(These facilities are discussed in detail later in this
chapter.)

3 Freezeback is a waste disposal method in which wastes are
placed in a below-grade impoundment and covered with gravel or
overburden. The influence of the permafrost surrounding the
impoundment and the long months of freezing temperatures in the
Arctic are expected to freeze the wastes in the impoundment in
place.

* * * 6/89 DRAFT * * *

-------
3-12

According to ARCO personnel present during the site visit,
the Kuparuk Field contains approximately 600 wells, which are
subject to periodic workovers. Approximately 500 barrels of
workover wastes are generated during each workover of a well.
ARCO personnel interviewed during the site visit reported that
some of these wastes are recyclable. ADEC and EPA have little
information on volume and characteristics of workover wastes
generated in the North Slope oil fields. ADEC and EPA do not
know whether ARCO or the other operators have developed this
type of information. The State currently does not require
operators to characterize workover wastes. These personnel
stated that 33 workovers were performed in the Kuparuk Field
during the 1988 summer season, generating an estimated 16,500
barrels of workover wastes and that these wastes were disposed
at the Pad 3 oily waste disposal facility and at the Oxbow
landfill.

According to ARCO personnel interviewed during the site
visit, pipelines in the Kuparuk Field are routinely pigged.
At the time of the site visit, ARCO personnel did not specify
what type of pipeline is routinely pigged; however, ARCO
subsequently submitted information stating that "the only
pipelines in Kuparuk which are routinely pigged are the water
injection lines. Oil production lines are not pigged." (ARCO
1988.)

According to ARCO personnel interviewed during the site
visit, many of ARCO's drill sites in Kuparuk have at least one
pigging pit. After completing a pigging operation, ARCO vacuum
trucks collect the pigging sludges, which are injected at the
ARCO oily waste injection facility. As of 1988, most of the
pigging pits in the Kuparuk Field were unlined. According to
ARCO personnel, ARCO intends to begin lining these pigging
pits, but has not proposed a formal schedule.

According to ADEC, it has no detailed information on file
concerning pigging waste characteristics and volumes. The
State does not require operators to submit such information.

In a letter sent to ADEC and the Army Corps of Engineers
and dated September 12, 1988, ARCO requested permission to
construct a small pit'within the reserve pit at Drill Site IE.
According to the letter, the small pit is required for pigging
operations, and the pigging wastes are expected to contain
trace amounts of "oil scale and iron sulfides." (ARCO 1988a.)

4 Pigging is a pipeline cleaning process in which a metal or
coated plastic cylinder is pushed through production piping to
remove any paraffin, solids, or scale that have collected in the
piping. At the location in the pipeline where the pig is removed,
a pit is usually constructed to receive the pigging wastes.

* * * 6/89 DRAPT * * *

-------
3-13

According to ADEC, ARCO does not plan to install a liner for
this pigging pit, claiming that a curtain liner will be
installed in the reserve pit in a few months.

In information submitted to EPA following the site visit,
ARCO states that new drillsites at which water injection is
beginning have no need for pigging operations. This is the
explanation given for the absence of lined pigging pits at
these sites. However, ARCO appears to store temporarily
pigging wastes at these sites, stating that the new waterflood
drillsites "are pigged to the reserve pits from which the water
is immediately removed." (ARCO 1988.) ADEC has reportedly
never approved the disposal of pigging wastes into reserve
pits. (Photos 1-7 document this site.)

ARCO Drill site 4

The arrangement of ARCO's Drill Site 4 is typical of most
drill sites on the North Slope where production and enhanced
recovery wells are placed around the perimeter of a large,
unlined gravel reserve pit. Gathering lines run over and
around the reserve pit.

On June 16, 1988, EPA visited this site, accompanied by^
ADEC personnel. At that time, material containing a dark, oily
substance appeared to have leached from the reserve pit, under
the road on the west side of the pad, and onto the tundra on
the west side of the road. According to ADEC officials, ADEC
requested three times during 1987 and 1988 that ARCO adequately
cleanup this spill site.

According to an ADEC letter dated July 22, 1988, an oil
spill at Drill Site 4 near Sump 1 was first observed by ADEC on
August 4, 1987. (ADEC 1988.) On August 12, 1987, ARCO filed a
spill report with ADEC stating that the spilled material was
approximately ten gallons of diesel fuel. The spill was
cleaned up, and, according to ARCO, no additional contamination
was noted prior to freeze-up. (ARCO I988d.)

On July 22, 1988, ADEC issued a Notice of Violation to
ARCO for failure to perform adequate cleanup of the Drill Site
4 diesel spill. According to the letter accompanying the
Notice, ADEC indicated that, based on the size of the
contaminated area and severity of contamination, 10 gallons of
diesel apparently could not have caused the entire problem,
especially if some site cleanup had already occurred. ADEC
suspected that "another source of contamination may exist, such
as the dike itself." In the NOV, ADEC required ARCO to
determine the extent and severity of contamination and report
the results to the Department by August 5, 1988. ADEC also
noted that, in ADEC inspections conducted after ARCO personnel
reported that the contamination had been cleaned up, oil was

* * * 6/89 DRAFT * * *

-------
3-14

found on the north side' of the north dike of Sump 1 and in the
sediment in the impoundment immediately north of the dike. In
addition, ADEC has detected a sheen on the water in the
impounded area during each site visit and a diesel smell in the
area. (AOEC 1988a).

In ARCO's response to ADEC's NOV, the company denied the
allegations that it unlawfully failed to clean-up
oil-contaminated gravel and soil on a dike and an impoundment
on the north end of Drill Site 4 and that it falsified
information submitted to ADEC. ARCO requested that ADEC
withdraw the NOV. ARCO also discussed in detail cleanup
procedures that had been employed and data on the levels of
hydrocarbon contamination found in the adjacent dike and
surrounding area. (ARCO I988d.)

According to ADEC, as of October, 1988, ARCO had contained
the spill to the satisfaction of the Department and was
remediating the spill area in conjunction with closing the
reserve pit on the drill site. (EPA did not take any photos of
this site.)

ARCQ Pad 14

ARCO's Pad 14 is an oil and gas production facility with a
manifold building where some rough separation of oil and water
occurs, an unlined gravel reserve pit, an unlined gravel relief
pit, and an asphalt-lined pigging pit. As documented by
photographs, EPA observed oil sheens and spillage on the
surface of the relief pit.

Relief pits receive hydrocarbon and liquid carryover from
periodic venting of production equipment. According to ARCO
personnel at the site, the pigging pit collects sludges and
debris from pipeline cleaning operations. ARCO removes wastes
generated by the pigging procedure by vacuum truck and hauls
them to the Pad 3 oily waste disposal facility or to the Oxbow
landfill. (EPA has no information on the specific
characteristics or volume of materials contained in these
relief pits or pigging' pits.)

Standard's Y Pad Drill Site

Standard's Y pad is a typical Prudhoe Bay North Slope
drill site in that production and injection wells are arranged
around a reserve pit, which is used to contain muds and
cuttings from development drilling on the pad. Production and
injection piping cross the above-grade reserve pit in several
places.

At the time of the site visit, breakup was underway, and
EPA observed that substantial quantities of snow remained in

* * * 6/89 DRAJT * * *

-------
3-15

the reserve pit.. According to industry and ADEC personnel,
snow is routinely removed from the surface of the pad around
the pit at breakup each year. ADEC requests that the operators
remove snow down to the last foot, and the State designates
specific snow disposal areas adjacent to the drill sites.

During the site visit, EPA observed that the pit had less
than six inches of freeboard. Development drilling was
underway at the facility, discharging water-based mud and
cuttings to the reserve pit. EPA observed that the pit area
was covered primarily by clear water (i.e., snow melt) that
could eventually be removed by dewatering over the 1988 summer
season. However, some areas of the pit appeared to have an
oily composition, while others appeared to be oily sludges.
(Photos 41-47 document this site.)

According to information submitted to EPA by Standard
subsequent to the site visit, Standard stated: "The substance
seen was from oil-based muds which had been previously
deposited during development drilling and not from a workover
or a completion or stimulation." Standard also stated that (1)
it suspended discharging oil-based muds to reserve pits pending
the results of a monitoring program being conducted to ensure
that the pits are providing proper containment, and (2) it no
longer use reserve pits for disposal of oily workover wastes,
which are now either disposed in Class II injection wells or
returned to the production process. (Standard 1988.)

According to ADEC, as of October 1988, Standard had never
mentioned the disposal of oil-based muds or workover fluids in
any of their reserve pit permit applications, and all ADEC
permits issued to date limit reserve pit disposal of drilling
wastes to water-based muds and cuttings only.

Although ADEC has not taken any action against Standard
for past disposal of oil-based muds and workover wastes at Y
Pad, ADEC has taken action in a similar case at W Pad. On July
22, 1988, ADEC issued a NOV to Standard for a permit violation
involving the disposal of oil-based drilling wastes in a
reserve pit at W Pad. ADEC indicated that the solid waste
permit conditions for the facility specifically prohibited such

EPA plans to request a copy of the Y pad permit from ADEC
to verify that this facility was permitted for disposal of water-
based muds and cuttings only.

* * * 6/89 DRAFT * * *

-------
3-16

disposal. In the letter accompanying the NOV, ADEC also
stated that the storage of oil-based muds in the W Pad reserve
pit caused a release of oily material to the tundra and that
Standard should reevaluate its drilling waste management plan
and consider total lining of all active reserve pits. (ADEC
1988c, 1988d.)

In its reply to the Notice of Violation issued for W Pad
dated July 15, 1988, Standard stated that the oily waste
deposited in the reserve pit was removed and disposed at the
Oxbow oily waste pit. (Standard 1988c.)

Standard's G Pad

Standard's G Pad is an oil and gas production facility
that has one main building, where oil and gas are separated,
and an unlined reserve pit surrounded by a series of production
wells. Drilling muds and cuttings, water and drilling fluids,
and other wastes are stored in the reserve pit prior to
disposal. Drilling muds and cuttings removed from the pit have
been disposed at the Oxbow landfill while liquids have been
disposed by annular injection.

At the time of the site visit on June 17, 1988, EPA
observed oil on the surface of the reserve pit. EPA also
observed dead tundra adjacent to the pad that appeared to be
the result of seepage of contaminants from the pit. During the
visit, ADEC personnel indicated that the area that appeared to
have experienced seepage of contaminants was not the same area
affected by the release of drilling waste in August 1987, as
discussed below. (Photos 144-148 document this site.)

Subsequent to the EPA site visit, standard indicated that:

On August 4, 1987, standard reported a spill of
approximately 50 cubic yards of drilling fluids which
overtopped the reserve pit walls at G Pad. The area
was sandbagged and a plastic liner placed on the
tundra to prevent further spreading during cleanup.
The area was flushed with water which was pumped back

In addition, ADEC cited Standard for failing to maintain a
copy of the permit at the facility and for failing to submit the
sampling designs for the "toe" samplers.

7 Standard personnel on-site at the time of the visit reported
that in the spring of 1988, Standard removed 8,500 cubic yards of
drilling muds and cuttings from the G pad reserve pit and disposed
of this material at the Oxbow landfill. Standard reportedly
disposed of fluids from the reserve pit via annular injection.

* * * 6/89 DRAFT * * *

-------
3-17

to the reserve pit and later disposed of by annular
injection. Water samples were taken to ensure that
nearby tiridra ponds were not affected, and
restoration and dormant reseeding occurred in 1988.
(Standard 1988.)

Standard also indicated that it would monitor the area in 1989
to ensure regrowth of tundra grasses, and would undertake
additional restorative measures if necessary.

As of November 1988, ADEC had not investigated the
apparent release (in addition to the August 4, 1987 reported
spill) observed during the site visit due to limited manpower.
(Personal communication, ADEC, November, 1988.)

Standard J Pad

Standard's J Pad consists of one main structure where oil
and gas are separated and a large unlined reserve pit which is
surrounded by a series of production wells.

At the time of the site visit, ADEC explained that the
oily liquids had flowed from the reserve pit onto the tundra
during the summer of 1987. EPA observed that the released
material had been removed and that some tundra outside the
repaired reserve pit was stained. (Photos 122 and 123 document
this site.)

According to information submitted to EPA by Standard
following the EPA site visit, Standard reported to ADEC on July
24, 1987, that 40 to 50 gallons of crude oil and diesel had
leaked from the north wall of the northeast reserve pit.
Standard also reported that, on July 26, 1987, 5 to 10 gallons
of diesel/crude had leaked from the dike wall of the west pit,
that both spills were cleaned up, and that impermeable
embankment liners were installed. (Standard 1988.)

On August 5, 1987, ADEC issued an NOV to Standard for
release of wastes from the reserve pit onto the nearby tundra
in violation of 18 AAC 72.210. (ADEC 1987a.) ADEC notified
Standard that the NOV related to activities that have occurred
at J-Pad only, primarily because J-Pad had been an ongoing
problem and leakage from the north pit had been documented.

ADEC also noted that multiple Department inspections of the
J-Pad reserve pit after breakup had revealed the continuous
presence of hundreds of gallons of pooled crude and lighter
[oils] and product within the pit, and that "several complaints
from other state, federal, and North Slope Borough inspectors
have also been registered with the department." (ADEC 1987.)

ADEC's letter that transmitted the NOV also noted that
Standard's use of the pit to contain oily materials (other than

* * * 6/89 DRAFT * * *

-------
3-18

the crude oil that is natural outcome of drilling into
producing formations), including diesels, hydraulic fluids,
light condensates, lube oils, and glycols, conflicts with the
Agency's position that "such disposal is permissible only if
the facility has undergone plan review to ensure against escape
of liquids" and that gravel dikes are generally considered to
provide inadequate containment. According to ADEC's letter,
Standard was allowed a grace period in the spring of 1987 to
develop a more appropriate alternative to depositing oily waste
in reserve pits, but both hydrocarbons and water were still
present in the pit on July 21, 1987, aggravating the leakage
through the pit wall. (ADEC 1987.)

The NOV also requested that Standard prepare and submit
within 15 days (1) a plan for an aggressive fluid management
program for the pit; (2) a plan for rendering the pit dike
impermeable; (3) a plan from removing hydrocarbons from the
North Pit at J-Pad; and (4) a conceptual plan and schedule for
long-term disposal of oily wastes other than in a gravel diked
reserve pit, including plans for interim disposal of oily
wastes while a permanent facility is designed and constructed
(ADEC 1987). Standard responded on August 8, 1987, and
committed to design and install an impermeable cut-off wall in
the leaking pit dikes by June 1, 1988, to decant liquids and
dispose of them by annular injection by September 1, 1987, to
develop a final plan for the containment and disposal of oil
wastes by September 30, 1987, and to construct these facilities
in 1988. Standard also stated that "until these facilities are
designed and constructed, all non-liquid oil spill cleanup
material will be placed in G and/or J Pad flare pits. G and/or
J Pad flare pits will be lined with an impermeable liner prior
to use and will be used until the permanent facility is
complete." (Standard 1987.)

ADEC has reportedly never issued a letter or other
document that approved the placement of spill material or oily
waste in a flare pit. According to ADEC personnel, instead of
constructing an oily waste disposal facility, as promised,
Standard continues to dispose of oily waste at the Prudhoe Bay
Unit Pad 3 Oily Waste Injection Facility.

Standard1 a Endicott Production Facility

Endicott is an oil and gas drilling and production
facility built on a gravel causeway that extends approximately
5 miles- from shore into the Arctic Ocean. According to an ADEC
report on the generation and disposal of liquid wastes,

Endicott project, when completed (ADEC 1988v):

will have approximately 120 producing wells. As with

onshore facilities, offshore drilling produces large

quantities of liquid and solid wastes. Where wastes

* * * 6/89 DRAFT * * *

-------
3-19

meet EPA discharge criteria, offshore disposal is
permitted via an EPA NPDES permit. Discharged wastes
include: Water-based muds, cuttings, completion
fluids, workover fluids, drill rig washwater, sewage
treatment plant effluent, desalination plant effluent
and fire control system test water. The Endicott
project discharged 3,506,000 gallons of muds and
cuttings during 1987.

At the time of the site visit on June 17, 1988, EPA
observed that drilling was being performed on a section of the
Endicott facility and that drilling muds, cuttings, and fluids
were being discharged via the permitted NPDES outfall to the
Arctic Ocean.

Conclusions

Based on observations at the sites visited, and the data
currently available to EPA (which are summarized above), EPA
concludes that:

•	The increasing use of below-grade, instead of
above-grade, reserve pits will reduce seeping of
reserve pit waste onto the tundra and the
breaching of pit berms during breakup.

•	North Slope operators reinject the vast majority
of produced waters for enhanced recovery
purposes. (This economical practice will
eventually cause the field to "sour" and thereby
create the need for hydrogen sulfide gas
protections at production sites.)

•	The disposal of reserve pit fluids by discharge
to the tundra or by road watering has, at least
temporarily, been discontinued.

•	More information on workover wastes at the new
ARCO Drill Site at Pad 3-0, Kuparuk Field is
needed to ensure appropriate management of these
wastes.

•	Follow-up at the Standard Y Pad Drill Site is
needed to determine whether and how oily wastes
were removed and disposed, and whether use of
the pit is now restricted to water-based muds
and cuttings.

•	Issuance of an NOV at W Pad and not at Y Pad for
apparently similar conditions indicates
inconsistent enforcement of applicable

* * * 6/89 DRAFT * * *

-------
3-20

requirements. The State also appears reluctant
to issue sanctions authorized by statute.

•	Follow-up by ADEC is needed at the Standard G
Fad site to examine the implementation and
effectiveness of the spill clean-up efforts that
Standard has planned for the reported August
1987 release and to investigate further the
apparent additional release(s) from the pit.

•	Information that is needed to evaluate the
feasibility of tundra restoration could be
developed by monitoring the tundra environment
in the areas that have received releases to
examine the effectiveness of revegetation, the
extent to which drilling waste constituents
bioaccumulate, and the effects on species
diversity.

•	Additional information is needed to determine
Standard's response to and ADEC's follow-up on
the NOV issued at the Standard J Pad.

•	As stated by ADEC, fluid management problems
occur because the pits collect water from
natural sources, primarily rainfall and
snowmelt. Problems associated with this
addition of water include: (1) Increased
reserve pit leakage due to increased hydraulic
head, (2) fluid overtopping reserve pit dikes,

(3)	breaching of reserve pit dikes, and

(4)	increased volumes of contaminated water for
disposal. (ADEC 1988v.)

3.3.2 Crude Oil Topping Units

EPA visited the only crude oil topping unit on the North
Slope. This facility is essentially a small petroleum refinery
that breaks out the diesel fraction of crude oil. The
resulting diesel fuel is used for the many vehicles on the
North Slope. Topping units generate a variety of wastes,
including separated water, hydrogen sulfide, vessel-cleaning
solvents, and vessel bottoms.

ARCO's crude Oil Topping Unit

ARCO operates the crude oil topping unit, which was one of
the first permanent installations built on the North Slope
during the initial development of the Prudhoe Bay field. A
flare pit is located behind the topping unit. According to
ARCO personnel, jet fuel also was made at the topping unit in
the past. At the time of the site visit, EPA observed that the

* * * 6/89 DRAFT * * *

-------
3-21

interior and exterior of the topping unit appeared to be well
maintained.

ARCO operates a diesel fuel storage facility adjacent to
the topping unit. At the time of the site visit, EPA observed
that portions of the berm surrounding the large storage tank
appeared to be saturated with oil. (See photos 100-104.)

According to ARCO personnel interviewed during the site
visit, this facility generates various waste streams including
water distilled from the crude oil, sulfur from hydrogen
sulfide removed from crude oil, vessel (tank) bottoms, heat
exchanger bundle sludges which are generated when the plant
pipes are flushed with diesel, and solvents used for cleaning
the vessels and heat exchangers. Vessel bottoms are removed
once every two years, while the bundle sludges are removed
every few months. According to the ARCO personnel interviewed,
tank bottoms have been disposed at the Pad 3 facility, and most
of the other wastes generated at the topping unit are disposed
at Pad 3.

According to a facility operator interviewed during the
site visit, the bundle sludges have failed the EP-toxicity test
for chromium and the RCRA characteristics test for
ignitability. To date, EPA has requested but not received
information from ARCO on the characteristics of wastes
generated at the topping unit. According to ARCO's most recent
RCRA biennial report, dated 1985, the heat exchanger bundle
sludges were disposed at Pad 3 injection wells. Standard and
ARCO state that disposal of topping unit bundle sludge ceased
at Pad 3 in August, 1985 (ARCO 1988; Standard 1988). ARCO's
latest RCRA biennial report has not been released. EPA has no
evidence of the shipment of bundle sludges to a RCRA permitted
facility. Thus, based on currently available information, EPA
cannot determine how the bundle sludges have been disposed
since 1985. ARCO does not have an EPA generator number for
this facility; however, ARCO does have an EPA generator number
for the numerous facilities in ARCO's Prudhoe Bay Unit, Eastern
Operating Area.

Officials with ADEC are investigating allegations that the
flare pit behind the topping unit has previously been used to
burn many of the wastes generated at this facility. ADEC
planned to sample this flare pit during the summer of 1988 to
establish whether the pit has received wastes exhibiting RCRA
hazardous characteristics. (Results of this investigation have
not yet been reviewed by the authors of this draft report.)

* * * 6/89 DRAFT * * *

-------
3-22

Conclusions

Based on observations at the site and the data currently
available to EPA (which are summarized above), EPA concludes
that:

•	The heat exchanger bundle cleaning sludge
generated by the topping unit is not an exempt
waste. EPA has listed heat exchanger bundle
cleaning sludge from the petroleum refining
industry as a hazardous waste (K050). Thus, EPA
concludes that these wastes are RCRA hazardous
wastes.

•	The topping unit may generate wastes identical
to wastes listed under RCRA has hazardous when
generated by petroleum refineries, such as K048,
K049, and K050: K048 is described as "DAF" or
dissolved air flotation float; K049 is slop oil
emulsions and solids; and K051 is API separator
sludge. The Agency recognizes that there are
issues that need resolution with respect to the
descriptions of these waste listings and that
further research is needed to determine
conclusively the regulatory status of any of
these wastes at this facility.

3.3.3 Gathering centers

ARCO and Standard operate collection and separation
facilities on the North Slope to separate the oil/water/gas
mixture produced in the Prudhoe Bay field.8 After separation,
much of the water and natural gas is reinjected into the
producing formation for enhanced recovery, while the oil is
sent to the Aleyska Pipeline. The gathering centers process a
combined volume of approximately two million barrels of oil per
day, along with similar volumes of produced water and natural
gas.

Gathering centers generate a variety of wastes, which
include:

•	Precipitates generated as a result of corrosion
inhibitors and biocides use to protect equipment
from hydrogen sulfide and sulfate reducing
bacteria and sludges removed from collection and
separation vessels;

8 ARCO refers to these facilities as "flow stations," and
Standard refers to them as "gathering centers."

* * * 6/89 DRAFT * * *

-------
3-23

•	Filters used to clean the glycol used in the
separation process; and

•	Some liquid wastes, such as "dirty water," that
are not reinfected for enhanced oil recovery.

Standard's Gathering eซ*nt?r ?

At the time of the site visit on June 15 lsaa fpa

aDDearaneehatFPAe faciliJyhad a very clean and orderly
appearance. EPA also noted that a large reserve or emergency

?i	J contained a red-colored algae that was striking

n2f 52	because	al9ae growing on the North Slope are

Jtraฐ^eh dฐ not ^ the causฎ of this algae
growth in the pit, which is used to contain spillage of water,
water mixed with fire-retardant chemicals, or prop?ietary

Sii? ire suppressant systems. (No photos of this

ff available because, for safety reasons, Standard did
not allow cameras inside the facility.)

d*fpof?s precipitate and sludge wastes that are
removed from collection and separation vessels at this facility

^aC^1XtJ' *AS Stated by a stan<*ard employee
operating Gathering Center 3 at the time of the visit,

thousands of barrels of collection and separation vessel
precipitates are removed annually* and the chemical analysis
that is occasionally performed on these wastes commonly detects
lead and chromium.

„ j	and charcoal filters that are continually

used to filter glycol, which heats the oil emulsions during the
separation process, are sent to the North Slope Borough
incinerator for disposal. (Charcoal filters remove chlorinated
hydrocarbon contaminants from the glycol. The glycol itself is
usually regenerated by removing the water through a heat
stripping process. The resulting water, and possibly other
vapors, are released to the atmosphere as steam.)

"Dirty water" tanks at this facility receive flow-back
from well stimulation, workovers, and completion operations
through the train separators. Both solids and liquids are
recovered in these tanks. The liquids are disposed through on-
site injection wells, while the solids are disposed at the Pad
3 oily waste pit.	^

9 As the Prudhoe Bay field grows older, the solids content of

the production stream is	likely to increase, which will increase

both the frequency of	vessel cleanouts and the volume of
precipitate waste.

* * * 6/89 DRAFT * • *

-------
3-24

The facility also has a large reserve or emergency pit,
which according to the operator interviewed during the site
visit, is used to contain spillage from fire suppressant
systems. In information provided after the site visit,

Standard indicated that the pit collects oil and/or fire
suppressant water/chemicals from the floor drains in the older
sections of the gathering center. These floor drains are
equipped with 2- to 3-inch raised lips around them so that only
liquids from a large release will enter the drains and thus
flow into the emergency pit. (Standard, 1988.)

Conclusions

Based on observations at the site and the data currently
available to EPA (which are summarized above), EPA concludes
that:

•	The nature of the material and the unusual algae
in the emergency or reserve pit at Standard's
Gathering Center 3 should be investigated; and

•	EPA needs more information on the
characteristics of the air emissions from the
glycol regeneration process to determine
compliance with State and Federal air quality
control regulations.

3.4 WASTE MANAGEMENT FACILITIES

This report covers eight types of off-site oil and gas
waste management facilities:

(1)	Used drum facilities;

(2)	Hazardous waste storage facilities;

(3)	Oily waste injection facilities;

(4)	Recycling facilities;

(5)	Oily waste pits;

(6)	Abandoned or closed landfills or disposal pits;

(7)	Landfill; and

(8)	Municipal incinerator.

Exhibit 3-3 summarizes the primary activities conducted at each
facility visited and provides an overview of waste management
practices associated with each facility. Each of the
facilities visited by EPA is discussed below.

3.4.1 Used Drum Facilities

Oil field operations produce large quantities of empty
drums that must be disposed. The storage and disposal
facilities generally store drums only until they can be

* * * 6/89 DRAFT * * *

-------
Exhibit 3-3

OVERVIEW OF MBTB SUNS HASTE NUUGDCIT FACILITIES VISITED

ป
ป
ป

00
ซ0

ป
ป

SELECTED FACILITIES

Santa Fa Pad Drum
Cleaning and Cruahing
Facility

ARCO Matarlala and Uaad
Drum Storage Facility-
Kuparuk Fiald

Standard'a Hazardoua
Haata Storaga Facility

ARCO'a Kuparuk Oily
Maata Injection
Facility

Prudhoa Bay Unit Pad 3
Oily Weate Facility

ARCO'a Oily Waata
Racycllng Center-
Kuperufc Fiald

Standard's Eaat Dock
Pita

ARCO'a Pingut Pit

Old Surfcote Landfill-
ARCO Fira Training
Facility

Oxbow Landfill and Oily
Haata Pit

Horth Slope Municipal
Incinerator

STATUS

Active

ACTIVITIES

Active

Active

Active

Active

Active

Inactive
Inactive
Active

Active

Active

Rinaas and crushes used drums previously
containing oilfield cheaicala, dlaael, and
dead crude.

Empty drums are stored on-site prior to
crushing and disposal off-sita.

Interia status RCRA facility atoraa a
variety of hazardous Hastes stored in 55-
gallon drusM packed Inside overpack drums.

Hpnrecyclable liquid oily wastes are
injected on-site in Claas II diaposal well.

Facility accepta oily wastea generated In
Horth Slope oilfield including liquids and
aludges. Liquids are proceasad through a
separation facility; resulting liquids are
injected on-site in Claas II disposal walla
and all aludgaa sre disposed in oily waste
pit.

In a process similer to crude oil
reclamation, usable crude la recovered from
oily waste stream. Resulting wastewater is
injected via Claas II disposal well.
Recovered crude is sent to crude stream.

Pravioualy diaposed drilling and aanitary
waatea in unllnad reserve pita.

Previously disposed oily wastes in below-
grade unllnad reserve pit.

Closed landfill la now uaed aa ARCO fire
training facility.

Active municipal landfill accepts
incinerator ash, nonrecyclable industrial
waste, sanitary waste, and all forms of
solid waste. Oily waste pit accepta oily
solids and sludges from production
operators and service companies.

Municipal incinerator accepts Industrial
and municipal soLld wastes.

WASTE MANAGEMENT

Used drums sre rinsed; resulting rlnsate is
collected in 500-gellon tank. Rlnsate la
periodically raanved to a gathering center
where it is mingled with the crude stream.
Solids are diaposed at the Pad 3 Oily Waste
Pit, and crushed drums are disposed at the
Oxbow Landfill.

Oil mlacible llqulda ara recycled to crude
stream, non-mlscible liquids are injected
down Class II disposal wells. Crushed
drums sre disposed at Oxbow Landfill.

Drums containing hazardous waata are
periodically ahlpped to lower 48 atatea.

Recovered oily sollda are diaposed at Oxbow
Oily Haata Pit.

All waataa received reaiain on-site.

CJ

I

to
U1

Nonrecyclable liquids are resioved off-slta
end disposed in a Claaa II injection well.
Oily solids disposed et Pad 3 or Oxbow Oily
Waste Pit.

Reserve pits were closed under ADEC-
approved cloaure plan.

Pit was closed under ADEC-approved closure
plan.

All incoming wastes are permanently
disposed on-site. In the pest, landfill
and oily waste pit has been dewatered
through pumping of stormwster to tundra
under permit from ADEC.

Incinerator ash is disposed st Oxbow
Landfill.

* This enhiblt Is based on limited information from site visits snd selected written materials collected primsrlly in 1988 from ADEC
and facility operators.

-------
3-26

cis done by rinsing and then crushing the drums,
j . . drums are disposed at the Oxbow Landfill. Drum rinsate
injected down Class II injection wells or recycled for oil.

Standard's Santa p^d Drum Cleaning and Crushing Operation

Standard's oil field operations produce large quantities
or empty drums that are sent for cleaning and crushing to a
arum cleaning and crushing building that is located at
PM !rd's Santa Fe Pad. During the visit to this facility,
epa observed that drums were stored temporarily on an uncovered
gravel pad that lacked secondary containment, standard
personnel interviewed during the site visit indicated that
standard stores drums in this area prior to rinsing and
crushing. The condition of these drums varied; some were in
good condition, while others were damaged (e.g., corroded,
rusted). Employees working at this facility were wearing Level
c respirators and protective clothing. (See photos 33-38).

According to Standard personnel interviewed at the site,
facility typically processes empty oil field chemical drums
that may contain residues of chemicals used in oil field
operations, such as biocides, pesticides, corrosion inhibitors,
solvents, emulsion breakers, reverse emulsion breakers, glycol,
alcohols, and xylenes. According to comments provided to EPA
by Standard following the site visit, the empty drums "have
been used for well returns, which consist largely of dead crude
and diesel." (Standard 1988.)

According to standard personnel at the site, a drum that
contains a sizable quantity of liquids will have its contents
removed by a vacuum truck at the facility, while solids in the
bottom of a drum are removed by hand. Drums are then rinsed in
a machine that sprays jets of warm water into the drum. The
rinsate is flushed into a 500-gallon collection tank inside the
building. The rinsed drums are then crushed on-site and
trucked to the Oxbow Landfill for disposal. According to
comments submitted to EPA by Standard after the site visit,
"[a]11 rinsate collected from the Santa Fe Warehouse is sent to
[Standard's] Gathering Center l,10 where the material is
recycled through the processing system, recovering oil to the
crude stream. Any water residuals retained in the wastewater
system are commingled with produced water for underground
injection.H (Standard 1988.)

10 This facility was not visited by EPA and, therefore, is not
discussed in detail in this report.

* * * 6/89 DRAFT * * *

-------
3-27

In these comments, Standard also states that:

[T]he residues from these drums are not regulated as
hazardous waste under Subtitle C of RCRA. Residues
that are regulated as hazardous waste are those
collected from drums that contain "commercial
chemical products" ("U" or "P" listed wastes) [40
CFR 261.33(c)]. Any solid waste residues collected
from drum rinsing operations at Prudhoe are not in
the category of spent "commercial chemical products."
(Standard 1988.)

Currently, Standard and AOEC appear to disagree on whether
the drum rinsate is a hazardous waste under 40 CFR Part 261
and, if so, what RCRA regulations apply to this facility. An
internal AOEC memorandum dated October 13, 1988, states that:

40 CFR 261.7(a)(1) provides that any hazardous wastes
remaining in empty containers or empty container
inner liners, as defined by 261.7(b), is not subject
to the regulation under Parts 261-265, 268, 270, or
124 of 40 CFR or Section 3010 of RCRA. However, when
these residues are removed from empty containers,
such as occurs when drums are washed out, a new waste
is generated, which la subject to RCRA regulation as
a characteristic hazardous waste. This provision is
discussed in the August 18, 1982 Federal Register on
page 36096. (AOEC 1988b.)

ARCO Materials and Used Drum Storage Facility - Kutaaruk Field

ARCO utilizes a central area or pad to store oil field
equipment, which includes drilling and completion materials,
piping, and spare parts. Some of these materials are stored in
a warehouse built on the pad, while other materials are stored
uncovered on the pad. This site also has an uncovered area for
storing empty drums. The drum storage area is surrounded by a
lined berm constructed of gravel. Empty drums are stacked four
drums high on wooden crates at the central storage site prior
to crushing and disposal. According to ARCO personnel
interviewed during the site visit, the empty drums previously
contained a variety of oil field chemicals including solvents,
acids, biocides, corrosion inhibitors, corrosives, caustics,
water treatment chemicals, and numerous hydrocarbon-based
chemicals.

At the time of EPA's site visit, some drums exhibited
visible signs of physical damage (e.g., mist, corrosion),
potentially allowing for residual contents to leak onto the
pad. EPA also observed that several inches of water had
collected in pools inside the bermed area. The water was
discolored by the presence of a black-colored substance. Foam

* * * 6/89 DRAFT * * *

-------
3-28

was visible on the surface of the water, apparently resulting
from residues leaking from the empty drums. EPA has no data
characterizing the stormwater from the storage area. (See
photos 8-12.)

According to ARCO personnel at the site, ARCO double
rinses and crushes drums at this facility. The oil-miscible
drum residue recovered during draining is commingled with other
oil-miscible wastes and sent to ARCO's oily waste recycling
center. Other liquid waste from drum cleaning operations is
hauled by vacuum truck and, according to ARCO, "disposed at a
State approved facility." (ARCO 1988.) ARCO uses a private
contractor to dispose empty drums. EPA has no data on the
characteristics or the volumes of drum rinsate generated at
this facility.

During the spring of 1988, a spill occurred at the
warehouse after drums of methylene chloride arrived in damaged
condition. As a result, according to ARCO personnel
interviewed during the site visit, ARCO shipped eight 55-gallon
drums of methylene chloride-contaminated materials to a RCRA
Subtitle C facility in the Lower 48 States. According to
ARCO personnel interviewed during the site visit, this was
ARCO's first shipment of hazardous waste from its Arctic
operations. Currently, AOEC and EPA have no reliable
information concerning the amount of methylene chloride or
other chemicals used in the North Slope oil fields.

Conclusions

Based on observations at the sites and the data currently
available to EPA (which are summarized above), EPA concludes
that:

•	EPA needs additional information on how the
drums received at these facilities have been
used, how long they are stored prior to
cleaning, and the chemical characteristics of
the rinsate to determine the regulatory status
of these facilities under Subtitle C of RCRA.

•	EPA and ADEC should inform operators and service
companies about the regulatory status of drums
and drum rinsates.

11 Alaska has no RCRA permitted commercial hazardous waste
treatment, storage, or disposal facilities.

* * * 6/89 DRAPT * * *

-------
3-29

3.4.2 Hazardous Waste Storage Facilities

There are three hazardous waste storage facilities on the
North Slope, all of which have interim status under Subtitle C
of RCRA. EPA visited one of these facilities, the Standard
facility on C pad. Standard uses this facility to store drums
containing hazardous wastes, such as off-specification
chemicals and laboratory wastes.

Standard's Hazardous Waste Storage Facility

Standard operates an interim status hazardous waste
storage facility on C Pad in the Western Operating Area of the
Prudhoe Bay complex. The site consists of a rectangular
unlined below-grade gravel pit, which is surrounded by gravel
berms on three sides — the fourth side is on-grade — and a
waste lubrication oil tank.

At the time of the site visit on June 15, 1988, EPA
observed that the site appeared to be operated in a neat,
orderly manner. The gravel pit area was used to store
hazardous waste in 55-gallon drums, which were placed inside
overpack drums as a method of secondary containment. The
overpack drums were stacked two high on wooden supports.
According to Standard personnel interviewed during the site
visit, the types of hazardous wastes stored in drums in the
gravel pit area at this facility included off-specification
fuels, solvents, waste corrosion inhibitors, unidentified
wastes, and laboratory wastes. Standard personnel at the site
also indicated that (1) waste shipments are made periodically
to a RCRA Subtitle C facility in the lower 48 states; and (2)
storm water that collects in the bermed area is injected in a
Class II disposal well.

Standard's waste lubrication oil storage tank is located
adjacent to the gravel pit area used for drummed storage of
hazardous waste. The tank is surrounded by a separate gravel

12	Standard Alaska Production Company submitted a RCRA Part B
Application for this hazardous waste storage area on Pad C on
November 4, 1988. (BP Exploration 1989.)

13	In comments provided after the site visit, Standard
indicated that the wooden racks are used to prevent drifted snow
from interfering with inspection of the drums. (Standard 1988.)

u The Standard personnel at the site indicated that Standard
has not analyzed the chemical composition of the storm water. EPA
needs additional information to determine whether this lack of
analysis is consistent with AOEC policies and regulations.

* * * 6/89 DRAFT * * *

-------
3-30

berm for spill containment that is lined. According to
comments submitted by Standard following the EPA visit, "all
waste oil that is stored at C-Pad is chemically analyzed for
parameters required by the used oil criteria in 40 CFR Part 266
(the used oil criteria).... Waste oil accumulated by
Standard at C Pad in 1987 was shipped to Chemron, a waste oil
recycler in Palmer, Alaska." (Standard 1988.)

According to ADEC personnel on the site visit, the area
around the waste oil tanJc was used for a short period of time
for disposal of ash. This ash apparently resulted from a
natural gas flare at this location which burned putrescible and
combustible wastes. (BP Exploration 1989.) (See photos 31
and 32.)

C
-------
3-31

lacks secondary containment for waste spills. Unloaded wastes
are processed through a shale-shaker, which separates liquids
from sludges and solids. The liquids, solids, and sludges are
stored in holding tanks prior to injection or disposal. The
oily liquids are injected via the Class II injection well at
this facility. A private contractor removes the oily solids
and sludges in dump trucks and disposes them at the Oxbow
landfill.

During the site visit, EPA observed oily stains on the
ground around the unloading area. (See photos 15 and 16.)

The ADEC permit for this facility authorizes ARCO to
inject wastes at a depth of 3,000 to 3,500 feet. Based on a
30-day average, the permitted maximum quantity of liquid
industrial waste disposal is 210,000 gallons per day. The
permit authorizes the disposal of produced water, waste oils,
reserve pit fluids, waste brine, crude oil and diesel fuel
samples, glycol, and domestic wastewater. (ADEC 1984.)

Although the ADEC permit requires the permittee to test
all materials that are suspected of being non-exempt hazardous
wastes and exclude them from injection, ADEC is not aware of
any chemical analysis that is performed on the wastes accepted
by this injection facility. According to ARCO personnel
interviewed during the site visit, most accepted wastes would
fail the RCRA ignitability characteristic because of their high
petroleum content.

The permit also requires ARCO to maintain a log on-site
that identifies the date of receipt and source of material
received, volume from each source, that the analysis has been
performed on each load, the results of such testing, and any
information on extraordinary occurrences. (ADEC 1984.)
According to comments submitted to EPA by ARCO following the
site visit, all oily waste loads received by the facility are
manifested under the Kuparuk Oily Waste Manifest system in
compliance with permit requirements. (ARCO 1988.)

Prudhoe Bav Unit Pad 3 Oilv Waste Disposal Facility

Standard and ARCO jointly operate the Pad 3 oily waste
disposal facility in the Eastern Operating Area of the Prudhoe
Bay field. Pad 3 is located in a industrialized area of the
North Slope oil field and bounded on all four sides by oil
production facilities, roads, pipelines, and reserve pits.
Structures at this facility include three injection wells,
which were originally drilled to test the response of
permafrost to different drilling conditions, a large lined oily
waste pit, and a process building. The three wells were
drilled in 1978; the pit was constructed in 1987. Liquids from
the oily waste pit are disposed in the injection wells.

* * * 6/89 DRAFT * * *

-------
3-32

The oily waste pit has a synthetic liner. Thermistors have
been placed in the bottom of the pit to monitor temperature.
At the time of the site visit, EPA observed a number of visible
cracks around the edges of the liner. The condition of the
liner at the bottom of the pit is not known. No monitoring
wells or leak detection devices have been installed at the oily
waste pit. Standard personnel interviewed during the site
visit were considering testing the pit for leaks during the
summer of 1988, but Standard had not yet selected a testing
method to use.

According to ARCO personnel interviewed during the site
visit, the facility lacked cathodic protection for injection
wells and hydrogen sulfide (H-S) detection or warning devices.
However, detection and warning devices had been installed by
August 1988, as was observed by EPA during a second site
visit.15 (See photos 25-30.)

This facility accepts a variety of liquid oily waste as
well as semi-solid sludges and oily, contaminated solids. The
injection well is permitted to inject liquids containing up to
15 percent solids. According to a letter from ARCO to ADEC
dated February 29, 1988, incoming wastes include water-based
and oil-based drilling muds, crude, diesel, diesel gel, water
gel, produced water, brine, gel breaker, workover fluids, lube
oil, arctic pack (diesel fuel), hydraulic fluid, spent acid,
caustic, sea water, fresh water, methanol, contaminated cement,
sand, gravel, snow, and other wastes. (ARCO 1988b.) The
facility also accepts drum cleaning wastes and ARCO's and
Standard's tank cleaning wastes, which include tank bottoms,
separation vessel cleanings, and heat exchanger bundle sludges
from ARCO's diesel fuel-producing topping unit.

Typically, wastes are transported to the facility by
vacuum truck or dump truck. As documented by photographs, EPA
observed that the liquid waste unloading pad lacks secondary
containment, so any spillage from hose breakdowns will drain
into the nearby gravel. (As further documented by photographs,
EPA also observed some oil stains around the solids removal
facility.) The incoming liquid wastes pass through a series of
solids removal processes. The separated liquids are injected,
while the separated sludges are disposed in the pit. Incoming
sludges or solids, which are not appropriate for injection, are
disposed in the pit upon arrival. These sludges and solids,
which do not enter the separation processes, include sludges
from vessel clean-outs and oil-contaminated gravel and snow
removed from drill sites and spill areas.

15 H2S concentrations of 600 ppm are fatal to humans.

* * * 6/89 DRAFT * * *

-------
3-33

According to ARCO personnel interviewed at the site,
fluids are tested for pH, specific gravity, and flash point
before they are injected. Testing is performed at the Pad 3
facility. Chemical analysis is not performed on the incoming
sludges. According to facility personnel, the sludge samples
are not tested for flash point because they are assumed to have
a low hydrocarbon content.

The operators of this facility utilize an internal
manifest system that requires a manifest to accompany each
shipment of incoming waste. As stated in the ADEC permit for
this facility, the permittee must record the date on which a
load is received and its waste type and volume "such that the
waste type category selected portrays the nature of the oily
waste stream." At the time of the site visit, EPA observed
that information was properly recorded as required by the
operating permit.

For regulatory purposes, ADEC views the Pad 3 facility as
two separate entities:

(1)	The surface facilities for the Class II
injection wells, which are permitted by ADEC
under a wastewater permit (and by AOGCC); and

(2)	The oily waste pit, which is permitted by ADEC
under a solid waste permit.

Currently, these permits do not allow disposal of RCRA
hazardous wastes.

The operators of this facility have applied to EPA Region
X for a permit classifying all three of the injection wells as
Class I non-hazardous disposal wells. The wells are currently
classified as Class II disposal wells under the state's
Underground Injection Control program and are regulated by the
Alaska Oil and Gas Conservation Commission. Public comment
prepared by Trustees for Alaska and received by EPA Region X on
the operator's application for repermitting these Class II
wells as Class I provided information that raises some
questions about the performance and integrity of the Pad 3
injection wells. EPA has not confirmed the facts alleged by
the Trustees. The major points provided by the comments are
included to indicate the nature and extent of the problems that
may exist at this facility.

The following summary of some major issues raised by these
comments includes concerns over the volumes and types of wastes
to be disposed at Pad 3. (Trustees 1988 and 1988a.)

• The volume of waste proposed for injection
for the next 10 years is approximately 10

* * * 6/89 DRAFT * * *

-------
3-34

times more than the volume injected in the
past 12 years.

•	The Prudhoe Bay Field is becoming a sour
field. The oil field is saturated with
increasing concentrations of hydrogen
sulfide. As of 1988, process vessel
sludges, which are eventually disposed in
Pad 3, contained concentrations of hydrogen
sulfide that approached 1,000 mg/L.

•	The Oily Waste Injection Facility is close
to ARCO's Drill Site 6. Wastes injected at
Pad 3 may invade the area beneath the
permafrost under Drill Site 6. This waste
is or could soon be in contact with Drill
Site € well bores at depths between 1,900
feet and 2,300 feet and for some distance
above and below this area. The corrosivity
of the waste could cause a catastrophic
wellhead failure.

•	The fluids injected at Pad 3 may
significantly affect containment of
injected fluid at Pad 3. Containment
ultimately depends on the integrity of the
overlying permafrost. The fluids injected
at Pad 3 consist of a large portion of
antifreezes or freeze depressant fluids
such as methanol, ethylene glycols, diesel
fuel, and natural gas liquids. Many of
these liquids, which are less dense than
water, may rise to the area immediately
beneath the permafrost.

As stated above, the comments submitted by the Trustees
for Alaska to EPA Region X on the application for Class I
status at this injection facility are included here to
illustrate the nature and extent of possible problems at this
facility. These comments have not been confirmed or refuted by
ARCO or Standard. The permit application for Class I status at
this facility is pending.

Conclusions

Based on observations at the sites visited and the data
currently available to EPA (which are summarized above), EPA
concludes that:

•	Given our knowledge of the wastes received at
the Kuparuk Oily Waste Class II Injection
facility, the operator should test non-exempt

* * * 6/89 DRAFT * * *

-------
3-35

wastes unless they have sufficient information
to be certain that the wastes are not hazardous.
As a practical matter, some testing is probably
necessary to provide that certainty.

3.4.4 Recycling Facilities

EPA does not have information on file to indicate the
total number of or types of operations performed at recycling
facilities on the North Slope. However, EPA did visit one
facility, ARCO's. Kuparuk Field Oily Waste Recycling Center, at
which oil is reclaimed from oily wastes such as lubricating
oils, workover wastes, pigging wastes, and diesel oil used in
hydrostatic testing.

ARCO's Oilv Waste Recycling Center - Kuparuk Field

ARCO operates an oily waste recycling center in the
Kuparuk Field for wastes containing recoverable hydrocarbons.
This facility is similar to a crude oil reclaimer in the lower
48 States. Structures at this site include four above-ground
separation tanks, three storage tanks within a lined gravel
berm, a heat treatment vessel, and an empty, partially lined
pit. According to ARCO personnel, this facility receives oily
wastes from well flowback, diesel from hydrostatic testing,
pigging wastes, lube oils, workover wastes, and other wastes.
ARCO does not perform chemical analysis to characterize the
wastes accepted by this facility; however, ARCO does use an
internal manifest system to track wastes being disposed here.
ARCO personnel were unsure of the purpose of the pit.

According to ARCO personnel interviewed during the site
visit, ARCO vacuum trucks deliver the oily wastes, which are
pumped into a series of four above-ground tanks that separate
the oil/water/solids mixture. Hydrocarbons are removed from
the incoming oily wastes by a heat treatment process and are
piped to the crude oil stream. The nonrecoverable liquids are
commingled with water destined for ARCO's waterflood
operations. The solids and sludges are disposed at the Oxbow
landfill.

As documented by photographs, EPA observed oily stains
from drips and spills on the gravel around the facility. EPA
observed similar evidence of spills from tanks that had
apparently overflowed. None of the tanks was equipped with a
high-level alarm to alert the operator of the impending
possibility of overflow. The unloading area, which had visual
evidence of what appeared to have been numerous spills, did not
have secondary containment. Consequently, spillage from hose
failure or uncoupling can drain into the nearby gravel. EPA
observed oily sheens on the water surface around the unloading
area during the site visit. (See photos 17-22.)

* * * 6/89 DRAFT * * *

-------
3-36

ConclMgigng

Based on observations at the site and the data currently
available to EPA (which are summarized above), EPA concludes
that:

•	ADEC should consider requiring submission of
records on the wastes disposed at this facility;

•	ADEC should investigate the pit with the unknown
purpose; and

•	Improved controls on waste delivery operations
would reduce waste spillage and the potential
off-site migration of contaminants, especially
resulting from snow removal operations.

3.4.5	Oily Waste Pits

The two oily waste pits visited, ARCO's Pad 3 and Oxbow
Landfill, are discussed in Sections 3.4.3 and 3.4.7
respectively.

3.4.6	Abandoned or Closed Landfills and Disposal Pits

These sites are significant because they still contain
wastes and they were closed according to former State
permitting requirements, which may not have been adequately
protective of the environment.

Standard's East Dock Pits

The East Dock facility is located on the eastern shoreline
of Prudhoe Bay approximately 3 miles southwest of Heald Point
and 2 miles west of the westernmost channel of the
Sagavanirktok (Sag) River. The three-celled reserve pit,
closed since 1987, was constructed in 1980 and was used for
disposal of muds and cuttings from off-shore drilling
activities during the 1981 and 1982 exploration drilling
seasons. Two of the cells received mud and cuttings, while the
third cell received treated sanitary wastes from the East Dock
camp. (Sohio 1984.}

At the time of the visit in June, EPA observed that the
pit closure activities had left the area with a tidy
appearance, although the site had not been revegetated. (EPA
did not take any photos of this site.)

EPA's review of site history documentation indicated that
on July 27, 1984, Standard informed ADEC that w[o]n July 23,
1984, Sohio [Standard] personnel discovered significant leakage
of the reserve pit dike in cell No. 2." Standard also

* * * 6/89 DRAFT * * *

-------
3-37

discussed its plans for correcting the problem. (Sohio 1984.)
On August 28, 1984, ADEC replied that leakage of the dike and
review of Department records raised several concerns.

•	First, authorization to use the East Dock area
as a mud sump had been limited to a three-year
period, during which the operator was to develop
a plan for the ultimate disposal of off-shore
generated drilling muds and cuttings. However,
the Department had not received the plan.

•	Second, the reported leakage indicates a failure
to comply with the Army Corps of Engineers*
construction permit requirement that the dikes
be impermeable.

•	Finally, ADEC had not received the annual
reports of the monitoring program as required by
the Army Corps of Engineers' permit.

As a result of these concerns, ADEC required the final closure
of Sohio's East Dock Reserve Pit facility and requested
Standard to submit final closure plans to ADEC. (ADEC 1984a.)

On August 7, 1987, ADEC granted Standard final approval to
proceed with the closure of the East Dock pits. Standard
placed gravel in the two mud-containing sumps and sampling
monitors and thermistors in late August of 1987. According to
Standard, thermistor measurements and water quality samples
were taken during the summers of 1987 and 1988. Standard also
indicated that results from the 1987 sampling would be
submitted to ADEC prior to October 1, 1988. (Standard 1988.)
However, ADEC informed EPA that, as of October 14, 1988, the
Northern Regional Office had not received this report.

According to Standard, the East Dock pit closure is being
used to test closure and revegetation techniques that will
eventually be implemented elsewhere on the North Slope.

arco's Pincrnt Pit

At the time of the site visit on June 16, 1988, Pingut Pit
was a closed below-grade reserve pit. When constructed, the
pit was approximately 270 feet by 380 feet, 13 feet deep,
unlined, and had no leak detection system. ARCO first used the
pit in 1976 to dispose drilling wastes, and later used it as an
oily waste pit to store drilling and production wastes. Liquid
wastes stored here included tank washing wastes, production
separator sludge, natural gas liquids, oil-based drilling muds,

* * * 6/89 DRAFT * * *

-------
3-38

lost circulation material waste, workover wastes, and pigging
wastes. (ARCO, 1987a.) 6

During the site visit, EPA observed that the pit had been
covered with overburden, which had been graded and leveled.
EPA also observed that the site was not vegetated, that no
petroleum odors were noticeable, and that thermistors for
monitoring the temperature of the pit were visible. Review of
the closure plan following the site visit in combination with
observations made at the site indicate that thermistors
appeared to have been installed and that the overburden had
been graded according to the specifications agreed upon by ARCO
and ADEC.

ARCO closed the pit in 1987 at the request of ADEC
following ADEC's discovery that the pit was discharging
•'nondomestic wastewater into and onto the lands and waters of
the state without a permit."17 (ADEC 1986a.) On June 11 and
12, 1986, during a general inspection (i.e., fly over) of the
area, an ADEC official observed and documented that
oil-contaminated water was overtopping the secondary
containment diJce around the pit and that a large quantity of
crude oil was floating on the surface of the pit. (Personal
communication, ADEC, 1988, and field notes, ADEC, 1986, Re:
Pingut Pit inspection, 11 and 12 June, 1986.) At this time,
ADEC advised ARCO of the situation. (ADEC, 1986a.) ADEC
collected one sample of the pit water from between the primary
and secondary dikes around the pit, which yielded a combined
benzene and toluene concentration of 800 ppm. (Personal
communication, ADEC, 1988, Re: Sample No. 1351, 12 June,

1986.)

On a subsequent inspection of Pingut Pit, ADEC officials
discovered that conditions at the pit appeared unchanged. On
July 29, 1986, ADEC issued a Notice of Violation (NOV) for the
oily waste discharges at Pingut Pit that required ARCO to
discontinue any further use of the pit and to submit plans and
a schedule for closing the site. ADEC charged that the oily
waste discharge was a violation of State regulation 18 AAC
72.210 and that "containment by the pit is inadequate for an
oily waste disposal storage site." (ADEC 1986.) The NOV also
noted that (1) no permits had been issued for operation or use

16	Information from this document was obtained by EPA over the
telephone. EPA plans to request a copy from ADEC.

17	Such discharges are currently prohibited by AS 46.03.100
and 18 AAC 72.210(a).

* * * 6/89 DRAFT * * *

-------
3-39

of the facility; (2) the facility's locations was "such that
any hydrocarbons or contaminants that escape from the pit will
go directly into the Sagavanirktok River floodplain;" and
(3) the Department of Fish and Game has shown "great concern"
about this possibility. (ADEC 1986.)

In response AOEC's directive that the pit be closed, ARCO
selected and ADEC approved freeze-back as the final closure
method for this pit. The revised closure plan submitted by
ARCO in February, 1987 (and apparently approved by ADEC20)
called for the one to two foot sludge layer on the bottom of
the pit to be covered with two to three feet of gravel followed
by six to seven feet of overburden graded to a final slope of
approximately one percent to facilitate drainage. At the
request of ADEC, ARCO estimated the "oil to soil ratio" of the
sludge in the bottom of the pit by measuring the oil and grease
content as a percent of the soil's weight for six samples
collected at various locations around the pit where the sludge
appeared to contained hydrocarbons. The resulting chemical
analysis of the six samples showed oil and grease levels
ranging from 0.3 to 12.6 percent of the wet samples, with a
median of 7.8, and from 0.4 to 15.5 percent of the dry samples,
with a median of 10.7. (ARCO 1987.)

To measure the effectiveness of freeze-back following
closure, the approved closure procedure included installation
of "a thermistor string to monitor the temperature profile down
to the sludge zone." (ARCO 1987.) Thermistor string #1,
located about 80 feet southeast of the pit center, was
installed on September 29, 1987 after closure earthwork was
finished. In response to an ADEC request, ARCO provided ADEC
with information on thermistor installation and thermistor
readings in May 1988. The thermistor readings provided for May
5, 1988, indicated that subsurface temperatures were 20.7ฐF or
less from 1 foot above to about 3 feet below the sludge layer.
(ARCO 1988c.)

The closure plan submitted by ARCO called for use of the
primary containment berm at the site as the source of

18	If constructed subject to current regulations, this pit
would be regulated by ADEC as a solid waste disposal facility and
required to obtain a waste disposal permit.

19	EPA plans to request additional information from the
Department of Fish and Game about the specific nature of their
concerns.

20	No written documentation of ADEC approval of the plan was
available in the files of the Northern Regional Office of ADEC in
Fairbanks.

* * * 6/89 DRAPT * * *

-------
3-40

overburden for fill and final cover of the site. At ADEC's
request, ARCO collected borings from six locations in the
overburden berm and at a control location approximately 60 feet
North of the access road to. Pingut Pad on October 28, 1986.
Samples were collected at three depth intervals from each
boring, which ranged in depth from 5 to 11 feet, and analyzed
for purgeable aromatic hydrocarbons (EPA SW846-8020), oil and
grease (Standard Method 503B), hydrocarbons (Standard Method
503E), and polynuclear hydrocarbons (EPA Method 610).
Hydrocarbons and polynuclear hydrocarbons were not detected (in
the ppm range) in amy of the samples analyzed. Purgeable
aromatic hydrocarbon concentrations reported were as follows:

Depth (feet^

Purgeable Aromatic Hydrocarbons fppbl

Control

2-3
4-5
6-11

5.5-69.9

0.0-295.0

6.4-110.8

15.5
5.0
17.0

The oil and grease content of the control sample was 6 ppm,
while oil and grease in the overburden samples ranged from 8
ppm to 58 ppm. Although ADEC personnel had some concerns (as a
result these testing data) that use of the overburden berm
material as final cover for the pit could lead to off-site
migration of contaminants when the top several feet of
overburden thaws during breakup, ADEC agreed to use of the
material as final cover. (Personal communication, ADEC, 1988.)
(No photos were taken of this site.)

Old Surfcote Landfill - ARCO Fire Training Facility

The Surfcote Landfill was ARCO's primary disposal location
for industrial wastes generated by North Slope oil field
operations before the opening of the Oxbow Landfill's oily
waste pit in 1980. In 1980, ARCO converted the site to a fire
training facility. According to ARCO personnel interviewed
during EPA's visit to this site in August 1988, various props,
soaked in diesel fuel, other flammable liquids, and/or natural
gas, are ignited for the staging of training exercises. After
a fire is extinguished, oily wastes drain into a lined
collection pit. At the time of EPA's visit, it was not
apparent whether the entire pad or only the pit was lined. EPA
observed a visible sheen on the pit surface. An oily residue
observed on the pad indicated that oily liquids may have flowed
across the gravel pad. Several unlabeled drums of oily waste
were located on-site at the time of EPA's visit. As stated by
ARCO, the practice of using liquids and gases that contain
hydrocarbons to ignite props at this facility is being
discontinued.

* * * 6/89 DRAFT * * *

-------
3-41

According to ADEC, the State does not have good records of
what wastes were disposed at this site during the late 1970s
ana early 1980s. However, according to ADEC, in 1980 ARCO
buried an estimated 9,300 to 20,000 cubic yards of scrap metal
in a single event at the Surfcote site under an ADEC solid
Yftrt f disposal permit. The waste included approximately 500 to
600 tons of crushed drums which were judged to be unacceptable
for scrap metal recycling because they contained chemical
residues.

Conclusions

Based on^observations at the sites visited and the data
currently available to EPA (which are summarized above), EPA
concludes that:

•	ADEC needs additional information to verify that
freeze-back is effective at the sites at
Standard's East Dock Pits and Pingut Pit
throughout the year and over the entire pit
areas;

•	Additional information is needed to determine
the effectiveness of the closure and
revegetation measures taken at Standard1s East
Dock Pits;

•	Additional information is needed to determine
what levels of contamination are acceptable in
cover material used in the Arctic; and

•	Without additional information, EPA cannot draw
conclusions concerning why it took three years
for Standard to develop and ADEC to approve a
closure plan for the East Dock Pits site.

3.4.7 Landfill

There is only one active landfill in the North Slope.

The Oxbow Landfill, operated by the North Slope Borough,
is the primary off-site disposal site on the North Slope for
municipal solid waste, incinerator ash, and industrial waste
that is1 not recycled or disposed through subsurface injection.
The landfill is located on a portion of an abandoned gravel
mine site adjacent to the Putuligayuk (Put) River. A natural
dike separates the landfill, which is located in an oxbow of
the Put River, from the river.

* * * 6/89 DRAPT * * *

-------
3-42

The landfill has two unlined pits, one for solid wastes
and the other for oily wastes, that together form an oval-
shaped area approximately 1600 feet by 1200 feet. (North Slope
Borough 1988.) These pits, which were originally part of a
gravel mine, are separated by a gravel berrn. The solid waste
pit receives industrial waste and domestic garbage and measures
1200 feet by 1200 feet. The smaller oily waste pit, which
measures 800 feet by 400 feet, receives oily wastes generated
by production and service companies on the North Slope. ADEC
has permitted this facility to accept all solid (i.e., RCRA
Subtitle D) wastes, including all oil and gas field wastes
exempt from RCRA Subtitle C regulation; however, the facility
is not permitted to accept RCRA hazardous wastes.

The Oxbow Landfill is the only oily waste disposal site on
the North Slope that is available to the service companies, and
as previously mentioned, wastes generated by service companies
are generally not exempt from Federal regulation under RCRA
Section 3001 and, therefore, are subject to regulation under
RCRA Subtitle C if they are listed or exhibit one or more
characteristics of hazardous wastes.

Both the solid waste pit and the oily waste pit are
constructed of gravel and are unlined. Gravel berms surround
both pits. Because permafrost within these containment, berms
serves as the only barrier to prevent the release of
contaminants from the pits, thermistors have been installed at
the perimeter of the pits to monitor the temperature of the
berms. ADEC does not have information available on the
frequency or results of readings from the thermistors. The
only techniques employed to prevent or monitor possible waste
migration are visual observation and thermistor readings.

The solid waste pit is currently filled to approximately
half its total potential capacity.21 Wastes disposed at the
landfill include airplanes, vehicles, used machinery, crushed
drums, building materials, insulation, tires, incinerator ash,
domestic garbage, and a variety of industrial wastes.

According to ADEC personnel present during the site visit,
waste lumber is routinely burned on-site, which constitutes a
violation of EPA's solid waste disposal guidelines at 40 CFR
257.3-7(a) ,22

21	This approximation is based solely on a visual estimation
by EPA of1 the remaining available capacity of the landfill at the
time of the site visit. Because the original depth of the gravel
mine pit at the time it was converted for use as a landfill is
unknown (to EPA), EPA cannot estimate the total capacity of the
solid waste pit.

22	Based on a preliminary review, Alaska's Solid Waste and Air
Quality Control Regulations do not appear to prohibit such burning.

* * * 6/89 DRAFT * * *

-------
3-43

On the day of the site visit, EPA observed a large
exposure industrial waste and municipal solid waste in the
solid waste pit. Seagulls were feeding on large piles of what
appeared to be incinerator ash.23 According to ADEC personnel,
the North Slope Borough has improved its housekeeping at the
landfill over the last two years in response to enforcement
oversight by ADEC. (See photos 87-98.)

The oily waste pit was opened in May 1980. ADEC reissued
a permit for the pit on March 3, 1987 (Permit No. 8636-BA023).
According to the North Slope Borough (1988), at the time the
permit was reissued, the life expectancy of the oily waste pit
was estimated to be 10—12 years, based on a remaining storage
capacity of 110,000 cubic yards and on the volume of waste
received annually at the site (10,000-12,000 cubic yards) since
1980. However, between January and September 1988, the oily
waste pit received 102,000 cubic yards of oily wastes,
including 72,000 cubic yards of drilling waste that was brought
to the oily waste pit over a six-week period in April and May.
Overall, the following volumes of materials were delivered to
the Oxbow Landfill during the first nine months of 1988 (North
Slope Borough 1988a):

Cubic Yards of
M
-------
3-44

constructing a second oily waste pit in an adjacent portion of
the former gravel mine site. The permit application proposed
improvements over the design of the current oily waste pit,
such as installing a full liner in the bottom of the pit.
However, due to concerns regarding pit design, maintenance, and
operation, ADEC and the Army Corps of Engineers have not issued
the new permit to the Borough.

In public comments on the Borough's application for
expanding the oily waste capacity at the Oxbow that were
submitted to ADEC, the Trustees for Alaska expressed concerns,
summarized below, about the performance and integrity of the
proposed second oily waste pit. EPA has not confirmed the
facts alleged by the Trustees, and includes major points
provided by the comments only to illustrate the types of issues
that can be raised by waste management practices on the North
Slope.

•	It is not clear that permafrost can be relied
upon for waste containment because:

(1)	The North Slope Borough's waste acceptance
criteria do not prevent the disposal of
wastes contaminated with glycol, methanol,
gasoline, diesel, or other light
hydrocarbons which will act as freeze
depressants and may prevent the freezeback
of the emplaced wastes; and

(2)	USGS maps show several old stream courses
immediately adjacent to the Oxbow pits
which may have thawed areas containing
water beneath them that may be in
communication with the Putuligayuk River.

•	The proposed method for anchoring the liner to
the berm appears to assume that the berm will
remain perpetually frozen, which will not be the
case.

•	Placement of the liner directly between layers
of gravel appears likely to puncture the liner,
either from the weight above or from frost
heaves below.

•	A viable plan is needed for managing the fluids
that will collect in the pit, which may be on
the order of 100,000 to 200,000 barrels per
year.

•	It is not clear how a "non-threatening" water
level can be maintained adjacent to the pit,

* * * 6/89 DRAFT * * *

-------
3-45

given that upstream ice jams have previously
raised the river level as much as 22 feet and
storm surges have previously (e.g., 1970)
flooded the Prudhoe Bay area as far as 3 miles
inland.

In a letter to the North Slope Borough dated Februarv 7
1989 (ADEC 1989) ADEC cited several reasons for refusingto
issue this permit:	*

• Because the Oxbow Landfill is adjacent to an
active gravel pit which will form a lake as it
fills with water and which lies on the shore of
an active river channel that may erode the
containment berms and dikes surrounding the
pits, the site would be in direct contact with
surface waters, resulting in the following
violations:

AS 46.03.710 - POLLUTION PROHIBITED. This
statute prohibits pollution of air, land
or subsurface land or water of the state;

AS 46.03.740 - OIL POLLUTION. This statute
prohibits the discharge of oil;

AS 46.03.745 - HAZARDOUS SUBSTANCE RELEASE
This statute prohibits the release of a
hazardous substance as defined in AS
46.09.900;

18 AAC 60.035(2) - This regulation states
that solid waste shall not be placed in
surface water;

18 AAC 60.035(3) - This regulation states
that waste, leachate, or eroded soil from
the facility shall not cause a violation of
the water quality standards in 18 AAC 70-
and

18 AAC 70.010(a) - This regulation states
that no person may conduct an activitv that-
will result in a violation of the water
quality standards.

• Although the pit design specified in the

Borough's permit application utilizes freezebaek
as a containment method, ADEC considers this
proposed method to be ineffective because of tho
oily waste pit's proximity to the gravel pit
Specifically, in the event that the gravel pit

* * * 6/89 DRAFT * * *

-------
3-46

fills with water, the resulting lake would thaw
the adjacent containment berm, thus preventing a
continuous state of permafrost in the berm.

Further, ADEC felt that annual dewatering of the
gravel pit to reduce the potential for thawing
would be impractical due to the permanent nature
of the waste pit.

• ADEC determined that use of the gravel pit for
the capture of wastes from the proposed pit in
the event of berm failure due to thawing would
be unacceptable because the Department does not
intend to exceed the currently permitted
disposal capacity of the gravel pit.

According to ADEC personnel, waste generators do not
provide the landfill operators with a chemical analysis of oily
waste prior to disposal in the oily waste pit and landfill
operators do not perform chemical analysis of the waste before
or after accepting it. According to ADEC personnel, the
Department does not require the Borough to analyze regularly
the contents of the Oxbow oily waste, nor is the Department
aware of any regular analysis that the Borough performs on the
contents of the Oxbow oily waste pit. Further, ADEC does not
require that drums accepted at the Oxbow be triple-rinsed.
According to ADEC personnel, the Department's criterion for
disposal of used drums is that no visible residues remain on
the walls or ends of the drum.

ADEC has not established formal criteria for storm water
management at the landfill. Currently, a sump, which is a low
lying area within the oily waste pit, has been constructed to
collect free oil and storm water. Based on available
information, EPA could not determine how the oily stormwater
collected in this sump is currently disposed. However, ADEC
has previously issued general permits for discharge to the
tundra of stormwater from the landfill. According to ADEC,
this discharge entered the Putuligayuk River through
percolation and subsurface flow. EPA did not issue an NPDES
permit for these discharges.

According to the report issued by the North Slope Borough
on the dewatering of the Oxbow Landfill, which occurred in
1985, supernatant from both the oily waste pit and the solid

24 According to Standard, "the North Slope Borough does require
that a manifest accompany each shipment and that the manifest
certify that the waste meets the Borough criteria for disposal in
accordance with their permit. Additionally, the contents of the
oily waste pit are analyzed regularly. All drums accepted by the
landfill must be triple-rinsed and crushed." (Standard 1988.)

* * * 6/89 DRAPT * * *

-------
3-47

waste pit was pimped onto the tundra under permit from ADEC.
(North Slope Borough 1985.) Discharge to the tundra from the
landfill has not occurred since 1985. Between May 30 and June
29, 1985, approximately 9-10 million gallons were pumped from
the oily waste pit. As required by permit, the Borough
sampled this effluent for total volatile organic compounds
(VOC), which in this case included benzene, toluene,
ethylbenzene, para-xylene, meta-xylene, and ortho-xylene; oil
and grease; chemical oxygen demand (COO); manganese; dissolved
oxygen; and settleable solids. The following concentration
ranges were detected for these constituents:

Constituent

Total VOC

Oil and Grease

COD

Manganese
Dissolved Oxygen
Settleable Solids

Concentration (ma/LI

0.004-0.360

1.4-10.8

105-219

0.16-0.44

1.6-13.2

trace

Between July 27 and August 17, 1985, approximately 14
million gallons of supernatant were discharged from the solid
waste pit under permit from ADEC. The following constituents
and concentration ranges were reported for this effluent:

constituent	Concentration (fliq/L)

Arsenic	0.007-0.032

Barium	0.01-0.3

Cadmium	0.005-0.009

Lead	0.015-0.084

Oil and Grease	1.1-5.4

The oily waste pit was dewatered again between September 9
and October 4, 1985, when 9 to 10 million gallons were
discharged to the tundra. Prior to the second discharge from
the oily waste pit, a water sample was taken from the pit which
indicated the following constituents and concentrations:

constituent	Concentration (mq/L)

Arsenic	0.031

Barium	1.0

Cadmium	0.006

Total VOC	0.473
COD 225

Oil and Grease	7.3

* * * 6/89 DRAFT * * *

-------
3-48

The above data (from North Slope Borough 1985) indicate that
the constituent concentrations in these discharges did not
exceed ADEC permitted limits.

In 1988, the landfill operators initiated an aggressive
snow removal program to remove as much snow as possible from
the pit before it melted during breakup. Snow removal reduces
future fluid levels in the pit and the need for dewatering.
Large mounds of snow containing gravel, debris, and potential
contaminants from the pit were deposited in a designated area
on the tundra. During the. site visit, ADEC indicated that the
gravel contained in the snow removal material is likely to bury
and kill the tundra. A sump located inside the solid waste pit
was created several years ago to collect snow melt. The
operators are in the process of closing this sump by freezing
the water in place.

Conclusions

Based on observations at the site and the data currently
available to EPA (which are summarized above), EPA concludes
that:

•	There is little remaining capacity for disposal
of oily waste on the North Slope. If new
landfill capacity for oily wastes is not opened
soon, the result may be either regulatory
compliance that severely impedes ongoing oil
exploration, development, and production
activities or regulatory noncompliance;

•	The North Slope Borough should have obtained an
NPDES permit prior to discharge to the tundra
and the Put River, and will need to obtain an
NPDES permit before future discharges would be
allowable;

•	Although thawing of the berms can be detected
through the use of the thermistors, EPA
currently does not have adequate information to
evaluate ADEC requirements or North Slope
Borough plans for remediation in the event of
such thawing; and

•	EPA needs more information to determine if the
North Slope Borough has adequate information
gathering mechanisms to insure that hazardous
wastes are not being accepted for disposal at
the North Slope Borough Oily Waste Pit.

* * * 6/89 DRAPT * * *

-------
3-49

3.4.8 Municipal Incinerator

The North Slope Borough Municipal Incinerator is the only
municipal incinerator on the North Slope. This facility, which
was not visited by EPA during June or August, 1988, is included
here for completeness. It represents the only major type of
off-site oil and gas waste management facility on the North
Slope that EPA did not visit.

North Slope Borough Municipal Incinerator - Deadhorse

The North Slope Borough operates an incinerator in
Deadhorse. The incinerator accepts primarily domestic garbage;
however, it also accepts some industrial waste. For example,
according to Standard personnel at the Standard gathering
center that EPA visited, Standard ships all the used filters
generated in its gathering centers to the North Slope Borough
incinerator. These filters include glycol heat transfer
filters, sock type filters, and charcoal filters.

According to ADEC, the incinerator's combustion chamber
operates at between 1000*F to 1200>F in the winter and around
1500ฐF in the summer. The ADEC permit for this facility
requires an operating temperature of at least 1500-F. High
operating temperatures are required for bum efficiency and
destruction of principle organic hazardous constituents (POHCs)
and other toxic compounds. ADEC states that the operators of
this facility are working to increase winter operating
temperatures.

In addition, the facility was first fitted with an
electrostatic precipitator to remove particulates in the spring
of 1988. As mentioned earlier, ash generated at this facility
is disposed at the Oxbow Landfill. (See photo 99.)

Conclusions

Based on observations at the site and the data currently
available to EPA (which are summarized above), EPA concludes
that:

• EPA needs to collect and analyze additional

information about the permit requirements and
the extent to which they are met to draw any
conclusions concerning this facility.

3.5 SERVICE COMPANIES

Service companies perform a variety of operations on the
North Slope, which are described in Exhibit 3-4. These
services include supplying oil field chemicals, such as

* * * 6/89 DRAFT * * *

-------
Exhibit 3-4

OVERVIEW OP HBTH SLOPE SEKVICE COMPANIES VISITED*

ป
ป
ป

a

SELECTED FACILITIES
Frahley Sit*

Deadhoraa Botel Laaaa

Aurora North Fual

B.J. Titan Oil Flald
Sarvicaa

Forward Alaaka Sarvlca
Company

North Slop* Salvage
Slta

Child'* Fad

Dowell-Schlumberger

N.L. Baroid

Halliburton

Vaco

Paak Service Company

SchLumbargar Offahora
Sarvicaa Fad

STATUS		ACTIVITIES	

Inactiva	Abandon ad aarvica ccMapany aita. Old

battarias, atructuraa, and druaa abandonad

on-aita.

Inactive	Abandonad hot*l. DoaMatlc and induatrlal

waata disposed on-aita.

Inactiva	Abandonad sarvica coaipany aita. Uaad

druu, awchinary diapoaad on-aita.

Activ*	Uaad drua* and tanka atorad on-aita.

Inactiva	Abandonad aarvica company aita with uaad

drina atorad on-aita.

Inactiv*	Abandonad aarvica company slta raaedlatad

by A8G0 and Standard.

Inactiv*	Abandonad aarvica company sit* reaediated

by ABCO.

Actlva	Frovidaa downhol* coaptation, workovar

aarvicaa, and varioua chaaicala.

Activa	Suppllas production chaaicala, cement, and

dry bulk chaaicala.

Activ*	Frovidaa downhole aarvicaa and auppllea

acida, complation fluids, ate.

Activa	Maintains dlaaal and gasoline maintenance

ahopa.

Activ*	Providaa a variety of oilfield aarvicaa

utilizinB heavy equipment, such as cranes,
pumper trucks, and conatruction equipment.
Also provides mlacellanaoua oil-field
chemlcala.

Activa	Provides downhole logging services to

production operatora.

WASTE MANAGEMENT

(Beceuae of aaverly Halted available
intonation, EFA cannot determine waata
management practices at lnsctlve and a few
active individual service company sites.]

Oily solids and sludges sre disposed at
Oxbow Oily Haate Pit.

Solids and sludgea are diapoaad at Oxbow
Oily Haste Pit.

Solids and sludges are diapoaad at Oxbow
Oily Haate Pit.

Sollda and sludgea are disposed st Oxbow
Oily Haate Pit.

CJ
I

U1
O

* Thia exhibit ia based on limited Information froa aita visits and aelected written materlala collected primarily in 1988 from ADEC
and facility operators.

-------
3-51

solvents, corrosion inhibitors, antifreeze, emulsion breakers,
acids, bases, biocides, lubricants, drilling fluids, drilling
muds, completion fluids, workover fluids. Service companies
also provide vehicle maintenance, fuel service, and drum
disposal services.

According to ADEC, most solid wastes generated by the
service companies are sent to the Oxbow Landfill, which is the
only permitted land disposal facility on the North Slope that
is available to service companies for disposal of solid waste.
Hazardous waste generated at these facilities are not exempt
from regulation under RCRA Subtitle C and may not be disposed
legally at the Oxbow Landfill.

While some service companies use oil burners to dispose of
oily, liquid waste, not all service companies have such
equipment. Based on available information, it is not possible
to determine how service companies not in possession of oil
burners manage liquid oily waste. Nor is it possible to
determine how service companies using oil/water separators
dispose of the water phase of the waste, which may contain
hazardous wastes. No Class II injection well on the North
Slope is currently available to service companies for disposal
of liquid waste.

Frahlev Service Company - Deadhorse

The Frahley Service Company, located on the Airport Lease
Tract in Deadhorse, supplied North Slope operators with a
variety of support services. Frahley's facility is no longer
operating. It now consists of several dilapidated buildings
located on a gravel pad. The predominant structure on-site is
an enclosed steel shed with a gravel floor. The gravel pad
does not have secondary containment to prevent the migration of
fluids spilled on the pad to the surrounding tundra.

At the time of the site visit on June 14, 1988, EPA
observed hundreds (estimated) of used vehicle batteries
disposed or abandoned at the site. (Spent lead acid batteries
that are not being reclaimed are a RCRA hazardous waste.)

These batteries were strewn about the gravel pad and inside the
buildings. The condition of the batteries varied. Some were
intact, while others were cracked, allowing battery acid to
escape.

EPA also observed between twenty and thirty 55-gallon
drums on the gravel pad, some of which appeared to be empty,
while others were partially full. EPA was unable to determine
the contents of these drums during the site visit. Because of

25 Frahley is a subsidiary of Massey-Ferguson.

* * * 6/89 DRAFT * * *

-------
3-52

the physical condition of some of the drums, spillage appeared
likely or had already occurred. EPA observed evidence of
numerous spills on the gravel pad. The observed spillage was
dark in color and had a strong hydrocarbon odor. Some of the
spillage appeared to have flowed onto the adjacent tundra.

EPA also observed that the gravel floor of the large steel
shed was black and appeared saturated with oil. Hydrocarbon
vapors were noticeable inside the building, which contained
partially full unlabeled drums, various other containers, used
machine parts, tools, and a variety of other debris. (See
photos 48-54.)

During the site visit, EPA also observed large algal mats
on the tundra adjacent to the gravel pad. According to ADEC
personnel accompanying EPA, this area of the adjacent tundra
area had, prior to 1985, received effluent from the sewage
treatment plant at the Prudhoe Bay Hotel. The treated sewage
effluent discharge point has since been extended further onto
the tundra.

On July 6, 1988, AOEC issued Mr. Jerold Johansen, the
current owner of the Frahley site, a Notice of Violation of the
oil and hazardous substances discharge regulations (18 AAC
75.080) for discharging hazardous substances on the Deadhorse
Airport Lease Tract both within the steel shed and on the
gravel pad. During an inspection of the Deadhorse service area
on June 15, 1988, an ADEC official observed evidence of spills
in the steel shed and used batteries disposed at the rear of
the pad, some of which had been broken open. The official also
observed open barrels of liquids including waste oils. The
official noted in the July 6 letter to Mr. Johansen that none
of the spills had been reported to ADEC within the prescribed
time period allowed by regulation. The Notice of Violation
required Johansen to submit a spill report documenting each
observed spill, remove and properly dispose the batteries, and
submit a cleanup plan for the site for ADEC's review and
approval. (ADEC 1988e, I988f.)

According to documents from ADEC and the attorney
representing Mr. Johansen, these parties have disagreed over
responsibility for discharges of hazardous substances at the
Frahley site. According to Mr. Johansen's attorney, Mr.
Johansen could not be held responsible for the discharges at
the site because (1) he did not use the property in any manner
following his re-acquisition of the property on August 24,
1987, the date of the foreclosure sale; and (2) the alleged
discharge of hazardous substances occurred while the site was
occupied by Walter Ratterman and/or Deadhorse Properties, the
lessors of the property before the foreclosure sale. (Kellicut
and Jones 1988.) (These defenses may be inadequate because
discharges at the facility have continued since the foreclosure

* * * 6/89 DRAFT * * *

-------
3-53

sale. (See Section 2.1.4.) The current owner may also be
liable for the cleanup of the hazardous substance releases
under the Federal Comprehensive Environmental Response,
Compensation, and Liability Act.) After initial contact was
made with Mr. Johansen's attorney over the telephone following
receipt of the letter, Mr. Johansen's attorney did not return
subsequent ADEC calls. ADEC is currently holding Mr. Johansen
responsible for cleanup of the site. (ADEC 1988e.)

As of September 21, 1988, the batteries at the site had
been moved to one corner of the pad and were being covered with
snow removed from the other areas of the pad; no cleanup had
begun in the large steel building, nor had any of the drums
been removed from the gravel pad. According to ADEC, an
unknown party removed the batteries from the site between
October 21 and October 30, 1988. (ADEC 1988e.)

Deadhorse Hotel Lease Tract - Deadhorse

Great Northern Services of Anchorage operates the
Deadhorse Hotel lease tract. Since its original use as a
diesel fueling station for vehicles at the inception of oil and
gas activity on the North Slope, the Deadhorse Hotel lease
tract has been a support services staging ground for Prudhoe
Bay oil and gas operators. The site now consists of an
abandoned hotel, several smaller shop buildings that house oil
field well service companies who lease the buildings from Great
Northern, an incinerator, and a lined pit containing two fuel
tanks. The fuel tanks have an estimated capacity of 10,000
gallons each and are situated in an area that serves as a
diesel fuel storage and filling area. These facilities sit on
a gravel pad that is surrounded by tundra. An access road
separates the site from a lake that serves as a source of
drinking water for the town of Deadhorse.

During the site visit, EPA observed a variety of wastes
generated by oil field support service companies that were
apparently abandoned on-site, including dozens of empty and
partially full 55-gallon drums, unused chemicals, used
batteries, abandoned tanks and vessels, steel parts, and
general debris. Some of the partially full, unlabeled drums
contained what appeared to be lube oil, snow pack, and
unidentified substances. The condition of these drums was fair
to poor. A few of the drums were leaking.

EPA also observed large piles of garbage stacked on the
gravel pad. The garbage contained a variety of wastes
including domestic garbage, painting wastes, used vehicle
batteries, and engine oil filters. An on-site incinerator
appeared to have been used to incinerate industrial waste and
domestic garbage. Incinerator ash was piled without secondary

* * * 6/89 DRAFT * * *

-------
3-54

containment near the incinerator. The State does not require a
permit for an incinerator of this size.

EPA observed-stains, apparently from fuel spills, and
odors near the fuel tanks in the fuel storage area and fuel
floating in pools on the gravel pad. According to ADEC
personnel present during the site visit, spilled fuel has
previously washed across the road serving this facility and
entered the adjacent lake.

As documented by photographs, EPA observed that storm
water runoff from one side of the pad had carried a thick,
unidentified white substance from the pad to the tundra. Fuels
and other unidentified substances appeared to have saturated a
several hundred foot area of gravel pad. One piece of
absorbent material measuring approximately three square feet
was observed in the spill area. (See photos 55-67.)

About three weeks after the site visit, ADEC issued a
Notice of Violation to Great Northern Services for the numerous
spills observed by ADEC during the site visit. The letter
accompanying the Notice of Violation charged that Great
Northern Services had failed to report, within the prescribed
time, these spills, which included hydrocarbons, calcium
chloride, ammonium chloride, and broken batteries. ADEC
requested that Great Northern Services:

•	Submit a spill report for each spill;

•	Perform an immediate cleanup of gross spillage;
and

•	Submit a plan for final cleanup to the
Department for approval before being
implemented.

A deadline for response by the owner was not included. (ADEC
1988g; ADEC 1988h.)

On September 26, 1988, ADEC received a response from
Alaska Technical Services, Inc., representing the Deadhorse
Hotel, that identified two areas of concern at the pad. The
first area was the fuel storage area described above. Alaska
Technical Services proposed excavating the contaminated
material for disposal at the North Slope Borough landfill
coupled' with testing the cleaned area to ensure compliance.
The second area of concern was the interior of a shop building
currently occupied by Arctic Coiled Tubing, an oil field
service company. Alaska Technical Services proposed to remove
the surface contaminants and to perform additional testing of
the pad under the existing wooden flooring. Alaska Technical
Services also proposed sampling the gravel on the remaining

* * * 6/89 DRAFT * * *

-------
3-55

pad, using a wide grid pattern. (Alaska Technical Services
1988.)

In September, ADEC officials met with the cleanup
contractor and discussed cleanup plans. In October, the
Department received a copy of a report•written by Alaska
Technical Services for the operator of the Deadhorse Hotel
discussing remedial work performed at the Deadhorse Hotel. The
report stated that, after discussion with representatives of
ADEC, three main pad areas with hydrocarbon contamination were
addressed: The fuel storage area, the Arctic Coiled Tubing
shop building, and a set of two pits in front of another shop
building. According to the report, contaminated gravel had
been cleared from the fuel storage area and the shop building
and disposed at the Oxbow Landfill. (Alaska Technical Services
1988a.)

The fuel storage area was found to have sections that were
"obviously contaminated with diesel oil." Nineteen samples of
the area detected total elutriate petroleum hydrocarbons
ranging from less than 1 mg/1 to 260 mg/1. Materials from this
area were excavated and disposed at the Oxbow Landfill. The
pit had not been refilled, pending the availability of gravel
for backfill. (Alaska Technical Services 1988a.)

Analysis inside the Arctic Coiled Tubing shop building
revealed extensive hydrocarbon contamination from hydraulic
fluid, which necessitated excavation down to the tundra. Two
surface samples taken inside the building measured 436 mg/1 and
472 mg/1 total elutriate petroleum hydrocarbons. Full
excavation had not been completed. The excavated material was
disposed at the Oxbow Landfill. The pit remained open pending
further action by the lease-holder. (Alaska Technical Services
1988a.)

Four samples of the gravel beneath the two pits in front
of the other shop building contained total elutriate petroleum
hydrocarbons ranging from less than 1 mg/1 to 14 mg/1.
Contamination in this area extended down to the tundra.

Excavated materials were disposed at the Oxbow Landfill, and
the two pits were backfilled with gravel. (Alaska Technical
Services 1988a.)

A letter from ADEC to the Deadhorse Hotel, dated October
28, 1988, acknowledged the positive response to the NOV in
terms of the cleanup of gross spillage. However, the letter
requested that a formal work plan be submitted for approval
before final cleanup is implemented. (ADEC 1988.)

• * * 6/89 DRAFT * * *

-------
3-56

Aurora North Fuel - Deadhorse

Aurora North Fuel, on oil field service company, formerly
used this site. At the time of the site visit on June 15,
1988, EPA observed that this facility contained dozens of used
drums, machinery parts, and general debris. Some of the drums
were not labeled, while others had labels indicating that they
contained hydraulic fluid, motor oils, or diesel fuels. EPA
observed that some of these drums were in poor condition, as
evidenced by visible holes and other signs of corrosion, and
appeared to be leaking onto the gravel pad, which did not have
secondary containment. Some absorbent materials were placed
around the leaking drums in an apparent attempt to contain the
spillage. EPA also saw evidence of several fuel spills in
other areas of the gravel pad.

According to ADEC, as of Fall 1988, it has been unable to
take follow up actions at this site because of lack of
manpower. (See photos 68-71.)

B. J. Titan Oil Field Services - Deadhorse

B. J. Titan operates an oil field services facility in
Deadhorse. Among other functions, the facility stores drums
containing various liquid chemicals and crushed drums. EPA
does not have adequate information to determine the disposal
method for drum rinsate or residue that may be generated at
this site prior to drum crushing. B. J. Titan also maintains
acid storage tanks, which are surrounded by a cement berm, and
an adjacent acid tank washout area.

At the time of the site visit, EPA observed that several
dozen drums were stacked in an apparently random fashion on
site. Most of the drums were stored without secondary
containment. Many of them appeared to be in poor condition,
exhibiting signs of damage, rust, and corrosion. While many
drums contained unidentified liquids, some had labels
indicating that corrosive liquids were present. EPA also
observed that the site contained a large number of crushed
drums.

As documented by photographs, the acid storage tanks at
this facility lacked adequate secondary containment. At the
time of the site visit, the cement berm around the acid storage
tanks was crumbling or absent in places. The acid tank washout
area was not provided with secondary containment. At the time
of the site visit, EPA observed evidence of what appeared to be
wet and dry cement spillage from the pad onto the tundra. The
tundra in this area was dead. As documented by photographs,
EPA also observed oily stains and spillage of an unidentified
white substance on the pad. (See photos 72-77.)

* * * 6/89 DRAFT * * *

-------
3-57

Subsequent to the EPA site visit, B. J. Titan constructed
secondary containment structures for the drum storage area,
even though State law does not require secondary containment
for drum storage. (ADEC, Personal communication, 1988.)

Forward Alaska Service Company - "Deadhorse

Forward Alaska, an oil field service company, operated a
site in Deadhorse leased by the State ADNR. The vacated site,
still under lease from the State, is located directly adjacent
to the North Slope Borough water impoundment, which is a source
of domestic water used in the Prudhoe area. Among other
functions, the Forward Alaska site was used to store used drums
containing various oil field chemicals. The facility includes
an on-site building that formerly staged oil field service
activities and stored oil field chemicals.

At the time of the site visit, EPA noted that a wooden
platform, supported on pilings a few feet above the pad, was
used to store a variety of used drums, batteries, and general
debris. EPA observed that most of the drums on this platform
were in poor condition, exhibiting signs of damage (e.g.,
corrosion, rupture). Some of these drums were found in a
horizontal position. Although the contents of the drums are
unknown, EPA observed that several drums displayed methylene
chloride labels. This storage area did not have secondary
containment; State law does not require secondary containment
for drum storage. During the site visit, EPA observed another
set of used drums being stored directly on the gravel pad
without secondary containment.

EPA also observed that the floor of the on-site building
appeared to be saturated with oil. Partially empty drums
containing a variety of oil field chemicals, including drums
labeled as containing isocyanate compounds, were also observed
in this structure. Some of the drums appeared to be corroded.

As previously noted, this site is directly adjacent to the
Prudhoe Bay domestic water impoundment. At the time of the
site visit, EPA observed erosion of the site and runoff from
under the wooden storage structure flowing into this
impoundment. (See photos 78-81.)

Since the EPA site visit, ADEC has stated that the
Alliance, a group of Deadhorse service company operators,
gathered all used drums at this site and placed them in a lined
area inside one of the structures on site. The Alaska
Department of Natural Resources, the lease manager on the
Forward Alaska Pad, is reportedly in the process of revoking
the lease for this property. According to ADEC, once the lease
is revoked, ADEC will sample the site and fund its cleanup.

* * * 6/89 DRAFT * • *

-------
3-58

North Slope Salvage Site - Deadhorse

The North Slope Salvage Inc. (NSSI) facility, which has
been closed since 1983, accepted used oil field drums for
storage and eventual disposal.26 According to ADEC,
approximately 14,000 used drums, partially full of oil field
chemicals, were stored on-site without secondary containment.
During breakup in 1983, leakage from these drums resulted in
the uncontrolled release of contaminants to the tundra. NSSI
ceased operations following this incident and removed most
structures from the facility. Currently,, there are no
activities on the pad.

Upon discovering the deteriorating drums, many of which
had been leaking for up to six months, ADEC required NSSI to
install a protective berm around the pad. The State also
requested Federal enforcement to encourage the operator to
clean up the site. The State took the lead in enforcement, and
NSSI initiated cleanup.

According to ADEC personnel, after NSSI mounted an
inadequate cleanup effort, ARCO and Standard voluntarily
financed additional site remediation. These companies were the
primary contributors of the drums at the facility. As part of
the cleanup, vacuum trucks transported the drum contents, which
consisted of mixtures of solvents, oils, fuels, and corrosion
inhibitors, to facilities in Deadhorse for use as boiler fuel
or to the Pad 3 injection facility for disposal. Most liquids
recovered at the site exhibited the RCRA hazardous
characteristic of ignitability. Extensive sample results for
recovered liquids are on file with ADEC. (ADEC 1983.) Drum
residues were incinerated by a natural gas flare, and the drums
were disposed at the Sand Dunes landfill, which is now closed.

In August 1983, ADEC sampled the NSSI gravel pad and
standing water northwest of the site and detected
concentrations of organic constituents in both the gravel and
water that included the following (ADEC 1983):

26	Although mismanagement of wastes at this facility occurred
more than five years ago, it is included because it is the only
example of an oil and gas waste management case that was divided
by the courts.

27	State law does not require secondary containment for drum
storage.

* * * 6/89 DRAFT * * *

-------
3-59



Concentration (uctJL)

Benzene
Xylene

Benzeneacetic acid
2-ethylbutanoic acid
Heptanoic acid
Methylphenol
Methyl naphthalene
Carbolic acid ester

20
67

3.8

2.4

2.4

0.02

0.03

18 and 9.1

According to Standard: "Following completion of the
cleanup, ADEC personnel also visited the site several times and
observed only very light sheens on the water between the gravel
pad and the containment dike that had been built around the pad
(March 1987). ADEC has conducted no other sampling program at
the site." (Standard 1988.) (See photos 82-85.)

Upon referral from ADEC, the State Attorney General
prosecuted nine felony criminal counts and a fine against the
operators responsible for this incident. The operators, Bill
R. Hobson Sr. and Bill R. Hobson Jr. were convicted on eight of
the nine counts:

(1)	willful pollution;

(2)	willful discharge of oil;

(3)	willful failure to notify ADEC of an oil
discharge;

(4)	willful failure to clean up an oil discharge;

(5)	willful failure to obtain ADEC's approval before
the disposal of a hazardous substance;

(6)	willful failure to notify ADEC of a hazardous
substance discharge;

(7)	willful failure to clean up a hazardous
substance discharge; and

(8)	willful unlawful disposal of solid or liquid
waste without a permit.

Mr. Hobson Sr. was sentenced to 60 days in jail and was fined
$2500. Mr. Hobson Jr. was sentenced to 30 days in jail and was
fined $1250. However, the jail terms were suspended in lieu of
community service. Mr. Hobson Sr. was put on five years
probation; Mr. Hobson Jr. was put on three years probation.
The terms of their probations prohibited them from engaging in

* * * 6/89 DRAFT * * *

-------
3-60

the salvage or disposal business involving drums, waste liquid
oils, or hazardous substances. (ADEC 1984d.) NSSI has not
re-established operations in Deadhorse since this incident.

Child's Pad - Deadhorse

Prior to 1987, Child's Pad was occupied by a Deadhorse
service company. The pad was subsequently used to store liquid
waste contained in 428 drums. (ARCO 1988e.) Most of the
structures on the pad were removed following AOEC's discovery
of leaking drums and the subsequent cleanup efforts, as is
discussed further below. The owner of the lease is bankrupt.
Nevertheless, several subleasees remain active on the pad,
including the operator of a store and the operator of a
mechanic's shop. At the time of the site visit on June 16,
1988, EPA found 49 drums of hazardous waste from the site
cleanup in a lined containment area on the pad, apparently
awaiting final disposal arrangements (see additional
discussions below).

In the spring of 1987, ADEC found drums on Child's Pad to
be leaking used oil and oil field chemicals onto the tundra.
Additionally, ADEC discovered solid wastes including domestic
garbage, used batteries, and painting waste on the site. ARCO
and Standard, who were the primary contributors of drums at
this site, volunteered to conduct the cleanup. According to
information submitted by Standard to EPA following the EPA
visit, ARCO and Standard agreed "to remove the solid waste to
the North Slope Borough Landfill, collect any abandoned drummed
material in a lined containment area, and sample the gravel pad
to determine the extent of any contamination." (Standard
1988.)

During cleanup, the solid wastes were segregated and
prepared for disposal. AM Test Inc. and Rocky Mountain
Analytical performed chemical analysis on all drummed material.
Initial analysis on some drums included tests for total organic
halogens, corrosivity, flash point, reactivity, and metals.
These results indicated that:

•	Flash point ranged from above 212*F to less than
60'F;

•	pH ranged from 7.3 to 9.0;

•	Reactivity was negative on all samples;

•	Total organic halogens ranged from less than 50
ppm to 25,100 ppm; and

* * * 6/89 DRAFT * * *

-------
3-61

• While most metals were absent or detected on

only trace quantities, the samples were found to
contain as much as 46 ppm of lead. (AM Test
1987.)

Initial sample analysis of drummed material found little or no
detectable amounts of trichloroethane. Subsequent analysis,
however, detected several other organic pollutants in the
samples. Specifically, the following constituents were found
in samples from 13 barrels:

Constituent

Number of
Samples with
Detectable Cone.

Concentration
Range (mg/1)

1,1,1-Trichloroethane

2

1 - 1.5

Freon*

7

55 - 18,700

Chlorobenzene*

2

321 - 970

1,2-Dichloroethene*

2

1-11

Chloroform*

2

2.9 - 5.3

Carbon Tetrachloride*

2

4.8 - 5.2

* Quantitation is estimated; the analysis was originally performed only
for the presence of 1,1,1-Trichloroethane.

Source: AM Test 1988.

A total of 428 drums of waste were recovered during the
cleanup of Child's Pad. The contents of 279 drums were to be
recycled by ARCO under a plan to be approved by ADEC; the
contents of 100 drums were to be disposed at the Pad 3 Oily
Waste disposal facility; and 49 drums of liquid material
labeled as hazardous waste were left on-site in the lined diked
area pending further action by ADEC. (ARCO I988e.)

In August of 1988, ARCO sampled the gravel in Child's Pad by
boring three holes into the gravel pad and taking Samples at
the base of the pad and at the surface at all three locations.
The samples were analyzed for total organic halides,
purgeables, and halogenated volatile organics including freon,
and EP Toxicity. The sample results were as follows:

* # * 6/89 DRAFT * * *

-------
3-62

Constituent

units

Number of
Samples with
Detectable Cone.

Concentration
Range

Barium

(mg/kg)

1

1.5

Lead

(mg/kg)

4

0.37 - 0.91

Total Organic Halogens

(pg/g)

4

0.10 - 0.46

D ichlorofluoromethane

(pg/kg)

1

25

Freon

(Atg/kg)

1

28

1,1-Dichloroethylene

(/jg/kg)

1

26

Methylene Chloride

(#jg/kg)

2

12.6 - 35

Chloroform

(pg/kg)

2

26 - 270

Tetrachloroethylene

(pgAg)

1

14.1

EP Toxicity:







Lead*

(mg/1)

3

0.37 - 0.91

Barium

(mg/1)

1

1.5

Wastes with an EP Toxicity concentration for lead of 5 mg/1 or more are
hazardous wastes.

* Wastes with an EP Toxicity concentration for barium of 100 mg/1 or more
are hazardous wastes.

Source: Harding Lawson 1988.

Based on these data, ARCO informed ADEC that ARCO would like
confirmation from EPA that the gravel may be handled as a
non-hazardous waste. ARCO promised to prepare a plan to
dispose the gravel, for review by ADEC, after receiving the
requested confirmation. ARCO also indicated that the most
likely plan would involve removing the gravel in the late
summer of 1989, to take advantage of thawed conditions on the
pad, for disposal at the North Slope Borough Landfill. (ARCO
1988h.) (See photo 86.)

Powell—Sch1 lirnhftrgftT - fteadhnrsA

Dowell-Schlumberger, a worldwide oil field service company,
operates a facility in Deadhorse. Dowell-Schlumberger
maintains its own pad and an adjacent pad for equipment
storage. Dowell-Schlumberger provides downhole completion and
workover services and sells various acids, completion
chemicals, solvents, and dry materials such as cement to the
oil and' gas production companies on the North Slope.

* * * 6/89 DRAFT * * *

-------
3-63

At the time of the EPA site visit, ADEC discovered a spill
that had resulted in approximately two acres of dead tundra.
On the pad itself, ADEC and EPA noted evidence of several other
spills and estimated that several hundred gallons of
unidentified materials had been spilled from various sources.
(See photos 105-120.)

In one corner of the operations pad, approximately 50 drums
were leaking an unidentified milky substance, which gave off a
very strong chemical odor. Elsewhere on the pad, a thick,
white liquid substance with a strong chemical odor was observed
flowing off the pad into the tundra. On one edge of the pad,
EPA also observed that a pile of unidentified white material
was stacked without containment and that the gravel around the
pile appeared to be stained a rust color.

On another corner of the pad, ADEC and EPA observed evidence
of spills that appeared to have originated in a materials
staging area and flowed onto the nearby tundra. According to
information received by ADEC subsequent to the site visit, one
of the unidentified substances may have been an emulsion
breaker.

According to State officials, the tundra behind this pad,
which is surrounded by various service company facilities, has
been heavily damaged by spills and poor housekeeping. Based on
calibrated aerial photographs of the area, ADEC estimates that
this area contains 60 acres of dead, contaminated tundra.

Subsequent to the EPA site visit, on July 6, 1988, ADEC
issued a Notice of Violation to Dowel1-Schlumberger for the
numerous spills on the Dowell-Schlumberger pads. ADEC informed
Dowell-Schlumberger that numerous spills had been observed by
ADEC while inspecting the Deadhorse service area on June 17,
1988, and that these spills had not been reported to the
Department within the prescribed time period allowed by State
regulations. ADEC indicated that tfcปre was evidence of many
spills throughout both of the pads, including the spills noted
above. The NOV also requested Dowell-Schlumberger to submit a
spill report for each spill, cleanup immediately the gross
spillage, and submit a plan for final cleanup to the Department
for approval. (ADEC 1988i; ADEC 1988j.)

Two weeks later, ADEC received a letter from Dowell-
Schlumberger outlining the cleanup activities that had already
occurred and its plan for final cleanup of the spills
documented in the NOV. About three months after the NOV was

At the time of the EPA site visit, ADEC personnel on site
were unaware of a spill report submitted to ADEC on January 5,
1988, in which 150 to 200 gallons of acid were reported as spilled.

* * * 6/89 DRAPT * * *

-------
3-64

issued, ADEC received some of the requested spill reports.
Dowel1-Schlumberger described the spills as 100 to 200 gallons
of wash water from cement batch mixer, 3000 pounds of propping
agent, 20 gallons of hydraulic oil, 4 cubic yards of bentonite
clay, an unspecified amount of class "Gn cement, numerous small
amounts of unidentified chemicals, and 20 gallons of diesel.
(Dowel1-Schlumberger 1988a.) According to the
Dowell-Schlumberger report, the spills occurred in January,
February, June, and July of 1988. The report did not identify
some of the spills observed during the ADEC inspection of June
17.

N.L. Baroid - Deadhorse

N.L. Baroid supplies drilling muds, cement, and a variety of
dry bulk chemicals to the oil and gas production industry. At
the time of the site visit on June 17, 1988, EPA observed that
liquids in 55-gallon drums were stored on this pad. EPA also
observed that other materials were neatly stored in boxes and
stacked in columns on the edge of the pad. ADEC personnel on
the visit indicated that they prefer that all chemicals be
stored in the middle of pads where spills can be more
efficiently contained and prevented from flowing onto the
tundra. Most of the drums and bags appeared to be in good
shape; very few were observed to be leaking. There was little
evidence of spillage on the pad. A small area of spillage was
evident around a diesel fuel storage tank; however, a gravel
berm lined with plastic appeared to have contained most of the
spillage. (EPA did not take any photos of this facility.)

Halliburton Service Company - Deadhorse

Halliburton is a major service company on the North Slope
providing workover and completion services to North Slope
operators. Halliburton uses acids, fracturing fluids, and
other drilling, stimulation, and completion fluids in these
services. The Halliburton pad is located adjacent to a former
sewage lagoon.

During the site visit, EPA observed an area of about one
acre of dซad and discolored tundra adjacent to the Halliburton
pad. (This facility is documented in photo 134.)

On July 30, 1987, ADEC issued an NOV to the operator for the
discharge of spent acid without a permit. "[0]n July 9, 1987 .
. . a pumper truck released industrial wastewater to the lands
and/or waters of the state. The driver of the truck stated
[that] the contents was spent acid that had been neutralized."
(ADEC 1987f.)

In response about a month later, Halliburton indicated that
some fluid was discharged without a permit and that the

* * * 6/89 DRAFT * * *

-------
3-65

discharge consisted of approximately 50 gallons of 12 percent
hydrochloric acid and 12 percent hydrochloric/3 percent
hydrofluoric acid mixture, which was left over from a
stimulation treatment, and approximately 2,000 gallons of fresh
water containing soda ash. Halliburton also indicated that
leftover acid is routinely returned to the Halliburton
facility, where it is neutralized and held in a 220 barrel
holding tank until it is disposed at the Pad 3 injection
facility. (Halliburton 1987.)

On March 7, 1988, ADEC indicated that its investigation
subsequent to the issuance of the NOV revealed evidence of pad
contamination on other areas of the lease pad and adjacent
wetlands. During phone conversations and meetings between ADEC
and Halliburton, Halliburton agreed to conduct an environmental
audit and a pad assessment, and to implement remedial actions
for pad contamination. (ADEC I988r.) In April 1988,
Halliburton did the following:

•	Proposed a schedule for specific activities for
ADEC consideration (Halliburton 1988) that ADEC
accepted on April 14, 1988 (ADEC 1988s);

•	Submitted to ADEC a description of the scope of
the environmental audit to be performed
(Halliburton 1988a); and

•	Nominated a private contractor to perform the
environmental audit that ADEC accepted (ADEC
1988t; Halliburton 1988b).

On August 3, 1988, ADEC notified Halliburton that the
completed environmental audit relative to Halliburton's
activities on the lease tract and a sampling and analysis
program, both of which had been completed in July, had not been
received. ADEC requested that Halliburton submit the missing
documents within fourteen days, but as of January, 1989, ADEC
had received no further correspondence from Halliburton
concerning this matter. (ADEC I988u.)

vecq Oil field Sgrvi
-------
3-66

•	Diesel vehicle maintenance shop;

•	Gasoline vehicle maintenance shop;

•	Heavy equipment maintenance shop;

•	Vehicle washing facility;

•	Painting and auto-finishing shop;

•	Carpentry and wood products shop;

•	Electrical supply and service shop;

•	Welding and steel fabricating shop; and

•	Waste incinerator.

After the move to the new location, VECO began
decommissioning and demolishing the old camp. The
decommissioning continued into 1988. According to ADEC
personnel, VECO has a history of environmental releases
resulting from their waste management practices. For example,
according to ADEC personnel, 50 gallons of paint were buried in
the VECO pad in 1986. VECO later reported that the paint was
cleaned up the same summer and a report documenting the cleanup
was filed with the ADEC.

Also, based on inspections conducted by ADEC, EPA's Region
10 issued a complaint against VECO on March 2, 1988, alleging
primarily violations of RCRA hazardous waste generator
requirements. On May 17, 1988, VECO agreed to a $55,000
penalty in that case.

EPA visited the old VECO base camp site. EPA observed that
the pad contained empty drums, areas of stained gravel,
abandoned equipment, and general debris. In one area of the
pad, EPA observed a large number of empty drums being stored on
the gravel pad and on wooden supports. The drums were
generally in poor condition, exhibiting signs of rust and
corrosion. EPA did not determine the composition of the
residual contents of the drums.

EPA also observed that the site contained several large
diesel fuel tanks. What appeared to be diesel fuel was evident
in the gravel area inside the containment structures,
saturating the gravel around the tanks. A spill of
unidentified material was observed on one side of the pad.
According to ADEC, the Department has requested sample data
from this area, but VECO has not responded. As documented by
photographs, EPA observed that located near this spill was a
shallow pit used to store oily waste. The liner for this pit
was observed to be tattered and the berms of the pit were
breached or very thin in places. An oily spill was observed
floating on standing water under one structure located on
pilings on this pad. (See photos 124, 125, and 157-163.)

Operators of this facility at one time cleaned used drums
in the truck washracks and steam-cleaned truck tanks that had
carried oily wastes and chemicals. According to reports on

* * * 6/89 DRAFT * * *

-------
3-67

file with ADEC, VECO disposed of this rinsate at Pad 3;
however, Pad 3 has been closed to service companies since 1987.
ADEC had not determined when drum and tank rinsate ceased to be
generated at this facility or if rinsate was disposed at
locations other than Pad 3. According to information submitted
to EPA by VECO following the site visit, this ririsate was
"returned to the owner as per the contract for that particular
proj ect.w VECO states that the truck and drum washing
operations have been moved to the new facility and are now
completely enclosed and winterized. (VECO 1988.)

Peak Service Company - Deadhorse

The Peak Service Company provides North Slope operators with
a variety of oil field services, utilizing heavy equipment such
as cranes, pumper trucks, and construction equipment. On the
day of the site visit, EPA observed that chemicals including
corrosion inhibitors, antifreeze, biocides, water treatment
chemicals, and cleaning solvents were stored on site, primarily
in 55-gallon drums. EPA also observed that some drums were in
poor physical condition and appeared to be leaking. The drums
were stored on platforms that were not provided with secondary
containment.

At the time of the site visit, EPA observed that three
10,000-gallon acid storage tanks, as identified by ARCO
personnel present during the visit, were located on site and
provided with secondary containment. This contained area,
which was lined with plastic, was constructed partially with
concrete. EPA observed that, in places, the concrete had
crumbled and decayed. In areas where the cement containment
had decayed, gravel was used to provide secondary containment.
EPA observed that the inside of the contained area held a
green-colored liquid of unknown origin. (This site is
documented in photos 127 and 153-156.)

Schlnmbcraer Offshore Services Pad - Deadhorse

The Schlumberger Logging Company maintains an oil field
service center and employee housing on this pad. The company
services and stores vehicles and logging equipment in an
enclosed structure on site. A pipeline from the facility
discharges treated domestic sewage to the tundra under a permit
from ADEC, which requires that the discharge meet secondary
treatment standards. At the time of the site visit, on June
17, 1986, ADEC and EPA observed an oily sheen on the pool of
water formed from the sewer discharge. Additionally, oil
stains on the tundra and surrounding ice were evident.

On June 30, 1988, ADEC issued Schlumberger an NOV for
failing to report the hydrocarbon spill observed during the
site visit. ADEC requested that the spill be reported, free

* * * 6/89 DRAFT * * *

-------
3-68

product cleaned up, and a plan for removing contaminated gravel
and oil on the tundra be submitted to the Department. (ADEC
1988k; ADEC 19881.)

On July 14, 1988, Schlumberger responded to the NOV with a
spill report documenting that the hydrocarbon spill observed on
June 17 consisted of approximately 10 gallons of waste oil.
According to the spill report,

•	The waste oil spill had affected approximately 160
square feet of tundra;

•	The oil was contained by a boom and soaked up with
absorbent;

•	The contaminated gravel and grass were removed and
disposed at the Oxbow Landfill oily waste pit;

•	The company planned to plant the area with red
fescue, tundra bluegrass, and Alyeska polargrass on
or about August 20, 1988; and

•	The company intended to prevent future spills of
this type through employee training. (Schlumberger
1988; Schlumberger 1988a.)

On September 5, 1988, Schlumberger informed ADEC that
seeding of the area affected by the waste oil spill was
occurring between August 25 and September 10, and described the
reseeding techniques employed, the seed mixture planted, and
the type and amount of fertilizer used. (Schlumberger 1988b.)
According to ADEC personnel, Schlumberger1s response to the NOV
was more complete than is usual for service companies receiving
NOVs from ADEC. (This facility is documented in photos 164 and
165.)

Based on observations at the sites visited and the
information currently available to EPA (which is summarized
above), EPA concludes that:

• EPA is uncertain if ADEC's existing authorities

enable it to require the current owner to clean up
the Frahley Service Company site. If ADEC lacks
this authority, ADEC should continue to encourage
the operator to accept responsibility for
appropriately disposing wastes on the site,
including contaminated gravel, and EPA should
investigate the use of CWA Section 311 and CERCLA to
affect clean up of the site.

* * * 6/89 DRAFT * * *

-------
3-69

The gravel removed and/or sampled from the fuel
storage area, the Arctic Coiled Tubing shop
building, and the two pits in front of the other
shop building at the Deadhorse Hotel Lease Tract
site may have been RCRA Subtitle C hazardous waste.

Because service companies may frequently
abandon/vacate facilities or go bankrupt (e.g.,
Forward Alaska), demonstration of financial
responsibility for closure of drum storage
facilities may be appropriate.

Conviction of the operators in the North Slope
Salvage case was achieved relatively soon after the
incident, thus demonstrating the potential
efficiency of the existing enforcement program.

As of June 16, 1988, hazardous waste storage at the
Child's Pad site exceeded the 90-day time limit for
accumulation, after which a RCRA hazardous waste
permit to operate a storage facility is needed. (40
CFR 262.34(b).)

EPA needs information on the chemical products
stored and spilled at these facilities to determine
whether contaminated soils resulting from cleanup of
spills are hazardous waste (40 CFR 261.33(d)); and

ADEC needs to obtain information on the types,
quantities, and management practices for any wastes
generated or stored by these facilities to assess
the compliance with applicable regulations and the
adequacy of current practices.

* * * 6/89 DRAFT * * *

-------
APPENDIX A
MISCELLANEOUS SITE VISITS

While visiting sites on the North Slope during June 1988
to collect information on oil and gas waste management
practices, EPA visited a sewage treatment facility and two
gravel mine sites. These facilities, which were selected by
industry, provide additional background information on
practices related to oil and gas operations on the North Slope.

Sewage Treatment Plants

Two facilities on the North Slope have been granted NPDES
permits by EPA Region X to discharge treated sewage. EPA
visited one of these facilities, Standard's Base Operations
Camp.

Standard's Base Operations Camp Sewaae Treatment Plant

Standard has one of two NPDES permits in the Prudhoe Bay
oil production area for discharge of treated sewage. Sewage
from the Base Operations Camp is treated at the sewage
treatment plant and the treated effluent is discharged to a
nearby tundra lake. The treatment facility has the following
primary and secondary treatment capabilities: Primary
screening, trickling filters, extended aeration, clarification,
chlorination, sludge conditioning, sludge thickening, and
incineration. Effluent discharged from this facility must meet
secondary treatment standards. According to Standard, a lab at
the facility monitors the plant effluent daily. Solids are
incinerated on site. (See photos 39-40.)

Gravel Mine Sites

In developing the Arctic North Slope oil fields, hundreds
of millions of cubic yards of gravel have been mined from
various mine sites in the area to construct an extensive road
network and gravel pads for drill sites, production equipment,
pipelines, and support services. The permits or leases under
which gravel mine sites are operated are issued by the Alaska
Department of Natural Resources (ADNR). To date, reclamation
and rehabilitation requirements in existing leases or permits
are nonspecific. A typical lease will state that the lessee
will develop a rehabilitation plan that satisfies the
Department of Natural Resources.

Currently, ARCO, Standard, and Conoco are negotiating
rehabilitation plans. (ADFG 1988a.) According to ADFG
officials, as new leases are issued and as existing five-year
leases for mine sites are renewed, the Department hopes to add
more specific rehabilitation requirements to the leases.

* * * fi/89 DRAPT * * *

-------
A-2

EPA visited two mine sites, the Sag River Mine Site C and
the Endicott mine site.

ARCO Sag River Min* site a - Kunarulc FipIH

The Sag River Mine Site C, which is no longer an active
mine site, was used as a source of gravel for construction of
roads, pads, and related facilities in the Kuparuk field.

As documented by photographs, EPA observed that industry
sometimes uses abandoned mine sites for disposal of snow and
associated gravel collected from pads during snow removal.
Gravel collected during snow removal from pads may contain
minor amounts of contaminants from crude oil and chemical
spillage. These spills are common, especially during the
winter months. The disposal of materials collected during snow
removal is not actively regulated by the State; however,
according to ADEC personnel, the Department does prefer that
these materials be placed in a confined area before melting so
as to minimize potential migration of any contaminants removed
with the snow and gravel.

In 1986, ARCO violated Alaska's Anadromous Fish Protection
Act (AS 16.05.870) by diverting the Sagavanirktok (Sag) River
into the Sag River Mine Site c without the approval of Alaska
Department of Fish and Game, which has oversight authority over
aquatic habitat, including running rivers, in and around mine
sites. (ADFG 1986.) ADFG stated in the NOV, dated June 16,
1986, that a channel was cut in a dike located on the west side
of the mine site, completely inundating Sag Mine Site C with
water after a two-day period. ADFG requested that ARCO develop
a comprehensive plan for rehabilitating the site that would:

•	Incorporate the possibility of converting Sag
Mine Site C into a water reservoir;

•	Allow fish passage into and out of the flooded
site;

•	Enhance fish and wildlife habitat at the site;
and

•	Present a plan for field monitoring of fish in
the pit and evaluate the productivity of the pit
as a fish habitat. (ADFG 1986.)

On January 27, 1987, ADFG encouraged ARCO to proceed with
ADFG recommendations concerning the rehabilitation of Sag Mine
Site C. ARCO's proposed rehabilitation plan stated that a
choice must be made between creating a fish and wildlife
habitat and establishing Sag Site C as a water reservoir. ADFG
disagreed, requesting that ARCO instead revise its proposed

* * * 6/89 DRAFT * * *

-------
A-3

plan to reflect the facts that water use and fish and wildlife
are compatible and that problems such as summer drawdown can be
addressed by seasonal constraints on water usage. ADFG also
indicated that the situation at Sag Site C underscores the need
for material extraction site rehabilitation plans in the
Prudhoe Bay/Kuparuk Development area, stating that there had
not been a material extraction site in the entire Prudhoe
Bay/Kuparuk Development area where a rehabilitation plan has
been completed, approved by the agencies, and implemented.

(ADFG 1987.)

After extensive review and negotiations with ADFG, the
rehabilitation of Sag River Mine Site C was completed in the
fall of 1987. The rehabilitation plan involved expanding the
pit and creating a shallow water zone covering about five
acres. The Alaska Department of Fish and Game believed that
the shallow water zone would enhance habitat and increase
productivity of the native fish species found in the pit.
According to ADFG personnel, the resulting 40-acre lake is now
providing productive habitat for native fish. ADFG personnel
are also hopeful that the successful effort at Sag River mine
Site C will encourage operators to agree voluntarily to such
rehabilitation in the future. (See photos 13 and 14.)

Endicott Gravel Mine

The Endicott gravel mine is located onshore near the
Endicott facility. Millions of cubic yards of gravel have been
removed from this site. According to Carl Hemming of ADFG, the
permit for the Endicott mine site includes some specific
requirements for rehabilitation. The requirements state that
overburden recovered from the site is to be placed on one or
two sides of the pit, allowing for the berms on the opposite
sides to be pushed back down when the pit is no longer used as
a source of gravel. It is hoped that eventually this will
allow for reclamation of the site as a freshwater fish habitat.
(Personal communication, ADFG, 10/26/88, Re: North Slope gravel
mine sites; ADFG 1988.) At the time of the site visit, the pit
was still being used as a source of gravel. (The Endicott
facility and gravel mine are documented in photos 130 and
135-142.)

Conclusions

Based on observations at the sites and the data currently
available to EPA (which are summarized above), EPA concludes
that:

• ADEC and ADFG should coordinate to ensure that
use of a gravel mine site for snow disposal is
consistent with reclamation plans for the site.

* * * 6/89 DRAFT * * *

-------
APPENDIX B
SUMMARY OF RECENT FACILITY INSPECTIONS1

Facility Type
Oil Company

North Slope
Borough

Service Company

Facility Name

Standard Hazardous
Waste Storage
Facility

ARCO Crude Oil
Topping Unit

Endicott Pad
Facility

Oxbow Landfill

Municipal
Incinerator

Aurora North Fuel

B.J. Titan oil
Field Services

Dowel1

Schlumberger
N.L. Baroid
VECO Inc.

Inspection Date

07/25/83
12/10/84
08/25/85
06/10/86
07/14/87
06/09/88
05/18/89

05/18/89

08/21/87
05/18/89

05/17/89

05/17/89

05/17/89

06/13/86

09/08/86

12/10/84

06/14/86
07/16/87
04/12/89

1 Only facilities discussed in this report are included in
this Appendix. This Appendix includes inspections by EPA and
ADEC to assess compliance with State and Federal hazardous and
solid waste regulations.

* * *

6/89 DRAFT

* * •

-------
REFERENCES

Alaska Department of Environmental Conservation (ADEC), North
Slope Regional Office (NRO), 1983. Analytical Report for
North Slope Salvage site, November 16, 1983.

ADEC, NRO, 1984. Letter to ARCO Alaska, Re: Modified Waste
Disposal Permits for ARCO CPF-1 (8434-DB024) and ARCO
CPF-2 (8436-DB012) Disposal Wells (Kuparuk Oily Waste
Injection Well), October 30, 1984.

ADEC, NRO, 1984a. Letter to Sohio Alaska Petroleum Company
(Standard Alaska), Re: East Dock Reserve Pit, August 28,
1984.

ADEC, NRO, 1984b. Waste Disposal Permit No. 8436-DB024,

October 30, 1984.

ADEC, NRO, 1984c. Letter to Prudhoe Bay Hotel, Re: Waste
Disposal Permit 8436-DB018, June 15, 1984.

ADEC, NRO, 1984d. Internal memo, Re: Summary of North Slope
Salvage, Inc. Convictions and Sentences, November 29,
1984.

ADEC, NRO, 1986. Letter to ARCO Alaska, Re: Notice of

Violation - Pingut Pad Oily Waste Pit, July 29, 1986.

ADEC, NRO, 1986a. Notice of Violation - Pingut Pad Oily Waste
Pit, July 29, 1986.

ADEC, NRO, 1986b. Internal Memorandum, Re: Review of Proposed
Modification of U.S. Army Corps of Engineers Permits,
September 9, 1986.

ADEC, NRO, 1987. Letter to Standard Alaska Production Company,
Re: Use of Reserve Pits for Disposal of Oily Wastes (J
Pad), August 5, 1987.

ADEC, NRO, 1987a. Notice of Violation - Standard Alaska
Production Company's J Pad, August 5, 1987.

ADEC, NRO, 1987b. Letter to ARCO Alaska, Re: Contaminated
Gravel at Child's Pad, October 22, 1987.

ADEC, NRO, 1987c. Letter with Attachments to ARCO Alaska, Re:
Solid Waste Disposal Permit for Pad 3 Oily Waste Injection
Facility, September 11, 1987.

ADEC, NRO, I987d. Register 103, October, 1987.

ADEC, NRO, 1987e. "Problem Pit List", 1987.

* * * 6/89 DRAFT * * *

-------
R-2

ADEC, NRO, 1987f. Letter with Attachments to Halliburton

Services, Re: Notice of Violation for Discharge of Acid
Without a Permit, July 30, 1987.

ADEC, NRO, 1988. Letter to ARCO Alaska, Re: Notice of

Violation for Drill Site 4 and Oil Spill Cleanup, July 22,
1988.

ADEC, NRO, 1988a. Notice of Violation - ARCO Drill Site 4,

July 22, 1988.

ADEC, NRO, 1988b. Internal Memo, Re: Used Drum Rinsate,

October 13, 1988.

ADEC, NRO, 1988c. Letter to Standard Alaska Production

Company, Re: Notice of Violation - Permit Violations at
Eileen West End/W Pad, July 22, 1988.

ADEC, NRO, 1988d. Notice of Violation - Standard Alaska
Production Company's W Pad, July 22, 1988.

ADEC, NRO, 1988e. Letter to Jerold Johansen, Re: Notice of
Violation, Frahley Pad, July 6, 1988.

ADEC, NRO, 1988f. Notice of Violation, Frahley Pad, July 6,
1988.

ADEC, NRO, 1988g. Letter to J. R. Thomas, Re: Notice of
Violation, Deadhorse Hotel, July 6, 1988.

ADEC, NRO, 1988h. Notice of Violation, Deadhorse Hotel, July
6, 1988.

ADEC, NRO, 1988i. Letter to Bobbie Joines, Re: Notice of
Violation - Dowel1 Schlumberger, July 6, 1988.

ADEC, NRO, 1988j.	Notice of Violation - Dowell Schlumberger,
July 6, 1988.

ADEC, NRO, 1988k.	Letter to Schlumberger Offshore Services,
Re: Notice of Violation, June 30, 1988.

ADEC, NRO, 19881. Notice of Violation - Schlumberger Offshore
Services, June 30, 1988.

ADEC, NRO, 1988m. Computerized Spill Report for 1988.

ADEC, NRO, 1988n. Internal memo, Re: Halliburton Update,
October, 1988.

ADEC, NRO, 1988o. Letter to VECO, Inc., Re: Cleanup of VECO
Facilities, June 29, 1988.

* * * 6/89 DRAFT * * *

-------
R-3

ADEC, NRO, 1988p. Letter to ARCO Alaska, Re: Waste Disposal
Permit for Pad 3 Oily Waste Injection Facility, July 13,
1988.

ADEC, NRO, I988q. Waste Disposal Permit No. 8736-DB024 (Pad 3
Oily Waste Injection Facility), July 13, 1988.

ADEC, NRO, 1988r. Letter to Halliburton, Re: A.D.L. Lease
47660, Pad Contamination, March 7, 1988.

ADEC, NRO, 1988s. Letter to Halliburton, Re: ADL Lease 47660,
Pad Contamination, April 14, 1988.

ADEC, NRO, 1988t. Letter to Halliburton, Re: ADL Lease 47660,
Environmental Audit/Consulting Contractor Selection, June
2, 1988.

ADEC, NRO, 1988U. Letter to Halliburton, Re: ADL Lease 47660,
Deadhorse, Alaska, Notice of Violation/Environmental
Audit, August 3, 1988.

ADEC, NRO, 1988V. Report titled: "A Review of Liquid Waste
Production and Disposal at Oilfield Facilities on the
North Slope of Alaska," March, 1988.

ADEC, NRO. Permit No. 8736-BA008. (No date.)

Alaska Department of Fish and Game (ADFG), Habitat Division,

Fairbanks, 1986. Letter to ARCO Alaska, Re: Sagavanirktok
River Mine Site C, June 16, 1986.

ADFG, Habitat Division, 1986a. Field Inspection Report -
Sagavanirktok River Mine Site C, June 10, 1986.

ADFG, Habitat Division, 1987. Letter with attachments to ARCO
Alaska, Re: Sag Site HC" Rehabilitation Plan, January 27,
1987.

ADFG, Habitat Division, 1987a. Internal Memo, Re: Kuparuk

River Deadarm Material Site Rehabilitation, September 10,
1987.

ADFG, Habitat Division, 1987b. Internal Memo with Attachments,
Re: Rehabilitation of Mine Site B in the Kuparuk Unit,
November 19, 1987.

ADFG, Habitat Division, 1988. Acruatic Habitat Evaluation of

Flooded North Slope Gravel Mine Sites (1986-1987) . by Carl
Hemming. Technical Report No. 88-1, August, 1988.

* * * 6/89 DRAFT * * *

-------
R-4

ADFG, Habitat Division, 1988a. Memo to Office of Management

and Budget, Re: Rehabilitation of North Slope Gravel Mine
Sites, October 24, 1988.

ADFG, Habitat Division, 1988b. Letter to Standard Alaska

Production Company, Re: Kuparuk Deadarm Gravel Pit - P Pad
Project, February 17, 1988.

ADFG, Habitat Division, 1988c. Internal Memo, Re: Meeting with
SAPC (Standard Alaska) on Kuparuk Deadarm, May 9, 1988.

ADFG, Habitat Division, 1988d. Letter to Standard Alaska

Production Company, Re: Kuparuk Deadarm Mining Plan, June
3, 1988.

ADFG, Habitat Division, 1988e. Internal Memo, Re: Material
[Gravel] Sales Contract, April 8, 1988.

ADFG, Habitat Division, 1988f. Internal Memo, Re:

Rehabilitation of Mine Site B and D, August 2, 1988.

ADFG, Habitat Division, 1988g. Internal Memo, Re: Restoration
Plan for Conoco Milne Point Gravel Pit, January 12, 1988.

Alaska Department of Law, Juneau, 1987. Letter to ARCO Alaska,
Re: Sag Site C Release and Settlement, August 14, 1987.

Alaska Technical Services, Anchorage, 1988. Letter to Brad
Fristoe, Re: Notice of Violation on Deadhorse Hotel,
September 26, 1988.

Alaska Technical Services, Anchorage, 1988a. Letter with

Attachments to Mr. Wilber Thomas, Re: Synopsis of work
performed at Deadhorse Hotel Pad, October 11, 1988.

AM Test Inc.,	Redmond, Washington, 1987. Child's Pad Sample

Results,	1987.

AM Test Inc.,	Redmond, Washington, 1988. Child's Pad Sample

Results,	1988.

American Petroleum Institute (API), Petroleum Extension

Service, University of Texas, Austin, 1969. Principles of
Drilling Fluid Control (12th ed.).

ARCO Alaska, Anchorage, 1987. Letter with attachments to ADEC,
Re: Pingut Pad Close-out Plan, February 9, 1987.

ARCO Alaska, Anchorage, 1987a. Close-out Plan, Pingut Pad
Solid Oily Waste Processing Facility, 1987.

* * * 6/89 DRAFT * * *

-------
R-5

ARCO Alaska, Anchorage, 1987b. Letter to ADEC, Re: Child's Pad
Cleanup, October 5, 1987.

ARCO Alaska, Anchorage, 1987c. Letter to ADFG, Re: Sag "C"
Reservoir 1987 Break-up Erosion, August 3, 1987.

ARCO Alaska, Anchorage, 1988. Letter with Attachments to U.S.
EPA, Re: EPA Contractor Site Visits, September 29, 1988.

ARCO Alaska, Anchorage, 1988a. Letter with Attachments to ADEC
and U.S. Army Corps of Engineers, Re: Reserve Pit
Modification - DS-1E, September 12, 1988.

ARCO Alaska, Anchorage, 1988b. Letter with Attachments to

ADEC, Re: Pad 3 Solid Waste Disposal Permit, February 29,
1988.

ARCO Alaska, Anchorage, 1988c. Letter with Attachments to

ADEC, Re: Pingut Pit Close-Out Thermistor Data, May 19,
1988.

ARCO Alaska, Anchorage, 1988d. Letter with Attachments to

ADEC, Re: Notice of Violation Drillsite 4 Spill Cleanup,
August 22, 1988.

ARCO Alaska, Anchorage, 1988e. Letter with Attachments to ADEC
and U.S. EPA, Re: Child's Pad Cleanup - Drum Disposal
Plans and Gravel Status, January 13, 1988.

ARCO Alaska, Anchorage, 1988f. Letter to U.S. EPA Region X,
Re: Child's Pad Sample Results, March 1, 1988.

ARCO Alaska, Anchorage, 1988g. Gravel Conference Minutes,

1988.

ARCO Alaska, Anchorage, 1988h. Letter with Attachments to
ADEC, Re: Child's Pad Soil Samples, October 25, 1988.

ARCO Alaska, Anchorage, 1988i. Letter with Attachments to U.S.
EPA Region X, Re: Application for Kuparuk Fieldwide NPDES
Permit, October 4, 1988.

BP Exploration (Alaska) Inc., 1989. North Slope Waste

Management Issues, Evaluation of the U.S. EPA Staff Draft
Report "Management of Oil and Gas Wastes on Alaska's North
Slope," March 7, 1989.

Bureau of Land Management, 1978. Beaufort Sea petroleum
development scenarios: Natural physical environment
impacts. Technical Report No. 21. Prepared through
Alaska OCS Socioeconomic Studies Program, sponsored by BLM
and Alaska Outer Continental Shelf Office. June, 1978.

* * * 6/89 DRAFT * * *

-------
R-6

Cargo, D.N. and B.F. Mallory, 1977. Man and his geologic
environment. Addison Wesley, Reading, Massachusetts.

Dames and Moore, Anchorage, 1978. Drilling Fluid Dispersion
and Biological Effects Study for the Lower Cook Inlet
C.O.S.T. Well, Submitted to Atlantic Richfield Company,
Dallas, Texas.

Dowell Schlumberger Incorporated, Deadhorse, 1988. Letter to
Brad Fristoe, Re: Notice of Violation, July 20, 1988.

Dowell Schlumberger, Deadhorse, 1988a. Spill Reports, October
7, 1988.

Enseco, Inc., Arvada, Colorado, 1987. Analytical Results for
ARCO Alaska, (Child's Pad), September 22, 1987.

ERL (Edgerton Research Laboratory, New England Aquarium),

Environmental Research Laboratory, Gulf Breeze, Florida,
1984. A survey of the toxicology and chemical composition
of drilling muds, submitted to U.S Environmental
Protection Agency, Report 600/3-84-071.

Halliburton, Anchorage, 1987. Letter to ADEC, Re: Notice of
Violation - Discharging Industrial Wastewater Without a
Permit - Deadhorse, Alaska, August 12, 1987.

Halliburton, Duncan, Oklahoma, 1988. Letter to ADEC, Re: ADL
Lease 47660 - Pad Contamination, April 6, 1988.

Halliburton, Duncan, Oklahoma, 1988a. Letter to ADEC, Re:
Fulfillment of Obligations under Notice of Violation,

April 25, 1988.

Halliburton, Duncan, Oklahoma, 1988b. Letter to ADEC, Re: ADL
Lease 47660, Choice of Independent Consulting Contractor,
May 17, 1988.

Harding Lawson Associates, Anchorage, 1988. Letter to ARCO
Alaska, Re: Child's Pad Soil Sampling and Analysis,
September 21, 1988.

Kellicut and Jones, Attorneys at Law, Anchorage, 1987. Letter
to James N. Leik, Re: Ratterman v. Johansen, et al, April
28, 1987.

Kellicut and Jones, Attorneys at Law, Anchorage, 1988. Letter
to ADEC, Re: Notice of Violation, Frahley Pad, September
6, 1988.

* * * 6/89 DRAFT * * *

-------
R-7

Kellicut and Jones, Attorneys at Law, Anchorage, 1988a. Letter
to James N. Leik, Re: Ratterman/Johansen, September 6,
1988 •

National Petroleum Council, 1981. Working papers of the
Environmental Protection Task Group of the National
Petroleum Council's Committee on Arctic Oil and Gas
Resources. December, 1981.

National Research Council, 1975. Petroleum in the Marine
Environment, National Academy of Sciences, Washington,

D • Cซ

Natural Resources Defense Council, New York, 1988. Letter to
ARCO Alaska, Re: Notice of Intent to Sue, February 16,
1988.

Natural Resources Defense Council, New York, 1988a. Letter to
Standard Alaska Production Company, Re: Notice of Intent
to Sue, February 16, 1988.

Natural Resources Defense Council, Trustees for Alaska,

Northern Alaska Environmental Center, and The Alaska
Center for the Environment, Plaintiffs v. ARCO Alaska,
Inc., Defendant. June 16, 1988.

North Slope Borough, Prudhoe Bay, 1985. Memorandum with

attachments to ADEC, Re: Final Report for Dewatering of
Oxbow Landfill, October 20, 1985.

North Slope Borough, Prudhoe Bay, 1988. Letter to ADEC, Re:

Solid Waste Management Permit Application (8836-BA014) for
second oily waste pit. July 29, 1988.

North Slope Borough, Prudhoe Bay, 1988a. Letter to ADEC, Re:
1988 Delivery Quantities for the Oxbow Landfill, October
6, 1988.

Norton, Alies, Curatals, University of Alaska, Fairbanks, 1975.
Ecological relationships of the inland tundras avifauna
near Prudhoe Bay, Alaska. In: Ecological Investigations
of the Tundra Biome in the Prudhoe Bay Region, Alaska.
Spec. Report No. 2, Biol. Papers, pp. 124-133, University
of Alaska.

Polar Research Board, Assembly of Mathematical and Physical
Sciences, and National Research Council (Committee to
Evaluate DOE's Arctic Terrestrial Environmental Research
Programs), 1982. Arctic terrestrial research programs of
the Office of Energy Research, Department of Energy:
Evaluations and recommendations. National Academy Press,
Washington, D.C.

* * * 6/89 DRAFT * * *

-------
R-8

Schlumberger Offshore Services, Deadhorse, 1988. Letter to
ADEC, Re: Notice of Violation, July 14, 1988.

Schlumberger Offshore Services, Deadhorse, 1988a. Spill
Report, July 8, 1988.

Schlumberger Offshore Services, Deadhorse, 1988b. Letter to
ADEC, Re: Revegetation of Spill Area, September 5, 1988.

Sohio Alaska Petroleum Company (Standard Alaska), Anchorage,
1983. ffaat Dock Mud Sumo Five Year Monitoring Program
Interim Report- for Years 1981 Through 1983.

Sohio Alaska Petroleum Company, Anchorage, 1984. Letter with
attachment to ADEC, Re: East Dock Reserve Pit Leakage,

July 27, 1984.

Sowers, G.F., 1979. Introductory soil mechanics and
foundations. Macmillan, New York.

Standard Alaska Production Company, Anchorage, 1987. Letter to
ADEC, Re: Notice of Violation - J Pad, August 18, 1987.

Standard Alaska Production Company, Anchorage, 1988. Letter
with Attachments to U.S. EPA, Re: EPA Contractor Site
Visit, September, 1988.

Standard Alaska Production Company, Anchorage, 1988a. Letter
with Attachments to ADEC, Re: Notice of Violation - W Pad,
August 1, 1988.

Standard Alaska Production Company, Anchorage, 1988b. Letter
with Attachments to ADFG, Re: Kuparuk Deadarm Pit Interim
Mining Plan, May 11, 1988.

Standard Alaska Production Company, Anchorage, 1988c. Letter
with Attachments to ADEC, Re: Eileen West End [W Pad]

Solid Waste Disposal Permits No. 8736-BA007, July 15,

1988.

The Petroleum Publishing Co., 1974. International petroleum
encyclopedia. The Petroleum Publishing Co., Tulsa,
Oklahoma.

Trustees for Alaska, Anchorage, 1988. Letter to EPA Region X
and Comments on ARCO UIC Class I Industrial Waste
Injection Permit, June 27, 1988.

Trustees for Alaska, Anchorage, 1988a. Letter to EPA Region X
and supplementary comments on ARCO Class I Industrial
Waste Disposal Application, August 15, 1988.

* * * 6/89 DRAFT * * *

-------
R-9

Trustees for Alaska, Anchorage, 1988b. Letter to ADEC and

Attached Comments on Proposed Expansion of the Oxbow oily
Waste Pit, November 30, 1988.

U.S. Army Corps of Engineers, Alaska District, 1986. Public

Notice, Re: Permit Modification Procedure, August 5, 198 6.

U.S. Environmental Protection Agency, Washington, D.C., 1987.
Report to Congress: Management of Wastes from the
Exploration, Development, and Production of Crude Oil,
Natural Gas, and Geothermal Energy, Volume l. Office of
Solid Waste and Emergency Response, EPA/530-SW-88-003.

U.S. Environmental Protection Agency, Washington, D.C., July,
1988a. Federal Register, "Regulatory Determination for'
Oil and Gas and Geothermal Exploration, Development and
Production Wastes", Vol. 53, No. 129, p. 25446, July 6,
1988

VECO, Inc., Anchorage, 1988. Draft Report of Industrial
Installations at Deadhorse. Alaska. June 1988.

West, Snyder-Conn, U.S. Fish and Wildlife Service, Washington
D.C., 1987. Effects of Prudhoe Bay reserve pit fluids on
water quality and macroinvertebrates of tundra ponds, u s
Fish and Wildlife Service Biological Report 87(7).

Woodward, D.F., E. Snyder-Conn, R.G. Riley, and T.R. Garland
U.S. Fish and Wildlife Service, National Fisheries	'

Contaminant Research Center, Jackson Field Station,
Jackson, Wyoming, 1988. "Drilling Fluids and the Arctic
Tundra of Alaska: Assessing Contamination of Wetlands
Habitat and the Toxicity to Aquatic Invertebrates and
Fish." In: Arch. Environ. Contam. Toxicol. 17, 683-697

(1988).

* * * 6/89 DRAFT

-------