Proposed Issuance of a Class I UIC Permit for Duck Island Unit (DIU) - Endicott Satellite Drilling Island (SDI), Liberty Development Project (LDP), North Slope, Alaska
Underground Injection Control (UIC) Program
Ground Water Protection Unit, OCE-127
NOTICE OF PROPOSED ISSUANCE OF A CLASS I UIC PERMIT FOR THE DISPOSAL OF OIL-FIELD PRODUCED FLUIDS AND NON-HAZARDOUS INDUSTRIAL WASTE FLUIDS AT THE DUCK ISLAND UNIT (DIU) - ENDICOTT SATELLITE DRILLING ISLAND (SDI), LIBERTY DEVELOPMENT PROJECT (LDP), NORTH SLOPE, ALASKA
Public Notice Issuance Date: June 10, 2009
Closure Date: July 9, 2009
1. Applicant
BP Exploration (Alaska) Inc. (BPXA)
900 East Benson Boulevard
Post Office Box 196612
Anchorage, Alaska 99519-6612
EPA Permit Number: AK-1I013-A
The U.S. Environmental Protection Agency (EPA) has direct implementation responsibility in Alaska for the regulation of Class I injection wells through the UIC program, which is authorized by Part C of the Safe Drinking Water Act. Class I injection wells are used for the deep disposal of industrial waste into naturally saline ground water, beneath any aquifers which could serve as current or future underground sources of drinking water (USDWs).
BPXA has requested EPA to issue a Class I UIC permit that will be utilized for the disposal of non-hazardous waste fluids including but not limited to fluids produced at the LDP facilities, located within the DIU, North Slope, Alaska. The Liberty oil field, located in the Liberty Unit, will be developed from the SDI to reach the oil reservoir about eight miles away on federal leases in 20 feet of water. The Liberty oil field lies southeast of the Endicott field located in DIU.
EPA is proposing to issue a Class I UIC permit to BPXA which will allow for the drilling and construction of up to two cuttings reinjection (CRI) wells on the existing SDI for disposal of fluids that may include non-hazardous waste fluids, drilling muds and cuttings, effluent from a desalinization facility, stormwater, produced water, well workover fluids and camp wastewaters. The CRI well(s) will be completed within the Ugnu Formation southwest of the SDI. The proposed first CRI well will be drilled to a final subsea depth of approximately 7,600 feet true vertical depth subsea (TVDss).
EPA has considered available waste disposal options and determined that underground injection is the most appropriate disposal method for non-hazardous waste fluids and oilfield produced water. Class I injection wells are the most environmentally sound method for disposal of exempt and non-exempt waste fluids, including but not limited to treated effluent, and will meet the objective of minimum storage and zero discharge of oilfield production and domestic wastes to the surface waters of the North Slope. Class I wells increase safety and reduce environmental risks by reducing handling and transportation activities and provide safe subsurface disposal in a controlled manner. Issuance of BPXA’s Class I UIC Permit Number AK-1013-A will allow EPA to maintain oversight and inspection of the wells.
The geologic setting at the DIU-SDI location is very compatible with the proposed deep disposal process. The Ugnu and Sagavanirktok Formations have been successfully used to dispose over 1.8 billion barrels of produced water in the Prudhoe Bay Unit (PBU) and over 110 million barrels of slurry and associated water at the near-by PBU Grind and Inject facility. The proposed EPA Class I permit limits injection to the existing and naturally saline injection intervals in the Ugnu and West Sak Formations at approximately 5800 – 7850 feet TVDss. EPA had earlier granted a “No USDW” ruling dated November 4, 2008 for aquifers between approximately 1500 feet TVDss (base of the permafrost) and 8,000 feet TVDss for the SDI-DIU, since the salinities exceeded the 10,000 milligrams per liter threshold required for USDWs as defined under 40 CFR 144.3 and 40 CFR 146.3.
2. Tentative Determination
EPA has tentatively determined to issue a ten year UIC permit to the above listed applicant.
3. Public Comments and Hearings
Persons wishing to comment or request a public hearing on the draft UIC permit for the DIU-SDI LDP facility may do so in writing by the closure date of the public comment period: July 9, 2009 at 5 pm Pacific Standard Time (PST). All comments should include the name, address, and telephone number of the person commenting, a concise statement of the exact basis of any comment, and the relevant facts upon which it is based. Any request for a public hearing must be in writing, contain the requester’s name, address and telephone number, and must state the nature of the issues proposed to be raised in the hearing. A public hearing will be scheduled if EPA determines, on the basis of the hearing request(s) it receives, that there is a significant degree of public interest in the proposed permit. All written comments and hearing requests should be submitted to Thor Cutler of the UIC program at the above address or via e-mail to cutler.thor@epa.gov .
4. Administrative Record
Copies of the proposed UIC permit, fact sheet, and permit application are on file and may be viewed at EPA’s Regional Office Library between 8:30 a.m. and 4:00 p.m. PST, Monday through Friday. Copies of the proposed permit and fact sheet may be requested from Thor Cutler at (206) 553-1673 or via e-mail: cutler.thor@epa.gov . Copies may also be obtained from the EPA Alaska Operations Office, Room 537, Federal Building, 222 West 7th Avenue, #19, Anchorage, Alaska (907) 271-5083 or through the Internet at www.epa.gov/r10earth/uic.htm.
BPXA Duck Island-Endicott Draft UIC Permit Fact Sheet (PDF) (8pp., 36KB)
BPXA Duck Island-Endicott Draft UIC Permit (PDF) (22pp., 66KB)