&EPA

May 2017

Proposed Re-Issuance of Underground Injection
Control (UIC) Permit at the Grind and Inject (G&I)
Facility, Prudhoe Bay Unit: Fact Sheet

This cover sheet provides a brief overview of the proposed re-issuance of Permit AK 1I008-B for the
continued operation of three (3) existing Class I Non-Hazardous Industrial Waste Injection Wells at the
G&I Facility located in Prudhoe Bay, with an option to operate up to four wells. For more information,
please see the attached document which contains comprehensive and technical details regarding the
proposed permit and the location for finding additional information.

What is proposed
in the permit?

Will a new well
be drilled?

Why is EPA
permitting these
wells?

What will be
injected into
these wells?

How can I
comment and/or
request a
hearing?

The permit allows for the continued use of disposal wells that inject non-
hazardous waste at a depth of approximately 6,500 feet. Injection is limited to
oil field wastes exempt from hazardous waste determinations and other non-
hazardous waste fluids in support of hydrocarbon development on Alaska's
North Slope. This permit is a reissuance of a ten year permit that is set to
expire in August of 2017.

Potentially. Three (3) Class I disposal wells are currently in use at the G&I
facility. A fourth well may be drilled, so long as the siting, construction, and
operation adhere to the requirements of this permit and the regulations for
injection wells (40 CFR §144-146).

These disposal wells take the place of alternate waste disposal options such as
surface discharge or handling waste off site and has been shown to be a sound
disposal option.

Waste for injection will include, but not limited to: drilling muds, produced
water, production fluids from downhole, storm water, rig water, sanitary and
domestic wastewater, as well as other exempt and non-exempt fluids.

EPA accepts public comments and requests for public hearings for proposed
permit actions during the public comment period, which begins on June 30,
2017 and ends on July 31, 2017. If you would like to make a comment or
request a hearing, review the "Public Comment" section at the end of this
Fact Sheet or go to www.epa.gov/regionlO.

Where can I find If you are seeking more information related to this fact Sheet, please go to

more	www.epa.gov/regionlO or contact:

information?

Tim Mayers at 907-271-3410
mavers ,timothv@epa. gov

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PRUDHOE BAY UNIT GRIND AND INJECT AREA UIC WELLS FACT SHEET

Proposed Re-issuance of Underground Injection Control (UIC) Permit AK-1I008-B
For the Operation of up to Four Class I Non-Hazardous Industrial Waste Injection Wells
At the Prudhoe Bay Unit (PBU) Grind & Inject (G&I) Area,

North Slope of Alaska

Background

BP Alaska Inc (BPXA) has submitted an Underground Injection Control (UIC) permit application for the
operation of up to four (4) Class I non-hazardous industrial waste injection (existing, sidetrack or
replacement) wells. Three (3) Class I non-hazardous UIC currently operate at the G&I Facility. The
injection interval depths of these three existing wells are at approximately 6,500 feet true vertical depth
subsea (tvdss) in the onshore Class I PBU-G&I Area. To provide more flexibility, BPXA has requested
the number of active wells covered under this permit, be increased to four (4). The approximately 7,680
acre area covers the twelve sections (Umiat Meridian Sections 13, 14, 15, 22, 23, 24, 25, 26 and 36 of
Township 11 North, Range 15 East and Sections 19, 30 and 31 of Township 11 North, Range 16 East)
and currently includes the Surfcote and Pingut Pads adjacent to the Grind and Inject (G&I) Facility of the
Greater Prudhoe Bay Area (GPBA), Alaska. These three existing wells are currently authorized as Class I
UIC wells and Class II disposal injectors that have been in service since 1998. In 2002, a small amount
of Class V material was authorized by EPA for G&I disposal on a temporary basis. The Class I wells
serve as a needed disposal backup option for Class I fluids and will primarily continue to inject solids
from reserve pits, drilling muds and cuttings, produced water, well work-over fluids, treatment fluids and
treated sanitary wastewater. The application was submitted on February 21, 2017. EPA previously
granted a No Underground Sources of Drinking Water (USDW) Ruling (dated August 18, 2006) for those
portions of the aquifers between the base of the permafrost at approximately 1,900 feet tvdss to the top of
the CM2 marker at approximately 7,312 feet tvdss, since these aquifers significantly exceed the 10,000
milligrams/liter (mg/1) total dissolved solids (TDS) threshold for a USDW.

Regulatory Framework

The UIC program is authorized by Part C of the Safe Drinking Water Act for the principal purpose of
protecting USDW from impacts by injection through wells. The UIC regulations broadly define USDW
(see 40 CFR § 144.3) as any aquifer capable of supplying a public water system with water of less than
10,000 milligrams per liter (mg/L) TDS. If injection does not occur above, into, or through a USDW, then
less stringent injection well permit conditions may be imposed than would otherwise be required (see 40
CFR § 144.16). As described below, aquifers below the G&I facility do not meet the criteria of USDW

under CFR § 146.4. Under these circumstances, the EPA Director of Compliance and Enforcement

(OCE) may authorize injection with less stringent requirements than would otherwise than be required
(see 40 CFR § 146.4). EPA intends to grant several waivers requested by BPXA, which are described
later in this fact sheet.

Primary responsibility for regulation of injection wells through the UIC program is split in Alaska
between EPA and the AOGCC. The AOGCC regulates Class II injection wells, which are defined as
those wells used 1) to dispose of waste fluids brought to the surface from oil and gas production

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operations, 2) for enhanced recovery of oil and gas, or 3) for storage of hydrocarbons which are liquid at
standard temperature and pressure (see 40 CFR § 144.6). EPA directly regulates the other four classes of
injection wells in the State of Alaska. The UIC regulations allow Class II fluids to be disposed of into
Class I or II injection wells. Class I fluids may not be injected into Class II wells.

BPXA has requested a Class I non-hazardous industrial waste injection well permit for up to four
(including as needed the future sidetrack or replacement) Class I wells and Class II disposal wells. The
total number of Class I wells at the PBU-G&I Area would not exceed four active wells at any time. The
G&I facility and wells were constructed specifically to grind, process, and inject drilling wastes from
existing North Slope development well reserve pits on a large scale basis. Between September 2007 and
September 2016, approximately 1.6 million (MM) cubic yards (cy) were processed and injected in the
three G&I wells. When combined with injection volumes from the April 1998, approximately 6.3 MM cy
of solid material as well as other wastes have been injected in a total of approximately 168 million barrels
(MMB) of fluid. The operation has allowed closure of about half of the North Slope drilling reserve pits.
Future injection during the next permit period is anticipated to add another approximately 90 MMB
between years 2017 and 2026 (approximately 123 MMB through year 2030). The forecast of injection
volumes during this period is considered conservative, and includes waste from ongoing drilling,
production and well operations, remaining reserve pit material and disposing of waste currently injected
at the Prudhoe Bay Unit (PBU) Pad 3 Class I disposal facility.

Those portions of the aquifers in the PBU-G&I Area between the base of the permafrost at approximately
1,900 feet tvdss and the top of the CM2 marker at approximately 7,312 feet tvdss (based on the DS 4-01
Type Log as shown on Exhibit 3-1 of the Application) are too saline (over 10,000 mg/L TDS) to serve as
aUSDW.

Based upon a review of the information provided by BPXA, EPA previously issued a no USDW ruling
dated August 18, 2006 that covers those portions of the aquifers below the permafrost to the CM2 marker
that include the injection intervals in the proposed Class I wells. Under these circumstances, the Director
may authorize injection with less stringent requirements than would otherwise be required (see 40 CFR §
144.16). EPA intends to grant several waivers requested by BPXA, which are described under the
Injection Zone Modeling and Transient Well Testing Results section of this Fact Sheet.

EPA Permit and General Project Overview

The EPA 10-year term permit would allow BPXA to inject non-hazardous waste such as reserve pit
fluids, drilling mud and cuttings, cleanup generated wastes, produced oil reservoir brine, production camp
waste water, production well work-over fluids, well flushing (seawater), storm water and other wastes
(that did not come up from down hole). The permit would allow BPXA to inject non-hazardous waste
fluids generated at North Slope Operations through the (the life of the permit or) abandonment and
decommissioning of the facility.

The proposed G&I Injection Zone extends upward over an interval of approximately 3,000 feet from the
Colville/Seabee CM2 marker at the base to the Sagavanirktok SV1 marker at the top with the
Ugnu/Prince Creek as the primary injection interval.

BPXA operates the G&I plant and Surfcote Pad UIC wells in the Prudhoe Bay Unit (PBU) that has

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produced oil since 1977. Current production rate from the PBU is approximately 300,000 barrels of oil
per day (bopd) into the Trans Alaska Pipeline System (TAPS). The G&I-02A, G&I-03 and G&I-04 wells
are located onshore on the Surfcote Pad adjacent to the Pingut Pad within the G&I area described earlier.
Well G&I-02 was sidetracked to a new bottom hole location; subsequently named G&I-02A. In 2007,
well G&I-04 was drilled to essentially replace well G&I-01 (currently, G&I-01 does not have
authorization for Class I injection). The surface locations of the three wells are as follows:

Well G&I-02A - Latitude 70.283259 Longitude -148.241338

Sec 26, T11N, R15E, UM
Well G&I-03 - Latitude 70.28351 Longitude -148.2390481

Sec 26, T11N, R15E, UM
Well G&I-04 - Latitude 70.282966 Longitude -148.24401
Sec 26, T11N, R15E, UM

BPXA is not seeking authorization for a Class I hazardous waste injection well permit under this
application. Therefore, any listed hazardous wastes would need to be collected, stored, and transported to
a RCRA-approved hazardous waste treatment or disposal facility. Those wastes which are hazardous only
because of a characteristic (such as ignitability, corrositivity, toxicity, etc.) may be treated to remove that
characteristic and then injected as a Class I non-hazardous waste. The only radioactive waste substance
which may be injected under the proposed permit is naturally occurring radioactive material (NORM)
from sludge or pipe scale (a mineral precipitate formed during production).

Geologic Setting and Injection

The PBU-G&I Area is very compatible for waste disposal via injection wells. Large volumes of fluids
including ball mill processed solids have been successfully placed in the Ugnu formation sands for many
years. In order to enable the solids placement process, the solids injection takes place at an injection
pressure that is above the fracture pressure of the receiving formation. The past 20 years of solids disposal
has demonstrated that the wastes are safely contained within the Ugnu/Prince Creek injection interval
without any detectable leakage above the confining zone above the top of the injection zone.

Injection. Arresting and Confining Zones

The PBU-G&I waste injection disposal intervals and overlying and underlying confining zones are
composed of sedimentary siliciclastic strata of Cretaceous and Tertiary age. These strata are assigned,
from deepest to shallowest, to the Colville/Seabee Shale, Schrader Bluff/West Sak, Ugnu/Prince Creek
and Sagavanirktok formations.

The proposed G&I Injection Zone extends upward over an interval of 3,000 feet from the Colville/Seabee
CM2 marker (at approx. 7,312 feet tvdss in well DS 4-01) to the base and the Sagavanirktok SV1 marker
(4,350 feet tvdss in well DS 4-01) at the top and includes the upper Colville/Seabee section, the Schrader
Bluff/West Sak, the Ugnu/Prince Creek, and the lowermost Sagavanirktok section. The primary injection
zone is the Ugnu/Prince Creek interval. The base of the Injection Zone (at the CM2 marker) is located far
below the lowest permeable sands (500 feet) in the Schrader Bluff/West Sak sands to ensure that the
deepest potential fractures emanating from G&I injection are contained within the proposed Injection

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Zone.

The Ugnu/Prince Creek sands are flood plain to deltaic deposits which are generally variable in thickness
(10-100 feet) and extent. Lateral continuity and connectivity of individual Ugnu sand units is generally
good and results from the amalgamation of laterally meandering and cross-cutting sand channels in a high
net fluvio-deltaic depositional environment. Thin flood plain mudstones are inter-layered with the sand
bodies, but are more variable in log character and thickness than the sand bodies and do not consistently
extend between wells that are more than one mile apart. As a result of their more discontinuous character,
Ugnu/Prince Creek mudstones are more likely to form regional baffles and not barriers to vertical fluid
movement.

The Ugnu/Prince Creek sands have good porosity (30-35%) and good permeability (up to 1,000 md)
however most Ugnu sands fall in the 100-200 md range. High quality Ugnu-Mc sands 50-70 feet thick
near the base of the injection zone (at approx. 6,400 - 6,500 feet tvdss) have received the bulk of the
injected fluid and solids volumes in the G&I wells in the past.

The Sagavanirktok formation SV1 marker (at approx. 4,350 feet tvdss) defines the top of the Injection
Zone. The SV1 interval consists several cleaning upward cycles of marine mudstones grading upward to
deltaic and shallow marine shoreface sands. The onset of SV1 shallow marine deposition marks the end
of the fluvio-deltaic deposition which is dominant in the underlying Ugnu/Prince Creek section. The SV1
sands and mudstones are very consistent in character, rock properties, and thickness in the G&I area as
well as the Milne Point, Northstar, and Kuparuk River Unit areas showing lateral continuity. SV1 sands
have good porosities (25-30%) and maximum permeabilities up to 1,000 md however, most sands exhibit
permeabilities in the 100-300 md range based on DS-4-01 log model results.

Above the Injection Zone, the Arresting Strata consist of marine silty mudstones and interbedded shallow
marine and deltaic sands in the SV2 and SV3 intervals of the Sagavanirktok formation. The SV2 and SV3
sands show maximum porosities of 25% and permeabilities of 50-100 md, and are poorer quality (tighter
and less permeable) than the underlying SV1 interval. The SV2 and SV3 mudstones range between 120-
150 feet thick (see DS 4-01 log) and serve as very low permeability barriers to vertical fluid movement
from the SV1 interval.

The upper Confining Zone includes 320 feet of massive to silty marine mudstones in the lower SV4
interval and 110 feet of massive marine mudstone in the lower SV5 section. The SV4 and SV5 mudstones
are regionally extensive and consistent in shale content and thickness. A cleaning upward 130 foot thick
sand/shale interval lies between the SV4 and SV5 mudstones, however, the presence of the SV4 and SV5
massive marine mudstones above and below the sand body should effectively isolate the sand from any
vertical fluid movement from below.

Structure

The structure maps created in the G&I area on Sagavanirktok SV3 horizon (base of upper Confining Zone
at 3,750 feet tvdss in well DS 4-01), SV1 horizon (base of Arresting Strata/top oflnjection Zone at 4,350
feet tvdss in well DS 4-01), and on the Colville CM2 horizon (base oflnjection Zone at 7,312 feet tvdss
in well DS 4-01) as shown on Exhibits 3-4, 3-5 and 3-6 of the Application show the eastern PBU regional
geologic structure. Structure mapping shows that the eastern PBU Colville through Sagavanirktok

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stratigraphic section dips monoclinally to the east-northeast at 1 to 2 degrees. There are no fault offsets in
the Schrader Bluff/West Sak through the Sagavanirktok formations in the eastern PBU area. Deep seated
faults locally offset pre-Middle Colville horizons to the far west but sole out upward in the basal to
middle Colville mudstones (below approximately 7,500 feet tvdss). In the eastern PBU area, the absence
of penetrative shallow faults in combination with regionally thick and continuous confining shales, result
in the G&I Injection Zone being effectively confined and well suited for the disposal and containment of
injected waste fluids.

The base of the permafrost in the G&I area ranges in depth from 1,820 to nearly 2,000 feet tvdss.
Regionally, the permafrost layer thins to the north towards the Arctic coast and eventually pinches out
seaward of the coastal barrier islands. The lower Sagavanirktok confining layers are projected to intersect
the permafrost base approximately 25 miles southwest of the G&I area. Pore spaces in sedimentary rocks
within the permafrost interval are generally plugged with impermeable ice, and as a result, the permafrost
layer acts as a regional barrier to direct recharge of surface waters to the Sagavanirktok and Ugnu/Prince
Creek aquifers throughout the central North Slope of Alaska.

Reservoir Rock Properties

Average rock and reservoir properties for the disposal interval have been estimated from wire-line log
interpretations, core samples, and reservoir testing at the G&I wells and other PBU disposal wells
completed in these intervals. In summary, the Sagavanirktok sands have excellent porosity, permeability,
and discrete bedding while the deeper Ugnu sands have good to very good characteristics. The sands in
the lower Ugnu and West Sak intervals are somewhat poorer (being fine grained and more compacted due
to deeper burial), however their properties are still acceptable for waste injection. Average rock and
reservoir properties for the injection interval are summarized in the table below.

Ugnu Formation Disposal Interval Average Rock and Reservoir Properties

Porosity (Sand Intervals)	+/- 30 %

Net/gross Ratio	(Varies)

Net Sand Exposed (assumed baseline)	100 feet

Transmissibility (millidarcy-feet)	3,500-7,200 md-ft

Permeability (millidarcies)	25-100 md

Average Ugnu Reservoir Pressure	3,010 pounds per square inch (psi) (1998)

Est. Current Ugnu Reservoir Pressure	3,100 - 3,200 psi (2006)

Temp. Gradient below permafrost	1.8 deg F/100 feet of depth

Original Ugnu Fracture Gradient	+/- 0.65 psi/ft

Injection History and Forecast

As of September 30, 2016 (since 1998) three (3) G&I wells have been successfully used to inject over
168 MMB, averaging 6 to 10 MMB per year during the past 10 years. The amount of solids injected has
totaled 6.3 MM cy. The actual waste injections volumes between the years 2006 and 2016 were fairly
close to the projected volumes used in the 2006 modeling. The projected future injection to year 2030 is
based on a conservative projection of future field operations including drilling, reserve pit closure

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activities, and disposal of other waste streams. This projection includes solids from reserve pits, ongoing
drilling, ongoing well operations, and production operations. Approximately 1.27MM cy is projected to
be injected during the time period between years 2017 and 2030.

Injection Zone Modeling and Transient Well Testing Results

The 2006 modeling was updated in 2016 using the same, third-party company, Advantek Waste
Management Services, using their state-of-the-art simulator. The modeling is based on well G&I-03 due
to its long history and larger cumulative injection than the other two G&I wells. With perforations at
approximately 6,600 ft TVD in G&I-03, fracturing extends up to approximately 6,270 ft TVD, well
within the Injection Zone which has a top at approximately 4,500 ft TVD. This modeling was based on
actual injection volumes from 1998 to September 2016, and included a conservative projection of future
injection to evaluate fracture growth to date and through year 2030. The results of the fracture modeling
study indicate that subsurface slurry injection of the permitted waste material can continue safely until at
least the end of the year 2030.

Results from Step Rate Tests (SRT) analyzed by conventional and multi-rate pressure transient methods
confirm fractures are the primary disposal mechanism. Both the fracture modeling results and well
testing results compare favorably and confirm the containment of fractures and injected fluids within the
injection zone.

Due to corrosion related to oxygen in the injection fluids as well as the erosive nature of solids injection,
it is critical to monitor for well integrity issues. Metal loss due to erosion and corrosion of the wells has
been documented in all three G&I wells and has warranted tubing replacements. For example, in 2006,
the tubing in well G&I-02 was found to have significant erosion and corrosion damage. The well was
sidetracked to a new bottom hole location as G&I-02A and the lower portion of G&I-02 was abandoned.
New tubing was installed as part of the G&I-02A completion. EPA issued an Authorization to Inject for
G&I-2A January 18, 2008. Similarly, the G&I-01 tubing was also found to have erosion and corrosion
damage and the well was shut-in in May 2007. New well G&I-04 was completed in late 2007 and began
injection following issuance of Authorization to Inject issued by EPA on May 6, 2008. G&I-04 has
effectively replaced well G&I-01 for routine injection, utilizing the G&I-01 flow line. G&I-01 could
potentially be used for disposal again in the future if the tubing was replaced and authorization to inject is
received from EPA. The G&I-03 tubing was replaced in late 2009, also due to erosion and corrosion
damage. Following the submission of the well completion report, EPA issued Authorization to Inject to
inject in this well on December 23, 2009.

Data from monitoring tubing wall thickness and cross-sectional areas from caliper logs has been useful to
track the progression of the metal loss. This data is also utilized to estimate tubing/casing mechanical
properties (burst, collapse and tension) and to adjust the operational pressure limits as needed. Metal loss
observed in surface well components (valve gates, seats and flange gates, tree cross, SSV and master
valves) has warranted consistent maintenance to address effects of corrosion and erosion of mechanical
parts.

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Subsurface Aquifers/USDWs/Aquifer Exemption

A USDW is defined as an aquifer which is currently serving as a source of potable water or which, by
virtue of its potential productivity and natural water quality (i.e., less than 10,000 milligrams per liter of
total dissolved solids or TDS), could serve as a public water supply.

The Federal regulations at 40 CFR § 144.7, 146.4 and 147 (b) (2) allow an aquifer(s) to be exempted from
protection as a USDW provided it meets several criteria. On August 18, 2006, the EPA ruled that there
are no USDWs within the 7,680 acre Class I G&I area (Umiat Meridian Sections 13, 14, 15, 22, 23, 24,
25, 26 and 36 of Township 11 North, Range 15 East and Sections 19, 30, and 31 of Township 11 North,
Range 16 East) between the base of the permafrost (at approximately 1,900 feet tvdss) to the base of the
proposed Injection Zone (CM2 marker at approximately 7,312 feet tvdss) as referenced in the Type Log
DS 4-01. The aquifers are very saline and exhibit total dissolved solids concentrations that significantly
exceed the 10,000 mg/1 TDS threshold for a USDW.

The Eastern Operating Area of the PBU currently has a Class II "no USDW' determination approved by
the Alaska Oil and Gas Conservation Commission (AOGCC Area Injection Order #4- effective July 11,
1986) for all aquifers beneath the G&I area.

BPXA submitted petro-physical and water sample data to provide support and obtain from EPA a no
USDW ruling for aquifers between the base of the permafrost (at approximately 1,900 feet tvdss) to the
base of the proposed Injection Zone (CM2 marker at approximately 7,312 feet tvdss) as referenced in the
Type Log DS 4-01 within the G&I area. The ruling dated August 18, 2006 applies to the area of current,
future sidetrack and future alternate wells. The original injection zone had an average total dissolved
solids (TDS) content of 35,000 mg/1 and has received fluids containing 21,000 TDS mg/1 or greater since
1998. The in-situ water has a gas solubility of 7 standard cubic feet of gas per barrel of brine, based on
salinity values and gas content from PBU nearby wells. Some methane gas exists in the Sagavanirktok
below 3,600 feet tvdss in formation waters.

As a result of the no USDW ruling for Class I injection and the existing Class II determination, EPA
intends to grant three (3) waivers of UIC regulatory program requirements as listed below:

(1)	Compatibility of Formation and Injectate (40 CFR § 146.12 (e) [4] [5] and 146.14 (a) [8]:
Based upon the applicability of past injectability studies, injection history at the PBU-
G&I Area, North Slope of Alaska, and the performance of the G&I wells since 2007,
EPA intends to waive the requirement to sample and characterize formation fluids and
the rock matrix in order to determine whether or not they are compatible with the
approved injectate stream.

(2)	Injection Zone Fracturing (40 CFR § 146.13 (a) Til:

The prohibition against injecting at pressures that would initiate new fractures or
propagate existing fractures within the injection zone is waived. Hydraulic fracturing of
the injection and arresting zones is allowed so long as fractures are not propagated within
the upper confining zone. Injection is limited to approved sections of the SV1 and CM2
marker intervals and external mechanical integrity demonstrations are required to verify
that all injected fluids are exiting in the injection interval and that there is no flow behind

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pipe due to channeling etc.

(3) Ambient Monitoring Above the Confining Zone (40 CFR § 146.13 (b)(1) and (4) and 40
CFR § 146.13(d)):

The requirement to monitor the strata overlying the confining zone for fluid movement is
waived since the aquifers at the G&I area are too naturally saline to qualify as USDWs
(meet "No USDW' criteria.

Summary of Proposed Action and Permit Conditions

EPA has primary enforcement authority in Alaska for Class I injection wells authorized under the UIC
program (Part C of the Safe Drinking Water Act). Class I wells are used to inject waste fluids for safe
disposal beneath any existing USDWs. EPA proposes to grant a Class I UIC permit to BPXA in
accordance with 40 CFR 144.33 for up to four (4) Class I non-hazardous waste injection wells at the
PBU-G&I Area, North Slope, Alaska. BPXA is authorized to sidetrack or substitute alternate new wells
in the event any of the above three Class I wells fail to function or demonstrate mechanical integrity.
However, BPXA shall submit all necessary well and construction/geologic data relating to any new
sidetrack or replacement Class I well(s) and give a 30-day written notice with proposed procedures prior
to conducting the mechanical integrity test (MIT) on sidetrack or replacement well(s). Again, no Class I
well shall inject fluids under this permit prior to successfully demonstrating its mechanical integrity and
obtaining an "Authorization to Inject" approval from EPA.

The draft permit contains general legal provisions common to EPA permits, specific technical
requirements that apply to all Class I injection wells, and particular technical, monitoring and reporting
requirements for the proposed injection operations at the PBU-G&I Area facility, North Slope, Alaska.
Underground injection of industrial oilfield waste is a disposal option that can replace the surface
discharges and above-ground transportation of waste. The conditions in draft permit AK-1I008-B intend
to allow injection by this method while protecting USDWs, human health, and the environment.

Public Comment

Persons wishing to comment or request a Public Hearing on this Class I Non-Hazardous Draft Permit may
do so during the public comment period. The public comment period will begin on June 30, 2017 at 9:00
AM, and end on July 31, 2017 at 5:00 PM. A request for a Public Hearing must state the nature of the
issues to be raised as well as the requester's name, address and telephone number. All comments and
requests for Public Hearings must be in physical or electronic writing and should be submitted to the EPA
as described in the Public Comments Section of the attached Public Notice. Please send your comments
and requests to the below address by the close of the public comment period.

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Tim Mayers, UIC Environmental Scientist

U.S. Environmental Protection Agency

Alaska Operations Office

222 W. 7th Avenue, #19, (Room 537)

Anchorage, AK 99513

mavers.timothv@epa.gov

After the Public Notice expires and all comments have been considered, the EPA's Regional Director for
the Office of Compliance and Enforcement will make a final decision regarding permit issuance. If no
substantive comments are received, the tentative conditions in the draft permit will become final, and the
permit will become effective upon issuance. If substantive comments are received, the EPA will address
the comments and issue the permit. The permit will become effective no less than 30 days after the
issuance date, unless an appeal is submitted to the Environmental Appeals Board within 30 days pursuant
to 40 CFR§ 124.19.

The EPA contact for further information is Tim Mayers at (907) 271-3410 or mavers.timothv@epa.gov

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