Underground Injection Control (UIC) Class I Permit Renewal for Pad-3 Prudhoe Bay Unit, North Slope, Alaska
Underground Injection Control (UIC) Program
Ground Water Protection Unit, OCE-127
NOTICE OF PROPOSED RE-ISSUANCE OF A CLASS I UIC PERMIT FOR THE DISPOSAL OF OIL-FIELD PRODUCED FLUIDS AND NON-HAZARDOUS INDUSTRIAL WASTE FLUIDS
AT THE PAD-3 OILY WASTE DISPOSAL FACILITY (PAD-3), NORTH SLOPE, ALASKA
Public Notice Issuance Date: July 29, 2009
Closure Date: August 28, 2009
1. Applicant
BP Exploration (Alaska) Inc. (BPXA)
900 East Benson Boulevard
Post Office Box 196612
Anchorage, Alaska 99519-6612
EPA Permit Number: AK-1I004-B
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).
The facility and associated wells were initially permitted with the EPA in August 1989 and re-permitted with the EPA in December 1999 under permit AK1I004-A. The current ten year EPA Class I Underground Injection Control (UIC) permit at Pad-3 to operate up to three (3) wells (current wells include OWDW-NW, OWDW-SW, and OWDW-SE) will expire on December 7, 2009. BPXA has requested EPA to re-issue its Class I UIC permit that includes the existing three Class I wells (or replacement wells if a well fails) that would continue to be utilized for the disposal of non-hazardous waste fluids produced at the Prudhoe Bay Unit, non-unit operations from other fields, and from off-site third party generators that support the oil industry on the North Slope, Alaska.
EPA is proposing to re-issue BPXA’s Class I UIC permit, which will allow for the continuing operation of up to three Class I non-hazardous waste injection wells at Pad-3. The existing wells are located onshore at the Pad-3 Oily Waste Disposal Facility, Prudhoe Bay Unit oilfield, North Slope, Alaska.
EPA has considered available waste disposal options and determined that underground injection is an appropriate disposal method for non-hazardous waste fluids and oilfield produced water. Class I injection wells are an environmentally sound method for disposal of exempt and non-exempt waste fluids, including but not limited to treated sewage effluent, and will eliminate or substantially reduce the 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. Re-issuance of BPXA’s Class I UIC Permit Number AK-1I004-B will allow EPA to maintain oversight and inspection of the wells. During the past nine years, EPA has inspected the facility on an annual basis during which 69 mechanical integrity tests (MIT) and 8 caliper surveys were performed on the wells. The most recent mechanical integrity tests performed on the three wells and witnessed by EPA were in October, 2008.
The geologic setting at the Pad-3 location is very compatible with the proposed deep disposal process. The Sagavanirktok Formation has been successfully used to dispose over 21.4 million barrels of waste fluids in the Pad-3 over the past approximately 30 years. The proposed EPA Class I permit limits injection to the existing and naturally saline injection intervals in the Sagavanirktok Formation at approximately 1978-2093 feet below land surface. EPA determined as part of the 1989 UIC permit issuance that there are no Underground Sources of Drinking Water (USDW) beneath the Pad-3 area 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. The wells have successfully demonstrated their mechanical integrity (both internal and external) on an annual basis, and the tests were witnessed by EPA representatives.
2. Tentative Determination
EPA has tentatively determined to re-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 Pad-3 facility may do so in writing by the expiration date of the public comment period: August 28, 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.
UIC Class I Permit Renewal for Pad-3 Prudhoe Bay Unit Fact Sheet (PDF) (6pp., 29KB)
UIC Class I Permit Renewal for Pad-3 Prudhoe Bay Unit Draft Permit (PDF) (22p., 79KB)