• Knowledge, Is Poorly Written and Organized. It Includes a Mix of Fact
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• UNITED STATES ENVIRONMENTAl. PROTSC'nON AGENCY WASHINGTON, D.C. 20460 OIIFICI OF IXTIRNAL AFFAIRS March 6, 1989 Patrick H. Quinn Director ~----~~~~-~.·~c.e of Concrasaional Liaison TO: Jim O'Toole Senar::a Energy Corr.llittae ' ---- ----------- Per your :equest, ac~achad is a copy of an tPA staff Draft P.eport on Manage::: em:. of Oil and Gas 'loiast.es on Alaska • s North Slope. Sylvia K. Lowrance, Director of EPA'.! Office of Solid Wasu, has inforoed me ~~at thi1 staff draft, which was relaa•ed without Agency knowledge, is poorly written and organized. It includes a mix of fact from EPA site visits with conjecture from non-!PA sources. 'tha report has had limited managemen~ revieY. !hat preliminary review re1ultad in aicnific:ant concerns about the quality of che report which dictates substantial additional work bc£ora this document will b• finished. As writ:en, ~lthough there appears to be some u.seful information in the re(lor't, it goes beyond what can be documented and is not an objective ~or~ray3l; nor does it in any way constitute an official Aiency finding or position. Should you have' any questions regarding che attached or related matters, please let mm know. DRAFT INTRODUCTION Purpose lOCi Sc:o ge Under Section 3001 Cb} (2) (A) of the 1980 Amendments co the Resource Conservation and Recovery Ac:t CRCRA). Congress temporarily exempted scvc:r:U types ot· solid wastes from M:JUlation :.i hazardous wasces. pendin1 further study by the EPA. A. mona the cate;onc:s oi wastes exempted were "drill:ing fluids. produc:e.d waters. and other wastes associated with the eJCploralion. deve1opme1u. or ptOCluction of crude oil or narural gas." S~tion 8002 cm> of the 1980 Amcndmems required. the A&cnc:y to study these wastes and submit a. report to Congress evaluating the status of their managcmenL In December o£ 1987. the Agency submiaed to ~nan:ss ics repon titled. "Management of Wastes from the Exploration, Development. and P!oduc:tian of Crude Oil, Satural Oa.s. :md Oeotherma.l EnerfY ··. · After the close of the public comment on the report to Conlf':SS, the Agency issued its regulatory determination in June of 1988 based on the report to ConsreA and subsequent public commems ('3 P'R 2-'446). The tei'JlatOry determination stated! "The Agency has c:ompfeced. these cviries and has decic!ed that reauiacion under RCRA Subtitle Cis not wammced. Rather, EPA will implement a du'ee·pronpd scrarcl)' co acldRss the diverse cnviroru:r~ental a.nd prosram.matic: issues posed by mese wuces by: ( 1) Improving Fed.en.l propms unclcr aist:iD& authcriries ira Subcide D of RatA. the Clean Wau:r Act. and Sale CrialdDI Wa• Aet; (2) wo.ric:tna with Scues 10 encaurap chanaes in their repla!:ion.s aari entorcement te in'qm)Ye some propams; and (3) woridns with Congress to develop any addirianal staN eery authorirics that may be required. .. This ciocumcnt representS parr of the EPA's onaoinl effort to characterize and ilna.lyza waste manaaement practices and Scate and federal reaulacory pro~fimS for wastes aencrated durin a the exploration. development and. prcduC1:ion ot crude oil and natuml ps. and to work with the Scaces and industry to improve exisana te(U1atary desisn. impiemenlllion. and enforcement. This document seeks to provide,_ description of current W::l.Stc management pr:~c:tc:es used on the Sorth Slope and present the major fac's and issues re!:uin& to these pn.c:t:ic:es. In preparing this document. EPA chose tO discuss a wid.c variety of f:~eUities (a tow or 3.S sites are desc:."ibed) ami present any available inform:u:ton on 1hese f:J.dllt:ies. ln de:sc:ibing a. IMde variety of facilities. this dccument auemprs to :denti!y major waste mana cement practices. and desaibe how current State reKulations are tmplementea 3lld enforccci as they apply to the current waste manocement practices on the :-,'orth Slope. It i.s EPA's intention that this document be usee! by the Stare in its ongoing effortS .:o im~rovc existing State regulatOry proan,ms by: 1) Providins the Swe with a description of the put perionnance its regulatory prop-am as it applies ta the management ,,f w::l.Stes gene:::ued. by the e:cplorwon. development and production of crude oil and ~:ltur:U gas: 2) Identifying existinJ deficiencies in C:Ut'I'eJU State rerulations and StatUtory J.uthority: and 3) Assessing the adequacy of current Sr.ate enforcement te$0ute= alloc~tion for enforcement of State reaulltions. • Funher. it is EPA's inwncion dw this d.oc:umant btl used by i.ndusu'y to: 1) Assess the environmentaL impac of cumm wasta manapma1 pncuces; l) Prawa a thirl:l pany miew oi indusU')''s enviltmmenta.l PfOIZ'IIU as implemented on the North Slope; a.rui 3) Promote the use o! resources to funher study topics such as innovative approaches co waste mana;crm:nr on the North Slope. was~~ mirUmizal:ion rechniqucs. n:cyclins oppommiaes. mel waste trea=ent techniques. so as 10 reduce induscry's reliance on clisposal options for wute mana1emenc. EPA will use this document tO rocus the Alency's eff'ons in doveiopina tailor= Standa:ds f'or d'1e mln&lement Of WUieS pnetated by lhe exploration, deveiopmenc. anci prcductiOil ofaude oil and nacura1 ps under RCRA Subtitle D. In addition, EPA will usc this cior:umcat 10 idenlify dlflciencics in other Pf01nft1S wid'&in EPA as thay apply tO the oil and 1as industry, and to identify deficiencies in ocher ~ prosrazm outSide of the Agency as they apply co oil a.nd 1a.s wasce manasemenc. EPA views Chis document as the first in a series o( similar documents that will be used to assemble and disseminate information on oil and. ps wucc manapment co Swes, indUS11'Y. and the public secmr. ,- n ,.., "' ,.T "..' . .. .' ...- Officials wim SPA's'flfficc or Solid Wasra.. Special Wuce Sra.nch. flrst toured. the ~orth Sl~ oil fielcb in the !all of 1987. On June 14 thr\Jugh 17. 1988, an EPA con~tor toured Sorch SlOJ)e oil production facilities. The con~tor was accompanied. by Sta.nctl:d .~Iaska and ARCO personnel on June 14 and. l.S. and was accompanied. by Alaska Department of Environmental Conservation CAOEO officials on June 16 and 17. In AuJUSt of 1988. a.n official with EPA's Qmcc of Solid Wasce. Special Waste Branch. toun:ci me North Slope oil fields with. bach induscy persoMel and ADEC pe%$0nne1. This document incorporates EPA's observations anci information obtainea over the past seve:o::tl years. Sites discussed in this repan are indi:ated on maps in fipes 1.2. and 3. The site descnpcions consist of observanons made at the individual sites; information from interViews with oil company offtcials. State of Alaska Oepanment of EnviroM1cnta.l Conservation <AOEC) officials. Alaska Oq1artment ofFish and Oamc orficiills. and oil field :tnd service company operaJDn: ragul.acory history of the sites where lpplic:sble or where infonnation i$ available; and recent regulatory developmentS at individual sires where applicable. Sites visiud were selected by industry officials a.nci AOEC personnel. and include drillsi&es. a_p.thcrinJ center, rccyciing cen~. oily waste injection facilities. a drum rinsing facility, a ~aae nacment facility, p-avel mine sites. the ARCO Crude Oil Topping Unit, the North Slope ~omugb's Oxbow landfill. a.n abandoned oily waste pit, abandoned resczve.pia. and servtc:i company sita in Oea.dhor.se. both active anci inactive. Photos were taken durin1 the site vishs and are referred to throughout the ~ext. The Resoun:e Conservadon and Recovery Act is the primary Feder:d statute govemina d'le transporw:ion. sunp, and disposal ol hazardous and solid wastes. Subtitle C of RatA applies co hazardous waste u defined under RaA Uli has stringent n:quiremencs for the transportation. scorap. and dirposl1 of ha:ardous wastes. EPA may gmt authority for implemetuation and ldminisndve responsibility tor Subd.de C to a State that develops its own propm to mana1e huan:iaus wu~a provided the prosram is equivalent to and no less sc:riJlpnc than the Fcdaal RCRA SublW.c C prop-am. Alaska is not yet a RCRA dclccated State: however. the Swe has pmmulpted hazardous waste .:• DR:4FT regulations and is presently enforcing them in cooperation with EPA. lf the State's h:u:arc1ous waste progr:un gains full authorization from EPA under RCRA. then enforcerr.ent of Subdtlc C will £&11 primarily on ADEC. Subtitle D o£ RCRA appUes to all non· hazardous solid wastes and provides broad.1eneta1 guidelines for the disposal of all non·huardous solid wa.srcs. Under Subtide Dt the Agency is not provided. with Feciemi enforcement authority. and Stara paniciparion i1t SubtitleD is lar1ely volunwy. As previously noted. EPA. in itS June 1988 teBUWory cfeterminaaon. provided for the exclusion of certain oil and ;as wastes from the Subtitle C pre gram. Acconiing to EPA's ref\1lar0r'i detemtination on wastes aenemed from the exploration. development, and production of ~ oil and namra.l ps: "Based on the la.nguaae of RCRA section 3001 (b) (2) (A) of the 1980 amendments tO RCRA. review of the stature. and supporting legislar:ive history; the Apncy believes thll the foUowi.n& wutes were tnctucted in the temporary eJ~temption set forth in the SlatUte: Prcduc:cd water. drilling fluid: drill cumngs: ripash: d:illln1 fluid.s and cua:inas tram offshore operations disposed of onshore: weU c.cmP,etion.