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\3SZ£/ NPDES Fact Sheet
Qil and Gas Geotechnical Surveys and Related Activities General Permit (AKG-28-4300)
FACT SHEET
Public Comment Issuance Date: August 15,2014
Public Comment Expiration Date : September 15,2014
Technical Contact:
Erin Seyfried
email: R10geotechpermit@epa.gov
fax: (206) 553-0165
The U.S. Environmental Protection Agency (EPA) re-proposes the National Pollutant Discharge
Elimination System (NPDES) general permit for the following activities pursuant to the provisions
of the Clean Water Act, 33 U.S.C. §1251 et seq:
Oil and Gas Geotechnical Surveys and Related Activities in
Federal Waters of the Beaufort and Chukchi Seas
(AKG-28-4300)
EPA Re-Proposes NPDES General Permit Issuance
On November 22, 2013, EPA released a draft NPDES general permit for oil and gas geotechnical
surveys and related activities in federal waters of the Beaufort and Chukchi Seas for public review
(Geotechnical General Permit; No. AKG-28-4300). The public comment period closed on February
19, 2014. Based on the comments received, EPA has made the following revisions to the draft
Geotechnical General Permit and re-proposes a revised draft for public review. EPA seeks public
comment only on the following proposed changes:
¦ Inclusion of a seasonal prohibition on wastewater discharges to the 3-25 mile lease deferral
area in the Chukchi Sea;
¦ Clarification of Environmental Monitoring Program (EMP) requirements and inclusion of
language regarding pre-existing representative baseline data;
¦ Clarification of Drilling Fluids and Drill Cuttings (Discharge 001) testing requirements;
¦ Revision of sampling frequencies for fecal coliform and total residual chlorine (Sanitary
Wastewater, Discharge 003); and
¦ Clarification of Notice of Intent (NOI) submission requirements.
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Fact Sheet - NPDES General Permit Re-Proposal
Oil and Gas Geotechnical Surveys and Related Activities
Page 2 of 25
General Permit No. AKG-28-4300
This Fact Sheet includes:
¦ Information on public comment and appeal procedures,
¦ A description of the re-proposed permit provisions,
¦ A map of areas where the seasonal prohibitions apply, and
¦ Technical information supporting the re-proposed provisions.
EPA Invites Comments on the Re-Proposal
EPA will consider all comments specific to the re-proposed Geotechnical General Permit, Fact Sheet
and revised ODCE before issuing the final NPDES general permit. Those who wish to comment on
the re-proposed permit may do so in writing by September 15, 2014 (31 days from the date of the
Federal Register notice). EPA will only consider comments on the re-proposed permit provisions.
Comments submitted previously on the initial draft Geotechnical General Permit need not be
resubmitted; comments addressing permit provisions or issues beyond the scope of this re-proposal
will not be considered.
All comments must include the name, address, phone number, and email address (if available) of the
commenter. Each comment should include a concise statement explaining the basis and relevant facts
that support the comment. All written comments should be addressed to:
U.S. EPA, Region 10
Attn: Director, Office of Water and Watersheds
Subject: NPDES Geotechnical General Permit Re-Proposal
1200 Sixth Avenue Suite 900, OWW-130
Seattle, WA98101
Fax: (206) 553-0165
E-mail: R10geotechpermit@epa.gov
After the public comment period ends, EPA will review and consider all comments related to the re-
proposed provisions. EPA's Director for the Office of Water and Watersheds in Region 10 will make
a final decision regarding the issuance of the Geotechnical General Permit based on all comments
received during both comment periods. Pursuant to 40 CFR § 23.2, unless the EPA specifies a
different time in the Federal Register notice, two weeks after the Federal Register publication date is
the "permit issuance date." The Geotechnical General Permit will become effective 30 days after the
permit issuance date. In accordance with Section 509(b)(1)(F) of the Clean Water Act, 33 USC §
1369(b)(1), and 40 CFR § 124.19(a), any interested person may appeal the General Permit in the
Ninth Circuit Court of Appeals within 120 days from the permit issuance date.
Documents are Available for Review
Pursuant to 40 CFR § 124.9, the Administrative Record for the draft and re-proposed Geotechnical
General Permit is available upon request by contacting Erin Seyfried at (206) 553-1448 or
seyfried.erin@epa.gov.
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Fact Sheet - NPDES General Permit Re-Proposal Page 3 of 25
Oil and Gas Geotechnical Surveys and Related Activities General Permit No. AKG-28-4300
The draft and re-proposed Geotechnical General Permit, Fact Sheet and revised ODCE are available
for review by contacting the EPA's Regional Office in Seattle or the EPA Region 10 Alaska
Operations Office in Anchorage (see addresses below) between 8:30 a.m. and 4:00 p.m., Monday
through Friday. The documents and other information can also be found by visiting the Region 10
website at "www.epa.gov/R10earth/waterpermits.htm".
U.S. EPA Region 10
Attn: Audrey Washington
1200 6th Avenue, Suite 900
OWW-130
Seattle, Washington 98101
(206) 553-0523
(800)424-4372
U.S. EPA Anchorage Operations Office
222 West 7th Avenue, Suite 19 (Room 537)
Anchorage, AK 99513
(907)271-5083
Z.J. Loussac Public Library
3600 Denali Street
Anchorage, AK 99503
North Slope Borough Library
829 Aivak Street
Barrow, AK 99723
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Fact Sheet - NPDES General Permit Re-Proposal
Oil and Gas Geotechnical Surveys and Related Activities
Page 4 of 25
General Permit No. AKG-28-4300
I. DESCRIPTION OF EPA'S RE-PROPOSAL
A. Background
On November 22, 2013, EPA issued a draft Geotechnical General Permit for public
review, and established a comment deadline of January 27, 2014 (78 FR 70042). In
response to requests for an extension of the deadline from the Alaska Eskimo Whaling
Commission and the Inupiat Community of the Arctic Slope, EPA extended the
comment period for an additional 23 days, from January 27, 2014 to February 19, 2014
(79 FR 4344).
Based on the comments received during the public review of the draft Geotechnical
General Permit, EPA determined that certain permit provisions warranted further
consideration and notified interested parties of this determination on March 21, 2014.
To further that process, EPA met with several commenters to clarify certain technical
issues and obtain additional information.
The public comments and subsequent information resulted in EPA revising several
permit provisions, as described in further detail below.
B. Permit Changes Subject to the Re-proposal
The following sections describe the changes made to the draft Geotechnical General
Permit that are subject to the re-proposal.
1. Chukchi Sea Spring Lead System Seasonal Prohibition
EPA received many comments on the importance of the spring lead system in the
Chukchi Sea for migrating bowhead whales and for other marine mammals such
as beluga and humpback whales and bearded seals, as well as certain bird species.
Having reviewed those comments, EPA has included a prohibition of all
discharges to federal waters of the Chukchi Sea within the area 3 to 25 nautical
miles offshore prior to July 1. This prohibition is protective of the spring lead
system, described further below, and the species that rely on it during the sensitive
spring migration, feeding, and calving period.
The prohibition corresponds with other federal regulatory requirements,
including the Bureau of Ocean Energy Management's (BOEM) decision to defer
the 3-25 mile area in the Chukchi Sea from leasing entirely. BOEM's
Environmental Impact Statement (EIS) for the 2007-2012 Five-Year Program
concluded that "the deferral would reduce potential impacts to endangered and
threatened species, including the bowhead whales and other whales; reduce
threats to marine and coastal birds because of their concentration in the deferral
area; and reduce visual-resource effects by moving the potential platform
locations farther offshore." The deferral area was developed based on a
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Fact Sheet - NPDES General Permit Re-Proposal Page 5 of 25
Oil and Gas Geotechnical Surveys and Related Activities General Permit No. AKG-28-4300
Biological Opinion from the National Marine Fisheries Service (NMFS) in 1987,
which primarily focused on the importance of the spring lead system for
protecting migrating bowhead whales (BOEM 2007).
EPA's selection of the July 1 date is based on the fact that offshore activities are
traditionally conducted during the open water (ice-free) season, which typically
begins on or after July 1, and ceases approximately 120 days later (Shell 2014).
This date also corresponds with NMFS' estimate of completion of the spring
bowhead migration (NMFS 2011). In keeping with this conclusion, NMFS has
applied a restriction in the 2012 Incidental Harassment Authorization to Shell,
prohibiting vessel entry into the Chukchi Sea through the Bering Strait prior to
July 1 (NMFS 2012).
This seasonal prohibition for the Chukchi Sea spring lead system is shown in
Figure 1 ("Figure 2" in the Permit), below, and has been added to Permit Part
II.A.6. ("Requirements for All Discharges") and states as follows:
Chukchi Sea Spring Lead System Seasonal Restriction (Permit Part
II.A.6.). The permittee is prohibited from discharging any waste
stream within the Chukchi Sea lease deferral corridor, which
corresponds to the area 3-25 nautical miles offshore, prior to July 1.
Figure 2 (below) provides a map of where this seasonal restriction
applies.
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Fact Sheet - NPDES General Permit Re-Proposal
Oil and Gas Geotechnical Surveys and Related Activities
Page 6 of 25
General Permit No. AKG-28-4300
2 CDA Region 10
SVEriH GISTeam
Figure 1: Chukchi Sea Spring Lead System Seasonally Restricted Area (see Permit Part II.A.6.)
Spring leads and polynyas (areas of open water in sea ice) serve as large heat
sources to the atmosphere, play a key role in ice and brine production, and provide
critical habitat for feeding, reproduction and migration to several seal species,
polar bears, and migrating bowhead, humpback and beluga whales (Martin 2001).
For example, data indicate that most calving by bowhead whales occurs during
the spring migration when whales are in the Chukchi Sea spring lead system,
although some calving also likely occurs in the Beaufort spring lead system
(NMFS 2010). Furthermore, Inupiat hunters rely on these spring leads and open-
water areas for spring whaling of bowheads from April to June (Norton and
Graves 2004 as cited in NMFS 2012).
The Ledyard Bay area, located between Cape Lisburne and the village of Point
Lay, is part of the spring lead system that appears to be a stopover point for a
substantial proporti on of seaducks, including threatened speci es of eiders, moving
to breeding areas on the Arctic Coastal Plain or western Canada. Similarly, this
same area appears important to many of these same birds once they leave
OK and £»as Geotechnical Surveying and Related Activities in Federal Waters
of the Chukchi Sea - Spring Lead System Seasonal Restrictions
EPA Permit Number AKG-28-4300
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Fact Sheet - NPDES General Permit Re-Proposal
Oil and Gas Geotechnical Surveys and Related Activities
Page 7 of 25
General Permit No. AKG-28-4300
breeding grounds and molt or stage prior to migrating to wintering areas (MMS
2007). Spectacled eiders and Steller's eiders make use of the spring lead system
when they migrate from the wintering area to the Chukchi Sea. The spring lead
system includes the Ledyard Bay Critical Habitat Unit and typically has
represented the only open-water area along their migratory path (BOEMRE
2011).
In general, sea ice in the Chukchi Sea is newly generated each year (Mahoney
2012). In the Chukchi Sea, there is a net northward flow, which enters through
the Bering Strait and branches into different bathymetrically constrained currents
(Weingartner et al., 2005 as cited in Mahoney et al. 2012). In the spring, the heat
flux associated with this northward flow enhances the early loss of ice in the
Chukchi Sea (Woodgate et al. 2010 as cited in Mahoney et al. 2012). These leads
form within the pack-ice zone and particularly around the seaward landfast ice
edge (MMS 2008). The most prominent coastal polynyas and flaw leads, the
openings between pack ice and landfast ice, form along the eastern Chukchi Coast
between Point Hope and Point Barrow, as well as to the north and west of
Wrangel Island, with less distinct flaw leads appearing off the northern coast of
Chukotka (Mahoney et al. 2012). Leads may expose large areas of open water
along the shoreline, creating contrast in color and texture between sea ice, land,
and sea. These leads separate a region of largely immobile ice in the southeastern
Beaufort Sea from the more mobile pack ice in the Chukchi Sea to the west.
The spring leads and polynyas support large concentrations of marine mammals.
Polynya regions annually absorb more solar radiation than adjacent regions
covered with thick pack ice due to the fact that the polynya regions become ice-
free earlier in the year. As a result, the polynya regions have a significantly
greater primary productivity than regions with heavy winter pack ice, thus making
these areas important for feeding. These regions also provide the only migration
pathways for bowhead and other whale species as they migrate from the Bering
Strait to the Beaufort Sea and Canadian waters. The following figures (Figure 2
and Figure 3) represent the general extent of the Chukchi Sea spring lead system
based on historical and the most recent year of data collected during four
consecutive months of March, April, May and June by Eicken et al. (2006) from
the MMS OCS STUDY 2005-068.
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Fact Sheet - NPDES General Permit Re-Proposal
Oil and Gas Geotechnical Surveys and Related Activities
Page 8 of 25
General Permit No. AKG-28-4300
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Figure 2: Location of the 1994 Chukchi Sea Spring Lead System in Relation to the Area of Coverage for the
Geotechnical General Permit (AKG-28-4300).
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Fact Sheet - NPDES General Permit Re-Proposal
Oil and Gas Geotechnical Surveys and Related Activities
Page 9 of 25
General Permit No. AKG-28-4300
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Figure 3: Location of the 2009 Chukchi Sea Spring Lead System in Relation to the Area of Coverage for the
Geotechnical General Permit (AKG-28-4300).
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Fact Sheet - NPDES General Permit Re-Proposal
Oil and Gas Geotechnical Surveys and Related Activities
Page 10 of 25
General Permit No. AKG-28-4300
The spring lead system and spring-migration corridor through the Beaufort Sea
extends farther offshore than through the Chukchi Sea (NMFS 2013). Offshore
activities, such as geotechnical surveys and related activities, are unlikely to occur
within the Beaufort Sea spring lead system during the spring bowhead migration
because the pack ice movement at this time of year would be too variable and
unsafe for vessels to get to an offshore location to conduct the activities (NMFS
2008).
Due to the relative nearshore location of the spring lead system in the Chukchi
Sea, its particular importance for feeding, migration, and calving for a number of
species, and to protect the spring subsistence hunting period, EPA has included a
seasonal prohibition on all discharges within the 3-25 mile offshore prior to July
1. This seasonal prohibition would reduce impacts to this sensitive ecosystem,
while simultaneously protecting the migration and calving corridor of bowhead
whales.
EPA's ODCE includes and expanded discussion of the spring lead system,
analyses of the discharges, and provides additional rationale for the seasonal
prohibition.
2. Environmental Monitoring Program
a. Baseline Site Characterization ("Phase I")
The purpose of the EMP baseline characterization requirement (Draft Permit
Part II. A. 14.) is to ensure that the geotechnical activity site is not located in
or near a sensitive biological area, habitat, or historic property. EPA received
comments that site characterization information/data is already collected
during preliminary baseline surveys or available through prior or ongoing
studies in the Chukchi and Beaufort Seas funded by industry and government
agencies. The revised language clarifies that this requirement can be met by
submitting existing representative baseline survey data, where available.
EPA has revised the requirements as follows.
Initial Site Physical Sea Bottom Survey (Permit Part
11. A.4415.d. I.). Conduct an assessment of the physical sea
bottom before initiating discharges authorized by the general
permit to ensure the geotechnical activity site is not located in or
near a sensitive biological area, habitat, or in the vicinity of
historic properties. The survey should provide both a physical
and visual characterization of the seafloor. If the proposed initial
site is located in or near a sensitive biological area, habitat, or in
the vicinity of historic properties, the permittee must report the
information to the Director in accordance with Section
II.A.4415.g.l.
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Fact Sheet - NPDES General Permit Re-Proposal
Oil and Gas Geotechnical Surveys and Related Activities
Page 11 of 25
General Permit No. AKG-28-4300
To meet this requirement, the permittee may submit existing
baseline survey data that are representative of the site location
and demonstrate that the geotechnical activity site is not located
in or near a sensitive biological area, habitat, or historic
properties. The existing, representative baseline data must be
submitted with the NOI for consideration.
Physical Characteristics (Permit Part II.A.4415.d.2.). Collect
physical data to characterize the conditions of the geotechnical
activity site and receiving waters. These physical data must
include surface wind speed and direction, current speed and
direction throughout the water column, water temperature,
salinity, depth, and turbidity.
To meet this requirement, the permittee may submit existing site
baseline survey data, provided the physical data (i.e. wind/current
speed and direction, water temperature, salinity, turbidity) is
demonstrated to be representative across the geotechnical survey
and/or related activity site.
The track changes represent the changes made to the original language in the
Draft Geotechnical General Permit.
b. Drilling Fluids and Drill Cuttings Deposition Evaluation
("Part II")
Based on a review of comments received, the Part II Drilling Fluids and Drill
Cuttings Deposition Evaluation requirement (Permit Part II.A.4415.ef.) has
been revised to require a narrative discussion rather than a map of the areal
extent and depth/thickness of the solids deposition. Given the short term
nature of the activities at each location (one to ten days) and the relative small
area of deposition, EPA believes a narrative discussion would be more
descriptive and useful for future decision-making.
Drilling Fluids and Drill Cuttings Deposition Evaluation (Part
II; Permit Part II. A. 15.e.). Conduct a physical sea bottom survey
immediately following cessation of geotechnical activities at the
site. The physical sea bottom survey should must include a visual
characterization of the seafloor and a narrative discussion of te
assess the geotechnical activity site condition. The survey must
map the areal extent and depth/thickness of solids deposition
caused by Discharge 001^ and discuss depict any potential
overlap from deposition caused by nearby exploration activities.
EPA retains the requirement to collect observations for potential marine
mammal deflection during periods of discharge of non-contact cooling water
(Discharge 009), however, it has been moved from Permit Part II.A.4-415.e.l.
to Part II.B.J. The purpose of this requirement is to collect information
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Fact Sheet - NPDES General Permit Re-Proposal
Oil and Gas Geotechnical Surveys and Related Activities
Page 12 of 25
General Permit No. AKG-28-4300
regarding potential deflection as a result of this discharge to inform future
decisions. EPA has added a requirement that the permittee must report any
observations of potential deflection in the following month's Discharge
Monitoring Report (DMR). The requirement to report any potential marine
mammal deflection during the following month's DMR would allow the
interested public to access that information.
This monitoring requirement at II.B.J. has been revised to read as follows:
Marine Mammal Observations Discharge 009 (non contact
cooling water) Plume Observations. The permittee must observe
collect observations for potential marine mammal deflection
during periods of non-contact cooling water discharge (Discharge
009). Observations of potential marine mammal deflection must
be reported in the following month's Discharge Monitoring
Report (DMR).
Since the marine mammal observation requirement has been removed from
the EMP, and is now a monitoring requirement specific to non-contact cooling
water discharges (Discharge 009; Permit Part II.B.J.), EPA has removed EMP
Objective #4 from Permit Part II.A.15.b.4.
The track changes represent the changes made to the original language in the
Draft Geotechnical General Permit.
3. Requirements for Water-Based Drilling Fluids and Drill Cuttings
(Discharge 001)
EPA received comments on the monitoring requirements and the frequency of
monitoring for water-based drilling fluids and drill cuttings (Discharge 001), and
has revised the relevant permit provisions, as described below.
a. Metals Analysis
EPA received comments that the metal parameters listed in Table A are
implicated by exploration drilling, not geotechnical boring. Commenters
indicated that the only metals of concern for a geotechnical program are
chromium, mercury and sulfides found in barite, which are not easily
absorbed by the marine life and can be pre-tested for concentrations from the
mud the operator purchases for use each season.
EPA has clarified that the metals analysis for drilling fluids and drill cuttings
(Discharge 001) is only required if barite is added to the fluid formulation.
Barite is the primary source of metals in the drilling fluid formulation. This
modification is reasonable and consistent with EPA's goal of collecting data
during this permit term to inform future decisions.
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Fact Sheet - NPDES General Permit Re-Proposal
Oil and Gas Geotechnical Surveys and Related Activities
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General Permit No. AKG-28-4300
Water-Based Drilling Fluids Metals Analysis (Permit Part
H.B.3.). The permittee must analyze each drilling fluids
formulation system for the metal contaminants of concern if
barite is added to the drilling fluid formation (see Table A). This
analysis is required once (1) per batch of drilling fluids mixed at
the facility drilling fluid formulation, and the analysis may be
conducted "pre-season." If a new mixture of drilling fluids is
created, or a new drilling fluid formulation system is used and/or
a new "lot" or supply or barite is used during the geotechnical
activities program, then an additional metals analysis is required.
The permittee may propose an alternative list of metals based on
site-specific data. The results of the water-based drilling fluids
metals analysis must be submitted to the Director with the annual
NOI renewal or within 1 year of completing geotechnical surveys
and/or related activities (whichever comes first).
The track changes represent the changes made to the original language in the
Draft Geotechnical General Permit.
b. Suspended Particulate Phase (SPP) Toxicity Testing
EPA received a comment seeking clarification of the term "batch." The
commenter explained that most operators will likely mix "batches" with great
frequency, thus necessitating that they perform testing multiple times per day
while conducting geotechnical activities. If this provision is not removed
from the final permit, or modified, the commenter asserted, it would result in
daily helicopter travel to and from vessels during geotechnical activities.
While the draft Geotechnical General Permit did include a definition of the
term "batch," it was not EPA's intent to require multiple samples to be
collected each day to meet the SPP toxicity testing requirements.
EPA has revised the SPP toxicity test sampling requirements to specify that
operators must conduct testing no less than once (1) per season and it may be
performed pre-season. If a new drilling fluid formulation is used during the
course of the geotechnical program, then a new SPP toxicity test must be
conducted. Because EPA has allowed the test to be conducted pre-season,
EPA has removed the reference to inclement weather conditions.
Please refer to Table 1, below, to view specific changes.
c. Mercury and Cadmium in Stock Barite
As discussed in Section 5.b. of this Fact Sheet, it was not EPA's intent to
require testing for mercury and cadmium to occur multiple times per day.
EPA has clarified within Table 1 of the Permit that monitoring for mercury
and cadmium testing of stock barite must occur once per season if barite is
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Fact Sheet - NPDES General Permit Re-Proposal
Oil and Gas Geotechnical Surveys and Related Activities
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General Permit No. AKG-28-4300
added to the drilling fluid formulation, with additional testing required if a
new lot/supply of barite is used. The initial testing can be completed pre-
season.
Please refer to Table 1, below, to view specific changes.
As discussed in Section 3.b. of this Fact Sheet with regard to SPP toxicity
testing, it was similarly not EPA's intent to require testing for pH to occur
multiple times per day for Discharge 001. EPA has clarified within Table 1
of the Permit that monitoring for pH must occur "once per season," with
additional testing required if a new drilling fluid formulation is to be used to
conduct the geotechnical surveys and/or related activities. The initial testing
can be completed pre-season.
d. PH
Please refer to Table 1, below, to view specific changes.
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Fact Sheet - NPDES General Permit Re-Proposal
Oil and Gas Geotechnical Surveys and Related Activities
Page 15 of 25
General Permit No. AKG-28-4300
TABLE 1: Effluent Limitations and Monitoring Requirements for Water-Based Drilling Fluids and Drill Cuttings (Discharge 001)
Discharge
Pollutant Parameter
Effluent Limitation
Monitoring Requirements
Average Monthly Maximum Daily
Limit Limit
Measurement
Frequency
Sample Type
Water-based fluids and
cuttings
SPP toxicity Note L9
Minimum 96-hour LC50 of 30,000 ppm
Once ocr season Note 1
Onco per batch
Grab 01 e 2
Drilling fluids and cuttings
Discharge allowed Note3 -8
Daily
Grab
Free oil
No discharge Note 4-x
Daily
Grab
Diesel oil
No discharge Note 5 -8
Daily
Grab
Mercury
1 mg/kgNote6
Once ocr season
Grab
Cadmium
3 mg/kgNote6
Once ocr season NoteSJ*
Grab
pH
Report (s.u.)
Once ocr season
Grab
Total Volume
See Section If.A. 15. (gal)
Daily
Estimate
Non-aqueous fluids
--
No discharge
--
~
Non-aqueous cuttings
--
No discharge
--
~
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Fact Sheet - NPDES General Permit Re-Proposal
Oil and Gas Geotechnical Surveys and Related Activities
Page 16 of 25
General Permit No. AKG-28-4300
Footnotes:
1
2
3
4
5
6
7
8
9
As determined by the 96-hour suspended particulate phase (SPP) toxicity test in accordance with Appendix 2 to Subpart A of 40 CFR Part 435, Drilling
Fluids Toxicity Test. The discharge of water-based drilling fluids or drill cuttings generated using drilling fluids with a daily minimum or monthly
average minimum 96-hour LCso of less than 30,000 ppm is prohibited. The permittee may conduct this test pre-season and must conduct this test no less
than once per season. If a new drilling fluid fonnulation is to be used during the course of the geotechnical program, then a new SPP toxicity test must
be conducted. If inclement weather conditions affect timely deliveries of samples, the pennittee must notify EPA within 21 hours and document the
conditions and rationale in the following monthly DMR.
The pennittee must analyze a representative initial sample of drilling fluids either during pre-season preparations or from the mud pit prior to
commencing geotechnical drilling operations.
No discharge allowed upon failure of the static sheen test as determined in accordance with Appendix 1 to Subpart A of 40 CFR Part 435, Static Sheen
Test.
The pennittee must analyze a representative initial sample of drilling fluids from the mud pit prior to commencing geotechnical drilling operations using
the static sheen test in accordance with Appendix 1 to Subpart A of 40 CFR Part 435, Static Sheen Test.
The discharge of drilling fluids or drill cuttings generated using drilling fluids which contain diesel oil is prohibited. Compliance will be demonstrated
by gas chromatograph (GC) analysis of drilling fluid collected from the drilling fluid used at the greatest borehole depth and of any drilling fluids or
cuttings which fail the static sheen test compared to GC analysis of diesel oil in storage on the facility. Whenever drilling fluids fail the static sheen test,
the pennittee is required to analyze an undiluted sample of the material which failed the test to detennine the presence or absence of diesel oil in
accordance with EPA SW846 Method 8015C (2007). Gas chromatography/mass spectrometry (GC/MS) may be used if an instance should arise where
the pennittee and the Director detennines that greater resolution of the drilling fluid "fingerprint" is needed for a particular drilling fluid sample.
Required if barite is added to the drilling fluid fonnulation. Dry weight in the stock barite. Results must be expressed as mg/kg (dry weight) of barite.
Required if barite is added to the drilling fluid fonnulation. The pennittee must analyze a representative initial sample of stock barite either during pre-
season preparations or prior to drilling at the first geotechnical borehole location of the calendar year and submit the results with the DMR for the month
in which operations commence. If any analytical result exceeds the mercury or cadmium effluent limitations in Table 1, the pennittee must report the
results to the Director in accordance with Section III.G., including the twenty-four hour notice of noncompliance requirement, of this general pennit. If
the pennittee uses the same supply of stock barite to replenish the mud pit during the season's operations, the pennittee may submit the same analysis if
no new supplies of barite have been received since the prior analysis. In this case, the DMR should state that no new barite was received since the last
reported analysis.
Record separate total daily volumes of drilling fluids and drill cuttings and report the separate daily volumes in the End of Year Report. Report
combined total volume of drilling fluids and drill cuttings discharged on a calendar day in the DMR.
The pennittee must report the following discharge occunences of noncompliance to the Director in accordance with Section III.G.l., including the
twenty-four hour notice of noncompliance requirement, of this general pennit: (a) exceedance of the SPP toxicity limitation; (b) failure of the static
sheen test; or (c) presence of diesel oil.
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Oil and Gas Geotechnical Surveys and Related Activities General Permit No. AKG-28-4300
4. Fecal Coliform and Total Residual Chlorine Testing
EPA has reduced the sampling frequency for fecal coliform and total residual
chlorine from weekly to monthly. EPA had received comments requesting that
the fecal coliform requirements be removed from the Draft Geotechnical General
Permit. In light of concerns over discharges of human waste to areas of
subsistence use and to ensure no unreasonable degradation of the marine
environment, EPA will retain requirements for fecal coliform and total residual
chlorine testing, which are consistent with discharge regulations found at 40 CFR
140.3 (CWA312).
Geotechnical surveys and related activities require a much smaller vessel with a
limited number of personnel, as compared to other offshore oil and gas activities.
Additionally, geotechnical activities are short term at any one site (one to ten
days). As such, monthly monitoring is appropriate to ensure protection of the
marine environment.
TABLE 2: Effluent Limitations and Monitoring Requirements for Sanitary Wastes
(Discharge 003)
Effluent Parameter
Units
Effluent Limitations
Monitoring Requirements
Average
Monthly Limit
Maximum
Daily Limit
Sample
Frequency
Sample Type
Flow
mgd
—
...
Daily
Measured/
recorded
BODs
mg/1
30
60
Weekly
Grab or
composite Note 1
TSS
mg/1
30
60
Weekly
Grab or
composite Note 1
Floating Solids &
Garbage
no discharge
Daily
VisualNote 2
Foam
no discharge
Daily
Visual N°te 2
Oily Sheen
no discharge
Daily
VisualNote 2
pH
s.u.
6.5-8.5
Weekly
Grab
Fecal Coliform
Bacteria Note 4
colonies/
100 mL
100 Note3
200
Monthlv
Weekly
Grab
Total Residual
Chlorine Note 5
mg/1
...
1.0
Monthlv
Wooklv
Grab
Footnotes:
1 Composite samples may be collected in lieu of grab samples and must consist of at least four equal volume
grab samples, two of which must be taken during periods of peak flow.
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2 The permittee must monitor by observing the surface of the receiving water in the vicinity of the outfall(s)
during daylight at the time of maximum estimated discharge and during conditions when observations on
the surface of the receiving water are possible in the vicinity of the discharge. The observations and time
of day must be recorded. The numbers of days floating solids, garbage, foam or oily sheen are observed
must be recorded and reported in the DMR.
3 Must be reported as the geometric mean.
4 If inclement weather conditions affect timely deliveries of samples, the permittee must notify EPA within
24 hours document the conditions and rationale in the following monthly DMR.
5 Must be maintained as close to this concentration as possible. Sample must be collected immediately after
chlorination and prior to any commingling of the waste streams. The analytical detection limit for this
parameter is 0.1 mg/1. Residual chlorine may be monitored according to test procedures approved under 40
CFR Part 136 or using a Hach Test Kit capable of measuring free chlorine in the range of 0-3.5 mg/1 with a
sensitivity of 0.1 mg/1 or better. Monitoring is not required if chlorine is not used as a disinfectant or for
facilities serving fewer than 10 persons.
5. NOI Submission Requirements
EPA is proposing that the Drilling Fluids Plan (DFP), the Best Management
Practice Plan (BMP) and the Quality Assurance Project Plan (QAPP) are only
required to be submitted as part of the NOI package if a permittee requests
authorization to discharge Drilling Fluids and Drill Cuttings (Discharge 001).
The requirement these submittals be included with the NOI package applies only
to operators using drilling fluids with added chemicals.
For those operators who intend to only use seawater (without additives) to
conduct geotechnical surveys and related activities, or those that intend to
conduct on-ice activities and discharge only a single waste stream, such as drill
cuttings not associated with drilling fluids (Discharge 011), the DFP, BMP and
QAPP do not need to be included with the NOI package. This change minimizes
the upfront paperwork submissions and documentation.
A BMP and QAPP must be developed by all permittees and are required to be
kept on site.
Please refer to the attached re-proposed NOI form to review the revised list of
required submissions. Permittees who will discharge drilling fluids and drill
cuttings (Discharge 001) are still subject to the full list of required submissions.
II. OTHER LEGAL REQUIREMENTS
A. Ocean Discharge Criteria Evaluation
Section 403 of the Clean Water Act, 33 USC § 1343, prohibits issuing an NPDES
permit for discharges into marine waters located in the territorial seas, the contiguous
zones, and the oceans except in compliance with the ocean discharge guidelines, 40
CFR Part 125, Subpart M. The guidelines set out criteria that the EPA must evaluate,
called the Ocean Discharge Criteria Evaluation (ODCE), to ensure that point source
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General Permit No. AKG-28-4300
discharges do not cause unreasonable degradation to the marine environment.
The area of coverage of the draft Geotechnical General Permit is within federal waters
of the Beaufort and Chukchi Seas. Since the Geotechnical General Permit applies to
discharges to federal waters, the geographic scope of the ODCE extends seaward from
the outer boundary of the territorial seas. EPA has revised the ODCE to incorporate
the changes in the re-proposed draft permit. After the close of this public comment
period, EPA will refine the ODCE analyses and conclusions, as necessary, to reflect
the agency's final decisions.
B. State Water Quality Standards and Certification
The Geotechnical General Permit's area of coverage is only in federal waters, and thus
the General Permit is not subject to Section 401 of the CWA.
C. Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National
Oceanic and Atmospheric Administration's (NOAA) National Marine Fisheries
Service (NMFS) and the U. S. Fish and Wildlife Service (USFWS) if their actions
could beneficially or adversely affect any threatened or endangered species and/or
their designated critical habitat. EPA analyzed the discharges proposed to be
authorized by the draft Geotechnical General Permit, and their potential to adversely
affect any of the threatened or endangered species or their designated critical habitat
areas in the vicinity of the discharges in a Biological Evaluation (BE) dated December
2013. EPA completed a supplemental analysis evaluating the effects of interrelated
and interdependent actions on the Pacific walrus on February 11, 2014. On January
31 and March 19, 2014, EPA received letters of concurrences from the USFWS and
NMFS, respectively, agreeing with EPA's determinations of effects. On March 13,
2014, in response to EPA's request for a conference on the Pacific walrus, the USFWS
confirmed that the proposed permit action would not jeopardize the continued
existence of this species.
EPA has reviewed the re-proposed draft permit and determined that the proposed
changes would not have an effect on the original conclusions that the discharges may
affect, but are not likely to adversely affect listed, proposed, and candidate species or
their designated critical habitat areas. This Fact Sheet, the re-proposed draft
Geotechnical General Permit, and the revised ODCE will be sent to NMFS and the
USFWS for review during the public comment period.
D. Magnuson-Stevens Fishery Conservation and Management Act
Under the Magnuson-Stevens Fishery Conservation and Management Act, NMFS and
various fisheries management councils must identify and protect "essential fish
habitat" (EFH) for species managed under the Act. The EFH regulations define an
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Oil and Gas Geotechnical Surveys and Related Activities General Permit No. AKG-28-4300
adverse effect as any impact that reduces quality and/or quantity of EFH and may
include direct (e.g. contamination or physical disruption), indirect (e.g. loss of prey,
reduction in species fecundity), site-specific, or habitat wide impacts, including
individual, cumulative, or synergistic consequences of actions. Agency actions that
may adversely affect EFH requires consultation with NMFS.
EPA's EFH assessment is included as Appendix A to the BE. The EFH assessment
concluded that the discharges authorized by the Geotechnical General Permit will not
adversely affect EFH. Similarly, EPA is concluding that the re-proposed permit
changes will not adversely affect EFH.
E. National Historic Preservation Act
The National Historic Preservation Act (NHPA) requires federal agencies to ensure
that any agency-funded and permitted actions do not adversely affect historic
properties that are included in the National Register of Historic Places or that meet the
criteria for the National Register. BOEM has conducted archaeological baseline
studies of the Outer Continental Shelf (OCS) of the Beaufort and Chukchi Seas to
determine where known historic properties may be located. These baseline studies are
used to identify archaeologically sensitive areas that may contain significant historic
properties.
For geotechnical surveys and related activities authorized under the Geotechnical
General Permit, the applicant is required to submit to EPA, along with the NOI, an
assessment of whether the activity may have the potential to cause effects to any
historic properties listed on, determined to be eligible for listing on, or potentially
eligible for listing on the National Register of Historic Places, including previously
unidentified properties. The NOI must state which historic properties may be affected
by the proposed activities and include a vicinity map indicating the location of the
historic properties or the potential for the presence of historic properties.
Additionally, prior to conducting the geotechnical activity, the operator must conduct
a baseline site characterization or provide relevant existing data to ensure the locations
are not in the vicinity of potential historic properties. The operator must notify EPA 7
calendar days from receipt of the physical sea bottom survey data, if the data indicates
the proposed geotechnical activity is located in the vicinity of historic properties.
Information from the NOI and/or the baseline site characterization will assist EPA
with ensuring the requirements of Section 106 of the NHPA are met.
F. National Environmental Policy Act
In accordance with the Clean Water Act (33 U.S.C. 1371) and EPA regulations (40
CFR 122.29(b)(2) and (c)(1); 40 CFR Part 6), issuance of NPDES permits for new
sources are considered major Federal actions subject to review under the National
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Oil and Gas Geotechnical Surveys and Related Activities General Permit No. AKG-28-4300
Environmental Policy Act (NEPA). A "new source " means any building, structure,
facility, or installation from which there is or may be a "discharge of pollutants," the
construction of which commenced: (a) After promulgation of standards of
performance under section 306 of CWA which are applicable to such source, or (b)
After proposal of standards of performance in accordance with section 306 of CWA
which are applicable to such source, but only if the standards are promulgated in
accordance with section 306 within 120 days of their proposal.
Construction of a "new source" commences if the owner or operator of the facility (1)
has begun, or caused to begin significant site preparation work as a part of a continuous
on-site construction program or (2) has entered into a binding contractual obligation
for the purchase of facilities or equipment that are intended to be used in its operations
within a reasonable amount of time. See 40 CFR 122.29(b). Significant site
preparation work is defined in the Oil and Gas Offshore Subcategory as the process of
surveying, clearing or preparing an area of the water body floor for the purpose of
constructing or placing a development or production facility on or over the site.
New source performance standards have not been promulgated under section 306 of
the CWA for discharges associated with oil and gas geotechnical surveying activities.
Furthermore, geotechnical surveying activities are not considered significant site
preparation work. As explained in the preamble for the final Offshore Subcategory
regulations, exploratory wells are not considered "significant site preparation work"
because the operations are conducted at a particular site for a short duration, typically
lasting only three to six months, and not necessarily followed by development and
production activities at the site. Moreover, even when development and production
does occur, it may not occur for months or years after exploration. See 58 Fed. Reg.
at 12457 (noting that "exploratory wells would not be new sources in any
circumstance"). The same is true for geotechnical activities, which are significantly
shorter in duration, lesser in scope and produce smaller discharge volumes.
As such, issuance of NPDES permits for geotechnical survey activities, including this
re-proposal, are not considered major Federal actions subject to NEPA review and a
NEPA evaluation has not been prepared for this permit action.
G. Environmental Justice (Executive Order 12898)
The EPA has determined that the discharges authorized by the draft Geotechnical
General Permit will not have a disproportionately high and adverse human health or
environmental effects on minority or low-income populations living on the North
Slope, including coastal communities near the proposed geotechnical activities. In
making this determination, EPA considered the potential effects of the discharges on
the communities, including subsistence areas, and the marine environment. EPA's
environmental justice evaluation and determinations are discussed in the draft ODCE
for the Geotechnical General Permit, and are based, in part, on the Environmental
Justice Analysis completed for the 2012 Beaufort & Chukchi Exploration NPDES
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General Permit No. AKG-28-4300
General Permits.
Executive Order 12898 entitled "Federal Actions To Address Environmental Justice
in Minority Populations and Low-Income Populations" states in relevant part that
"each Federal agency shall make achieving environmental justices part of its mission
by identifying and addressing, as appropriate, disproportionately high and adverse
human health or environmental effects of its programs, policies, and activities on
minority populations and low-income populations..." The order also provides that
federal agencies are required to implement the order consistent with and to the extent
permitted by existing law. In addition, the EPA Region 10 adopted its "North Slope
Communications Protocol: Communications Guidelines to Support Meaningful
Involvement of the North Slope Communities in EPA Decision-Making" in May
2009. Consistent with the North Slope Communications Protocol, EPA sent early
informational letters in May 2013 to all of the coastal entities (City governments, tribal
governments, marine mammal commissions, North Slope Borough, Northwest Arctic
Borough and the ANCSA Village and Regional Corporations) on the North Slope, as
well as the whaling communities of Kivalina, Diomede, Wales, Savoonga, Gambell,
and Kotzebue. EPA held two informational teleconference calls to determine level of
interest in this project; those meetings were held on May 14 and May 21, 2013.
During the public comment period for the draft Geotechnical General Permit, EPA
held meetings with the North Slope Borough Mayor's office, the Native Village of
Barrow, the Alaska Eskimo Whaling Commission, and the Inupiat Community of the
Arctic Slope. In addition, EPA hosted a public hearing in Barrow on January 8 and a
teleconference hearing in Anchorage on January 10, 2014. EPA planned for
community and tribal consultation meetings in Kaktovik and Wainwright, but was
unable to attend in person due to weather conditions. Instead, the agency held a
meeting with the community of Wainwright via teleconference on January 7, 2014.
Finally, EPA has notified tribal governments and local communities and stakeholders
on the North Slope of the re-proposal and of the opportunity to provide comment on
the re-proposed draft permit. EPA has also concluded that the changes included in the
re-proposal do not alter the conclusion that the permit action would not have a
disproportionately high and adverse human health or environmental effects on
minority or low-income populations living on the North Slope, including coastal
communities near the proposed geotechnical activities.
H. Tribal Consultation (Executive Order 13175)
Executive Order 13175 (November, 2000) entitled "Consultation and Coordination
with Indian Tribal Governments" requires federal agencies to have an accountable
process to assure meaningful and timely input by tribal officials in the development
of regulatory policies on matters that have tribal implications and to strengthen the
government-to-government relationship with Indian tribes. In May, 2011, the EPA
issued the "EPA Policy on Consultation and Coordination with Indian Tribes" which
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Oil and Gas Geotechnical Surveys and Related Activities General Permit No. AKG-28-4300
established national guidelines and institutional controls for consultation.
Efforts have been taken to provide tribal entities and North Slope, Northwest Arctic,
and Bering Sea communities with information about the ODCE and draft Geotechnical
General Permit development process, and to simultaneously seek early input into the
EPA evaluations. In May 2013, the EPA held two information sessions via conference
call with members of tribal governments, native corporations, and subsistence
commissions to inform them about the upcoming NPDES permitting action and seek
input.
Pursuant to the EPA Region 10's Tribal Consultation Procedures, in determining
which tribal governments to invite for consultation, the EPA considered whether the
action could potentially affect a tribe's resources, rights, or traditional way of life. On
September 19, 2013, the EPA sent an invitation for tribal consultation to the following
tribal governments: Native Village of Kaktovik, Native Village of Nuiqsut, Native
Village of Barrow, ICAS, Wainwright Traditional Council, Native Village of Point
Lay, Native Village of Point Hope, Native Village of Kivalina, Kotzebue IRA
Council, Native Village of Diomede, Native Village of Wales, Native Village of
Savoonga, and the Native Village of Gambell. Included with the invitation for tribal
consultation was a summary of the draft Geotechnical General Permit's requirements.
During the comment period for the draft Geotechnical General Permit, EPA held tribal
consultation meetings with the Native Village of Barrow and the Inupiat Community
of the Arctic Slope.
Consistent with the Executive Order and the EPA tribal consultation policies, the EPA
will honor requests for consultation meetings on the re-proposed draft Geotechnical
General Permit from federally-recognized tribal governments.
I. Pollution Prevention Act
It is national policy that, whenever feasible, pollution should be prevented or reduced
at the source, that pollution which cannot be prevented should be recycled in an
environmentally safe manner, and that disposal or release into the environment should
be employed only as a last resort and should be conducted in an environmentally safe
manner. The permittee will discharge at the facility in accordance with best
management practices that will address the provisions of the Pollution Prevention Act.
J. Oil Spill Requirements
Section 311 of the Clean Water Act prohibits the discharge of oil and hazardous
substances in harmful quantities. Discharges specifically controlled by the draft
Geotechnical General Permit are excluded from the provisions of Section 311 because
these discharges are limited to amounts and concentrations which are deemed to be
protective of State water quality standards. However, the permit does not preclude the
institution of legal action or relieve the permittee from any responsibilities, liabilities,
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Oil and Gas Geotechnical Surveys and Related Activities General Permit No. AKG-28-4300
or penalties for other unauthorized discharges of oil and hazardous materials which
are covered by Section 311.
K. References
BOEMRE (Bureau of Ocean Energy Management, Regulation and Enforcement).
2011. Alaska Outer Continental Shelf OCS EIS/EA BOEMRE 2011-041
Chukchi Sea Planning Area Oil and Gas Lease Sale 193 in the Chukchi Sea,
Alaska. Final Supplemental Environmental Impact Statement Volume I.
Chapters I - VI and Appendices A, B, C, D. U.S. Department of the Interior,
Bureau of Ocean Energy Management, Regulation and Enforcement, Alaska
OCS Region. August 2011.
Eicken, H., L.H. Shapiro, A.G. Gaylord, A. Mahoney, and P.W. Cotter. 2006.
Mapping and Characterization of Recurring Spring Leads and Landfast ice in
the Beaufort and Chukchi Seas. OCS Study MMS 2005-068. Anchorage, AK:
USDOI, MMS, Alaska OCS Region, 141 pp. plus Appendices.
Mahoney, A.R. 2012. Sea ice conditions in the Chukchi and Beaufort Seas.
November 2012. Prepared for The Pew Charitable Trusts' U.S. Arctic
Program, Geophysical Institute, University of Alaska Fairbanks, Fairbanks,
AK.
Mahoney, A.R., H. Eicken, L.H. Shapiro, R. Gens, T. Heinrichs, F.J. Meyer, and A.
Graves Gaylord. 2012. Mapping and Characterization of Recurring Spring
Leads and Landfast Ice in the Beaufort and Chukchi Seas. U.S. Department of
the Interior, Bureau of Ocean Energy Management, Alaska Region,
Anchorage, AK. OCS Study BOEM 2012-067. 179 pp.
Martin, S. 2001. Polynyas. Encyclopedia of Ocean Sciences. 5:2241-2247.
MMS (Minerals Management Service). 2007. Chukchi Sea Planning Area Oil and
Gas Lease Sale 193 and Seismic Surveying Activities in the Chukchi Sea
(OCS Report MMS 2007-026). May 2007.
MMS. 2008. Beaufort Sea and Chukchi Sea Planning Areas Oil and Gas Lease Sales
209, 212, 217, and 221 Draft Environmental Impact Statement (OCS Report
MMS 2008-0055). November 2008
NMFS (National Marine Fisheries Service). 2008. Final environmental impact
statement for issuing annual quotas to the Alaska Eskimo Whaling
Commission for the subsistence hunt on bowhead whales for the years 2008
through 2012. National Marine Fisheries Service, Alaska Region, Juneau, AK
and Seattle, WA.
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Oil and Gas Geotechnical Surveys and Related Activities General Permit No. AKG-28-4300
NMFS. 2010. Biological Opinion, Authorization of Small Take Under the Marine
Mammal Protection Act for certain Oil and Gas Exploration Activities in the
U.S. Beaufort and Chukchi Seas, Alaska for 2010. July 13, 2010.
NMFS. 2011. Effects of Oil and Gas Activities in the Arctic Ocean Draft
Environmental Impact Statement, Volume 1. U.S. Department of Commerce,
National Oceanic and Atmospheric Administration, National Marine Fisheries
Service, Office of Protected Resources. December 2011
NMFS. 2012. Incidental Harassment Authorization issued to Shell Gulf of Mexico,
Inc., 2012 Open-Water Season in the Chukchi Sea, May 2, 2012.
NMFS. 2012. Final Environmental Assessment for the Issuance of Incidental
Harassment Authorizations for the Take of Marine Mammals by Harassment
Incidental to Conducting Exploratory Drilling Programs in the U.S. Beaufort
and Chukchi Seas. U.S. Department of Commerce, National Oceanic and
Atmospheric Administration, National Marine Fisheries Service, Office of
Protected Resources, Silver Spring, MD.
NMFS. 2013. Biological Opinion, Oil and Gas Leasing and Exploration Activities in
the U.S. Beaufort and Chukchi Seas. National Oceanic and Atmospheric
Administration, National Marine Fisheries Service, Office of Protected
Resources. April 2, 2013.
Norton, D.W. and G.A. Graves. 2004. Drift velocities of ice floes in Alaska's
northern Chukchi sea flaw zone: determinants of success by spring
subsistence whalers in 2000 and 2001. Arctic 57:347-362
Shell. 2014. Responses to EPA's Questions. Submitted via email on various dates.
April 20-May 30, 2014.
Weingartner, T., K. Aagaard, R. Woodgate, S. Danielson, Y. Sasaki, and D.
Cavalieri. 2005. Circulation on the north central Chukchi Sea shelf. Deep-Sea
Research Part Ii-Topical Studies in Oceanography, 52(24-26): 3150-3174.
Woodgate, R.A., T. Weingartner, and R. Lindsay. 2010. The 2007 Bering Strait
oceanic heat flux and anomalous Arctic sea-ice retreat. Geophys. Res. Lett.,
37(1): L01602.
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