•

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

~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. nar:menc. and stimulation fluids: basic sediment and water :and other tank boaoms from s_roraae !aciiities chat hold ptoduc:t and exempt waste: :ccumulatcd materials such as hydrocarbons. !Qlids., sand. and emulsion from production separators. t1uid autins vessels. and production impouncim.en~:~; pit slu.ciaes and contaminated bottoms from storaae or disposal of exempt wastes; workovcr wastes: sas plant ciehydr.uion wasms. includin& &lycol·based compounds. glycol ftlt~n. filter mediL backwash. anct molecular seives; gas plant sweetening wastes for sulfur removal. includinl lmines. a.tnine filters. amine rurer media. bac:.kwub.· precipiaued amine sludae. iron sponae. and hydtoaen sulfide scrubber liquid and sludse; coolin1 rower blowdown: spent filters. rutet media. and backwash (assumina tho fUtet iaclf is nee haza:dous and the residue in it is !rom an exempt wutc saam); packicg fluids; produced. sand: pipe scale. hydrocarbon sclid.s, hydzsa=s.. and ocher dcposics removed from pipinl and Cti}uipmcnE prior tO tra.nspoftllica: bydroc3rbcn·beari.nl soil; pislfnl wastes from pUteftnl lines; WUU!S from subsulfaf::e ps sunp and rea"ieva.L excepc for the nonexempt wastes listed below (see ncxc paaraph]; consticuems remavect from pn:r.tuad warcr before it i.s injected or otherwise disposed ot. Uquid hJdrocart:lons removed f'rom the prcduction mam but not from oil refinina: gases from the production swam such as hyc:froscn sulftde and carbon dioxide. and volatilized hyc:.trccubons; materials ejected fmm a pnxhlcinl well dwing the process known as blowdown: waste crude from primary fte14 open.tions and prcduction:

... .. DRAFT

:wi light organics volatilized ·from e~empc wastes in reserve pia or impoundmentS or prcduc:tion equipment''

The regulatory determination further swes: ''The Agency believes thac the roUowing wastes were not included in the ori&inal [RCRA Section 3001 (b) (2) (A)) e."emption: unu$ed fnu:Nring fluids or acids: ps plant coolin a tower cieamns wastes; pa.intinl wastes: oU and au service company wa.su:s, such as empty dnuns. drum rinsate. vacuum auc:i: rinsate. sandblast media. painting wastes, spent solvena, spilled. chemicals. :uui waste acid: vacuum cruck and drum rinsate from aucks and drums a-ansponi.na or .:onWnina non-exempt waste; refinery wuUtS: Uqui4 and sollcl wuces aencrated by crude oil anc:l tank bonom recla.imen; used equipment lubrtcacion oils; was1e compressor oil. filters. and blowdcwn; used. hydraulic fluids: waste solvenm; wasce in r:ansponalion ;:npeline·related pia: c:1ustic or acid cleaners: toiler clea.nina wasta: boiler refrlc:ory bnck.s: boiler SCTUbbcr fluid.s. sludaes, and ash: incinftllar ulr.laboncory wastes; sanitary wasta: pesticide was~es: radioactive cracer wuces: and drums, insuladon. and misc:c:Uaneous solids."

Crude oil and natunJ sas explorauon. ckve!Dpmenc. and prcduetion waste :na.nagement is regulated by several aaencies on the North Slope. The Alaska Dcparcmcnt of Environmental Canse:vation (ADEC) ls the primary pollution c:cnaol agency within the Suue. ADECs responsibilities include issuins permitS for all solid wasu: disposal :1etiviaes: permimna wasmwucr discharges, a.nci air conwninant emissions: inspa:ling fteJd opcralions; permittinl and inspecdnf commercial waste ma.napmenc faci.lh:ies and surface insrallaaons ar Class II injection facilities (the Alaska Oil and Gas Conscvation Commission has primacy under the Feder.al UnderJI"'UNi Injection Concrol (U!C) program ror regulation of Class II injec:ion welLs as discussed below); repladns hazardous was~e. w overscena oil spill concrol effonr. tlkinl entorcemc:nc aeuons where necessary: a.nd workinc widl iDdusa"'/ to impaove cu:rnmc was111 management med'lods. As Alaska does not ' have pri.rmiGy for the Nalional PoUucion DischarJe EliminaD.on Sysrem (NPDES) program. A.OEC coordilwes with EPA lepon X, which administerS the NPOES propvn in Alaska.

Currendy. ADEC can i.Jsue Nocices of Violalion for oil tldd activir:ia chu are ouc of compUance with Swe n:JUla&ions. and it can write compliance arden to specify actions tha~ will brin1 the noncomplyin1 operator into compliance. Hawwer, .ADEC does not have the: auchority ra issue f111es or shut dawn praducdcn for noncomJttilaa wilh Staa: D;:~/~~F:T I ' envUonml&ual rqui.arions.t If ADEC belleves thai a particular incident or nonc:omplla.nc:e warr.mts additional effort on the pan or the State beyond issuinaa c:ompl.ianc:c order. ADEC c:m request that che State Attorney Ge:tcn.l punue che maner in eowt. Under this un..ngeme:u. cbe court can levy a. fine apinsc the noncomplyina operator. To date, only once in the case of Sonh Slope Salvase. tnc. (described in the text under the section discussi.nc service companies) has the Swe Aaomey Oeneral obtained a fine or penalty in coun against an operator conducting business on the North Slope.

Under the Safe Orin.ld.nl Warr:r Act. t."le Utllderp'Ound Injection Control prosnm provides for five different classes of injecrioft wells. where the clus desisnation is dcpenclant upon the use of the well (this repClft discusses the first two classes, as Class tU. IV. :lnd V are not relevant to this n:port). ~la.u I injection wells an: usually designed and ;:ermined for the disposal of RCRA hazatdo\:S wure, although a Ow I well c:an be permitted. for receivina nonhazardous induscrial waste. Class a injection wells are those ~sed by the oil and gas industry to reinject pmduc:ed water for enhanced recovery and for the clisposa.l of indusrtial wastes exempE from replac:ion under RCRA Subtitle C by RCRA section 3001

t.Jnder Section 404 of the Oa.a Wau:: Act; the U.S. ArttJy Corps of :Engineers is n:sponsible for isaums permitS for dredp and. fU1 *=tiviries on wetlands defined u pan or the wacc:s of the Uniccci Sraca. EPA bu review responsibility f'or sueh pamiu. On the North Slope. the Army Corps of Ensineen' primary responsibility is issuins permits for constz'UCUG~l of sravel pads fCI' industrial fadlides. atK1 eonsrruc:Uon of snvel road.l. causeways. a.aG islands. (The North Slope o:l fielt!s ar= located in desisnaa:C wetlands). On the North Slope. all pads. roads. and facilides must have Sccrion 404 permits. The

1 Many apncics t.ftat rep&ar.= ctMt oil and .. produCiial iadumy in odlar Swa have sudl uhoriry. DRAFT t:.S. Fish and Wildlife Service bas cotnmenc responsibility for permits issuect under Section 404.

The U.S. Bw-e3u of L.lnct ~anaaemenc is responsible for all oil and gas activity on (c:der:U :1nct Indian l:Lnd.s. The authority includes lewna. bondinc, royalty ananaemencs. construction and well sp:leinl rarulations, wasce handling and disposal site r=iama.aon, J.nd site maintenance. Ha.lf of Alaska's 370 million *=res are under fedeta.l. ownership, and t.~erc :sre currently approximalely 1$0 producing oil and au wells on fcc!eralleases; however, all current activities in the North Slope oil prcduc:tion area occur on State lands.

The AJ:Wca Ocpanmcnt of Namr:r.l Resources issues surface and subsurface oil ami g:J.S le:ues on Scace land. The Oepanmenc also approves plans for operation of all oil and )j:l! f:tcllities on State lands. and conducts field inspections of oper:u:ions and lb::mcionmencs.

The Alaska Department of Fish and Oame has jurisdiction over the use of surface w:um on the North Slope in conjunction with wildlife and aquatic habitat manaaemeric: however. this jurisdiction docs not include issuance and enforcement of NPOES pennies ras discussed above. ADEC assiscs EPA Rertoh X in issua.nce and enforcement of NPOES pe:milS on the North Slope).

Ugujd Wute prpductfqn qd Qlspmal iJLOII and Ga:s ErgdgUJqn tiJ£iUUa

In March of 1988. A.OEC complcu:cl a rcporc enude.d.' .. A Revin ol Liquid Wuw. Pnxiuction and Disposal at OilfteJd Ft.ei11ues on me Notth Slope ot A1aslca." The re;10r1 discusses cypcs of liquid was= pnerued an4 r.be various achods of disposal utilized. Accorcl.ina to me repon (ADEC 1988v): "AcrivUics usccWcd wida peuoleum exploration. and oilfte!d daYelopment and opencion ~...... _. quaadlils ofw..,. The chanc=r of cbese wasta. bcxh liquid. and solid. vary a area« deal. Wurcs are produced on aud offshore and an: d.is'posed by subsurface injec:Uoa and dilcharp to rhc land. a.nc:1 wacen of the st:ue and marine waren." The repon cU.scusseS the wurc manapmenc practices for sevcr:U high volume liquid wasteS includina prcduced water, reserve pic fluids. hyd.rasr.acic testi.nl fluids. domestic wutcwacer. and. excavadon dewacerina. DR1~FT Subsurface Injection of Wutes

As discussed in the ADEC repon. subsurf2ee disposal of wasta has occurred ht both shallow or nonhydrocarbon beannagcolopc icnes, and deep hydrocarbon bearing geologic zone.s. Wasta injection into nonhydn:lcarbon bearinl %ones has occurred through ll'l.nula.r disposal Cdisposal through the annulus or 5i'ace between che casing a.nci tubing in a well) anci thrcu&h dedicated. waste injection wells such a.s those at lhc Prudhoe Bay t:nit Pad 3 discussed in dcwllater :n this text.

Produced ware: represents the largest volume of liquid wute generated on the ~orth Slope. For example. in the monrh of December. 1987, more than 924 million &3.1.lons of water were prociuceti in North Slope production operar:ions. According tO the ADEC report. produced water coming t'rcm the oil prcd.uction zones on the North Slope .:ont:lins approXlm:ueiy 20.000 m~ toca.l dissolveci solids (TDS). approximaceiy 20 m8fl suspended solids. a.nd 20·2-'0 mi/1 hydrocarbons. Produced wace: also contains varying ~ountS of volatile organic compounds. such u benzene. toluene. a.nd xylene. that are included on rhe lut of texic priority pcUuwus c:onmined in Section 307 (a) (1) of the Clean Watr:r Act of 1977 (EPA 1987). CI.Ufencly, on. the North Slope most produced wacer gcncr:ne.d is n:injcca:d in a warerflood prosram for en1ww:eci n:covery. Ac the enc1 of 1987. there wen: 355 en.h.ancc:d recovery wells l'liDJe=inl'praciuced wucr back inco tbe hyd.rocarbon bearing formations.. Before the wuertlocci program came on line in 1981. most produced water was disposed tJ\rough dedica~ shallow zone injection wells such as those .: • P1cl3.

[n addition rc the injecdon wells lo:au:d at Pad 3, shallow zone dedicated. wasta injection wells locatai at dlc 1arp &a&he:rinl a:ncers:or oil/W&~~r/ps seplftlion facilities are used for disposal of mixed wures a well u some prcduc:ed w... Accordin1 to the ADEC reporc. mesa wastes 1te similtt in c:onta~t to:those injected at Pad. 3. As mentioned cariier. - Uquid WUf8 is disposed mrouah annular injte'&ioa. As sr.aect in me ADEC repon: "hljec:d.on of liquid. WUIII into shallow nonhyciro;arboa polopc zanas Utroulh well annuiiu a c:ommon prw::ce i.n che North Slope oilftclds. Our first year ol record for chis activiry on the North Slope is 1983 .... Typica1 onshore disposal depUt is between 2.000 and 4,000 feet. Onshore disposal clepth has occutred as shallow u 1.000 reea.•• In \986. a. total of 116 thousanc1 pllons of liquid wuu: wen disposed cbrou1h tbe amwli of 171 I

, D o·~• • • \ '=TJ . wells. In 1987. i 4.4 thousancigallons of waste were disposccl th:oulh the :s.nnuli of 89 wells.

Surface Disposal or Wastes

Several methocis of surface disposal of wasces have been used on chc North Slope including disch.a.rze of reserve pic fluid to the tundra. surfa.ce oilins, disposal of reserve pit f'luid.s to roads. discharge of hydrostatic testina fluids to the tundn, clischargc of treated domestic wasce water. and cxca'laaan dewarerins. As discussed below. some of rhese p~cticcs have been discontinued. whUc othen .are currend.y being used !or liquid. waste jisposa.t.

Qischarp of Reserve Pit Fluids to the Tynckil

Oil production fa.cilitics on the Nofth Slope arc centered around large. generally unlined pits constrUcted of gravel. refem.ci co as ··resc..-..e pitS". In the course of development of the North Slope oilfteicis. hundtecis of reserve pir.s have been COftSC'\lCted in J.ssoci:ttion with both exploratory and prcduclion oil well dtillln1 (AOEC 1988v). The reserve pits are consaw:teci within the unconsoUdaced gravel pads gsed to support production equipment on the Ata'ic: t'W'ldn. ancf. prad.Ucaon wells are drtlleci around the perimeter of these reserve phs. Accon1ins U) the ADEC report on 1iqW&:l waste pnenrion J.nd disposal. in the course of devel~ment and o~ticm of producUon wells wasteS are deposited in the reserve pir.s i.nclud.inl drilllns muds. cuttinp, prociuceci water, auck linsaces. crude oil. ril wastewater as well u ccntamitlated snow and spW materials. As sr.:ued in the ADEC :epon (ADEC 1988v): ''fluid anasemcnt problems occur because the ?its collect water from natural sources primarily rain!all and snowmelt which mcs with reserve pit fluids. Problems UIOCiated with this addition o! water include: 1) increased reserve pic lcakqe d.uc co i.nereued hydraulic head. 2) fluid ovcnoppinl n:~scrvc pic dikes. 3) bre:~Cbial of reserve pit dikes. and 4) it1cn:ased volumes of ccncaminared. water for disposal.·

AccordinJ'CO 'A.DEC. wacil the 1988 summer scuon ditctsup r.o me tundra under ' permir with ADEC was the mea common methad d. disposal of reserve pit fluids. As the ADEC n:pon stateS: ''The most recenc raet'te pic dewuennaaenenl permit ra:tuires a notice of dis-posal. eamplete with characterizal:ion of pic fluids. and emblishes effluent Dn.Of·.!:T .. .• a: Umicuions. monimring and reponing requirements. E!fluenc limitations include: COO of 200 mg~1: saliniey of 3 ppt: setde3.ble solids of 0.2 m.l/1, oil and grease of 1~ mg,r1. total. :u'Omatic hyd.roc;arbons of 10 m1fl. ana pH berween· 6.5 anci 8.5. Aaaitional effluent li.m.it:~.tions exist for specific elcmencs." In 1983, ARCO. Conoco. and Standard. dewaten:a reserve pits through discharge co the tundra; in 1984. ARCO and Standan:i dew at~ reserve pies thtou&h discharge to the tundra;. in 198.5, ARCO. Exxon, and Scandarc1 dewarmd reserve pies through discharae 10 the tund:l; in 1986, ARCO. Conoco. Standard :utd Exxon dewarered reserve pies throuih d.is4:harse tO the n.mdta: and in 1987 ARCO dewa.tered. reserve pitS through dischat&e to the tundra. Durin& the 1986 season. a record volume of 64 ..568 ..S20 gallons of n:serve pit fluids were ciisc:harp:i to the tundra.

ADEC has compiled a list of approximately~ reserve pitS refem:ci to as the ''Problem ?:t L.ist" (ADEC. 1917e). ADEC has documented splllage.leakina. bn:aching or ovcnopp1ng at these "problem pits'', Currently. Sorth Slope operators have ceaseci all dewaterini of the reserve pits ontO the tunc:im ancl efforts have bepn co line leaking reserve ~its. repair bre2ched berms around reserve pit3. and close out several of the "problem pits". ADEC has not issued a permit for dcwaterinl of reserve pits throu1h discharge to the tundra since the 1987 summer season. Althcush the currenc recuJarions allow such discharges. as a matter of policy AOEC dces noc andcipace issuinl any further permitS for these aisc:harges.

Because the use of pe:manenc reserve pitS is currently an iratearal pan of Nonh Slope oil and cas production operations, the foUowtna discussion is included. It should be noted tha.c wtille many unlined reserve pitS are currently in use on the Nonh Slope. new State regulations require that conscruclion of new n:serve phs include a full liner. rn addition. the indusr:y is experim.ennna wi&h the possibility ot ellminazin& pcrm111ent reserve pits a.t prod.uc:icn facilities on rhe Nonh Slope in areas rhac an= noc yet developed.

Ill me fall of 1981, t*SOilDil wich tbe U.S. Fisil and W'Udlife Service (USFWS). w Baa&Ue Ptr:iftc: Nonbwesa l..abontcries pub~ an anicle dcscribina a study they ccnclucted a& ftve clrill siteS mearurina rhe impaa of reserve pu seepap and discharae tO the sunoundina tundra (Woodwant. Snyder·Conn. Rilay,and. Oarlud. 1988). Accordina to the authors: "The objectives of this m.u:ly were co select five drill!Zia sites in che Prudhoe Bay area. de=mine the inarpcic: and oraanic c:hemiszry of water in rhe reserve pirs and sWTOundinl ponds, a.nci c:orrelar.e these ftndinss with acute and chronic toxicity evaluations

\J of water from these pitS and ponds." As state:! by the aulhon : "tn 1984. A.OEC pennictcd the discharp of reserve pit fluids inco tundra wet!a.nds rrom 23 pia in &he Prw:ihce Bay :u-ea. ;u,ci in 198' the t1uids tram about 40 rescve pits were dischar&eci inro the tundra in the Prudhoe Say-Kuparik area. both from onshore ana offshore sources.''

The l!SFWS·Banelle amcle explains: "Durin& exploration anc1 prcctuction. reset"Ve pits are used for szorace of excess c!rillina fluids. cuttings. boiler blowdown, and rig· wa.shinl fluids. More than 600 additives are potentially available fer usc in d.rilllng t1uids (API 1969: Dames and Moore 1978: National Reseirch Councill983). ~any additives are known to be toxic. such as aromatic hydroc:arbons,! bactericides. brines. Ugnosulfonates. emulsifiers. and metals (ElU. 1984). Despite rhe complex composir:ion of n:serve pit wastes and their jXItential toxicicy ta aquatic oraanisms arul migra~~XY birds. discharges !Tom &he pits occur more frequently on the Nonh SlOpe of Alaska than u sires i.n the ..:ontetminous 43 states. P<:rmafrost a.nci low evaporation rat=s inhibit nanuallosses of reserve pit fluids. and repetitive use of the same reserve pit for multiple wells and fresh 5nowmelt each year continue to add volumes tO the· pia."l

The article further explains: ''IA addil:ian• to oU prociuction.. the wetlands on the Nonh Slope serve as important summer nestin1 and. rearinl pounds for numerous species of shorebirds, wacetfowl. seabirds, rapcon. and puserines (Nonon '' al. 197.5). Some of these species have no other known bradinl JI'C)Und or are threale:necl with ext:incuon. Wetiilnci ponds are rich in zooplankton, important in waterfowl fooct chains. The spring thaw in the wetlands and the production of invcne~a:es is closely tied to the cimc of waterfowl nesnna. a.nci coincides with peak dischaqes of drillins fluid wasta &om reserve pits. Wetland jXInds arc COMa:tecl by netwerfa of nann! croup that eventually re3Ch fish producina stn:ams. tn 1983, the dewau::in1 of reserve pits resulted in a sir;nifica.nt impain:nent of wam:r ctuallry in ponds adjacent ro n:MS"Ve pies (Wcsc and Snyder-CoM 1987). WMa c:cxapm=i co ponds further ttom drtlli sites. adjacent ponds wens lower in mbundance IDd c:lvcnity of aquatic lnvenebrar.o. •

Accordiftl to the an:iclo: "Ions c1e.vale41n WIW" were Ba (barium), 0 [chlorides 1. Cr [chromium]. K [potaSSium}, so. (suU'acesJ, and Zn (tine). Conccncnuions ofCu

2 Reterencea in me tJSFWS U'Licle are included in tr.c re!e:DIIftiCe lisr. !or dUI da:\JmenL

: t DRAFT (copper!, Ct (chromium!, Fe [lronj, Pb (lead.], and Si [sUical in sedimentS wen: higher in ne:1r and cliswu ponds than in eonaocl ponds. The predominant oraanics in drill site w.aters :1nd se.climena consisted of wmatic and pantnnic: bydrccarbcns cha:a.cteristic or' pe::oleum or a refined product of petraleum. •• .Ions elevated in R.P [reserve pit] water were J.lso siinifiQndy increased in NP (near pond} and DP [distant pond.] water. only those signi:1cantly incre:ssed. a.bove CP [eontrOl pond} walers are repomd here. Conc:enlr.ltions I of Cl. K. and SO" were significantly e!evaced in eisfu of the nine NPs or CPs sampLed. and Ba and Na were sianificantly elevated at seven. The maiJUNde of' increase was gre:m:st ror S0.1.: in NP and DP water, it was elevated by 80- to 470-fold above the mean of the CP stacons. Tr:a.ce elements Cr and Zn at NP4 and 7 were increa.secl 3· to 6·fold above botckiJ'Ound concentrations. ·•

The reserve pit sediments sampled i.ndic:aled.:much hiaher concen~r.Ltions of :norganic ions than c1icl the reserve pit wacer sampled. Aluminum was found in reserve pit sediments in concentrations a.s high as 21.000 mlf1ca: barium as hian as 7,380 mg/ka: chromium a.s hich as i92 mwka: .copper u hip u 1.780 ml/ka: lead as hi&h as l.300 mg/ka; 3l'lci zinc as high as 2.290 mlfka. • Aromatic hydrocarbons clea:cted in wau:: ami secUmenu tmm the reserve pits. near ponds. and diswu ponds included al.kylaced bcnmnl. naphthalene, tluortne and phenanthrene. Paraffinic hydrocarbons were also d"tected in rucve pits. near ponds and distant ponds. ~ea.n concencrations of' wmad.c hydrccarbons in wacer umples ranged tTom 0.07 u&fl in a con1r01 ponci to 9.6 u~ in a disuc -pond; and che ranae for sediment I samples taken was 2• .5 mflkl in a ~serve pit to 133 m~1 in a near pond to l63 mr/ka in :1. reserve pit. For pantflnic hyclrccarbons de*Ud in scdimascs the mean c:oncenrralion level ran gee from 7 ml/'ka in a diswu pond to 700 milk& in a n• pond.

Near pond and dlstaDt pond scdimencs indicaa:d hiahc conc:ennlions of i.norpnic ions thaa. 61 car pond aad distant pend wa&c:r sampled. AcGonBaa to the anide: "For the seven NP and DP swiont where triplicate (Mdimc:nrl samples were a&Wyzed. Cu. Cr. Fe. Pb. and Si were che mast trequcndy elevar.ed. u.:r.. over blckptJund were peatest at NP6. where c:oncenrrarions of Pb and Cr were i~ by 22· and 14-fold l'CSl*tively.'' For ne:r pond sediments, barium conceniDC'ions rupd. from l·J60 mflka co 9J93 mr/kr. chromium concena"'tions ranpd fltom 107 mflkl to 559 mlfkl; copper ccnCC1ltn.tions r:utled from 24 ml/kl to 46 ma/k~ and lead concencralions nmpd tram 30 ml/ka to 133

'... " mgfkg. F« distant pond. sed.iinenu. barium c:oncencrations ranged from 292 mgllca to !7.737 mlfka; chromium concenm.tions rangt!d from ~0 mglkg tO 189 m&'ka; coppc: conc:encration.s ranged from 18 mWkg to 39 mli/ka; and. lead conc:ennr:ions raztieti t'rcm 9.3 m~g co 44 mg/kg.

I The t.:SFWS-Batrelle authors 10 on to state: "In 96-ht ex-posures in the field. toxicity to Daph!Ua Middtndol'jftWJ was observed in water from all merve pia. and from two of f\ve ncar ponds. but not from diswu ponct.s. In labcntory tasu wim Daphnia ' nt.agnQ. a:rt»Wth and. rtprcciUCUOn Wert reduced iA dilucionS Of l.,,. drillin1 fluid (2.5 drillina fluid: 97 ..5 dilution witb warer) from one reserve pic. and 15 ~ drilling fluid. from a ' sec:ond.. Growth and. ~production were not af!ec:ted at these diludons of fluid. from the other three reserve pits.''

On February 16. 1988. the SUW'3l ResOW'Ces Defense Council (NROC) notified. St:tnda:d Alaska Production Company and ARCO Alaska. Inc. of their intent to file suit for ' violations of the Federa.l Water Pollution Conr:oi Act. 33 U.S.C. It 12.51·1376 (the "Clean Water Act"). Accord.ing t0 the letters from NR.0C r.o SWKiarri and AR.CO: .. ARCO (and Scand.arcil has disposed. of material from itS n:;crve piu in various ways. AR.CO (and. Standard 1:Ulows some of the reserve pit wasta to leak. seep. or ocherwisc esgpe from the reserve pits. Such leaks violate the ''Section 404 pennia'' frcm U. Army Corps of En&inem pursuant to which ARCO was allowe.ct torconsr:uct me n=scrve pits. Suc:h leaks also violate the Clea.n Water Act beCause r.hey are discharaes of pciluta.ntS for wh.ich ARCO lac:ks a requi:cd National Polluwu Dlscharp Ellm:iiW:icn Sysze:m (NPDES) pem'l.it.

''ARCO (and Sr:wt.ard} abo "dewatetS" the ~e pits by discharJingliquid. from the pits di.n:a!y ontO the tund:1. wedancis. Such dischlqes violate dle Oean Wa= Act I because mey are discharps oi poUuwns £or which A.RCO tw Standanil ~ a requited !'JPDES permit. In addition. AICO (and Stlftdan!} •pplies some of me liquid from the reserve pill fla:a mobile ~rUCks ontO roads in tundra wetlands and d1ereby into such wetlands. Such discharps violare the Clean Waa:r ~et becauSI at.y are diseharges of pollutarllS for wftic:h AR.CO (and Stand.ud]lacks a required NPOES peat."

...., DR/\FT To date. NRDC has pioceeded to fUe suit: against ARCO. Alaska: :-nmc has not tiled. suit again~ Stancin Alaska Production Company.l

Dis)J'JJ.l gf Re!erye Pit Suid! tg Rgw

As statcei by the ADEC report on liquid w&StO pneration a.ntJ disposal on the North Slope (AOEC l988v): ''Road waterina. a meteod. of. dust suppression. is a widespre:d praaice at Nonh SloJ'C oil prccluction facillcies. Wuer !rem local rivers. lakes or flooded mLne siw is used !or road wuerina. Reserve pic tlu.i.d.s are also disposed onto reads in the same manner. Reserve pit fluids may contain hydrcCa:bons. mccall. and other texic substances. The !ate of water bome poUuwus in the·roadbed is nee known at this time. Some possible fates of poUutan~ include aaenualion or chemical aaenuar.ion in the roaclbed.. washing or leaching from the roacibed to the SWTOUndina environment. or escape in road dust to the environment. A permit allowina on-road di~ of re!Crie pit fluids was developed and first issued. in 198-'. The two permits issued in 198' were issued.. late in the road. watering season and. only 1.13.5.890 aa.llons of pic fluids wero discharged. Two similar permits were issued. in 1986 and 1987 which·allowed 36.924,.594 and. 26 •.540,346 gilllcns. respectively, of reserve pit fluids to be Qisposed to roads. An adclitional permit was issued in 1986 allowin 1 on·road disposal or secondary treaCed domestic: wastewater :llld under this pennir. 638.400 pllons of waa:r from one sewap l&IOCft were disposed to the reads." Curinl the 1988 summer season. North Slol'C operacan did not dispose of :-eserve pit fluids throuah road. wateri.na.

On October 4, 1988, ARCO applied to EPA Relion X ror a. ftc!dwide NPDES I permit for the Kuparuk field.. In adclirion to other cl1scharles. che application requests t.ha.t ARCO be allowed co resume disposal of reserve pi£ fluids throup n:Midwaccrinl. As stated. I in the cover lcac: (A.RCO l988i): .. Of me:so sourc:a. mas arw: C\&ft'lndy penuiua:l by the State of A.1uka Oepanment of !Aviroamemal Canservacion. Please ncxe thu. with respect to the lase .,.,_lial sourc& ill me lt)1)Ucalion (Sou= 00.5, dlsdlarp of reserve pte waters to roads). we .. uld.na for 111 EPA ~of w~emct or noc such activity is subject to NPDES permimnaaucbaity. We hDe encloled a SQidy widl the application which we

l NR.OC praceedld waUl ill sui' apinlc A.RCO benua duriaa \hi 1987 swruner !IUQn WI com~y conu.nued 10 1111 dilcftalp to die IUftdra ua means ot dewlrlrilil re.sene piU. Slllldard aid nee CliJcharp rcsc:rve pit wac u:t Ulll wnc1r1 in 1917. ·

I I . I DRAFT believe deraonsaat=s that NPOES authority dces not extend U) suds acri"'ity. As you know, ARCO has halteti use of reserve pit fluids for road watering anct will nee resume such lenvity una! all state lLnd !ede:3l permitting issues are resolved."

,. .~ccordini to the ACEC report on liqu:ct waste generation and disposal: "Hydrostatic testing of pipelines anct vessels is a common pnaice during oilfield development. Several types of fluids an used. including freshwater. salcwaccr. methane!, ilyc:ols. and cliesel. It wacer is the test fluid. disc:ha.rse to the n.uu.t.ra is allowed. via an AOEC aenc:nl penniL The permit ma.y be used fer discharges ofless than l •.SOO.OOO gallons of wacer. Written notification to the depazanent prior tO discbarae is required for discharges of greater th:&n so.ooo aallons: however. d1e pe:mic effluent limiwions apply to all d.ischaties of hydrcsca.&:ic test fluids. Post-discharge l'I:J'Oninl is requireci only for noti.fiC31lon of permit non-compliance. Test vessel fillure anct dischJ11e of test fluids n pocentiai sourca of pollutants. The greacest amount of hydl'Csratic teSt fluid discharged during our yean of record occumt.i

Staflcc Oilin&

As discussed in me ADEC repan: (ADEC l9:88v): "Oilinl roads for dust suppression anc:t road su:face maimen.a.nce baa been ~ne in many pans of the naaon for many years. This ICUvity has occurred in Alaska via me surface oilin1 permic issued by ADEC. Projec::ed. appUcalion voluma of oil is requifed in pennil appUcuions but n:pon:inc of actUal volumes of oil used wu not required •.mtil \914. Th:roup 1984 a pea& dis'Parir:y c:dsmct betw- the unawus of oil permiaecl tar disdsarp and at::Nil volumes of fluids I applied co roads under tbis pamh [see table below]. ,This occurred because raerve pic fluids containing a small perc:encap of oil were applild co raids Wider mis pcrmic. 'Tbe surface oilln1 permit wu not intendect to perm.b me disposa1 of w~~tcwacer anct chis &CUviry was reduced in 1985 and ceased ift 1986.... No rold ~ilinl cccuneci in 1987." l I I

jj DRA!=T lW. .W! ARCXJ Permitted Oil Volumes 200.000 350.000 Est:i.tnafad Oil Ap lied 23.468 22..9.53 Pit rtwds AppuJ 2.5.881.744 l6,922.800 AJyes.lc:.a Penr.itted Oil Volumes .5.000 .5 •.500 Estim:ucr:t OU Applied 1..500 Conoco Permitted Oil Volumes 100 Pit Fluids Applied 3,683.400 Crowley Permitted OU Volumes 2.5.000 2.5.000 Estimaceci Oil Applied 20,.530 SAPC Permitted Oil Volumes 430.000 360,000 Escimateci Oil Applied 21.840 Total Permitted Volumes otou 660.000 740,000 • I

Opcrargn

Scanctarci and ARCO. the nvo major openuors on me Norch Slope. conduct most oil and aas production. drillina. and exl'lor:aeion oP.eracicns on the Nonh Slcpe; however. Conoco operates the Milne Point ftekl. and Exxon -.nd ChtM'OI'l have drilled cxplon.tory wells in the Prudhoe Bay prociueCion area. In addition co the onshcn production on the Nann Slope. S8Ycral latp operacors iacludlna Texaco and Amoco have production faciliries toc:ued i~y offshore fiaD the Prvclhoe Say ana.• Waste manapment practices ._._ durifta the lim Yistcs iftc.luded: injectina oily wau:s lftCl drillina fluids into cent:l'liU.Ied Class II injecz:ion wells (lnjectkm ~~ used by die oil and aas industi""J for

4 T"hcM o«shcn !~eiUclel were na& ~-- n • .,.u1aUy di.lnllei in dUa tepa~~: hawewr tate _..,ice c:am.- IOciiiiG on d'le Nc:lni Slapt pmvidl rn.aariU1 and IIMI:IIIA bocb OAIDole and otrshore raciliacs. &tid onsnon dispo• Cadlillll sudl u w. O:tbaw lladt1U are I&IOd _, ansncre and otrshc:n producaon f~eilida for..,.. dirpoaL

.6

·------<>·,.····-···~- .. • DRAFT'

enhanced r=overy and disposal a:c classified by EPA's tlndersround Injection .Control program as Class m: Storing damaged ~5-ja.llon drums in overpa.:k containc::s: r'.JUini and removina sludaes frcm used drums and injecting the wasteS in Class II dispcsai wells; characterizing and storing hazardous wastes in mu provided wit!\ secondary containment: Jisposing of oily wastes in unlined flare pits. lined and Wliined pi1Jin1 pitS. and pania.lly lined anct Wllined M:serve pits: and disposal of snow removal materials (snow and Fa.vel) in former pvel mine sites.

As oil is depleted from the Notth Slope fleldl. increasin1 amounts of water. n

As mentioned. dozens or independent service companies provide the enr:ire production inciusrry. both onshore a.nd offshore. wi~ a variery of oil field services. The scmc:e companies ac Oeadhorsc build their own f~ries on liDcllased. from the State. The services provided include sU'PJ)lyina oilfield opcfaccrs wich a number of oil field chemica.ts. These chemicals include c:lea.ninl solvems. corrosion inhihi=s. a.ntiirceze. emulsion breakers. sut!acuncs. acid!. bases. biacidel. and pn:scripcion formulations as well as lubricana. clrillinl fluids. drillin1 muds. and completion a.nct workover fluicis. ~any of tbe service ccmpanics acnau: unused. d1s;a:dcd product and spenc chemicals. some of which may exhibit RCIA hazardous c~cs.

The waste manapmenc and sunp pnc1ic::s1of service companies vary significantly. however. many of those observed showed evidence of releasa of contaminantS to the tundra. The c:ravel pads of manY, service companies showed evidence of frequent chemica! spillage wftich reached the s~n1 Nndn. Numercus incidena I

!"' DRAFTi of sptllaie mulr:inl in an estimated 60 acres of deacl rundn. are d.ccumenred by AOEC.' The chemicals are usually stored in SS·sallon arums or in bulk W\la in areas that are not provided with secondary containment.

I Ln mid· t 985. interim status under RCP.A Subtitle C expired for the Pnldhoe Bay tJnit P:u13 injc:c:on faciliry (discussed in deW! i.n this text), and Pact 3 stopped accepting RCRA hazardous wasta. In 1987. the operaccrs of Pad. 3 stopped ac:ceptins a.ll thircl parry waste for disposal. which includcct all service company wastes. At d\is time the Oeadhorse service companies had to find. alternate ways to h~c and dispo• of their wastes. As a.n 3.ltemati.ve to dispos:LI of oily wastes ac Pad. 3. some service companies have aatuireci wa.ste oil burners or incineratorS for use as space heac.n. a.nd oil/water 1eparaters !or scgreaatin g oil from rinsing operations.

lnciner.uors or waste oil burners arc not requited to be permitted under State or fec:le:-.U air qua.liry refUlad.ons wnil they reach a 1 million BTUI1loar ratin1. According to ADEC. then: are no Swe or federal recuJ.ar:ions spedtlc to wuce ail burners operating below the 1 million BnT/bour ruinl. The service Qomp&n)' i.ncincnccrs and waste oil burners on the North Slope are rated below thi1ltvel. Oenerally. none of the wastes 1cner:ued by service ccrnpanies are charact.crizl:d for hazanious =nstituenu prior to disposal or incineration. Under fcden.l replad.o~ wuce oil to be usccl in approved equipment must meet use.cl oU fUel speciftcadons. (However, it a company bums wute oil :hat it generated itself. the fuel can be off-specifica~.) OU fuel specificaEions require that the oil contain no more than 1000 ppm haloPftS.

While some sc:vicc c:ompuy opcrau:n r.aay!U. oil bumc:rs to dispose of oily, liquid wure. noc all service companies have such equipmeal. Based on available in!omwion, it is not possible to determine how ~ companica not in possusion of oil burnet! "*"P Uquid oily was.. Nor is it possible·so claermiftc how service companies usina oil/Wia' separuon dlspole of the water ph~ of the wua which may c:onrain toxic: elemenu. No CaSI a injecr:ion weU Oft the Nri Slbpe is cu.mmdy available to service I companies tor disposal of liquid waste. A=lrdinl to ADEC. most solid wasteS 1enerau:d by the service compames arc sene to the Oxbow la.ndft1l (described in deQi1 ta= in the text). I DR!~:=T which pnMdes me only legal' means available co service compa.n.t.s Cor disposal of solid waste.

Accord.ini to me July 6. 1988. Recwarcry Ce:e:mination, (~3 At 25446) which ci~r1es the :ypes of oil fieki wastes subject to RCRA. soiid wastes cenmted from an oil field suppon: services site are not exempt under R.CRA Section 3001 (b) (2) (A). and. are subjec: to n:aularion under RCRA Subtitle C. almcush Alaska is nac yet a RCRA ddepteci Stare. The State of Alaska has promulaated hazardcus waste reaularions and. is presently enfortinl them in cooperation with EPA. It the Swe's hazarcious waste pi'Oinm &ains full iluthoriz:u:ion hom EPA under RCRA. then en!ac:emenc of Subticle C ac thae service company sites will !all primarily on AOEC. A tlow chan d.epic:tinl management and disposal of i1ll major waste sa-eams aencra.cee by North. Slope service company operators is presented in figure S.

The Sortil Slope Borouah operates two majpr disposal !acillti.es on the North Slope. the Oxbow lanclfUl and the Nonil Slop: B010u1h inci.nen.=-. both of which are permittee by ADEC. The Nonh Slope BorouSh incineracor acc:epa i.tld.uscrial and dom.~stic waste. anci uh from the incineruor is d.isposc4 ac me Oxbow lamifUl. The Oxbow is an unlined landfill located in a ponion o£ 111 abandoned aravel mine site. and is described in detail later in this text.

Alaslca has no commercial RCRA·permiuect Tra.ancnc. Srmaac and Disposal (TSD) f01cilicies (Ot me tr!:ltm.cnt and disposal of R.CR.A hazardcus WUte. Allltnetaa:n of RCRA hazan:tous waste in Al&ska must ship the wasre ro TSD !acilid.es in the L.ower 48 States for disposal. or store wua:s onsit& uncL:r interim stams.

\11 jor flpciJna

• ADEC inspec:fDI'S lack die auchoricy lo isiUI ftft• « shuc in prociuctiOil for violadons of State reaularions or lack of responsa r.o Nocices of Vtolar:ion. This l.:k of ! DRAFT

3.uthority reduces the effectiveness of ADECs entoR:ement: of Swe and fedef:U regulations.. especially where service company activities are involved. Furthermore. l.lthough ADEC C3n forward ems to the State's Actomey Ocnera.llor resolution in court. the Stare Aacmcy Oenerli has persueci only one insrance of noncompliance through the ..;ouns in a c:s.se involving Sorth Slope Salva1e. Inc.

• There ate cases of dccumerned non-ccmpiiance wiUI existinl State regulations by both the large prcduction compa.nies and the smaller service companies. However. noncompliance on tho pan of semce com.,.,Ues is more trequecc. involves more serious violat:ions of Scare re,Wations. a.nci service companies are less ax2perativc when responding co Notices of Violation.

• Operators have been claiminl (and continue co claim) the RCRA exemption for wastes that clearly are not covered by the exemption. For example. AACO operata a .~mall "topping unit" or miniat'Ul'Bretinery on the North Slope that prcciuces diesel fueL Based on available data. it appears that ARCO hu never trea~eclaa hazardcus any of the wastes generated from this operation. nus facility may JCneratl wuu:s that are listed as h3Z:U'dous when seneraced by peaoleum refineries lJr:ludiA1: [(041, dissolved air flotation 'float"; K049. slop oil emulsion ana· solids; KO,O, heal exchan1er bundle sludps ·and c!ewn1 wuces: and KOS 1. APt separator slucip. In addidon. sct\'ice companies may generate wastes that tnt RCRA hazardous such as paincinl wutes. solvenu. and off. specificar:ion Kids and chemical blends.

• There are no specific Swe solid or ~us wa.ue replar:ions for desip, opm.lion, and mai.ftu:nancc or performance ot c::nr:alized. or c:ommezcial waste G"'WmCnt 3.nd c1isposal facilities. For example. permaflos:c is rellecl upon for waste comainment in the dcsian and opcrarion of IZLil'1Y waste c1lspos&l t'ac:ilicia; however there are no Srara requiremencs ror delrrmiDilll cht presence or·~ of permafrosc W1dcr and around WISUI ""•ICII*U ta&:ilica. ncre are no Stale n:quftmencs c:ummdy in place for the manapn•• ol t.p voluma of StOrm war that accumulare in facilities such as the Oxbow landfill. which is the only lanciftll on me Norm Slope thai is used for disposal of ind.usuial solid and oUy wastes senmreci by Norm Slope exploration. development. and pl'lXiuc::ion facilities. • W'hile there are no regulations specifiC: to comm~..ai or a:nU"4llz=i waste dis-posal !adlilies. AOEC does bave the authority to issue aeneral pennies for :u:ttvilies such as disc:harp of stormwau:r from a landfill: however. there are no formal critcna tor such general pen::ntu. anct permits are issued on a case·by·case basis. The Anny Corps of Engineers have authoritY W1cicr Section 404 of the Cle=1 Water Aa to require speeific provisions when issuins a pc:mUt for conswction ac::ivities on the Norm Slope. including those activities invoiving silins anci const:rUc:tio:'l of ~;Cmrnercial or centralized waste m:ltla;emenc facilities.

• Cutrendy, Nonh Slope oper.arors haw ceased roadspreactin1 and discharginc reserve pit fluids to the runc1r.&; however, current State regulations clo not prohibit road.sprelldinc and discharces to the n:.nctn.. As a maner of policy ADEC has r:lken the position that no mon: ccner:U penniES will ~e issued tor the d.ischarge of reserve j:tt fluids to the tundr.l. In October of 1988 ARCO submitted an NPDES permit application to EPA Region X n:quesrina. amons other things. dw a general permit be issued !or ro3dspn:3tllng of reser't'e pit fluids in the Kuparuk field.

• Based on cum:nc cenenrion f3t4S. tbci:e is noc adequate !wure wute .treatment and disposal c39acicy on the North Slope for solid incluscrial wasteS such u oily sluctces aene:ulli by vuious operations. For example.. the oily wasco pit at the Oxbow liUlCifill is nearing capacity. an4 because of inadl:.quacies in the permit appiic:acion recently submitted by the North Slope Borough. ACEC and the Army Corps of Enpneen have not issued a new permit that would have allowed for expansion or the oily wute ciisposaJ. Clpacicy at the Oxbow.

• None of the semce companies on chi Nonb Slope has access co a disposal facility on the North Slope !or liquid wasteS. Many l'ff these service companies aenen.tc a wide vll"iecy of liquid wast~~. such as sbop wuccs. off·spccit!carion acids and chemicals. oUy vacznpnuuct rinsue. paint thinners a.ncl solvencs. While 50IDI of the l.qer service campania bave installed oiVwuer separacors and oU bumers for maaapment of liquid wasres. many of the smaller service =mpanic:s do not have such facilides. Ba.seG on currently available informaaon. neither the SWII nor EPA can deulrmine how much of chis liquid waste is managed.

• t DRAFT

SITE D£SCRIPTION5 • ARCO ALASKA

The remainclet of this repon is orpni=:t into four sepan.te secr:ions: the tlrsc -sec:ion describes the AR.CO Alaska sites visited. the seconct section d.esctbes the Stanciard Alaska Pn:xluc:tion Company sires visited. the thin! secr:ion describes the wasa: manaaement facilities operated by the North Slope Borouah. and the fourth sectf.cn describes the service company sites visited..

The new ARCO drill sire is composed of a ar.avell'td with below·a;rada reserve pits. We Us drilled on this drill sice are !or development of the exisuns field. This site n:presents ARCO's fim use of below•pade (illltead of above·aralie) reserve pits at a production drill site on the Nonil Slope. Below·lflde reserve piEs are excavaa:d below the I sround surface. It is beli«r~ed ttw use of below·lflde venus above·Jl'lde ~serve pits will minimi:e scepinl of n:serve pit wasce onro che runrn and will minimize pic benn breaching during breakup. ARCO will be usinl below·lftde reserve pits on several new drillsircs in Kuparuk over the next: several drillinl seasons.

Durin I drillinl of production weils a dlc drill sice. drilliD& mucl and cuuin1s aR disch~r~ea inro this unlined. below·s;rade n:s.r... pit. Upon completion of driUin1 at this drill site. tbe liquids in me mc:ve pit will be injected down the annulus of tho well. and the solids will be covered widl overbutden a.nd frazen into place inside the pit usm1 a method. refemd ro u "~ "6 Additional pladucdoft wells on this pad will be drilled around me reserve pU. and pradue1:kln piptna will be placed around ics perimea:r. This new

...... : DRAFT

type of ~serve pit configuraaofl will allow for easier solids ~moval, should. the need arise ~rior to closure of the ~serve pit. Frequentiy 'Nith older reserve pits. pnxiuction piping was constrUCted. over the pit from one side to the other. thus making it difficult tO ~move the remalninl solids. Wells in chis field are rypically drilled to a depth of apprcximarely 6.500 feet.

[n addition to the drillinl ri&, a workcvc ria.was ita operation at the time of the site visit. This workovcr rig is usca to comple:e the well and brini il into prociuction once it has been drilled to the ciesir=d depth. Woricovcr rip are also used to ''woricovcr·· a well l:lter in the production phase. Stcci Wtks containina the cemenc and brine solurion used. in weH completion were located acljacent to the wcrko¥er rig. Additional seal tanks are use.ci :o store displaced fluids generated from the borehole and wasrc fluids generated from .:ompletion and workover operations. Wastes genentccl durinS completion and worlcover •lper:lrions arc disposect of in the Kupan.t.k oUy waste injection facility, the Kupan.t.k recycUng center. the PrJd.hoe Bay Unic Pad 3 oUy wasa: disposal weU and pir. or the Oxbow landfill. (These facilities are discussed in detlillarer in thi$ text.)

Accordina co ARCO pencnnel. the Kuparuk fleld contains. approximately 600 wells. and workovers of these we11s are pcrformea periodically. Appmximalely SOO barrels of worlcover wastes are JCnmted per workaver per well, aad. some ofthis waste was rrponcd by ARCO to be recyclable. Accon:tina to A.OEC. it hu lirde informarion on file on volume and ch:t.r:~.aerizadcn of workover wasze lcncmueC ia the North Slope oil tic!ds, and ic is not known if ARCO or the odter operaten have d.evelopcci this type of information on workover waste. Durinl dte 1988 s~ season. 33 workovers were performed in the Kuparu.k field. represenlinl appro~awciy 16JOO bands of workcver wasu:s. These wastes are di.spoted of at me Pad 3 oily wuce ciispou1 t¥illry 01 at the Oxbow landftll. ·

.Ac=rdi.q to ARCO personnel incerviewed ~~ the size visit. pipcllnes in tho Kuparuk field are roucinely piged.7 At the time of.the sire visit. ARCO personnel did. not specify what typ. of pipeline is routinely piged: h~ever. in i.nfomw:ion submiaed by

7 PiiJinl is a pipeline clanint praccu in wbidlametal Cl! called plalti= c,lindlr ia puaht4 lluoup pnx:iUI:Uon PliMI ra rcmcM aay pll'lll1a. solidi. or ala.M ...,, coUctM illtbl pipUIJ. AS 1M location in !be pap:Une where the pia ia miiGYIId a pit. is IIIUIIly CCftiii'DCtld lD receive& dlt pigiq wuca.

_.... ARCO followina the EPA ccrnractor\isit. ARCO sa&tes (ARCO 1988): "The only p1~lines in KUl'aruic which are rouunc!y pigJC(i are the: water injection lines. Oil production lines are not piaied. ·•

According to ARCO personnel interViewed during the EPA con~or site visit. many of ARCO's drill sites in Kuparuk haveatleastone pi1Jin1 pit. and some are lined. whtle others an: not. Upon completion of a piaJin& operation. r.tie pigJina slud.ges are coUected by vacuum truck and are injected at t.r.e ARCO oily waste injmion fadlity. At the present. most of the piJJinS pica in the Kupa:uk field. an: unUned. Ac:coniing to ARCO pcrsoMeL ARCO intends to bcain linin I these PiiPI pia. althouah no fonna.l. schedule h:u been prcposed.. Accordinl to AOEC. it has no ialormation on rue conc:m'lina ch:uac:te:i%:1tion of pigJing wastes and. volumes aenera=d.

In a letter sent to ADEC a.nd the Army Corp~ of Encineers ciated September 12. 1988. ARCO ~uestcd. permission to c:onsau.c: a smaJ.l pic within the reserve pit 1t Drill Sire 1E. According to the letter. the small pit is rsquired for piJJiDI operations. and. the piiJing wastes are expec:cci to contain traee amounes of "oil sc:aie and irorl sulficies" (ARCO 1988a). Aa.achc:d to the letter is a dialfUD de:pic:tina me pit to be conscruc:a:d. The diagram of the pic&ini pit is clearly labeled. "Uncr noc to be insralled... Ac:ccrd.in1 to AOEC. A.R CO claims tha: the liner is noc necessary because a cunain liner will be installed. in the reserve pit in a few month$. ADEC smtes that it has.nevcr lf'pnwed the disposal of pig&inl wastes tnco reserve pies or into the pads upoa which the reserve pies a.n: constructed.

ln information submitted to EPA CollO\\inl the EPA con~ visit.. ARCO states (ARCO !988): ..'The new drillstms. u which waa:r injccion is bcpnniaJ, have no need for pig&inc OS*'Biions. Acccrdi.ncly, those aires clo noc have lined pigins pic:s. These new d:illsites wida waarflccxl operadans are piged to me ~serve pia from which the water is immediar&ly ~ .. As noted above. ADEC has ,never approved the disposal of pigJiniWIIRIII inra reserve pies. aldloup ARCO appuntly uses &be r=erve pies for temporary scarase of pi gina wuces.

At the A.RCO drill site. new raerve pies were beinl pnpand for iilNR usc. These new reserve pies were panially l1necl widla ~ maa:rta1 thal is used cc ins\IWe the c::cposed permafrost. (I'bawed pctmalrost causes subsidence of thla surtace. a.nd exposed.

:.s ~ P;~r· D ~ ... J ' .. 1

pennai'rosc wUl mcit clu:in1 tHe summer season.) Disposal of this insulation matena.l in the Oxbow land!l1 is planned followina the summer cmllina se:uon. Overbu:dcn from exc:J.vation of all pia on site was sw:ked on one ec11c of the dtill site. This overbun:ien will evenrua.lly be used to close the resr.'\l'e pirs. (Refer to photos 1·7.)

Site 41t 1 ::\RCQ >Jaredal• Stora1c and Drum m:pgul &rsp • Kyparuk Fjeld

ARCO ulilb:.es a ccna'al area or pad. for materials stOrale including drillinl and completion materials. tubulan Cpipinl), and spare pans. This si:e also ha.s an ar= for storage of empty dmms. The pad. contains a warehouse for storage of some materials. while others are stcrcc:i outSide. This pasc sprinJ, a spill occu.rreci at the warehouse when dzums of methylene chloride anived in damaacd c:ortdition. As a resulc. ci1ht -'~·gallon drums of methylene chloride-contaminated materials wen shipped to a RCRA Subtitle C a-eatment. stcruge. and disposal (TSD) facility in the Lower 48 States. (Alaska has no RCRA permitted commercial TSD facilities.) Accordina to ARCO personnel interviewed during the site: visit.. this was AR.CO's Mt shipment of hazardous waste !rom thoU' Arctic oper.1tions. Cumntly, ADEC and EPA have no infatmaJ:ion conctminl the a.nn&W usagt of methylene chloride and o~ chemicals usei1 in the Nonh Slope oil fields.

Empty drums are stored az me central sunae site prier to cmshina and disposal. The: empty drums ~iousty contained a variecy of oil fielcl chemicals including solvents. ~ids. biocides. corTDsion inhibitors. c:orrosiva, caustics. warer treaanenc chemicals. anci a number of hydroc:&rbon·bued chemicals. Empey d:ums are sw:kecl on wooden cr:ucs four drums hiatt. At the time of the sim visic. some dnmu exhibited visible sicns of. physical damage. rust. a.nd corrosion, a.Uowina f'or residual conterltS co leak out.. The empty drum storage ma is surrounded. by a lined "4coasncteci of pvel. On the day of the site visit several in.c:hcs of wa&er bad. collecu:d. Ln pcoJs inside the bennld area. The wuc:r was hiJhly discolc:nd by che pmencc of a bl&ckish subt;uu:e, and toamina ICUon. albe surface of the wt11r wu evident. apparently resuldtll flam residues leakinl from the !ml)ty drums.

At the A.RCO materials s=ap area. drams 11'1 double drlined and. c:rushed. The I oil· miscible drum midue recovered durin& drlininals cornminlled with ocher oil-miscible wuces and re:cyeted in AReas oily wuu: recyclinl cenrer. wblle Other Uquic:t waste from dn.Jm cleaninl operations is hauled by vKUUm auck. and ac:cordinl to ARCO is "disposed DRA.rT

:lt a State approved f~ility" (A.RCO 1988). ARCO u.ses a privacc c:ontn~.etcr tO dispose of l!!mpty drums.

(Refer ~o photos 8·1l.)

Site # 3 ARCO :\hlftdoO:d Mlgc Sjtc • Kugaruk Ccld

l.n developing the Arctic North Slope oil fields. hund:eds of millions of c:ubic: yards of gravel have been mined from various mine siteS in the area to c:onstruct zravel pads for drill sicc:s. production equipment. pipelines. suppon services, :mel an extensive road network. All pads and roads are elevated 5 t'eet above the tundra with ,nvel. The mine :;ites cover areas on. the order of millions of square ·yards and are up co 40 yards deep. l:su:Uly. between 10 and 20 yards of overburden must be remove and st.aek&Ci uijacent to :."'tc rmne site before suir:able pvel is reached.

As doc:umenced. by photo1f3phs, indu:scry sometimes uses chese abandoned mine sites for disposal of JrilVCl and snow c:oUected f'mm pads durin1 snow removal. Oravel collected durin I snow removal from pads may contain minor amou.ncs of c:onraminanu • from crude oil and c:hemicai spillaae. These spills ate common (hund:eds of spills arc reponed ea:h year), espccially aurina tho winter months. The dbposa1 of material collected. during snow removal is not replatecl by the Scaa:; however, accordinc to ADEC. the Dep:sn:ment does prefer that snow removal malCrial be placed in a confined area before melting so as to minimize pomnw mir;ralion of any ccntaminanta removed with the snow lnd grave! durinJ snow removal.

The permits or lases wxler whi= an,vei mint siu=s a opemei are issued. by the Alaska .Dcpanmem of Nuural Resources (t)N'R). To elate. reclmacion and n:habilicalion reqWtcmems SUIIId in exiscinatases or permio ~ nonspedftc. A typical lase will have a n:cla.awicla pnwisioll sCIIin1 dw a rehabilitalion pian will be dnelopecl &hal sad.sftes the Oepan:mem of Naa.nl Resources. However. this process may be chan &in I·

In 1986. ARCO vio1acocl the ONR. permit pcmin1 aclivilies at the Saa River Mine Site C by divemn1 the Sa1 River into the mine siat without: the lfPIOVU of Alaska Depanment of Fish and Oame. (Alaska Oepanmac of FISh and Came hu oversiibt authority over aquacic habitae in ancl around mine sltes inclw:JiniiUMinl rivea.)

., ••.. •~~ ..J. ,'' ..../, r:.ri -. ~· . ' Ac:c:ordina to the leuer =companyinl the Notice o!'Violalion. dared June 16. 1986. (AOR:i t 986): "Sasecl. on informalion obtained from .1\RCO and from or.ber indivic:iuaJ.s in tb~ Prudhoe Bay Are3 a cha.nnci was cut in a dike located on the west side of the mine site with 11. dozer [bwld.ozerl somc:rimc: on the: 8th of June. By the evc:nina of the 10th of June Saa Mine Site C was completely inundated with wacer." The lener aces on to ~ucst that a comp~hcnsivc pl3.11 for rehabilitation of the sice be developed by ARCO that would: inecrpora.cc the possibility of convertins Saa Mine She C into a water reservoir.: provide for fish passaae into and out of the flooded site: provide tor enhancement oi fish and wildlife habitat at the sire: ancl ~sent aplan for fiekl manitOrlnJ of fish present in the pit and evaluate the produelivicy of the pit as a fish habiw. ·

I In a letter from AOFO co ARCO dated January 27, 1987, ADFO is encou:agina ARCO to proceed with reeommenciations mad.e by ADFO concemina the rth.abilitll:ion of Sag Mine Site C. ARCO's proposed rehabilita.Eion plan for Saa Mine Site C Salted that a choice must be made between ertarina fish and wildlife habiw and esmblishinl Sas Siu: C :u a water reservoir. ADFQ disacreed. a.ncl scaud: ·"In summary, we request tiw ARCO rcconsider.ics prefmed opEion and instead sel«t arid propose 1 ntYision of its proposed plan which takes into considera&ion the commcncs ~by ADFCi in the 1une 16, 1986 Solice of VioW:ion. A prefmeci option should reflect the fact that waaer usc a.nd tlsh ancl wildlife are compatible ancl that problems such as slmm:ler drawdown can be addressccl by seasonal consU"aincs on water usa1e."

The ADFO leazr dated January '1.7, 1987 IOCS on to swe: "The Sac Site C sicuar::ion underscores the need. fer mueria.l sire rehabillwion plant in \he Prudhoe Bay/ Kupln.lk Development area. To our knowledp.. ~has nee been a mareriahicc in the enti:e Pnuihoe Say/Kuparuk Developmcnc area when 1 rehabUlcmon plan hu been completed.. approved by 1M apzscies. and lmplemenced. A side bcrletit of 1 pzoperly conceived lftd implcmeared tehabiliradoa plaa. &1beU aftlt tbe taa. tor d1is sice should. increase our !eld experieftce and on·sill knowledp of whac consdtuca effeclive ~aunrion and associarllcl CICOftOinic cffidmc:y. ·•

Attar extensive review lftd ncaad.uions wi1ft ADFO. the xehabiUt.llioll of Sat River Mine Site C wu coraplCU!d in the fall of 1981. ,. rehabilicadoa plan involve the expansion of the pit and the c:readon of a shallow ,.-arer zone Coverinl about ftve a.:::es. The Alaska Department of fish anci Oame be!.ieved that the c:racion of the shallow warer I .....,. •

i·"", ;:. ~­ r...... • • .,.I \ ..' • i zone woukl enhance habitat and incr:asc productivity of the native fish species found in the pte. Accon:.ting :a officials with the Ala.5ka Oepanment of Fish and Game, t.ie mullin& 40 1cre 1.1ke is now providing productive habitat tor native fish.

Currently, simil.u rehabllitacion plans are beinl negotiatecl with ARCO. Scandani. :J.Ilci Conoco, includ.ing rehabilitation plans for me ~uparu.k Oeaaarm area. Kuparuk Mine Sire B. Kuparuk Mine Site 0, Conoco Milne Poinc Mine Site and Put 23 and l7

Sjte • " .\BCO's Kuparyk Oily wu,, Injmtgn Eacmsx

A.RCO d.isposcs of nonrecyclable oily wasteS in itS Kupuuk oily waste injection facility. W a.sres are received at r.he fll:illry by cu.¥ ·truck. The driver of the tank uuck usually makes the necessary hose connections to discbarae the concacs of the a"Uck. The wastes are processed throu&h a sh&le·shakct, which sepan.ces the liquids from the slud1es and solids. The liquids. solid.l ancl slu.dps an sccr-.t in hald!.nl canks prior to injection or disposal. The oily liquids are injecu:d via 1 Class II injection wc11. The oily solids and sludges gener.ued by this process arr: removed by a private conrractar and di.sl)osea of at the Oxbow landf'lll via dump trUck$.

Accorclinl ta the ADEC permit fer this tacilicy, wu~a ce to be injecu:ci at a depth of 3.000 to 3-'00 feet. Bua:lon a 3Q.day averap, dle quanlicy ofUquid iftdusui.al waste disposed is ~»~ co exceed 210.000 plloas per clay. The pa1Dit provides that wuccs accepllble far dllposal ac this fiCi.U.cy include ~ wuer. wate oils. reserve pi& fluids. Waste brine. c:rude and diesel fuel samples. alycol and domeslic wua:wa= (ACEC 1984}.

A cbemical analysis is noc pcdormcd on th~ wasta KCepted by chis injcc1ion !aciliry. However. the AOEC permit for the !adllty swes tlw U1e permittee shall rest ail mararials that are suspccu:d or beinl hazardous an~ exclude them from injecrion. • • ("-. ... . -..,. • • • l! .: . . . l DRAFT

Acccrdin1 ro ARCO personnel interviewed durin1 me site visit. most acc:pwi wastes would !ail tbe RCRA ignicabUiey c:ha:rac:eristic because or their hi&h pe:oic:um contenr.

Acccn:iin& to the ADEC permit for this facility, the permittee is requ.ired to maintain a Ioi on site that will con~lin the date of receipt and source of material received.. volume tTom e:~eh source. what type of moniccrin& has bec:zs performed on each load and the results. and any informacion on extr.lOC'dinaty occu:renccs. According EO informacion submiacci to EPA by ARCO fcilowinl me EPA connc:ot site visit. all oily waste loads an: manifested under the Kupan.Uc OUy Wure Manifest: system in compliance with permit requi.mncnts.

Durin& the site visit. oily satins were noted on the pwxi arounci the unloading :ue~. and there is no concainment for the unload.inr area.

~He • ' A RCO's Oily Wg:stt Bcc;ysflna Center • Kugaruk Fjeld

ARCO mainrains an oily·wasu= teeyclin& center in the Kupan.U&: ftelcl for wasteS containin1 recoverable hydrocarbons. This faqiliry·is similar to a c:rude oil rec:iaimer in the L.owcr 48 States. Hydnxarbcns an removed from the incoming oily wastes by a heat treatment process and sent to rhe cruc:le oil S1Z'I!Im. 'The nonrecoverable Uquida are ~ommin11ec1 with water destined tor ARCO's watcrflood operations. The solids and sluclps are disposed of ac the Oxbow landfill. This facility receives oily wastes from well flowback. d.iesel from hydrosQCic testin&, and piiJinl wastes, llabe oils. workover wastes. and other wastes. The oily waste~. received by Che facillry via vacuum tUJ.k rrucks. art pumped into a series of tOtU above around tanks ltw: separate The oil. the water. and the solids.

As cb::umcnccd by phocopphs. oily - tlom drips and spills wen: eviclent on the araveliDIIICl the tacillry. Similar ~ls were evident from tanks chat had overflowed. and none of cbe uks were equipped witt& hi&h·level alarms ta a1eft The operAIDl' ot the possibility of overflow. The .anlo'Ciina area. which had visual evid.e~~C~ of chranic spills.. ' is not provided wich secondary conllinmem. Consequendy. spillap from hose breakdowns or uncouplial is lllowed tD drain in10 r.he nearby pavel. thus allowinl the potenrial for off she mipcion of concaminan&S. Oily sheens wem visible on the water I surface around the unloadina area durin1 cbe si• Yisic.

jl) Thn:e ocher facility storaae ta.n.k:s are contained within a ,ravel bma. which is lined. An e.oonpty. partially lined pit was located immediately adjacent to the recycling facility. ARCO employees in attendance durin; me EPA cona~C:or visit ~Nent unsure of the purpose of this pit.

So chemical analysis is pcrlormocl r.o cbar.lcterize me wasu=s accepted by this (acUity; however, ARCO does IlK an internal manifest sy11em co cr.u:k wastes being disposed hen:.

(Refer to phor.os 17 ·22.)

SUt i* § Ptudhgc Bay Unit !ad l OUy Wa1tt QfSQQIII Facility

Stand..a:tt ancl ARCO jointly operue the Pat.l3 oily waste disposal facility in the E~tem Operaans Are3. of the Prudhoe Bay tleld. Scrucmres ac this f~Qlity include three injection wells. which were oriliJWly drilled !or the purpose of cestinJ the pcnnafrost under dif!cn=nt drilling conditions; a latae 1ineci oily wa.sce pit and a precess buUding. The three wells were drilled in 1978, a.ncl d:1e pic WfS const1'U=cl in 1987. Uquids from the oUy wasu: pic are pumped down the injecti011 wells. Pad 3 is located in a heavily induslrialize.cl area of the Non.b Slope oil ftelcL bounded on all tour sides by oil production facilities. "'ads. pipelines. and reserve pits. AReas Drillsice 6 Pad is approximately SO yards ncn.h of Pad 3. F'or regularcry purposes. ADEC views me Pad 3 racUity as cwo separate entities: the surface facilities Cor the Cass Il injec:ion wells are permitted by ADEC under a wastewater permit. and. me oily waste pit is; permitted by ACEC under a solid waste pe:miL

The ape:raun of chis £aciliry have applied c0 EPA. Resioa X for a permic I c:lassifyU11111 dU'ec of tb.e injeczioa welll u Class 1Nonh&Ziftioa disposal wells. The wells are cu:rnady classii!ed u Ctass II disposal wells Wldcr dle Underpou.nd. Injecdcn Canr:roi pi'OIIIID. ancl are replaced by the Alaska Oil and Oas Conservation Commission. Public cormnenc received by EPA Repon X Oft thc:'opncars appticadon tor permia:in& these Class li wells as Cus I. provided intcrmacicn that raises some questions about the performance and i.ruelrity of the Pad 3 injection ~ These c:ommencs are discussed later in this section. '."'' ' .....J ,\ ....11 T '... • • ~ ' 1 .

nus rac"Jiry acceptS a· variety of liquid oUy waste in ad.didon to semi·solid sludges lnd oily, c:onr.aminated solids. The injection well is permitted to inject Hqu.ids containing 'JP to lS pe.rcem solids. Acc:ordins co a.Iener from ARCO co AO'EC dateci .February 29. 1988. incoming wastes inciuda wa.ce:·buccl and oil-based drillinl muds. crude. diesel and dlesel gel. wa.cer gel. prociuceci wacer. brine. pi breaker. workover fluids. lube oil. arctic pack (liiesel fuel). hyd.r:luiic tluid. spent acid. caustic. sea waasr. fresh water. methanol • .:cnt.:ln".inated cement. sand. &ravel. snow. and ocher wastes (ARCO l988b). The facility J.lso acceptS drum cleaning wasce:s and ARCO's and Stand.a:ci's ca.nk clc:a.nin1 wastes. which typically inciude Wlk bottams. sepua.rian vessel clcaninp. and heat exchanger bundle sludieS from ARCO's diesel !Uel·producins toJ'Pina uniLS Currently, the pemtits for this facUicy do noc allow for disposal of R.CRA hazardous wastes.

T]1:lically. wastes :Lre cr:1nsponed tO the facility by vacuum c:uck or dump ~rUck. As documented by photos. there is no containment ~a around the liquid waste unloading pad. so any sptllage from hose breakdowns drains inm the nearby Jr3Vel. The incoming liquid wastes pass through a series a! solids removal prcCesse$. ihc separated liquids are · :njec:tcci. while the separated slud;es are disposed of in the piL Incamin; sludges or solids. which are not a.ppropriate for injection..are·disposed of in the pit u_-pon amvai. These sludges and solids, which do not enter the 509aration processes.. include sludges from vessel clea.naouts and oil-concaminaced pavels II'ICl snow removed from drill sites anci from spills o( any c:onwninantS chat may occur.

' According tO ARCO personnel inter'Vie~ durin& the site visit. the fluids destined to be injec=:i are tested. for pH. specific F"vifY, ancl flast1 poinr. TCS1in1 is performed at :he: Pa.d 3 f:sc:illry. Chemical analysis is not performed on me inc:omina slud&es. According to fa.ciliry personneL che sludac samples are not teSrld for t1asb point because they are assumed to have a low hyd:n::l:arbon c:onu:m. Tbe operaun or dUs fiCility implemem an inmmal mamfes system dw requins a manifest to accompany each shipment of incomin& waste. This il noc required UDder the permit iaued by ADEC. AI staled. i1l r.he AOEC permit for tbis fadlicy, the paminec muse .. Record all loads by dale n:c:eiv«i. wasce type. :w1 volume such that the was• cype cateaory sc1ected pol"'nys chc nlll'llm of the oUy waste

8 ARCO's 101'Piftl unil is 1 saWI tetinery U. pradUCa (uel for U. lllllY vetaict&t oper-.1 an tAl Norm Stop.. and is d.iscussai in doQa.llaa:r ia chis ceaa.

1"... f':). "· . • _. I 4 • ,t ·, '=Tt

str=m.'' At the time of the EPA con meter site visit. information was properly recorded :u required by the opcr:ltinl permit for this fou:ilirJ.

The oily waste pit is lineci with a synthetic liner. al1d thermistors have been placed I in the bottom of the pit to monitor temperature. At the time of the site visit. the liner had a !'\umber of visible CT':lCks around the edies. [tis not·lmown whether the liner in the bottOm of the pit has similar cr:u:ks. There an: no monitorin1 wells or leak deteCtion devic=s pn:senr at the oily waste pit. Acccmiin1 to Standard personnel inten"iewed. during the site visit. the pit may be tested for Leaks durin& the summer of 1988. alchou1h the methcd to be I used is undetermined.

As documented by phocographs. some oil stains were observed around the solids removal f~illty. According to the operator present durin1 the site visit. snow i~ removed ~om Pad 3 and deposited on adjacent tundr:l. w\thout sampling the snow ror the presence of sptlled m3terial.

Accordin1 to AACO pef'SoMel inte:\'icwed during the sill visit. there is no cathodic protection for the injection wells u this fadlir,', and no H2S deteCtion or warning devices were being used at the time of the site visic. S~ce the EPA conU'KU:Jt site visit. as observed by EP.A\ personnel visic:inl the facility in Aupt of 1981. H2S de=::ion and warning devices ha~e been put in place.9 (Re!er co phocos 2.5·30.)

As mentioned earlier. public comments submitted to EPA trom the Trustees for Alaska on the oper.llors application !or Class I scams at Pad 3 proYide information that r:liscs issues concerning the performance aNi inteazity of me Pad 3 ~ faciliry. EPA has not confirmed the facts alltled by the Trustees~ and includes majCI' J)Oints prov1ded by the commencs to indicLte the rwure and extenc of thl problems wbic:h may exist at this (acUity. 1'hao c:cmmenra were prepand by a r~ senior pmd\&Ction en peer who worked for ARCO lot a number of yean on the Nanh Slope, and many of the comments 3.t"'! based ca -=al experience ac the Pad 3 facility and at numerous ocher oil pnxiuction rou:illaes in opcmion on the Nonn Slope. AJ discussed in the commena. this former senior produc:Uon enpeer had KCCSS to data maintained by ARCO penainin1 specifically to the P:uJ 3 (Killey and to the surrounding at~:a.

--,. ... DRAFT~~ ~r

One of the issues ra.iKci by these comments concerns the volumes and rypes of wastes to be diSl)Osed at Pac:13 (Trustees 1988: Truscees 1988a). As swcci by the commentS: '"The volume of wascs praposcd for injection u this Ca.c:ility over the next LO yean is appro,Qmately 30.000.000 bmels. This is ten times more than hu been injected in the past 12 years.·· This projected volume would result in disposal of approximately 10.000 bam:ls of waste per day u Pad 3. The comments point cue: "The nnspon of 9,000·1 0.000 ba.rrels per day of wuce to Pa4 3 will.require 60-70 1$0 baml cruckloads per day. This [is] a auck every twency minutes cr so wund the clock. The wasts manifestin1 and contrel sysu=m p-resently in use by ~CO is incapable of contrelling this volume of waste."

The North Slope oil fields are becominl sour fields. As silled in the public comments submir.cd by the TrusteeS: "The Prudhoe Bay Field is beeomina a sour field. sa.tur:ued with incrwina concenln.l'.ions of hydmseft sulfide (Hi,S). since the inception of the war.ert1ood project in 1984. Concenmuions of H1S approachina 1.000 ppm are now found in numerous process veueis-.in North Slope facilities. TheM vesseLs contain sludge. saru.raced with H1S and sulface reclucill1 bacteria. which is cvencually dis'poseci of at Pad 3.... These materials will present si!IDiilcmc ~essilll problems a& the Pul3 racillty and IT'.Ay have dcscruc:ive effectS on the injection wells 1M n:ceivinl aquifer."

The commenu go on co address concerns a~c the cunene locadon of the Pad 3 f3Cility: "The sinalc most pnrslin1 problem wich the pmenc siana or the OW!F (OUy Waste Injection Facility] is itS close proximity to AH.CO Drill Site 6. Ic appears probable. indeed. a.lmcsc cemift. that WIS1IS injected at P3d 3 have invaded. the area beneah the ~enna.frost under onu Site 6. This waste is or will .soan be in concact wirh Crill Sire 6 well bores between the 1.900 and 2.300 (OOC de'pth and fbr SOIDI cilSWICC above and below this area. ·• Table C-1 ot Auachmenc A of ARCO's permit appUcalioft idenlify sevll21 wells widUD .5~ teet of the Pad 3 wells. and cne as close·a 440 feet.

In addilioll tD coacems aver the proximicy ot Pad 3 =:. Drill Sica 6 wells. several monitarinJ wells were drilled wicbi.n 300 teet of the injccticn ..,.lls ac Pad 3. Accordinl to the Trusu:cs' commems: "AcccrdinllO AOOCC files. closure wu effected on these wells by wcldina a steel plaa: over the casin1." Under cumnc Unde:J;round Injection Conl:n)l (l]IC) n:gulacions. weUs muse be plu1pd usinJ ~nc plup in cri=cal inccrvals; weldins a. steel plate ave a casinc is noc considered a sa!c ~ adequate mcdlod. far pb.1gin1a well r·'). '·. ~r ...... • • .• I

Tbe Trusa=s' commera ao on to add:ess concerns about the ability of permafrost to contain the wasr.e injected a& P= 3: "The o:mtainment of the injected. fluids at Pad 3 ultimately depends upon the integrity of the overiyin& pennat'rosL The bindin& a1ent for che soiJs W'ithin the pennafrou ts ice. The fluids injected at Paci 3 c:cnsist of a large portion of anafreczes or freeze depressant fluids such as methanol. ethylene alycois. diesel fuels Ulci natural g:u Uquicis. Many of these are li&hter than water and will rise to the area. immediately beneath the pmnafrost. Thawinl of the petmafrcst in this an:a has been OCC"..urinl and. will continue. ·•

The Truscecs' comments discuss many concerns pcnaininl ro the physical inteancy of the injecaon wells. Accord!na to a ponion o! the commenrs: ''The wells were drilled as permafrost test wells fifteen yean aao. and were never in~endc:d or designed for waste injection. Their use for waste disposal in the past may h.ave diminished whatever Ufe expectancy they had. ... t.he Pad. J we!ls have a sinpe wall tailpipe over the last 200 feet or more of the well depth. It is possible that this cailpipc may no lonacr exist due to corrosion from previously injected wasces."

As stated. above. the comments submitted to EPA Refion X Oft the application for • Class I status at this injection fac:ilicy are included here to illustrUa the nacure and. extent of possible problems which may exis~ ll this fac'Jiry. These commentS have not been· conflrme:i or refuted by ARCO or Standa.Jd. The permit applicarion for Ow 1 status at this facilicy is pending.

Pinr1n ph is an abaradoned. deep. below·lflde raerve pit lhu was rn use4 r.o Wspose o! dlilli.nl wastes. and later operated by AR.CO u an olly WUte ph. The pic was ~sed !or tbe =r~minmcnt of liquid. WUICS fiarn aps=ximately 1976 to 1986. Uquid wastes storeci here iDc:luded. tank Wllhinl wuta. pttlducticn scparuor sludp. naanl ps liquids. oll·based drilli.n1 muds.. lese c:ircuialion macerial ware. workover \VUieS, and piiJinl wastes. Acccrdina to ACEC *'raul~ one sample taken ac cbllite ift 1986 iDcticaced the pn:serace o! benzene and toluene ill & tacal concen~ of 100 ppm. The pic hu undeflone c:losun: as described law in this so:Uon. The pit wu appmximately 9 feel deep, was never lined. and no leak deleC'dan syStem wu ever used. lncomina w&su:s were never I I ? .. -- DRAFT !

c:hara.ctctizcd ;mor to disposal. On IW1e 11. 1986. d.urina a aenoral inspection of the area. :1n ADEC offtc;ial documented. that oil-conwninateci waccr was ovcnop-pinl the seconci,a.ry conW.nrnent dike 3t0und the pit. and a larae quantity of erucic oil was floating on the surface of the pit. At this lime. AOEC advised ARCO of the situation.

On subsequent inspections o! PinJUt Pit in: July of 1986. ADEC officials diseovm:d that conditions at the pic h&d not cnanlcd. On July 29. 1986. ADEC issueci ARCO a Notice of Violation for the oily waste ciisCharaes u Pintut Pit. Acr:ordJna to the !e=r from ADEC tc ARCO accompanyina the Notice of Vlolar:ion. the oily waste d.ischarac '.lias a violation of St:ue Re.,Uaaon 18 AAC 7%.210. anc:1 that "containment by the pit is ina.dequar.e for an oily waste disposal s~orap site" (ADEC 1986).

The ADEC letter nata: "~o pennia have been issued Cor operation or use of this flciliry :~.nd itS loc:u:ion is suc:h that any hyc:ltocarbons or contaminantS thu escape from the pir will ao directly into the Saaavan.i.riaok River flocxiplain. The Oepanmcnt of Fish and Game has shown are~ conccm abouc this occu:rina." The lcaer sou on co swe: "Any pit tha.c is use:! for storing oily waste must 10 thtcu&h plan r~Yiew and demonstrated to be impenneable. A. disposal permit may ~ be z:quireci. The pit ac Pin rue has never received plan approval or a permit.'• ne Nod.ce o!VioW:iOn nsquested a close-out plan and sehedulc !or compleanc close-out CACEC 1986&).

Prior u:a closure. me pit c:onrained 1 to 2 fee& ot oily sludp on U1e floor of the pic. Chemical a.naJysis of the sludp provided ro ADEC by ARCO on February 9, 1987, showed oil and pue levels U. Wel samples ran~a from 0.3'1 to 12.69&. Oil and p-ease levels in dry samples ranged from 0.4'1 to 15 ..S'Ia (A.RCO 1987).

Freeze-back was cne closure method choscin by ARCO aad approvecl by ADEC for the final closure cf this pit. Accordmt tO ARCO's close-out plan for the pic. the bottOm of the pit Wll c:r.noand wizb 2 lO 3 reet ot pavel follcwcd by 6 to 1 fea of overburden. Overburda. awaia1 \&Sed ro close the pic wu the auuerial used ill rhe S\lft'OUDcltnl dikes prior to cloluft=. Acconiinl to analysis pertonned by ARCO Oil me overbuzden material. used to cap the pit. purpable aromaric by~ wee fouacl in all samples taken u six swions a.ncl at different depchs in the ovcrbuldeD. Ac a depth of l to 3 tea. puqeable aromatic hyc:fmcarbon concem tanpd from'~ ppb co 69.9 ppfJ. Ac 4 to ~ feet of depth, pW'Jcable aromatic hyd.rocarbon content ranpd fi'cm 0.0 ppb to 29~.0 P'Pb. Ac d.epths ' r:mpnJ &am 6 feet te 11 feet. put~Ubl.e aromatic hydroCarbon content ranseci from 6.4 ppb co 110.8 ppb. Oil and pue content of t:,e samples ranaee from 8 ppm to 'a PP!fl· According co ARCO. the final two feet of overburden used. tO cap the pit was unconwninau:d CARCO t 987a). However, based on existi.ns infcrmacion. ADEC is unable co verify this.

Prior te closure. the oily waste that had csc3J'ed from Ptnauc Pit aurin& the swnmer o{ 1986 was not r«overed. and the sWTOunciina ~of the pit was never monitOred for residual conwninari.on. At the time o( close-out. r!lermi.suxs wens placed in the pic to monitor temperature. Accordinc to ARCO's closure plan. the overburden cap would be i'f'3dca tO a final slope of approximately 1t, ro W:ilimcc dninale. The plan ps on ro st:ue: ··nte lack of erosion concem also indicates a revcaet.&Uon effort is not necessary.'' A.t the time of the site visit. the a.n:a where the pit was located was covered with overburden :J..nd levei=:i in a tidy manner.

Sjte • 8 Old Sudsgte taaqflll • A RCO FJrc Irajolna F1sillty

ARCO currently uses d!e old Sutfcotc ~U siw u a flrl tn.Wn1 facility. The l:utcifUl wa.s closed. in 1t:n9-1980. The Surfcoce 1~11 was ARCO's primary ciisposal loc:uion for indu.ttria! wastes pnc:ntld by Nonn Slope oil ftcld operations prier te the opcnmg of the Oxbow landfUL Acc:otdinl to AOEC. the Scare daes not have good recants of what was ciisposed at this site: or other sires durinl the lace 1970s and early 1980s. However. it is recorded in ADEC records that the Surfcocc site wu used for the one-time burial of an estimated 9300 to 20.000 cubic yants of scrap mal in 1980 under a solld waste d.isposal permit from ADEC. The wasce. estima:td tO be approximately 3,000 to 6.CXlO tons, inelw:led approxiaw.ly '00 to 600 unis of cruJhec:l clrwns which we= ju.daed. te be unaccepaable for scr.ap meca.t recydina because they concaifted residues.

ACCCIIfttilla ta ARCO personnel inceMewed durin1 EPA's visic in Aupst. cturins the staginl of ft:e ftghtina ex.erciscs at this facility. ciiesc:L other flammable liquids or nat\U"3l ps are ipiced on variOus props ac the facUlty. After me fire is extinJUished the oily waste runs off i.nco a Uned coUeclion pit. At the time ot EPA's visit. it was noc apparent whether the enlirl pad is lined or just the pic area. There was a \lisible sheen on ths pi& sutf:sce a.nd oily liquids had flowed a.:ross the pavel pad as evidenced by an oily residue I

...• . DRAFT:·--· on the pad. ScYenl unlabeled drums of oily wute wcr= located on she at the time of EPA's visit i.n August. As stated by ARCO. the pr:u:t:ice of usina liquid oily wastes at this f:!Cilicy is beini phased out.

Sjtc • 2 .4BCO Drill Site •

AR.CO's Drill Site 4 is typical of most drill site~ on me Nofth Slape whc~ production and enhanced recovery wells are placed ;around the perimeter of a lqe. unlined gr.r.vel reserve pit. Oathcrin&li.nes arc run ovc:r and arou.ncl the reserve pit.

ARCO Drill Site 4 has experienced repeated pzoblems widt soil ancl sediment conwninarion on the west side of the drill sim. Accordina to an ACEC le=r daa:ci July 22. 1988. an oil spill aE Drill She 4, near Sump 1 was first observed by ACEC on August 4, 1987 lADEC 1988). On Aususc 12. ARCO filed a spill n:pon with A.OEC scaang that the spilled m:ue:ial conslstcd of approximately ten pllons of diaei fuel (ARCO 1988cl). The spill was cleaned up. and acccntin1 to ARCO. no addir:icnal contai'.Cinaaon was noted prior to freeu-u-p. ' On June 16. 1988. this site wu visited by dle EPA ccn~Z'Kter accompanied by ADEC persoMel. At that lime. it appeared ttw macerial concainiaa a dark. oily substance had leached from the reserve pic. under the road on· the west side of the pad. ancl into the tundra on the wesc side or the road. At the time of the site visit. the wa~er around the rundn on the west side of the road was coveted with an oil shan. and the same oUy material ha.ct t1owccl onto the tundra. A=miinl to ADEC otftcWa. Ln 1987 and 1988 ADEC had requested three times that ARCO perfonu adequare clean~ u this spill site.

I On July 22. 1981. ADEC issued ARCO a MOtica of Vlolacion for failure to perform adequate cle~~~~~p aa. the Oril1 Slce 4 diesel Sl'lll CADEC 1918a). Acccrdina t0 the letter ac:compaa.yia1 me Nocic:e: "Stveral inspeclians of the site have bee made by depanment penoMil siD:a ARCO penome1 nrpcrrecl thac che c:omaminalion. had baa cleana:.t up. Oil was found on t.he north side of the nonh cli.Q ot Sump 1 and. tn 'Che sediment in the impoundment immediately ncnh of the dike durini eadl of d\ese inspecdons. tn a.ddir:icn. water in the impounded area has had a $heen on it durtn1 each si• visit and the area has a diesel smell." The lecu:r goes en to state: "The original cU spill report swes that 10 pllons of diesel wen: spilled. The size o{ the c:onwn.inau!d area and se

[n ARCO's response to ADECs Notice of VloW:ion datecl Auaust 22. 1988. the company states: "ARCO Alas.kL Inc. denies the allqations ol the State ot Alaska. Depanment of EnvironmenQl Conservation r.tlac it unlawfully failed to c:lcan•up oil· ccnwniru~.ted. gn.vei and soil on a dike and impoundment on the nanh end of Drill Site 4 . .~RCO a.lso denies the a.llccsaon that it falsifted inlormad.on requind by 18 AAC." ARCO llso sr.:ued in the response: ... "ARCO requesu that A.OEC withdraw the Notice of Violacon d.attd July 22. 1988." The response .dto discusses in dem.il cleanup proc:cd.urcs t.hat had been employed and data on levels ot hyd:ocatbon conwninalion found in che adjacent d.i.ke and surround.ins a.ru (A.RCO t988d) • • According to ADEC. as of October, 1938, A.RCO has achieved c:onWr1ment of the spill to the sarisfaetion of die Ct'pan'ment. Cleanup ot the spill area is beinJ accompUshed in conjunction with e!oseout of the reserve pit on the drill site. (No phocos ot this site were taken.)

Site • 10 :\BCO's Crudt 011 Igppjn1 Unit

ARCO operues tbe cnade oil tcppin1 unit used tc make fuel tar the many veh.ic:les used on the Nonh Slope. 'The unic wu one of me first permanent installacions buUt on the North Slope durinl me iDlzill development of me Prudhoe Bay t!eld. The toppUll writ is a smaJl petrOilam refinery dlll breaks ouc the dlacl tnu::rion of c:rude oU. A=mlins to ARCO pe:scaael. jet f'uel also was made a cbe tcppinc unit in cbe past.

The site aeneraca various wau= snama includin1 wacer disr.illcd otf the crude oil. sulfur from H1S removed. from crude oil, vessel baaoms (rank bcmcms). heat exchan;er bundle s1uc11es (Jenerared when me plane pipes are flushed W'idl diesel), and solvCflts used. for eleaninJ the vessels and heat exc:hanprs. Acccrdtftl co ARCO personnel on site. che '"= T r' .;.)I "-· ; I vessel bottoms are removed, every 2 ye:tn. while the bundle sludps arc n!moved every few months. and. to date: are di5l'Osc:d at the .Pad 3 (acility.

Acc:ordina to the facility opm.ter i.nterVieweci durin& th= site visit. the bundle sludges have failed the EP·toxicity ccst far ~tuxxnium and the RCR.A. characa:rislies test for l&nitabiiicy. In information submitted to EPA by Standard subsequent to the EPA contr:1Ct0t visit. the statement is made

To ~te no cioc:umenced shipment of bundle sluases has been made to a RCRA ?ermined f:u:ility. Accordina to ARCO's most rr:ccnc RCRA biennial report. d.:ucc.t 1985. the hc~t exchan1er bundle slud&C$ were disposed ac Pad 3 injection wells. Standard and AR.CO stace t.ha1 disposal of toppins unit bundle sludp ceased aa Pac13 in Aucusc.. 1985

The topping unit may sene!"'Je wa.su::s idemical to wastes listed under RCRA has h:u:a.rdous when acnerared by peuoleum refineries. These wastes include K048 lhrou&h K05l: K048 is described. as "OAF' or diuolvecl air flccalion flcal: K049 is slop oil emulsions and solids; K0-'0 is heal cxch.anser bundle slucl.ps and clea.ni.ns wasta: and K051 is API sel'araccr sludp. ARCO does noc have an EPA aenmcor number for this r:scillty; however. A1lCO does have a.n EPA aenerator number for the nume:ous facilities in. ARCO's Prudboe Say Unic • Eascem Opcraaa1 Area.

Pad. 3 is used u the disposal tacilky tor mast wutes paerueci.u the teppiftl unit. Officials wi~ ADEC are iftvemplinl allepd.ons dw the flare pit behind rho toppinl unit has been used in the past to bum many of me wasta &enerated.ll this facilicy. Samplia& of this flare pic was to be pcrtormcc:l by ADEC 4minl tbe summer of 1988 10 mablish if wastes exh.ibitinl RCRA ha.z.udous characteristics have beeft disposed of lA chis pic. CW'!'ently, resulcs ftoom samptin1 this flare pil are unavailable. •

( ~ :". t-T ' I DRAFT I

AR.CO maintains a diesel fuel storage facility adjacent to che toppinl unit. tt was noted durinl the site visit that portions of the berm surrounc:iinJ the large storace tan.k. .1ppe:u'Cd to be sar:unted w-ith oil. (Refer to ~hotos 100·1 04.}

Sits • 11 A BCO Pqd t4

ARCO's Pad 14 is an oil and JU prcxiu.crian facility thac tnclu.des a manifold building (some rou.1h separ.u:ion oec:urs hen:), a resmre pit. a relief pic. and a pigzing pit. The relief pit, which is loc::ued on the fat edte of the pad adjacem to the tUndra. is made of unlined a;ravel berms. 'W'hen p.s pressure in facility vessels becomes too geu. the &as is vented co this relief pit. which is similar to a nare pit tn desitn and. cons~uon. As doeumented by photographs. oil sheens and spillaae were evident on the surface of this pit. It is not known whether the pit was u.sed. to dispose of other wastes.

Relief pits and t1.are pir.s on the Nann Slope are cenen.\ly unlined and c:on.s&:rUcu:d with gravel. Ac:c:orriin; to ADEC. relief pus commonly n:ceive liquid carryover from the ventina process. Further. no fonna.l samplilla or SW"Y'ey has ever been performed on the relief pits. Field enJitteers with AOEC have ~nally inspcecl most all ndief pits on the Sonh Stope. and. as observed at ARCO Pad 14, have seen oil slicks in many, oily rincs 31"0und the inside waJJ of relief pic berms, and evidence thac the J'lliet pia leak. Acccrding to A..OEC. none of these relief pits have liners.

The piiJinl pit at AR.CO Pad 14, which is locatld near dle main mucmre, is lined with an asphalt material. The piJJinl pit coileca sludps and dtbrts from pipeline cieanini operations. Wastes generaced by the pialinl prrx'C'dute are removed by vacuum nck and hauled to the Pad 3 oily waste disposal !acUity or hauled to the Oxbow La.nclfUl.

~I tO ARCO iD i.nfonna&ioa svbmiced tollowift11bc: EPA concrac:tor site visit (ARCO 1988): ""tho '"pia:inl pic" is an emeqcnc:y pic. which is lined with a Chevron Lnc:iuscrial MalnDe liner. The emerpnc:y pic ia use:l only to collect slud1es and debris from wa~~r iDjecUon pipeline operations. Lines do nac cany hydrocari:lons. cherefore no solvents are intreduced intO the pipeline prior to piainJ operadons ..... (See photos 128. 129, and 1~2.)

.,.' .. . .·· .... DRAFT SrrE DESCRIPTIONS • ST AN'DARD ALASKA PRODUCTION CO~IPANY

Site • t Scgndard's. Hazprdgu:t Wutc Stoaa Sftc

Srandatct o~tes a.l'laza:c1ous waste stcnp area on C Pad in the Western Oper:uina Area. The types of hu:udcus wastes saed at this facility include off· specification fuels and. solvents. waste corrosion inhibitors. unidentified wastes found in SS·ga.llon drums. a.nd laboratory wastes.

The site consists of a beiow-p-ade lr.J.'ICl pit \hat is SW'l'OIInded on three sides by jT.lVei berms. The SS·&allon drums an placed inside overpack drums as a method of secondary (:Ontainment. The ov~a.ck dzun:s are stacked. two (2) hip. on wooden supports. Accordin1 to Standard perscnnel interviewed durin aOle site visit. after an unspecified volume of wastes an: caUccted. a shipment will be made ro an appropriate • RCR.A Subdtle C TSO facility in the Lower 48 Swes. Accordina to AOEC. Standard has an EPA senerator number for their Norm Slope ope:adons. and has an interim status permit for container sroraae of R.CRA hazardous w:we 11 this site.

The bmneci area containina the SUftd dn&ms is unlined. Stotm water that collectS in the bermee area is injected down a C1as.s a disposal well. accctdinl ro Staadard l'ersoMel. Chemical analysis is noc performed on this storm water prior to injection.

Stand:arcl's waste lubricad.on oil srorap taDk is loc:aled adjacenl to che hazardous waste sunp ana. The tank is su:t'l'Cuaded by a ~ pawl berm for spill containment. The be:med ueaii'Oaltd cbe waa lube oil tank is Lined. Accardlnl tO informacion suba:Lirlld by Starldad followiriJ the EPA COfttl'ICU)t visit. i.nc:omin1 WISI8 oils an: chemically analyzed for parameter~ rcquind by me \did oil crillria iA 40 CFR Parr 266 (mews. flaslrpoint. a.ncl orpzlics). Analysis Is performed by Oemical and. Oeclogical L.abonccncs in Anchoraae. The wuce oil is shipped ro Chemtan. a waste oil recycler in Palmer. Alaska (Standarcll988). Accordinc co ADEC. the area uound dle waN oil tank

....I • DRAFT r:·-:: . ~- was uscci for a shon period oi time as a landfill !or inciner:uor ash. (Refer to photos 31 lnd l!.) s;c, .tt 2 Standard'S Sgnta Ec Pad prym Ctqgz and Cru3biDI Oocarign

A drum clc:mina and crushina buildJ.na is loc=d ac Standard's Santa Fe Pad. Scancl.atd's oil field operations pnxiuce larp quantities of empty drums mac are sent to this f3cility for clcani.nc and c:rushi.ns. Drums may contain residues of biocides. pesticides. corrosion inhibitOrs. a variety of solventS. emulsion breaken. reverse emulsion breakers. glycol. alcohols, "ylenes. c.Uesel. and various omcr oil tlcld chemicab. along with dead ~.:rude and c.Ucsel coUecteci from well remms. Employees worldna in this facility wen: level C respiratOrs and prorec:ive clothina.

Drums are brouaht to the facility by auck. The condition of the drums varies: some are in good condition. while others an: damaged. c:omxied. or rusted. tt & drum contains a si=ble quantity of Uquids. its contentS are removed by vacuum cruck. Sollds in the bottom of the drums are removed by hand. Drums are r.hen rinsed in a drum rinsina machine. which sprays jetS of warm water inco the dnmt. The rinsa1e is tlushed into a .SOO.gallon collection tank inside the buildina. The rinsed dnlms are then cn:ashed by an on-site drum crusher. All solids generated d.urinl chis process. includina the cnsshed drums. are sene to the Oxbow land.flll. SPA believes rhac cleanin1 of dnlms prior U) disposal as described :J.bove is a desirable wute manacemenc practice.

Accordinl to Standard (Standard 1988): "All rtnsae cclleaed tram me Santa Fe Warehouse is sent to SAPCs Oa&hcrin1 Cenwrl, whera che ma&eria1 is recycled through the precessing system. recaverin1 oil to the cnule stream. Ally water residuals n:W.ncd in the wastewater system are ccmmin&led with produced water tor u.nde:plund injection.''

Ac m. riml of dse sial visic. no secondary c:ontaillment wu provided ror the area where £n«minl druma are sund. anci &be pwel area mn:wi the facility buildinl showed evidence of oily stains. (Refer to phcxos 33-38.)

Cumndy. Standard ud ACEC do noc apoee on whac Federal environmental rcsul.acions apply to this faCI!ty. As ADECpoina ouc in a memo dau:d October 13. 1988 (ADEC t988b): "40 CFR l61.7(a) (1) (R.CRA] provides thll aay hazan:lous wastes I :.... .· ~ ·-: ;· DRAFT rema.ining in cmpcy containers or empty conrainc:r inner Uncn. u cle(1ftcd by 261. 7Cb). \s not subject to the regulation under Pans 261·265. 268. 270. or 124 of 40 CFR. or Section 3010 of R.CRA. However. when these residues are removed. from empry c:onwners. such :1s occurs when d.rums are washed out. a new waste is generated.. which il subject to R.CRA (Subtirie C1 regulation as a. charac:criscic: haza:r:tous waste. This provision LS discussed in the August 18. 1982 Federal Rcrister on pace 36096 .....

ln i.nfom:'luion submitted to EPA subsequent to the EPA conttaetcr site visit Stand.vd. States that

Site it 3 ~tandard's Gathtrinl Center .!

ARCO and Standazd operaze larp c:oUection and separation facilities on me Nonh Slope to separate the oil/warer/ps from eJ1 fluid pnxiucec:l in the Prudhoe Say fielci.lO After separation, much of the wacer and natural JU is n:injeclld uno the produc:in1 formanon. while the oil is sene to the Aleyska Pipeline. All of the flow stations and gathcrinc centers combined process approximately two million blft'Cls of oU per day, 3long l S&aadlft il canwc iD lll&iDI f.bl& anty mid• &am V ar "P'" l1ltlld WUIII ua replar.td u bwrdcua. HQWe\'Cr, all.. JII*IUII by rillliq c!nalu eomailinl JAY commetcial chemical prodUct. is subject ID rep1lr:iaa .... Rc::RA SublideC ua ~ "-'dDuu wua. furdllr. ptOduc:liCa chemica's are escmpc ~ ...... uada" RCR..A Subcidl Conly~- lbly have e....Sibl 011 and aas ptOducuaa praca~.a- .-. u....a. di.ardad Pft)daan cnemicall• ni'Wet~Matpc trom ~ unG~:t RCR.A S&&bcidl C wbca pslallf.lld by •Y 11C11Ct of od aid ps up1cnliol. dl~ n pteducUan. [ft addillCft, WillitS l'ftG1IId by such CUViUU U eq&u\'lllllftl ftWIIflniiiCe., Pliftlinf, Jlld plllieidl SflniC c.:woc:.taled 'MUD Nonft Slope Oil and PI procSucaon 1n 1101 UllftPl from rqalatiOft under ROtA S~&bade

10 ARCO n=!ers r.a dlcsa !zilicia u ·now scaaons. • and Staad.lrd retcn r.a t.bem u ·pllba'inJ CCftCcrs.:' DRAFT with equally large volwnc:s of produced water and natunl gas. The facility tou~ haci ~ very dean and orderly appeu:u~c:e.

These t"acillcics senerate a variety o! wastes. Precipitates add sludges from collection anci separation vessels are removed periodically .11 Cczrosion inhibitors and bioc:ides are added to these vessels periodically to prevent corrosion from HzS and sulfate· recucina bacteria. As s&ace.d by a Scandard employee operating Gawnnc Center 3. thousands of barrels of collection and SCl'aration vessel pn!clpitates are ~moved annually.

As the Prudhoe Bay field srows okier, it is anticipated that more solids w1U be inherently present in the production SU"eam. This will increase the frequency of vessel cle~ouu and thus produce mon: and more precipitate waste. The precipitate wastes are disposed of ;u the P:u1 3 facility. Accordinatc Standard persoMel openrinc Qatheri:tc Center 3 at the time of the site visit. chc:mic:U analysis is occasionally performed on collection 3nd separaaon vessel prec:ipiwes. a."ld the metals commonly found include le3C1 lnd chromium.

Olyccl is used in larp quanticies to hCft che oil emulsions clurinl the separation process. The glycol is continually filterwd usinl sock filters or charcoal filters. which are sene to the Nonh Slope Borouah inc:inemor fty disposal. (Charcoal fUle:S are used to remove chlorinated hydracarbon contaminana from the 1lycol. ne Jlyeol itself is usually regenerated by strippin& me water out thtou1h a heac process. The resultinc water is relea.seci to the atmosphere u steam.)

"Dirty water" W1ks are present ac these facilities. These tanks indirectly receive flow-back from weU stimulacion. workovers, and completion operaaons chroup the train separaron. SWldara's Oatherin1 Center 1 receives &he rinw.e ~tnenced at the Santa Fe Pad drum cleanina t'acilliY. Bodl solids and liquicb are =overed in chese tanks. The liquid pardaa ot this wuze is disposed of thrcaah injection wells loculd on site. while the solids arw cHsposeci of u the Pad 3 oily waste pit.

Each scpanzion facility has 1arp mc:ve pies or emerpnc:y pits. Accordinl tO the opcmor interviewed durinl the site visit a Ollherin1 Center 3, the pits are for containment DRAFT of spillage trom rtte suppre$S'arlt systems. The medium in these systems is usually wa[e:. water med with fi.nt·reta.rda.nt chemic::Us. or propriewy chemicals. At Oathenns Center 3. the separ.uicn f:Jeillty toured. thae re$C%'Ve ?its conain reci-colcnd aJpe tha& are str'.king in appearance. (Most alaae in the North Slope is not reel in color.) Slte pmonnel d.o not lcnow the cause of this alpe pawth. Acc:ominl to int'annation submitti!Ci by Standard. subsequent to the EPA conaac:or visit (Scandard 1988), these pita are used. to provide containment of a larae spill of audc oil re!easi!d in the event of a.n aecident in the gathering e:1c:ility. (So phctos of chis site are available i:2ec:wse camm.s are not allowed inside these iathering (acUities. l

Sjtc 11 4 Stgpdard'$ Bau Ogcpatign3 Camp Scwlll Tmrmcut Plggt

Sta.ncia.rd hu one or two NPDES permitS in the Prudhoe Say oil produc::ion area for disc:h:trJe of c-e:.ted sewaJe. Sewaae iTem the Base Operations Camp is treaEed at the sewage treatment plant ;and treated emuenc is discharaeci direc:ly to a nearby tundr3 lake. The crc::acment facili:y h3.S the follawina primary and secondary treatment c:apabillcies: · primary sc:recninJ. tricklina filters. extended aeration. c:taritlc:ation, c:hlorinacion. sludge . ' ~onditionina. sludge thickcnina. and inc:ina:nuion. Emuenc discnaracd from this facility must meet secondary stand:l.rds. Accotdina 10 SWldard. a lab at the facility monitors the plant effluent daily. Solids ate incineraceci on site. (lleter to photos 39-40.)

Si(c f ! Stpndard'! Y Ppd Drill Site .

Standard's Y pad is a rypiw drill site mme Prudhoe Bay tleld. in that prcduc:ion and injection wells are amnpclaround a resiii"YY pic. which is uaed to contain muds and cutunp from development d:rillln1 ora the pld. Production and injection piping cross the reserve pis ilia number of places. 1be reserve pic is conmucred above arac;1e. and during the site vi.ric.u documenrcd by photosraphJ. the pic appoand to have Uule (lea than six inches) fzeebalrd. Much at me COftcena observed du:inl the sill: Yisic consisted ot snow melt that would evenNa.Uy be n:moved by dewuerin1 over the 1988 summer susora.

At tht time of the site Yi.sic. development drilllna wa under way and wacer-based mud and c:uam1s were beinl discharpd tO the reserve piL Other unidentified wastes had ~lso been placed in the reserve piL Some of these substances appeared to have an oily

-•• I DRAFT

composition. while others appeared to contain a thic:k. beige substance swirled. in oil. Al the time of the site visit. it was hypothesized that the oily substance observec:i coulcl b~ worxover or ~mpletion t1u,id.. According to information su,bmittee by Sca.nciw subsequent to the EPA contractor visit (Scandarci 1988): ".•. the substance seen was from oil·basca muds which haa been previously deposited eluting development drilling and not from a workover or a completion or stimulation. At the time of the (EPA concnctor} visit. water· based muds wen: being dischatlcci to the pit from the ril on the weil pad. It is i.mpon:a.nt to note tha& SAPC recently decided nDl to discharge any more oil-based muds to reserve piu. even thouah this pra.c:tice is allowccL''

Under the new drilllna waste regulations recently promulptcd by the Srate of Alaska. reserve pit disposal of drilling waste c:m include such wastes as oil·based d.rillinl muds. woricover flu,ids. acids. hydtocarbons. a.nc:i brine. usumin1 thac the reserve pit is fully linect.l2 In pe:mit applicaaons Cor disl)Qsa.l of c1rillinl wasces in reserve pits. the 1pplican.t must. list by type :mel by volume all wastes to be d.isposod. Accorttin1 co A.CEC. Standard has never mentioned the ctis'posal of oil·bued muds or workaver fluids or othc: wastes in any of their permit applications. and because of Ute absence a{ a request tO d.ispose of oil-buecl d.riWna muc:is or other o~ wastes iD Sta.ndani's pennit applications. A.DECs review ot Standard's n:serve pit permit applications has not included inquiries c:oncc:mins workover fluic:is or Other wures C*"P' wacer·based zaucls and cun:i.ngs. Ac:eon:lins r.a ADEC. all pmnia issued to c.We limit reserve pit disposa1 of drillin1 wastes to wat;r-based muds and cuu:inas only. For example. in Appendix A of AOEC Permit 8736-BA008. Sec-cion U. parapph D it is stipulated ttw the permicce will "Limit disposal to the pit ro watet·based. drillina muds and c:uainp."

Accon:linl co wetland permits issued to Sra.ndard. and ARCO by the Army Corps of EnJinnn for con.muc:iCft ol reserve pits in azctic: wed.Mds under Section 404 of the Clan Water Act (U.S. Army Corps of Enpneers 1986): ".. .re.ve piu shall be mu:len=cl impem:sabl& !Wmat.n:ttt alone is not a suftk:ient bmier. Hydmcatbons clischatBed into relief pits. flare pies. a~~ pia shall be removed and property dispasec1 of u soon u practicable durin I the wmt.er but be!ore sprina brakup and within 72 hours of discovery

ll Accarditll fD ACEC. the new drillinl wut1 tepWioa rec.nr.ty pn:xaulpred by r.he Sill& of AWka require Uta& rarve pill bllinat wftln IIIey n cCIIIIN:UICL '1'bd is vflt'J diffennc tmm Ute old re.,u.ians llW bad no requiremenu Car tf.ncn. DRAFT durin& periccis of thaw." As scared by A.CEC. placement o! any hydrocarbons. such as oii· based d.riUinl muds a.nc c:uuin1s in reserve pi1s c:onflic:s with the Army Corps oi Enginem' requirement th:~ot they be removed. wichin 72 hours ol disCQve:y durinc periods of thaw.

In a related case. on July ll. 1988. StaMarcl n:ceived a Notice of Violation from ADEC for a pemtit violation involving the ~sal of oil ba.secl drilling wastes in a reserve pit at w Pad. Acccniin1 to the leuer !rom ADEC tO Slandan:l accompanyinc the Notice of Violation (AOEC 1988c; ADEC 1988d): "The incident involvec:l the disposal of oil based drillins wastes in the south reserve pit ar W ~ Pennie Conditions A.Il.O and A.Il.E of Solid Waste Disposa.l Permit 8736--BA007 spccit1ca.lly prohibit such disposal. In addition o. field visit reve:Lled that a co;~y of the permit "'U noc available at the faciliry as required by Condition a.rv. and that the samplin1 desians (or the ··r.oc·· samplers hac:i not been ~ubrnircect as required by Conc:lir:ion A.II.H." Acccrdinc u:> A.OEC. the s~ers1e o! oil based muds in the W Pad reserve pic resultecl in a release of oily marerial to the Nndn.

The AOEC letter coes on co say: "SAPC hu proposed a:. overall dri.Uina waste m:u1agemenc plan Cda=:l March 18, 1988} wtucb reiies heavUy on fluid manapmenr as a mAin bamer to contaminant micraaon. Althoulf\ the reserve pit ac W Pad is lined tea larJe extent. none of the reserve pitS presented in SAPC's plan are cctally lined. Violations of the type occurring durin I July 10..14 are of panic:ular conccn when unlined pies are \.nvolveci. It is requested that SAPC reevaluate dteir d.rillinl waste manaccment plan and consider tecallininl of all active reserve pia." In iu reply to the Notice of Violation issued f'or W Pad dared July 1.5. 1988. Srandaftt states that the oily wute deposited in the reserve pit was removec:l and disl)Osecl at the Oxbow oily wasza pit (Sr.andan:l 1988c).

Ac:cc:ardinl tO i.nton:aacioa submim:cl by SCindard to EPA followinl the EPA. cont:raetel' visir (Samc:i:&ftl1988): "SAPC (Sr.andard) suspended ctischlflinl oil-based muds to re.vc pies padinl me results of the extensive monitolinl prolfllll SAPC is conduetifti1D ensure ma the pies are providiJII proper conWIIment." Swulaftt aocs on to srate th.u "SAPC no lonpr uses reserve piu tor disposal of oily workover wastes. which 3R now either disposed of i.n Clasa 11 tnjeclioa wells Cl' n recycled throup the production process.'' Accordinl to A.CEC. dischar1es of any workover waste ot oU·baseci drillinl fluid has been and is c:UZTendy a violarioft of all past and ~nt reserve pit pet'l'l2its issued by ADEC to Standard. Ac:cordinl co ADEC. ic lacks adequate information Oft

...., DRAFT

ch~on ana velum: of workover fluids a~nerated a.s Standard has never included a request to dispose of worlcover wastes in a reserve pit pennit appiic:u:icn.

Ac the time of the site \'isit. breakup was under: way anti subswuial quantities o£ snow had not yet melted in the reserve pit ac Standard's Y Pad. Accordinl to indusrry and A.DEC personnel. snow is :ourinely removed from the swface of tbe pads at breakup e=h year and.. in nwsy insta.n~ is det'Osiccd en ad.jacen' a.md.ra. Since crude oil spills and chemical spills are common durin I the -Mntcr monEhs, the pocen'Eial existS for spilled malCria.l. to remain in the snow rhaz acc:umulares on the pads an4 thereby be r.r:wfcr:red to the tundra. However. ADEC requestS thac me operators only remove snow down to the la.st Coot and the Stare desisnatas specific snow disposal areas adjacent to the drtll sites.

Sjtc ii 6 Standard'! [ast Qos:k Plt!

The East Cock faa:ility is lor:ated on the eascem shoreiine of Prudhoe Bay :spproximately 3 miles southwest of Heald Point and l miles west of the westernmost channel of the Sapva.nirittok (Sal) River. Th; three-celled me'1"Ye pit was c:onsc:ructecl in 1980 and was used for disposal of muds and ~rd.np from olf·shori drillinl activities during the 1981 and 1982 exploration drillin1 seasons. Two of the cells received mud and cuu:i.ngs. while the thin1 cell received ftafecl S31'1iwy wasces flom tbe East Dock camp.

Consc:ruction pennim issued for the raerve pim in Novea:2kr 1980 stipula&ed dw Standarcl would clcsip and conduor a monicorinl prosram ro tut the impem:le&bility of the sump design over a five year perioct. Two preliminary rcpons of result.s were submine.d in L984 ancll98~. and a f1nal n:pon was submitted in. 1986. Acccm:tina ro SW'ldard. the n:~n coneluded tha& no adverse envi:onmencal ~ to d\e s\ln'OUtld.ina area VtU observed.

On Ildy rJ. 1984. SWidard. wroce a leu. co ADEC ro inform the Oe9anznent of the rceen.t dike le&kap iDddal a& the Eas' Dock :esc:ve pit (Sohio 1984). The leaer states chat ''On July 2.3, 1984 Sobio (SW'Idardl personael discovond sipiftant leakap of me reserve pit dike in cell No. 2. .• " The leuer also discusses Stand.arO's p.lafts far cotret::on of the problem.

------·-··· I DRAFT

.'-DEC replied to this incident wtth a. let~er to Standard datiCi AufUSt 2!. l984 cA.DEC t984a). The ADEC lem:r states that: .. Lewp of the d.ike and review of de-pan::nent records has raised several concerns by the cieparanenc." The letter ioes on to sr.:ue: ''The authori=tion (to usc the E:st Docie area as a mud sump) was limited to a three y=r period. Curing that three year period Soma wu to develop a plan for the ulr.imace disposal of off-shore gener.ue.cl d.rillinl mucb and cuttings. The plan has not been received by the Depanmenc." The AOEC leaer also suzes: ''The dikes [uoW1d the reserve pits] were to be im~ble. Yout recent norific:u:ion of leakaae inc:ticaces failure to comply with the pennit condir.ion requiring an impermeable c:Wce. ·•

The ADEC tetter aces on to swc: ''The Oeparuneru of Army permit [Army Carps of Engineers] required Sohio co desilfl and conduct a mon.itorinl proanzn to test the tmperme3billry of the mud sump design. Annual n:pons of the monitorina procram were :o be submitted to the Oiscict Enlin= and made available tor t'!"'iew by Fedc:ra1 a.nd State J.gencies. The dep:uunent is noc aware of any ongoins monitorina proa:ram conducted by Soh1o. To dace the depan:menc has noc received the ''annual repcms·· of the monicorins program. Sy way of this leti~r the Oepan:menc is requmna the ftna1 closure of Sohio's East Dock Reserve Pit f:1eillry. Please subrni1 finuclosu:e pla&U."

According to informacion submiued. by Standard ro EPA Collowinl the EPA concractor site visit. a final approval to proc:eal with the close--out of the Eut Cock pits was :-eceived from ADEC oft Aucust 7, 1987 (Srandard 1988). Oravcl was placed in the two mud-conwnina sumps in lare Aucust of 1987, and samplina monitorS and thermistors were installed. Accordinl co Standard. thcm1istot measurement~ ancl wuer quality samples were taken durin I the summen of 1987 and 1988. Standani saas: "A report of the results from the 1987 s:uraplin1 will be submiued 10 A.CEC prior tO October 1. 1988." However. ADEC i.nton:DI:d. E.P A thac as of Oc:tober 14, this repGil had ncn been submiacd.

Ao::old.iDI t0 St&Ddard. me East Ooci: pit c:loSUN is a tal for proposed closure and reveaetatiaa lldmiques evenmally to be used for me Nonb Slope ftelds. ADEC norcs that. generally I'IYeptadon has aoc been lried on a laqe scale. and a andlrd. practical method. of doing sa has noc been developed. Tbe methods and cccbnoloiY for larp·scale reveaetar.ion is unproven. WhUe the cJosed site of che Ease Cock Pbs has ftOl been revepmted. ac the 1i~ of the EPA con.G"KUX' sice visit. che pit closure acuvi1ies had 1m the area with a r.idy appearance. (No phocas were abn of this sire.)

.c .• I

sue • 1 Standard'' G Pad.

Standard's 0 Pad ism oil and gas prcducuon facility thac has one main structure. where oil and i:l.S ~e separated.. ancl a. tqe urlined. reserve pit. At the time of the site visit. :u1 extensive 011 sheen wu observed on the surface of the reserve pit. Accon:iing to ADEC. this pit ovm1owed on Au ;usa: 4, 1987 and discharJed 50 cubic yards of d.ri.llinl muds and cuttincs to the cundra. Ac the ume of the site visit. the pit appeared to have been leaking a.s evic1c:nccd. by dead. tundra adjacent tO the pit. The area that appeand tO have experienced seepage of contaminants :u the time of the site visit was noc the same ma impacted. by the re!ease of drillins waste in August of 1987.

Drillin& muci.l and c:uuings. wuer and drilling fluid$. a.nci other aebris are stem :r.side the reserve ptt. rn the spnns oi 1988, Standa:d. removed 8.500 cubic yarcis of dri.lling muds and curcings f'Tom the a pad reSI:I'\'e pic and disposed of this material at the Oxbow landfill. Fluids in the reserve pit were disposed of via aMular injection.

Subsequenc to the EPA concractor site visit. Standard subtaiueclldditional information c:oncemins me 1987 spill CSW1darc:ll988): "On Aupc 4, 1987, SA.PC reponed a spill of approxiuwcly 50 cubic yards of d.rillinl fluids which overtopped the n:servc pic walls at a Pad. The area wu sancibageci and a p1atic liner placed on me tundra to pn:vent further spreaclin1 duri.nl cleanup. The area wu flushed with wuer which wa.s pumped back to tbe reserve pic and later disposed of by annular injection. Water samples were taken co ensure thu nearby tundra ponds were not &ft'ecu:d.. and. restoration i.l.nd dormant reseedin1 occumci Ln 1988. The area will be moniund in 1989 to ensure regrowth of tw'l.dta II'&QCS. and add.laonat n:storaeioa measures will be undenaken ii necessary. Durin I me sum"* of 1988, liners WC'II insulled in pans of the Ci Pad reserve pit walls wbc:re leakap wu ~ ..

Al)IC scues tha£. to date. it has not ha.c1 the manpower to monitcr and roUow up on this sile. mus sicc is documlftted in photOS 144-148). DRAFT

Site # a Standard I PJd.

Standard's J Pad. is similar in desisn and operation co Sr.ancia.n:i's Ci Pad. On Auaust '· 1987. SwvJara reccivec:t a Notice of Violation i"'m A.CEC !or disposal oi oily wasu:s in the reserve pit. :md seepaae ot oily wa.stes frcm the reserve pit onto the nearby tundra. According to the letter a=cmpanying the Notice cf Violation

'Tnn:e different reserve pies in SAPC's Pn:dhoe Bay Westem Ope:atins A.r= have been useci in n=nt months for the diSl'Osal of oily wu"s: includini1·Pad. Ci·Pad. anci mosc recently N·Pad. Oe-posiced oily wuus hu often oriprwecl trom spills at loc:uions ocher than the pad. where the materials have been disposed.. In addition to the cxpec::eci c:"UCie otl. :r.acerials or material matrices deposited in these pits have included diesels. hycir:.ul.ic: r1u.ids. liiht condcnsata, lube oil. and alycols. The at'Cidled Notice of Violation rel~tes to ac:iviaes which have ex~ at J·P:a:i only, primarily because J·Pad ha.s been an ongoina problem and lewse &om the nonh pit has been docwnen'Cid. Multiple depan:menc in~pcc:tions of the J·Pacl tese\'e pic since lnakup have revc:aled the continuous presence of hwu:treds of gallons of poolld crude and Upcer 'roils) and pn:xiua within the pit. Sevc::al complaincs tram other swe. federal. and Nom Slope Borouah inspectors have also been rqisund wich the ~.. In sphe of ics idend..ftc:alioft of ihese alleJed violations. however. ADEC swes th.ac ic la.:ked rhe necessary enfarc:cmenc staff during the 1988 summer season to monicor ami follow up on che oUy wute d1sposa1 incident at N Pad.

ADEC's letter Joel on co sea~~: '1c is recoplizcd that dischatp of some crude oil into a reserve pit is a natunl OUICOml of drilUnJlnto producinl £omw:ions; however. these liquids muse be raDOYed. in a tialy manner so u co prevenc tbeir leachinl from che piL These an tbl oa.ly h)'drocarbofts thai may be aJ1owed to be discharpllnro a ~serve piL"

lbc liar a1so assens tba& ia tba spina of 1987 SCII'ld.anl hid aped tD develop an approprial:a ahemative tO deposil:inl oily wasta in raerve pitS: ".•• it wu aped that SAPC wou.ld be allowed a sr=e pefta:l iD order to drlelop a more appropri.aEe &lcemaave to deposilinJ oily wuce in I'ISII"W pies. ln the interim. ic wu &pad dw conwmnacect marcriaJs noc dJtec:Uy re1acecl tD drillln1 would no Ianser be placed in the pirs. and chat a caressive tluicl manapment would be ~ ln Older to prevet escape of DRAFT

cont:Uninanu. As of July 2l."l987 both hydro:arbons ana water were still present in the pit. agi"lvaans the lcwse throu&h the pit wall."

The Notice of Violation states thac Standard must provide AOEC with a c:cncepNai plan for long-term ciisposal of oily wastes. cthc:t than in a cravel diked reserve pit. The plan was to include a proposed timellne far complerins the Storale facili~ and plans for · interim disposal of oily wastes while a permanent facility wu beinl desianed and constrJc:ted. Sta.nclard responded ro the Nocic:e of Vtolaaon by letter. statinl (Scandatd 1987): "SAPC will develop a tlnal plan for the canminmcnt and disposal of oil wasces by September 30. 1987 and consC'Uct these facilities in 1988. Concepcually, this plan will be a cont3irunent f:LCillty desianea to ensure adequa11 conWnment of 111y liquids and facilities to inject resic1ual1iquids. Curing the interim pericd until these facilides are desipted and conscruc:teci. aU non· liquid oil spill cleanup rrwmial will be placed in Q and/or 1 Pad f1aR pits. G and/or 1 Pad flare piu will be lined wich an impermeable liner prior tO use and will be used W\til the permanent facilitY is complete." ADEC swes that it has neve: issued a letter or other document dw approved of the placement of spill maccrial or oily wuce in a flare pit. Instead of constructitll an oily waste disposal facility as discussed in Standard's leuer. Standard continues to dispose of oily wure ac the Prudhoe Bay Unic Pad 3 Oily Waste Illjection Faciliry.

At the time of the sire visir. the spillap twl been n:movcd, alchoulh there wen: signs of some stained tundra outside the repain=d reserve piL Aa:ordiDI to infomw:ion submitted to EPA by SWidani followa the EPA ccmiDCtDf site visit (Scandard 1988): "On July 24. 1987. SAPC reponed a 5lril1 of 40 co '0 pllons of crude oil anci diesel from a leak in the nonh wall of the nonhast reserve pic 11 J Pad. and on July 26. SAPC reponed a spill of ~ co 10 p.Uons of diaellc:nxle £rem me cWae wall of dte west pic. Both spills were cleaned up, llld impawble embankment linm have been insW1ed." (This sile is documentld ill photos 122 and 123).

SJtc ! 9 Standard's EncQqtt PmdyctiQil FacUlty

Endicott is 111 oil aDd ps drillift1 and pn:xtuCiioA facillcy built on a pel causeway thu extends approximawly 5 miles from shore ift10 me An:tic Ocan. Acconiinl to a previously mcncioncd ADEC reJ'C)ft on pncacioa and c11S1'0Sil of liquid wastes (AOEC

,__ " ------·---·~------~- t988v): "Oreau:r than ~ driiUng operations h:1ve occurred in the nearshore areas of the Se3ufon Sea. the SAPC (SWtdartil Endicoa project is the only prcduction f~iliey to date .1nd when completed will have :lpproximately 120 producing weUa. As with onshote facilities. offshore drilling produces large quantities of liquid and solid wastes. Where wastes meet E?A discharge cnteria. offshore Cisposa.l is permitted via an EPA NPCES pe:mlc. Discharged wastes include: wat=" based muds. cuttings. completion fluids. workover fluids. drill rig washwater. sewage treatment plant effluent. desalination plant effluent and fire c:ona-ol system teSt water. The Endicott project discharged 3.~.000 iallons of muds anci cuttin1s during 1987."

At the :me of the siu: visit. clrilling wu bcinl performed on a section of the Endicott facility. Drilling muds. cuaings. and fluids arc disc:hqed directly intO the Arctic Oce:J.n via the permitted. SPDES outfall. The ~~ is a feeding zraund for arctic aquatic life in the summer.

The Enciic:oa pvei mine is located onshore near the Endicon fadlicy. Millions of cubic: yards of p-avel have been removed trom this site. Accordin1 tO Carl Hemming wim the Alaska Department of Fish anc1 Oame. the ~c for the Endicon mine me includes some specific: requirements for ~habilitation. The requiremcna swe that cvencually. overburden recovered tram the site is to be placed on one or two sides of the pic. allowing for the berms on the opposite sides to be pus!:ed back down when the pit is no lon1er used as :1 source of gravel. It is hoped that evenawly Ulis will allow for reclamation of the site as a freshwater fish habitat. At the time ol me sUe visic. the pic was still bcinl used as a source of sravel. ('The Endic:cu faciliry and pveJ mine are documented in photos 130 and 13~·142.) DRAFT

SITE DESCRIPTIONS • SORTH SLOPE BOROUGH FACILITIES

Sjtc • 1 Osbgw LandOII

The O,;bow landflll. operued by the North Slope Borou&b. is the primary offsite disposal sire for municipal solid waste, incinarar ash and induscrial waste that is noc recycled or injected on me Nonh Slope. The ~aftdtUJ. is locaced all a portion of an ~bancianed sravel mine site. The lancifill has two wsiinecl pits. one very larac unlined pit for industrial waste md domestic 1arba1e (the oripnal pvcl mine site) and one smaller :mlined pit designated Cor oily waste.

The oily waste pit was apenee in May of 1980 and the pamit for the pit was re~ssued by ADEC on March 3. 1987 (Pemtit No. 8636-BAOl3). The oily waste pit was designed to receive law of 10.000 cubic yards o! waste mnually. As of Sepcembe: 1988. the oily waste pit had receivect Ul2,490 cubic yardl of wure since January 1. 1988. A i3tJe portion of this w~ 7~000 cubic yards. consisred of clrilUna waste that was brcu1ht to the oily waste pit over a six week pericd in May and June of 1988. After the past year of operation. the oily waste pit is nearin1 capacity. Accordin1 to a let~ from the ~orth Slope Borough (Nonh Slope Borausb 1988) to ADEC dated Oc:cber 10. l988. the following quantities of materials were delivered to rhc O,;bow landfill durin&l988: Month Mem1 Solid Oily Wum To111 ...... ______.... ______Jan. 88 1.388 1,490 2,818 feb. 88 1.6.56 825 2.481 Mar. 81 %.'70 754 3,324 Apr. 81 l.l03 8,672 10,875 May88 2,140 69,,99 71,739 ]UD. 88 1• .589 844 l,433 Jul. 88 6.061 5,781 11.848 Au1. 88 4,444 6,374 10.818 Sep. 88 3,606 8,151 11,757 ···-·-·-·--·-...... ______......

$6 DRAFT

TOTAL 2~.663 102.490

As mentioned. the oily waste pit is conmucted (rom &n.vel ancl is not provided wi.th ~liner. ThermistorS are placed around d'le perimeter of the pit to monitar tempcra.EURs. No information is available on the frequency or results of rc=din1s from the therm.istars. Permafrost serves as the only oamer to prevent miarauon of waste materials from the piL ~o other techniques are employed to mcnircr rar possible wute miaraaon. A sump. which is a low lyinl area within the oily waste pic. has been created to coUec:t f1'ee oil anci storm water contained in the waste pit. Based on available inlamwion, it is not possible to determine how the oily scormwacer from the oily waste ph is cummdy disposed.

ADEC has not esr.abllsheci formal criteria for stonn water management ac the t~dful; however. ADEC ha.s issued. senera.l permits in me past for <.lisc:harae to the tuncira of stormwacer !rom the landfill. Throush rundra flow this dischatJe has enter=:! the Put River. which is directly adj~ent ta the land.fill Accordina to the last reparc on the · dewaterin1 of me Oxbow lanciflU. in 198-' supcmaant from the oily waste pit and !rom the solid waste pit was pumped onto the tundra under permit from AOEC (North Slope Borough 198.5). According to the rcpon: ..... app:oxinwely 9-10 million aallons were pumped from the oily waste pit between May 30, a.ru1 June 29, 198-'." As required by permit. the effluent was sampled for tOtal benzene. tOluene. ethylbcnzene, pan-xylene. mcta·x:..tene. and onh~>"ylcne; oU and paso: chemial oxypn demand: manpnese. settlellble solids; and ctissc1ved oxypn. Quandacs of total bcnzaes. coluenes.. and xylenes detected in the effluent ranpd from 0.004 ppm to 0.360 ppm; quancilic:s of oil ana srcase detected in me effluem ranpcl fi'om 1.4 mWJ ~ 10.1 ml/1; chcmic:al oxygen dcmaacl in the effluent ranpci from 10-' D1fll co 219 mfll; quanD.ucs cf manpnao in the eftluenc ran sed. 0.16 mr/1 co0.44 mall: a crace of serdable solids were demctec!: and dissolved oxygen in the effluent ranpd from 1.6 mill to 13 ..% mfll. Accardin 1 to the clewuerin&l'el'O"· · between July 27, ana Aupst 17, 198S, approximately 13.7 million pllons of supemaranc were discnaraed from the solid wasu= pit under permit from AOEC. Arsenic lCYels in the effluent ran1ed from .CI.1'/ mlfl to .032 mr/1; barium 1CYels ranpd from.Ol mlfl to .3 mWt: cadmium levels ranaed from .005 mfllra .009 mill; lead leYels ranaecl from .015 mill to .084 ml(l: and oil and areue levels ranaccl from 1.1 mr/110 S.4 mill.

c­.,; DRAFT

Accordini to the dewatering t"C'PPrt: "Pumping of the solid waste pit for the most pan was very routine. On several occasions the screens on the sucdon hoses became pluiied with tloaana material and dec:ru.sed pump efficiency. The diael pump was lose for sever.r.l d.:Lys due to a breakdown. On Ausun 14 oil containment booms were placed 3round the suction hoses and oil absorbant pads were laid on the water surface co remove rhe oil sheen.'' The oily waste pit was dewacered apin between September 9. and Oc:ober .;., 198,. As stated by the repon: ''TocaJ. estimal:ld volume dischatpd liom Scpa:mber 9 tlu'ou&h October 4 is 9 to 10 million pllons." Prior tD the second. cUschqe from the oily waste pit. a water sample was taken from the pit which i.ndiQ.ted the presence of the following constituentS: 2:-' mill chemical oxypt'l ~ 7.3 m&tt oil and &r~ase; 0.031 mill arsenic: 1.0 m!/1 barium: 0.0015 mfll cadmium: and 15 ppb to 164 ppb toW volatile OI'Ja.nic compounds.

This dischqe co the tunclra flam the l&Dd.fU1 has net occurtBd !or two yean. In 1988. the landt'lll operuon inir.iated an agressive snow removal program co remove as much snow as possible ffom the pic before ic melEed durin I bre:&kul'. As a msult of this snow removal program. latp mouncl.s ol snow cocuaininl sravel. debris. ancl pocential · conra.rninancs from the pic were depolir.ed i.n a ciaianaccd area on the tundra. Durin I the site v;sic. the AOEC indica&ed. thac it is likely d'lll Jr&Vel conaairlect m die snow removal material would bury and kill the cundra. A sump located inside the solicl waste pic was CTC3.ted several yean &JO to collect snow melt. The operators are i.D me precess of c;losing this sump by freezing the warer in place.

Accordinl to AOEC. WISI8 pner:uars da aoc provide the 1andftl1 operators with a chemical analysis of oily waste prier t.o disposal iA dse oily waste pil. and addicionally, no chemical analysis of the wute 11 performeci ~ the la.nd8JJ operaa:cn bet'ore or altar acccpcl.na me Will& Ic shoakl be noted that me Oxbow landfiJ1 is ctac only oily wutc disposal site oa cbe Nonh Slo9e dw is available ta the service companies. and as previously m=t:ianed. waaces pnerared by service compuies 1re ncx aempc fnxtl federal reJUW:ion under RCR.A Secdan 3001. a.nd. arc dlerefore. sub,ie= ta tu.11 zquladon UDder RCR.A Subtiuc C. Based on cum:ntly available i.nlormuion. it is not possible cc dcrmninc if RCR.A hazardous wasta are clisposcd of ir&Uiis oUy wure pit.

As seated by Swulard (Standarct 1988)r ".. .lh• Norrh Slope Borouah does require

·~ 'N"" .,. -.-•• .;.....•·•• l ,...••·-••••..$• ,.,.:. • ""'"""-"'""''--~~ •• , ...... 1.1 e•."•h ~·h• .p::1e ..,.••• lr·' J •t.·•...- ,...... ,. _ ::..t11.. c~~• -.;e.;;;.~v• .,...;"'-. th•·•....., .:...... ·-•· , ...... DRAFT

~"lc: Borou&h criteria for disposal in acccrdancc: with their permit. Additionally, the contentS of the oily wasu: pit are :utalyzed resularly. All drums accepted by the l:l..l'ldfill must be :iplc·rinsc:d and C"USheci." Acccrc1in1 to AOEC. the Department does nee require that the contents of the Oxbow oily waste be analyzed reJUlarly, nor is the Oepamnent aware of :uty reiUlar analysis that is pmonnect on the contentS of the Oxbow oily waste pit. Further. ADEC does not require that drums acr:epred at the Oxbow be a'iple rinsed. Ac:ording to ADEC. the criteria is thac no visible residues remain on the walls or ends of the dnlm.

In the fall of 1988. the North Slope Borgulfl submitted a permit applicaaon to the Anny Corps of Eng1necn and ADEC (or expansion of oUy wasu: clisi'Qsal capacity inta a ~ec:ond oily waste pic in an adjacent portion of the former Jl'IVC:l mine site. The permit lppli~.:ation provides for improvementS over the design of the current oily waste pit such as U\stallinc a full Liner in the boncm of the pit. Howe"Yer. because of i.nad~uacies in the pit design. maintenance. 1M openrion as described in the permit appUcatian. ADEC and the Army Corps of Engineers have nee issued the new permit to the Borough •

. In public comments subminec:l to EPA from the TNStea tor Alaska on the Borough's application for expandin1 the oily wua: capacity aE the Oxbow, in!ormad.on is provided thaE raises issues c:onccmina the performance ancl ina:picy of the second oily waste ptt• as proposed. EPA has not c=nthmeciI the facu alle1ecl by the TrusteeS. and includes major points provided by the comme:us to indicate the nuure and extent of the problems which may exist if this penni£ is iss1xc1 u submitted. These comments were prepared by a former senior producdon enlinecr wbG worked fer ARCO for a number of years on the North Slape, and many of the ~a are based oa acNal experience u numerous ocher oil pnlduclion facilities in operadon on che Nonh Slope. The commentS are extensively n:f~ references have becft deleted from text quoced below.

Oae ollhe issues raised by these cC~D~m~Srs concems &he iluepicy of me pe:matro• iD IIXl arowui cbe proposed site for me sec:oad oUy wum pic (Tnascca 1988b): The Oxbow is namoi tor the shape of the P\mallpyuk River ill diU area. which is dtu of an oJiibow. This shape is indicative of a m.eanderinl Stream course ancl of excluded elbow$ of old stream counes. A number of these old stream courses can be seen in rbe Oxbow area by referring to the USOS Beechey Point B-3 Quadranlle. These old meam courses may have formed "taliks" benealh &heir szreambcds which ~ thawed areas concainin1 water. .. DR.AFT

The usas Qua.dra.ng!e map c:lesrly de'pictS at least two such areas immediately adjacent to the Oxbow pi"· one co the souch and one to the north. These areas m:Ly be thawed and may be in commwuwon with the PutUlipyuk River. The exisa:nc:c of thawed areas immecij.:uely adjacent to the proposcci Oxbow SOWP tl (Solid OUy Wa.sce Pit tll must be investisaced prior ro the issuance of a. Solid Waste Permit .... !'lSB's (North Slope Borouch's] waste accepWtce criteria does not preclude the accepca.nce of wastes contaminated by 1lycol. methanol. gasoline, diael. or omer llpsc hydrocarbons which will 3Ct u freeze point depressants and may prevenz che lreeuback of the emplaced wasces. Light hydrocarbons interred into the SOWP may nuW!y the t'reezabllck method of d.isposal .... Ac this time there is no suppon !or a. desian based on the existence of connnuous permafrost."

Another tssue raised by the comments involves the anchorifts mechanism and um:Jrity of the p.roposc:dlincr: ''The anchorin& ma.hcd sugaested tor the boaom line: in Det:W A does noc appear workable. The ancborina mechanism desian appears ro assume tha.c the berm will remain perpetually frozen. This may noc be the QUe on a lona tcm:a basis. and certainly will not be the case on a shan term basis. NSI has stated at numerous points in their application that the upper 5-6 fee& of fill will thaw each year. Tbe anchoring layers of grave! in the benD lie between 2 ancll feet in clepdt. ••• The pvel suaacs'Ced for rtll in DeW.l B. above and below the lh1er IC'pe:II'S likely to punccure the Utter under pressure. either from the weip of the flll abavt ch.e liner or tram frasc heaves below the liner. At tease one foot of sand should be placccl neu to the liner on either side of h to protect it from the cravel, some of which will have sharp edaes."

The commentS 10 on to discuss &he North Slope Soroup'a assertion that it will maintain a n.on-du'eaflninl water level in rhe adjacent area of the Put 23 pit. As stated. by tbe commcacs: "NSB should be required co

L Floodinl of d\e Pumllpyuk !Uver. Ice jams upsCR~~D ol tbe Puc 23 pit have raised the river levei u much u ll feer acccrdiAIID USOS teCOids •••

d. A stonn surse from the Beaufort Sa. A sam su:rp ia 1970 flooded the Prudhoe Bay an:a to a dlsrance of 3 miles inland.. 'These evencs oocur periodicaLly. and a .. DRAFT

resea.n:h of the available references reveal thaz a storm su.rse eapabic o£ coverina the Oxbow SO\VP tl. 4 and me Metals Pit appears to be smtistieally probable i.n the next ten ye:ll'S. ·

Another issue raised by the commaus involves wuerfowl and wacerfowl habitat: "The arc:£ a.roWld the mouth of the PutuJipyuk Jtiver provides critical habitat for a number of species inc1udini pcsc. loons. and brant. Runoff from the Oxbow aru enters this a:e3 vt:ty quic:lc.ly ... Failu.re of the containment tram the Oxbow pies would result in contamination of and perhaps loss of this habit3L ..

The comments 10 on to ad.d.n:ss the 1eneratiDn olleachaze at the second proposed oily waste pit: "A eonsidc:n.ble amount of leachate will be producecl in this pit due to the sarur.ued natun: of m:~ny of the wastes processed. This will be especially trUe in the summer when the upper ~ to 10 feet of the wa.so=s chaw a.ncl runoil occ:.sn. Some of these fluids will coUec:t in low ~incs such as the sump depicted in aa.a.c:hmenc S. However, it would be imi.J:ionai to expect thau.ll the fluids in a pit. comparable in size to 8 football field!. is goina to cooperate and collect ac a ccN:r&l point. ••. NSB has nee proposed any viable plan fer the collection. nnspon. and disposal of these fluidi ... .At a minimum. it 3ppem that SSB should plan on ha.ndliftl 100.000 10 100,000 bamls per year of fluids from this piL"

The solid. waste pic (or Metals Pit) ac Oxbow is opentld u a sanilll')' landfUL The land.fill is currently tuled tO approxima&aly half ia teal potential capacity. Like the oily waste pit. the solid. wasre pit is coa&a'UCU~d ftona pavel and does not have a Uner. ThermistorS are plli:ed araund the perizmw of the pit tc monitor~·. Po:mafton serve~ u tbc only barrier ID pmrem the release of ecacaminants. No other techniques are Clnl'loyecl ro I:DCGitcr tor possible waste mipCon. lncominl wuta are noc characterized by the l:mdfDI openr.ors. Accordinl ta Swe otftcia.ls,. the lanclftlllw scrvtd. and continues to serve.. as cbl disposal sire for IJI:)SC of the w1.1111 cbac are noc recycled at injectect generated by Nardi Slope oU flold operadoas.. The wasu=s disposed ot at the laadfill include airplanes, vehicles. &&sed a:mchincry. C'nllhed drl.lms. buildlftl materials. insularion. tires.. incine::uor ash. donu:scic prbap, and a variety of indus1rial wasw. Accarc:linJ to A.CEC. wasu: lumber is roud.nely bameci on site. This buminl onliu: constiwtes a violation of EPA's solid waste disposal regulations ac 40 CFR 2.57.3·7 C:s).

(il DR.4FT

On the day of the sin: visit. a sipsifica.r.~ volume of ind.usrri&l waste and. mW1icipa1 soiid waste was exposed. Sea&ulls were feedinJ on la.r&e piles of what appeared. to be incinerator ash.l3 Ac:cordinJ to A.OEC. the North Stope Borouth bas improved its housekc:pinJ at the la.nd.ftll over the last two yean in response to enforcement oversight by ADEC. (Refer tO photos 87·98.)

Sjlc • 2 ~grtb SJgp• Bgrpugn )funtcj:qal lgciacracgr • Qgdboge

The North Slope Boroush operaces an itlcineracor in Oea.dborse. The incincracor primarily acce;ns domestic aarba1e; h.owever. some indus1ri.al W&Re is accepted. For examJ.7le. a.ccordina to Standard personnel. all used fUtm generated in the larse &atherini centers and flow star::ions are sent to the North Slope Boroush incinerator. These include glyc:ol heat transfer filters. sock type rllten. and charcoal tiltm.

Accon:iinc to AOEC. the incincraccrs c:ombusdonchambctoperara between 1000° F to 12000 Pin the winter and. around 1'000 Fin the summer. TheADEC pmmc und:et which this facliey operata nquires an opmuna tempmatute of 1~ P'. ADEC sa&ces that the operators of this facility are woricinc on ways to increase wuuc operalinc temt)Carures. High open~ I temperanns are required for bum cfftdency l4cl demuc:tian oi principle oraanic hazardous constituents (POHCs) and ccher toxic compounds. According 10 ADEC. me facility was ftueci with an elec:U'OSU&Cic: precipirator to n:a:aove panic:ulales in the SJ.7rina of 1988. As menaoned e:uiier, ash pneraced ac t.bis tadlicy is disposed u the Oxbow lancifill. This facility wu not tou:eci durin I the N'on.h Slope visit (Refer to photo 99.)

SITE DESCRIPTIONS· SERVICE COMPANIES, DEADHORSE

ll Encinet:aiGr ub tram cne Nanb Slope iftcinlrarar i:s ~ of a dtt Oxbow landlUL 't11e Nonb Stope incinnmr.l.oc:ar.ed in Cadbcnl. accepa badllndusna 'MUll lad dcrnciDe .,a.p.

61 Sjtc Ji 1 Fr;tblcy Scryi'c Cgmgany • Pt;tdbgr''

The Fr:l.hley scmce company provide.ci Non.b Slope operauxs with a vuicty of suppon services.l4 The Franlcy sire in Dacihonc is now abandoned. a.nd thcrc aR no cu.rrent operations at the site. 'The sire consists of several dilapidated swc:tUra loc::ued on ll gra.vel pad. Ac the time of the sill visir.. hund:ecis of used. vehicle-type baucies were disposed or abandoned on site. In some cases. me batteries were saewn a.botu the ll'Ouncl or wen: found inside the st:Uctura. The condilicn of the baaeries varied.; some were inw:r while others were cracked. :Ulowi.ns battery add to escape.

BcrNeen rNenry and thirty .53·sa.Uon drums were abandoned on site. Some of the drums appe:.red to be empty. while others were partially full. The cantena n unknown. Bec~use of the physical condition of some of the drums. spillage is inevitable. So ~eeondary conCLinment was present on this pad for preventing mill'lion of spilled material.

The pn=dcminan' swcwre on site is a srccl buildinl wich a aravel tloor. At the lime of the site visit. the floor ofu.is buildin1 wu ha.Wy sacumed widl oil and appan:ti black in color. Gasoline ancl diesel vapon inside the buildill1 were not:iceable. (At the time of the site visit. the building was closed on all sides.) In additicn to debris. half-empty. unlabeled drums. used machine pans. tools. and various other containers were presenc inside the building.

The pa.vel pad suncuad.ina the steel buildiq showed CYideftce of numerous spills. The spillqe was c1ar¥ in color IDCi had a predominant h~n odor. Sofn!= of the spUlaae appeand co have tloweci into chc adjacenc nmd:a. Trash and debris were p-resent in the rundra u the time cf the sire visit.

Ourilll tbe sire visit. ADEC pmonnel indic:al8d that at one ame d2e a.uuka na di:ectly adj~C~GC to the Fmhley PIA received etn.uau from rhe .-. czam=nt plane ac the Prudhoe Bay HoleL Accoldit11 co u. ADEC lear to tbe operu:w ol cbe PNd!loe Bay Hotel c:WedJune 15. 1914(ADEC 1984c): "Thecurremdilc!ulrp localioncausafloodinl within the Airport Llase Tr.u:a. This pond.ect sewqc effluent is coasiderecl a health hazarr.i

14 Frahley is a subsicliaty of Maucy•Fei'JUS'ft. DRAFT

to the worU:s and inhabicants of the 3rea. It is expected that at the end. of a. one 'fe'Jt period.. an altemacive disposal site wW be round that will temO\Ie tbe effluent from populated areas.·· The treated sewaae efftuent d:ischarp pcint wu moved. f'u:ther out onto the Nndta. Large algae mats are still visible trom the effluent cllscharps. ana as ~ocumented by phorographs. much of the vegewion in the area is dead.

On July 6. 1988. ADEC issued. frahley a Nociee of Violacicn (AOEC 1988e: ADEC 1988fl. Ac:otd.ina to rhe ac:c:ompanytnaleaer: "On June 1~. 1981. while inspecting the De3dhorse service are:: ' observed a number of problems on the Frahley pad. The problems included spill:a ll1 the shed on the pad and used baneries sron:d on the back of the p:ui Some of the baaeries have been broken open. In addition, there an open bmels that .:ontain liquids including waste oil. Sonc of these spills have been reponed ro this cei):utment within the presC:ribeci time period allowed by srate regulations." The le:er lOG on to state: ''Tne violation noric::e requestS that .a. spillrepcft be submitted. for each spill. ·.~~aste batteries be removed anci P,mperiy disposed of ancl a plan !or final cleanup be subrruned to the ciepanment for approval prior tO implemenwion."

On September 6, 1988, AOEC received a lcrmr fmm the a=mey of the current owner of the Ft:Lh.ley pad. (Kellicur and Jones 1988). Acc:otdina to this letter, the eun-ent owner. Mr. Jerry Johansen. re-acquired title to che propeny followins a forecloswe sale on the property. The letter aces on to sure: "In any evac a!T&r such m·ICC{Uisition o! the subject property. Mr. Johansen has nee utillzed the property whacsocver. It is our beUef that a.ny allepd clischarp of hazardous substances occurred du:rinl the cime of occupancy by Walter R.attem:uln antJ/ot Dadb.or5e Prop:rdes." Ac:cord.ins to AOEC. after lnir:iaJ. contact was made with Mr.Iolwlsa's auomcy over the telephone, Mr. Johansen's attorney has not reru:med subsequent ADEC calls. ADEC 1s hoklilll Mr. Johansen responsible for cleanup of che site.

Aa:cm:li.DI to ADEC. as of October 21. 1988. the batteries located on sice had. been moved to one comer. and the baueries wem beial c:cwered wbb snow temOvcd from the other areas of the pad.. No cleuup bid bcpn in ctae shed. and chi drums bid aoc been removeci Some time between Ocmbcr 21 and October 30, the baftll'ies locaced on sia: were removed by an unknown pany. (Refer to phocos 48·.54.) · · · --:-DRAFT

Site ii 1 Qpdbgr" Hgtet t.enc Trast • Qeadhonl

The Oeadhorse Hotel lease crac: has hisEoriQlly been the site lor scactnc support services for Prudhoe Bay oil ancl iU operatOrS. The hotel is currendy abanc:1cned. :md a variety of ~astes aeneraced by oil tield support services have been abandoned on site. includini dozens of empty and partially full -'-'·gallon drums. unused c:hemiC3ls, used baneries. abandoned W\ks and vessels. steel pam. and aener.t.l debris. Some o( the partially full. unlabeled dnuns contain what appun to be lube oil. arctic pack. and unic1enlified substances. The condition of these drums wu fairly poor. anc1lewse was evident from a. few drums.

I..arae piles of prbace were scacked on site. The carbase contained a variety of w~ste including domestic garbace. pa.inans was=. useci vehicle baCleri.cs. and eneine oil :then. An onsite inciner:uor appeared to have been useci to incinerue inc1u.scrial waste and, domestic ga:ba1e. UriC piles O( incincn.Eor ash were evident near the inciner.r.tor. The Scate does not require a permit for an incinerator of this size. Storm warer runoff from Lhe ash piles .d:ains unconl:fCIUed to d'le SU!TO\JndiDI rund.ra..

The sice wu prl\'iously \~sect u a diesel tueiinJ station tor vehicles. Two diesel fuel W1.ks. ea.ch with an esdmued capacity of 10.000 aa11om. wee used at one time ud ~ abandoned on site. Diesel spills and odors wee C'Ytdent near these tanks: in some areas diesel fue! wu flo&UnJ in pools on the Jr2Yel pad. Because secondary c:ontainmenc is not proviciecl. the spilled diesel fuel has me pocenlial ro misrza= off the pad in10 the su.rrounding n.mdn.. Aa:ordina to ADEC. them have ban inStallCeS whue spillaac washed across the road servinsws facilicy and eDn:reci the adjacenc lake. The adj.:enc lake serves as a source of drink.ina water for Deadborse..

As dccm.Deftred by phocapaphs. storm waternmoft from one side o! me pad carried a chick. unidefttined whica substance from the pad to the tundta.. Fuel spills and other unicfenrilloi submnces have ccmplelely sami'IICC1 the pvel pid in this area. An :uu:mpr had been made by service col21l'lfties operUns Oft die pad 10 clean up tbe spill with absorbent materials. buc this attempe appeand to be stYerely inadcqurc. One piece o( absorbenc rnaceriJJ. measutina approximately em. square !eec wu placed oft the spill area. The spill area measured seven.lllundted square r.. . -- DRAFT

On July 6, 1988. ADEC issued Oreac Northern S~ces (operators of the De:u:ihorse Hoce.t lease a'IC:) a Notice of Vtolalion for the numerous spills observed on June 17. 1988 CADEC 1988s; ADEC 1988h). Accon1in1 to the leacr accompanyinJ the Notice of Violation: ··en June 17. 1988. whila inspccdnJ the Oeadhorsa service area. I observed numerous spUb on the Oedone Hotel pad. The spills included hydrocarbons. calcium chloricie. ammonium chloride a.nd bt'oken bam:ries. 'These spills have noc been reponed co the depanmenc within the pru:ribcd time period. allowed by Stare l'IIUUOftS. '' The letter JOCS On to State: "The spills ale locaad al various locations thtouibouE the pad.. The violation notice n~:~uesu rhaz a spill report be submined tor each spiU, the immeCiate cleanup of cmss Sl'illaac and the submiual of a plan. fot final c:lear&Up, to the ciepanmenc for apProval before bein1 implemenced."

On September 26. 1988. AOEC recciveclalettet from Alasb Tec.'mical Services. Inc.• rcpresend.na the Dea.dhone Hotel (Alaska Technical Services 1988). Accoft!ina to the letter. the foUowtng plan was submitted to clean up and or mnove any contaminants u this location:

"The area clitectiy behinci d\e main hocel built.lina and lt.ljacanc to the t\acl sten.ae uea shall be excavated a.nd removed co d2c bc:lrouab liDdftU: Tea:ia1 tc ensure compliance wUl be clone ac this time prior to haulial any addbionallandftll. Tho buildina now SCl"''ina u Amic Coil Tubinl Co. shop will have cbc su:rface cona.minaa removed a.ad additional testina shall be clone under the existinl wooden tlcorinJ. Sampla of tbe pavel shall be tested in a wide arid panem on rhe n:mainin1 pad wich cmpftlais oe me area between Arctic CoU Tubinl shop ancl tbe rear of me pad a.s discussec.t at OW' meeaaa:•

Ac::cord.inl ta ADEC. the cla.nlq1 of the Dtldborse Hocell*l hal pnx:eeded: however, the dnmap plan WUMVCI' a,provecl by cbe Depanmena. In September, offtc:ials wirb ADEC 1D1C whb EM clamlp CCIIUICfDr u the Dacfb!1 tr~ p:o:i wi:h h)·Qoc.e:lrbon :onu.-ni.:'Ultion were 3d:i>"'!nt:i. A~ ~Jf "...'\!s t~ C"NQ oft:,:

66 ····DRAFT

t."we ll"Cas have been clea:ec:i of the conwninall:d sravel [disposc:ci at the Oxbow oUy waste j:lit land brought to compliance &Wdelines suggested by the F3.irbanks office of the ADEC." t Refer to photos ~~·67 .)

Sjtc 11 3 Aurora -.;gab Euct • Ptadhoat

Aurcra North Fuel oil field service company has an abandoned !acUity in Oe:ldhorse. This f;cilicy contains dozens of used drums. machinery pans. and pneral debris. Lcwge was evident from a few of the5e dnlms that were in poor condition. The drums were placed directly on the pvel pad withouc seconc:Luy ccam.inment. providin1 the potential ror drum con rentS to mi;rue onto the ~arl)y tundr&. Some of the drums .:onwr:ed unidenafied substances. Othcn had labels indicatins rbal hydraulic fluid. mocor ells. 3.nd diesel fuels were present. Some absorbent mamials were placed around the leUin1 drums in an attempt to coawn the spillaae. There wen: numerous fuel spills over the gnvel pad.

As previously mencioned. wuza generaa:d ac this site are subje= ro full n:aulalion under RCRA Subtitle C to the extent that they c:lChibic RCRA hazardous chara=risacs. According to ADEC. the depanment has been unable to respond and follow up on this sice bec:~use of lack of manpower. (Refer to photos 68·71.)

Site # 4 B I, Iltan Qll EJ•Id Scatsa • Qndbggc

B. 1. ncan opcrues an oil field semc:es eac:ulty in Deadhone. Cozens of used drums were s~Xcd in random fashion on si& Mos& dnlms "MR placcci din:aly on me gravel pad. wichout secondary eOftWnmeftt. Many of the cinJms were in poar condition. exhibitinl sips of damap. rust. and corrosion. While many of the drums containecl unidentified Uquicls. some had labels indicalin1 thu conosive liquids wc:e present. The lack of secoDdary concainmenc allows for potencial miption of conaminancs off sire and onto adjacent tundra. nte sile contained a lafle number of czushe4 dtums. The disposal method for the drum =idue prior co crushin1 i.s unknown.

B. J. ntan maintains acid tanks and an acid washout aza adjacent ta the tanks. As documented by photographs. the acid tanks lacked adcquaus secondary containment. At the

67 I

DRAFT

r::ime of the site visit. the cement berm around the acid tanks wu crumb lin I and was entirely Jbsent in places. Acid spills in this area were evident from the discolored gravel. The acid washout area was noc provideci with secondary containment and coWd potentially allow the mill'3tion of conwninanrs off site ontO the umcita. There was evidence of what appe:ared to be wet 3Jlc1 dry cement spillage on co the tundra from the pad. The tundra in this area was dead. As documented by photoaraphs. at the time of the site visit. large. dark oily stains :1nd an unidentified white substance were presenc on the pad.

Accord.ina to ADEC. B. 1. Titan has ccnsuuc=d seconda:y containment strUctures for drum storage. However. ADEC also swes tbat State law does not require secondary containment for c:Uum storage. Any such containment is volunW"Y. As previously mentioned wastes aener.1ted at this site ~ nee exempt from hazardcus waste ~;ulation under RCRA Section 3001. and are subject to full reJUiation W'1C1er lt.CRA Subtiue C to the extent U\at they exhibit RCRA hazardous characteristics. (Refer to phocas 7'2.·17.)

Site ! $ Egrwars:t A,111ke Scryisr Cgmgaoy • Qgdhoas

Forward Alaska oil field service company abanclonecl a sire in Oadhorse locateci directly adjacent tO the Norm Slope Borouah wacer impoundment which is the primary source of drinking water for most semc:e companies locaced in Ceadhorse. A wooden plaEfonn. usec:i co store a variety of used dzums. baueries. ancl~tneral debris. was supponea on pilinp a few feer above the paC. The pavel pad atauftd chis scrucun was stained with spillase. Damaged drums we:e abaadonecl in a horizonw posicion. thus providin1 the potential far any c:oncena tO aca;c onoa the pvel pad. Mosc of the drums were in very poar condicion. exhibitin1 sians of dama1e and corrosion. Several of the drums displayed methylene chloride labels. There was no scconduy containment around this stcrap aa.

As previously nocecL this sire is ditecUy aijaanc to me wata' impoundment from which. the Nonb Slope Baraulh draws muc:h of lcs wucr tor domestic use in dle Prudhoe ma. On the day of the site visic. runoff !rom under me wooden sccnp sCNCtUre was flo win 1 into Lhis impoundment. Such cpisocles of nmoff pose me potendal tor ccncaminancs tO mipre into the lake. Sisns of erasion from the sia: into the lake were evident around the swragc area.

68 1 ••~; .. DR .. -,.,. ' ·- i.

An onsiu: builclin& wa$ once used for smpn1 oil field service :u::tivities and. stort."'lg oil field chemicals. The t1ocr of this scruc:ture wu sU'W'Ited with oil. Pwa.ily em"ty drums ~ontlining a. varic:y of oil field chemicals. inciudinl drums labeled as concaining isocy:t.nate compounds. were present in this SlnlCtU:e. Some of the d:ums wens in poor condition.

On one side of the facility, a larp number of used drums were stored d.ireelly on the gr:1vel pad.. At the time of the site visit. the waccr level was neat these d:u.ms because or' breuup. There is no secondary concainmlnt around these drums, chus pfOvidins the poa:nria.l fer micration of contaminants from these drums onto the aandta a.nd. into the :ldjaccnt water impounctmeni.

Since the time of the EPA eonC'IC:cr sire visit. A.CEC sr.aces tha.c the 'Alliance', a group of Cca.dhorse service company operatOrs. pmered. all used drums at this sire and placed them in a Lined area i.nsicic one of the sm:tc:nns on site. The Alaska Oeparcment of ~arunl Resources. the leuc manaaer on the FCJtWazd Alaska Pad. is in the process of revoking the lease for this propeny. Accordina to ADEC. once the lease is revoked. A.DEC will sample the site ll_'d provide the tw'1din1 for cleanup. (Refer to phocos 78·81.)

SUe • § ~grtb $1ggc S••x•a• Site • Qeadbpnt

Sonh Slope Salvaae I=. (NSSn. a facillty dw a.:cepted used oil field drums. was responsible for an unconaolled release of concamilwla to the tundra durin I breakup in t 983. NSSI eeased. operations followina dUa inciclat. mosc of me s11'UCNRS were n:moved.. and currently there are no ICUvid.cs on the pad. Upon referral from AOEC. the Stau: Attomey General's otftce wu succ:aaful ia olnainiAa in courc a total of nine felony c=ounu and a fine aaai.nst the operators responsible for this incideftt. The operaran. Bill R. Hobson Sr. mel BiU R.. Hobson Ir. were convicled oa seva of chc nine couns:s includinl willful di.tc:iwp ol oil. willful failure to nodty ADEC ot an oil d.lsch.up. wi11!u1 failure to clean up aa Clil disdw'p, willt\U failUZ'I! to obtaia ACECs appn:wa.l befin rhe disposal of a hazardous subswK:e. wtlUU1 !ailunl co notify ADEC of 1 hazardous subsa.nce dllcharae. wUllul failun: ro clean up I hazardous substanCe dbchqe. anct wWful unlawfUl disposal of solid or liquid. waste withow; 1 permit. Mr. Hobson senior received 1 toal of 60 days in jail md Mt. Hobson Jr. received a total of 30 days in jail; howeYer. the jail tcnns were suspended in lieu of community service. Mr. Hobson Sr. was tined a total of $2500 and DRAF-T

Mr. Hobson Jr. was fined a total of S 12.50. ~..r. Hobson Sr. was put on five yean probation: Mr. Hobson Jr. was pur on thre: yevs probation. The specific condition of ~heir probations was thaz neither engage in the salvage or disposal business involving dnlms. waste liquid oils. or hazardous subsrances (A.OEC 1984d).

. Accon1in1 to AOEC. approximately 14,000 u.seci and pani&Uy full .5.5·p.Uon c1rums of oil tield chemicals were sterad on size without secondary contaiftmenr. Many of these drums leaked for a period of up tO six monchs belen bems discovend. ADEC discovered the spillage in the spring of 1983. and upon diJCOVery ot the leakina drums. required that a procecrive bc:m be plac:ec:t around the pad. At Lial time Fedcn.l enforcement was requeSlCd by the Scare to aid in encouraginc the operator co clan up the site: however, the Swe took the lead in enforcement. :md cleanup was conduCted.

Accon:iing to ADEC. after an inadequate cleanup effort was mounwi by NSSI, A.RCO and Standard volunteered co finance additional sire remediadon as they wee rbe primary contributors of the dnuns u the site. The liquids. primarily mixrures of solvena. oils. fuels. and corrosion inhibicors. were collec:t'.eci by vacuum can.k tn~eks and ~= eidter sold as boiler fuel or injecw:l u the Pad 3 injecdoll facility. Most Uquids recovered were used as boiler fuel in Oeadhone facilities. Acconiin1 co A.OEC. ~~ liquids recovm:d. u the site exhibited the RCRA hazatdous chanctabtic ofiptill.billry. Extensive sample resultS fer n:covered liquids an: on file with ADEC CAD!C 1983). A narun.l ps flan: was used to incinerate the residues in the approximately 14,000 drums. and the drums were disposeci at the Sand Dunes landftll. The Sand Dunes landflll b now closed.

ln August ot 1983. AOEC ~ampled me NSSI pavel pad and standin1 wao:r northwest of the site to check !or contamination in the aravel pad and to check for off-sice contaminadon. Acconlina co analytical dala on ftle in r.he ADEC oftlcc in Fairl:IU!Jcs dated November l. 1983, low levels of orpnics were det=eti in the pvel and \\rater samples taken (AOEC: 1983). Orpnics detcetld included: benzene a 20 ppb, xylene at 67 ppb, methyl naplub•lene u .02 ppb. carbolic acid ester ac .03 ppb. axa of naphthalene, various sanared hydzocarbons. unsaancect. hydrocarbons. phenol. and 5-methyl-4-phenyl·l· oxazolidinone. memylphenol u l.4 ppb. benze11eacedc adclll 9.1 ppb and 18.0 ppb. hqnanoic acid at 2.4 ppb. an.d 2·echylbuWlOic Jdd 11 3.1 ppb.

iO DRAFT

Accord.in1 to Standard

Site • 7 Child's Ppd • Qtpdbggc

Prior to 1987. Chilct•s Pad was occupied by a Oeadhorse sl'r'Yice company. In the spring of 1987. ADEC d.iscovem:i that 1 lqe number o£ oil rwld drums were inapprcpri:nely stored on Child's Pact in Oeadhorse. Most of the s~NCNreS were removed. t'ollowinc this incident. anc:t cl.UT'endy there are SC\'en.t subleasea active on the pad. incluctina the oper:uor of a store and the operaror of a mec:hanic:'s shop. The owner of the !c:t.Se is bankrupt.

Acc:cniins to AJ:JEC officiais. drums ,.,..leakinl used oil and oil field cneriucals .onto the tUndra. Adcllrionally. solid wares includinl domestic prbap, used baneries. and pllintinl wum wen: discovered on si&e.

ARCO and. Scanc:iard volun=ted tc pay for clealwp of the lice. Accordina to informa.rion submiaed by Standard ra EPA !ollowiD1 d'le EPA conncmr visit (Standan:l 1988): "ARCO and SAPC made an apeemenc with rhe Swe "'remove die solid waste to the North Slope Borou&h LandtUl. collect my abandoned drummed r:zweria1 in a line.d containment area. a.nd sample the pvel pad co clccermiDe cbc aresu of my conraminalion."

Dwinl cleanup, t.he solid wums wee stlf'plllcl ud prepmd fer disposal. Chemiealualysia was pertomsed on all drummed 111111ria1 by AM Tcsc Inc.llld Reeky Mou.nt.aizl Aulylical in Aupst and Sep~~m~bcr. 1987. Inid.al analysis oa some drums. dated SeptaD.bcr 30, 1987, included testS for rota1 orpnic: haloacns. eorrosiviry, flash point. reac:dvicy aru:l meals. These results indJc.ued that flash point :upcl from above 212° Fro less than fU F. pH ranpd from 7.3 to 9.0, ractiviry wu ncprivc on all samples. Tocal Orpnir: Haloaens ranaed !rem las than '0 ppm tO ~.100 ppm. and while moll metals wen :absenc or detected on only cnce qU&Addes. the samples were found. tO contain as mw:h as 46 ppm lead.

71 ..

Accc:rdina ta a lem:r accompanying additional test resula submined to A.RCO by AM Test Inc:. ciawi February 24. 1988. samples of dnlmmcd material wen: a.nalyze.ci by .A.M Test for mchlorcethanc: on.ly (lime or no de:ec:able amounts of this subsW1ce were round). In subsequent analysis. it was determined that several ocher 011a.nic poiluwus were present in the samples

.-\ccorciinc to a letter trom A.RCO tO ACEC a.ad EPA dater.i January 13, 1988. a tow of 428 d.-ums of waste w~ recovered durin& the cleaaup of Child's Pad: the contentS of 279 ci.'"Jms were to be recycled. by ARCO, the contentS of 100 d:ums were to be disposed. ~t the P:ul 3 OUy Waste d.isposaJ. facility, ancl49 drums were r.o be disposed. of as ha%3tdous wasn! (AJlCO 1988e). As the letter swes: ''The 49 d:ums of liquid material lllbeied as ha.z:lrclous waste in the aaachments will be left on·sin: in ehe lined di1cec1 area an the Child's Pad pendina further action by AOEC." To date, the 49 d:ums of huatdous w:ute arc heicl in the lined. containment area on the pad awaicinl final disposal :uranaemena. Accordin& to Srandard: "A plan co ~lethe wuus.oU thai meeu the used spec fuel criteria and for handlinl the hazardous wuus disposal ot die dzummed. waau: is currently beina developed for tho Swe."

In Aupst of 1988, ARCO sa.mplecl the pvcl tn Child's Pad by borinl three holes intO the pvel pad and takiftl samples ac the base of the pad. and taiina samples at chn:e surface locadcas oa the pad. The samples wae analyud ror total arp.nic halides; pur1eablcs. aact halopnarect vclacile orpnics iru:lucb& freon; and !P Toxicity. Sample results showed 1..5 mflkl barium in one sample; IBid levels in four .samples ra.npci tram .37 m~1 m .91 m~1; cocal orpnic halide levels in foursampla ranpd from .10 uats 10 .46 ufla: dichlonxlifluorometl'lue wu found in one sample ac 2S uiJii.J: treoA wu found in one sample u 28 uwts: l.l«hloroetl'lylene was found in one sample u l6 ulfkr.

..... o~ft.AF.T

methylene chloride was foWtd in cwo samples .ac 3-' and 12.6 ur/ks; chloroform was found in two samples at 26 and 270 ul/k~: and tctraehloroethylene wu found in one sample at I 4. 1 uilk I· EP Toxicity analysis on the pave.! showed leac:l in samples u .73 mwl •.37 m111. 3nci .91 m~ (the RCRA muimum allowable conc:nmuion for lca.cl in an EP Tox.iciry :est is .S matt). Barium was found in one EP Toxicity sample u 1..5 mall (the RCRA ma.:dmum allowable c:oncenttacion for barium in an EP Toxicity test is 100 mfll). (Ha.rding Lawson 1988).

Accordin1 ta the letter accompanyina me Child's Pad sample results from ARCO to AOEC CARCO 1988h): "Encloseci is a copy of che analytical resulm from pvel samples ta.ken from Child's Pad this Au,ust. It appears chat the ;ravel may be handled as a non· ha.=:dous waste. We would Ukc to confirm this with EPA. W'hen this is confirmed • .~RCO will bep prcparaaon of a pl&n to dispose of the pvei for NView by your depanmenL The most likely scenario would involve removal the end of summer 1989 to take aavanra1e of thawed conciiuons on the pad. and we hope the N'onh Slope Sorouah L.and.fUl will have a permit ancilccacion by Uw time to receive che Wastes." (Refer to phOtO 86.)

Sits I I Po••U·Sshlumbcrt•r • Dpd)gpU

Cowell·Schlumbcqer (DS),alar1e. worldwide oil fte14 service company. has a facility in Oeadhonc. OS maincains its own pad and. an adjacent sun.p pad for uorap of equipmcnc. OS provictes downhole completion and workcver services and sells various ~ds. completion chemicals. solvena. atiCl dry ·maseri.als sueh u ceaaenc to che oil a.nd gas production companies on me North Slope.

On cbl clay of me size visir. ADEC dls.:oYered alarp spill area. d1e resuk of which was approximalcly two ac:es of dead tundra." '1"he source of chta spill was from the stor.~ae pad. Ac:c:oftiiftl ta ADEC. if a tundra ana n:ceivial a spi.U rt:mains wun.rcd. there will be lirde or no revepi&Cion. lt the spill area b tlushecl ouc scon atrer a spill. then

15 Al che time of r.be 5ill visit. ADIC: ~ Clllli&l wen1 ...,.. ola .,W rcpaft submiar4 r.a A.OEC on January'· 1988. in which t"' ta 200 pUaas of acid w•r~pcl"rrd u qJiUecL

13 DRAFT

revegemcicn of the rund.r:l may occur. At the time of the site visit. the r:und:a wu bW:kcneci where the spill had taken pla.ce.

On the pad i~lt. it was estimateci by ADEC and the EPA coru:r:taor that hundreds of sa.Uons of uniden=fieci material~ had been spilled. ('This is dccumented. in phoropphs.) A large pile of primarily chalky white material •Nhich also containect some dark. olly material. was sracked up on one mae of the pad. The pile of macerial was n01 provided with any measure of eontaiMWU. a.nd the aravcl an:nmd the pile wu rcaincd with nm· colored chemicals. Various other spllls anci .sa:i.Jls were observed around the equipment :storage area used by OS.

On the OS operations p.ad. approx.imautly ~0 lcakini d.Nms were found in one comer. The unidentified substance lca.k:ina from the drums appeared milky white anclsave orf a very saona chemica.t odor. Sianiflcanc amountS of an unidendflcd thick. white liquid substance wen: observed flowina off the pad inta the nmd.ra. This r.nacerial also pve off a st:rOng chemical odor. According to State offlcials. the area of tundra behind this pad (it is surrounded by various ocher service companies) has been espcda11)1 impacted. by spills and. bad housekeeping. Based on calibrated uri&l phocap'aphs ot r.he ana. ADEC estimates that this area conwn.s 60 aaes of dead. COftWDiDareci CW1dll. Emsion from runotr was observed on the edie of the DS pad. immediately adjace.nc co me lai:ina drums.

On anomer comer of the OS pad. more !.Jrp-size spills were observed uound a materials sa.sma area. One spill wu composed of act.ry, chalky subszaace. while another ilppeared as a white milky substance. Yec anocher rpil1 area contained a frothy, milky substance whh small capsule-bubbles mac apparecl ltd. on.nae, and areen in color. Accordin1 t0 tn!onmuion rec:tivtci by ADBC subsequent co che site visit, Ibis panicul.ar subswsce may bave belli ID emu1sioll brai:er. All of these awerials hiG f1owut onra me nearby tundra.

On July 6, 1988, AOEC issued a Nodce of Vlolatlon. to Dowell Schlumbcqer, Inc. (or the numerous spills on me DoweU Scblumbcrler plds (AOEC 1988i; ADEC t 988j). Accordina co me Jeucr accompanyin.a the Nocice of VialaciOft: "01\June 17, 1988, while inspecQni the Oeadhotse service ua.l observed fturnll'OUS spills an rbe Dowell Schlumbe:pt pads. These spills have DOt bleD 1111:poncd co me dlptrm'leftC within the pn:scribed rime pcriad allowed by suze repiadcaa." '1\altn.t.er 1011 on co swe: ''The DRAFT spills c:ited inclucle dry c:hemiC:als under t.he stan~.se tank on t.he eastern ectac of t.he main p:ld. spills trom dnlm stcrase in t.he southweSt c:omcr or the main pad. a dry chemical sptU next to the drum storap. a dry chemical [spiUl on the eastem eeae of the SlCtaiC pad. ana a. !iquid that su:rounds t.he stcn.se pad. There is evidence of many ether spills throughout both of these pads."'

The Ncri.c:e of Violaaon n:q,uesu:d a. spill n:pcm be submincd for each spill. r.mmcdiate cleanup of grcu spillaae and the submiaal of a pLan for ftna1 cleanup tO the Oep:uunent fer approval before beitla impleanlld. On Ju.ly 20. 1988. AOEC received a te::er from Dewell Schlumberpr outlininl their plan f« cleanup of the spills clcc:umented in the Notice of Viola.aon, and cleanup activicics chat had. already~ The le:mr does ~ot identify the spilled material. does nee cllscusa volumes released. and cloes not discuss sunpling or c::-tanctenzacion o£ wastes prior to dsposal.

On Octaber 7, 1988. A.OEC received some ot the spill repcms n:q,uested in the July 6. 1988 N'odce· of Violation. SpillJ are described as 100 co 200 aallans of wash war.er from cement bacch mixer. 3000 pounds of propptn1 aprac. lO pllons of hydrauiic oil, 4 cubic yards of bentonite clay. unspecified amowu of class "0" cement. numerous small amouncs of unidc:nrifled chemicals. and lO 1allons of diesel (Dowell·Schlumberpr 1988a). Accordina tO the sl)Ul repons l'ICeived by ADEC on Occober 7. the IPills occurrec1 in I:lnu3t)'. February. June and. July or 1988. Some of the spills observed durinl the AOEC :nspection of June 17 wen= noc identified in any of the spW reportS submiacd. by DS in October.

As previously mentioned. wasw 1encratld by cbis service company are not exempt from any ponion of RCRA a.nd arc subjea co tU11 replacicn under I.CRA Subulie C to the extent dw they are RCRA hazardous. (Refer to phoa 105·120.)

Site I ! N,L. largfrl • Dgdbgm

The N.L. Baroid service company u1ill.zes aoocl envizonmaual manapment practices on ics pad. when compared co other senif:e'compa.nies. N.L. Ba:oid supplies drillinJ muds. cement. anc!a variety or dry bulk chemicals. Some liquids in .5.5-pllon drums are also slOred on this pad. All maccriaJs were neady StOred and scackeci iA boxed 4 ·,h.:~.n.s. How~.·er. the !':":lte:'ia.l wu stcr:d.

Site , to Halliburton Ssryigr Cgmgany • P••dtlon•

Hallibu.rr.on is a major service company on the Nonh Slopt pmvidlna workover and completion services fOI' North Slope oper.uon. Ralllbunon uses acids. fracturin; fluids. :1nd other drilling. stimulation, and completion t1uicia in prov\d.ins these services. A former o;ewage lascon is loc;ueci adjacent to the HallibW"tOn pad. Ac:contillt to an ADEC leaer ancl Sorice ot Violation elated July 30. 1987 (ADEC 1987t): "!nc:loscd is a Noric:e of Violation for the discharginJ of spent acid off the back of Halliburton's L..eue Tract in Oeadhorse. Alaska. The violation was observed on Iuly 9, 1987. On thal day a pumper czuck releasee indusai.al wasrewue: to the lands aru:J/et wacers of the scace. The driver of the erucic stacc:cl the contents was spent acid thac ha.cl been neuiZ'Illz:ed. No permit bu ever been issued by the Department 10 Halllbunon tor this type of d.ischlrae."

In a letter respondins to the Nor:ic:a ofVlolalion dau:d Aupst 12. 1987, Halliburton states (Halliburu:sn 1987): "Upon invemprins dds maacr. I find dw we did apparantly discharge some fluid without 1 permit. This wa done without my lcftowled1e or approval. and the Oeadhorse employees nave beeft sp:cii1cally insti"UCtCd that no funhcr discharges of this son are co be tl'.1ldc. The wucewue: wu pnlll'l.ted in che followinl fashion: On July 8, 1987, 1 sdm.Wation triiiiDeftt wu pcfonned fot St.anc!ar4 Alaska Procluctioft Company where ll'lt H~bloric Kid and a a:Wuu.re of llt. Hydtoch1oric:t3«1 Hydrofluoric Add was injecul:llam Well Number 17 oa E Pad. A small volume (appmximarely !0 pllons) remained in the add amkcr at me completion of the ueas:meru. and. was mumc:d to out facility in DeadhCII'SI. The lcftowr acid wu neull'll.lzed in me tranl'pOft usina approximau:ly l.CX:O pJlons of fresh water ccaua.inina scda ash. This l.OOO Jallons was the volume of fluici dtac wu d.ischarpd." •

The letter zoes on co s'taas that leftover acid is routinely r~umed ta the Hallibunon facility and that after neunlization the acid. is held in a l20 barrel boldin& tank. Frcm the holding wUc. the xid. is transported to the Pad. 3 injection. !ac:ility.

An ADEC letter to Halliburton dated MatCh 7. 1988 stares (ADEC 1988r): .. On July 8. 1987, the unpermitted dischar1e of was~ewuer from an acid truck ta Hallibunon Service's pad on A.D.L. Lease 47660. near Ceadhorse, Aluka. resulted in the depamnent issuina Halliburtcn a f'ormal Nocic:e of Violation. Subsequent i.nvestiaati.on revealed md.ence of pad ccmwninacion on ocher &real ot' me lease pad. and. adjacent wetlands. Durin& phone conversations and meeanas between you and dcpan:ment sm.tf. it was &itCed. that Hallibuncn would conduc an en~nmental audit. pad assessment. and. implement remedial actions necessary to properly address the d.epanmenrs concem for pad. con !:Imina non.··

The AOEC letter goes on ta requesz a list of speciflc ta.SJa to be pcrformecl in fulfillment of the envilonmcntal audit and. subsequen' remedial effort. In a lener fro~ Halllbunon ta AOEC daceci April 6~ 1988, tbe corrtpany commiueci in wririna to ''perform ;UJ necessary remedial action re1ardln1 any d.ischaraa at our Cad.horse.. Alaska leased. facility'', and a schedule was submitted ror ACEC considenrion (HallibUftOft 1988). tn a letter from AOEC to Halliburton cWed. April t4. 1988. the Depannwnt swes itS conc:umnc:e wim HaJLihun&:ln's proposed schedule for remedial actions (ACE~ 1988s). On April25, 1988, Ha.Uibu.non submitted to ADEC an extensive scope for me cnvitonmenw audit ta be perfonneci on the facility (Halllbunon 1988a). A=ordinl ~o Iacer correspondence. Halliburton nomiftacecl a pri\'are concrac:u:rr ro perform d1e environmental :tudit on the lease. and ADEC c:oncumcl wir.h tbm choice for conU'IC10f (A.CEC 1988c. Hallibunon 1988b}

ACIX'trdiAI to a lem:.r tzom ADEC darlcl Aupu 3. 1981 (AOEC 1911u): .. lA c:orrespondi:Da:l da%ed April 6, 1988, Ha111bunon commiad ro pcrforminl a number of activities iD rapons. ta a Nocice at VIolation issued ro Halllbunon tor illepl disch&r~e of wu~ewaa:r an me above referenced leue net. One of Ha111butrotl's commi=enu wu ta submit ta the cleparr:menc by July 11, 1988, copies of a comp.letecl cvin:nu:nenw audit relative to Halliburton's activilia on the lease a.:t. Anocher c:ommkrt•n' was for HalliburtOn to submit a sampllnl and analysis Pft:Jsrtm to chc d~m by July 15, 1988. To date. d1e d.epanment has received neimer the envil'oftmental audit nar the samplina and

... .., • DRAFT

:malysis prosnm. In a.d.ditiori. no communication has been received ttom Halliburton ind.ic:uinga need for additional rime to submic tbc:se dccumcnts."

The ACEC lea:er ps on to swe: " It is mquested that HaJJ.ihunon submit the missing documentS within f'ouneen days from the date of this letter, Ilana with a wria:cn cxplanar:ion for their delay.'' To dace. ADEC has n=ived no fu.Mer ccrrespondence from Hallibunon concerning this matter.

As i.ndicau:d in a photopaph, at lease 1 acre of dead. and discolored rund:a is o.djacent to the HalliburtOn pad. (This facUity is Coc:umczned. in photo 134.)

Site I t 1 YECO Qil Fjeld Ssrvtcc Comgpny • Qgdhgm

VECO. Inc. has operated an oil fteld service facilicy at Oeadllorse since me mici- 1970s. The first f:u:ility established. cal.led tbe old VECO base camp. wu cleccmmissicned i.n 1987. At this time, V!CO purchased anomer t'adlhy and movecl ics base hcadquartan co the new locar:ion in Ocadhorse. The cunene VE<:O facilities consist of me f'ollowins: a diesel vehicle maincenance shop. a aasoline vehicle mablcena.nce shop. a heavy equipment maintenance shop, a vehicle washin1 facility, a paindll& and aucc-ftftishina shop, a c:~rpentry and wood pnxl.uc:tS shop, an elecaical supply and service shop. and. a welding and steel fabricaans shop. The complex also ccatainl a wutc incincaror.

After the move to t.he new location. VECO bepn decomrnislioftina and. demoiis.hinl t.he old camp. The decommissicllinJ CODrinued intO 1988. The old VECO base c:unp was the sice visited by the EPA .camnr=r. Accordiftl t0 AOEC, VECO has had a history of en'Y'i.ronmenal mlases resultinl f:Dm wUte manapmanc pracuces used. For example, a.::can:tin1 to Stat~ oftldals, ~0 Jallons of paint were buried in the VECO pad. in 1986. Acc:anllq 10 ADEC. VECO has reponed dw d'le paint wa dancd up the same summer, Uld a reporc documenlinl tbe cleanup was ftled wid\ the ADEC.

The pad concaiDed a number ot spills. empcy drums. 1arp IIIU ot stained pvel. abandoned equipment. and a•eral debris. fA one aa of me pad. alarp number of empty drums were scored, some on c.he pvel pad and. some on woodl:n suppom. The drums wen: Jenerally in poor condition, uhibitinl sips of damap, ruse. and corrosion. The composition of the residual contents ot t.he drwnl is wllmown.

78 DRAFT

At the tiJ::M of the site ·visit. the site contained several Iarae diesel tanks. Diesel fuel was evident in the :~.rCa inside the containment strUctures. and the Jravel arcu.nd. the Wlks was saruratlld with diesel fuel. A la.rp spill of unidentified macerta.l was ob.serveci on one side of the pati. Accon:Una tO ACEC. the Oepanmcnt has n:questlli sample data from this a.r=. and VECO ha.s never responded. As doc:ummued. by phorosrapns. near this spill was a shallow pic used ro store oily waste. The Uner is ranered and the betms of the pit were breached or very thin in places. A latp oily spW wu obse:ved fiOuinl in standinl water under one stNetur~: located on pilin p on this pad.

Operaton of this fa.c:ilicy at one time cleaned. used dnm:s in the nc:k washtacks and ste:un cleaned trUck tanks that had carried l;:ily wastes ami chem:ials. Ac:c:on:ling to reports on file with ADEC. V'ECO disposed of rhis rinsata at Pad 3; however. Pad. 3 hu been closed to service companies sinc:c 1987. Currently. AOEC is unable U) de:ermiM when:: :his rinsate was disposed. Accord.inl te iniomuzion submiued rc EPA by VECO following the EPA contraCtor site visit. this rir.sate was "•• .retun'led to the owner as per the con=c:t for that particular project.'' VECO swes tlw the wc:k and d.Nm washin& opera.tions have been moved tO the new facility and are now compleldy enclosed a.nci winterized.

As previously mencione::t. wastes senctallld. u this site an noc aempc from any portion of RCRA and are sub~ te full replation under RCRA Subtitle C to thlexrent chat they exhibit RCRA haz.anlous c:hancterisr:ics.. (See photos 124 anci 12.5 a.nd. 1-'7·163.)

Site 1t n P:sk Smiq Cgmpany • Qgdhmt

The Peak Serme Compay prcvida Nonb Stopa openaon wilb a vvic')' of oil field services. tad. udliza heavy equipment such u cranes. PUIDI* INCks and conscruc:Uon :quipmac. Oa me day of the sire visU. many ctJ.emi.ca1s l.ncludinl corrosion inhibitors. 3.ndf'reezl, bioddes. wmr ueac:a:wu cbcmicals. and clllllinl solvcaa wcra srcnd on sire ~rimarily iA .5S.p11cm dnams. The dNms were lt.ond on plactorms lhac were no& pl"''Yicleci .vith secondary c:oruai.nmrmt. At the time of tbe site visic. some dn&ma were 1ft poor :hysic:al condition and appeared tO be laldna.

·• , .. .t . .a,..t .u-t.~o. S"'" ...... _. 1.' · "\'t~ •• 1: ....._ :t"'::'Ylu- - ...n .... c .• - .• ...... ••r.•": .. -..... c. .,...,., •~ls c... ''ft•"'' ~-:'11iiliio- _... "-"'·- ...;;1 :..: ...... , :~;::; ''r..-Ja ·"..,. ·"' ..

79 . , DR.4FT

plastic. wu consaucted pan:ially with concrete which h3d c::umbleci a.nci decayed in places. presumably from exposure to acid. In areas where the cement ccntainment h:ui dcc:1yed. grave! was used to provide seconctary conu.inmenc. One or more oi the tanlcs nl4 ap-pa.n:nrly lea.kcct as the inside of the contained area was sai.'W'3tecl with ;reen-cclored ~pillage. l'This site is doc-.Jmented in photOS 127 and. 153-156.)

Site • 13 Ssblumtzsrztr oa,bgrc Ssrylqs Pad • Qqdhqac

The Sc:hlumber;er Lo1Jin1 Company maimains a service center and employee housing on this pad. Vehicles and loaJina equipme:u ans stored and serviced in an enc:lose4 sauctun:. A pipeline discharps mated domestic sewa1e tO the tundra under a pe:m.it from ADEC. which requires that the dischatp meet secondary treatment star~darcts. At the nme of the site visit. :&n oily sheen wu observed. in the pool of wau:r formed frcm the sewer discharge. Ad.dllionally, oil stains on the cunc1ra and sum:nmdins ice wen= evident

On June 30. 1988. ADEC issued Schlumbfqer a Nocice ofVioliUion for the hydrocartlon spill observed on June 17, 1988 (AOEC 1988k: AOEC 19881). Acconiinl to the letter a.ccompanyina the Norice of Violariort: "On June 17, 1988, while inspecana the Deadhorsc service area. I obse:vec:i a hydrocatbon spill on me wesrem ed1e of the Schlumber&er Pad. L.case Tract 13. This spill has noc been~ u:t the c1epa.rcment within the prescribed time period allowed by stare replalions... The lellllr aces on to swe: ''The violation notice n:quesu thac the spill be repoalld. free pnxlw:l cleaftcd up a.nd a plan for removtns contami.t'wcd gra"VC! and oil on che amdra be submil:lecl to chis dapanmenl. ·•

On 1uly 14. 1988, ADEC received a leaet !rom Schlumbcrpr oudininl their responSI to ctse Nolicc of Violation (Schlumberpr 1988~ Schlumberpt 1988a). Enclosed. 'Nith the J.eculr WIS I spill repon dccummrinl ~hal Ull hyd:ocarf:lon spill observed 0D Jl.lne 17 consisrld ot apprax.imllllly 10 pllons ot wasti oiL Acccrdinl 110 the spill~ the wure oil spill bad affected apprDXimar.ely 160 square feet ol n&rJdrL The oil wu coruai.ned by a boom and soaked up wldl absorbent. 'T'he conwninllld ar&vel and lfiSS WU removed and disposed u the Oxbow l..andtUl oily Willi pic. The spill repon dbcusscs SchlumberJet's plans to nrvepwa the area with red fescue. tundra. bluepus. and Alyeska

80 poJargnss. According to the spill report. planting would occur on or about AuJUSt 20. 1988.

Schlumberget s letter discusses the company· s intent to pnrvent future spills of this type thrcusf'l employee tr:Uni.ng. [n a lcncr frcm Sch!WJJberJer to AOEC da.ted September S. 1988. Schlumbcqer docwnenu that seeding of the azea affected. by the waste oil spill was occurring between August 2.! and SCJ)U:mber 10 (Schlumbe:pr 1988b}. This lett=' discusses the seed miJI:r:un! used and the type ancl amount of fc:n:iJ.iar used. It also disc:ums the rescedin& cechn.iques employed. Accontins fD ADEC. the Schlumberger response to the Notice of Violation represents a mere complete response than is usually For-JlC:omin& from semce companies rcc:eivin1 Notices of Violatica frcm ADEC. (This facility is documented in photos 164 and 16!.)

81 • DR.AFT

REFERENCES

Alaska Depa.rancnc of EnV\rcnmcnw ConserYacion (A.DEC), North Slope RcgionDJ. Office (~0), 1983. Analytic3l Report !or North Slope Salvage site. !'fovember 16, 1983. ADEC. :-fRO, 1984. I..cttcrto ARCO Alaska. Re: Moditlccl Waste Disposal Pennies for ARCO CPF·l (8434-DB0%4) and ARCO CPF·2 (8436-08012) Disposal WeUs (Kupa.t"Uk Oily Waste Injection Well), October 30. 1984.

AOEC. !'-fRO. 1984a. Letter to Sohio Ala.ska Petroleum Company (Standard Alaska), Rc: East Dock Reserve Pit, Augu.st 28. 1984. t\DEC. ~RO. 1984b. Waste Disposal Pmnit No. 8436-08024, Oc:tcbcr 30, 1984.

ADEC. ~"RO. 1984<:. Lc::er :o Prudhoe Bay Hotel. Re: Waste Disposal Pennit 8436- 08018. June l.S. 1984 .

.~DEC. NRO. 1984<1. [ntcmal memo. Re: Summary of ~orth Slope Salvage, Inc.· Convictions and Sentences, November 29. 1984.

ADEC. NRO. 1986. Letter to ARCO Alaska, Re: Nodce of Violation • Pinpt Pad Oily Waste Pit. July 29, 1986.

ADEC. NRO, 1986a. Nocice ofViolarion ··Pinpn Pad Oily Waste Pit. July 29, 1986.

ADEC. N'RO. 1986b. Internal Memorandum. R.e: Review ofproposca modiftcacion of U.S. Army Corps of Encinecrs permits. September 9. 1986.

A.DEC. N'R.O. 1987. Letter te Standard Alaska Prcducdon Company. Re: Use of Reserve PftS fof' Disposal ot Oily WasteS (1 Pad), AUJUSl '· 1987. ADEC. NRO, 1987a. Notice of Violation· Standard. Alaska Production Company's J Pad. AuiUSl 5. 1987.

ADEC, NKO. 1987!). Leuer to ARCO Alas.ka. Rc: Contaminare.Q Ot&\'d at (.."bUd's Pad. ()Q:Qb;r 22. 1981.

ADEC. NR.O. 1987~;;. Letter with atrachmenrs ro ARCO Alaska. Rc: Solid Waste Disposal Pctmic for Pad 3 OUy Waste lnjec:tion Facility, September 11. 1987.

ADEC. NRO. 1987d. Register 103. October 1987.

A.OEC. NRO, 1987e. "Problem Pit Usl", 1987. I DRAFT··

.-\DEC. :--.'RO. 1987!. ~tter with attachmentS to H:illiburron Servicc:::s, Rc::: :--ioace of Violation .Cisc:narge oi Acid. without a. Permit, July 30. 1987.

ADEC. :-."R.O. 1988. Letter to ARCO Alaska. Re: Notice ot Violation for Drill Site 4. 3J1d Oil Spill C!e:mup, July 22. 1988.

ADEC. ~RO. 1988a. Notice of Violation· ARCO Drill Site 4, Juiy 22. 1988 .

.-\DEC. !'IRO. 1988b. Internal M:cmo. Re: Used drum rinsate. October 13. 1988 .

.-\DEC. SRO. 1988c. L.cuer to Standard AlasJca Proclucd.cn Companyr Re: ~od.ce of Vlolarion - Permit Violations at Eileen West End/W Pad.. July 22, 1988.

1'\ OEC. ~RO. 1988d. Sotiee of Violation· St:and2rd Al.U.U froduc:tion Comp:my't W Pad. July 22. 1988. A.DEC. !'lRO. 1988e. Lc:ttcr to Jerold Johansen. Re: Notice of Vlolad.cn, rrahiey P:td. July 6. 1988.

ADEC. !'lRO. 1988f. Notice: of Violation, ftllhlcy Pad. July 6, 1988 .

.-\DEC. :-fRO. 1988g. Letter to J. R. Thomas. Re: Notice of Violation, Dea.dharse Hocei. July 6. 1988. A.DEC. NRO. 1988h. Notice of Violation. Dcad.horse Hotel, July 6. 1988. A.OEC. NRO. 1988i. Lcm:r to Bobbie Joines. Re: Notice of Violation - OoweU SchlumberJcr. July 6. 1988.

ADEC. NRO, 1988j. Nocic:c of Violation • Cowell Schlumberp. July 6, 1988. A.OEC. SRO, t988k. Lcucr to Schlumbl:r1er Otrshore Services., Re: Noti.cc of Vioianon. · June 30. 1988.

A.DEC. !'fRO. 19881. Noacc of Vloladon • SdtJumbericr Off'shon: Services. June 30. 1988.

ADEC. NR.O. 1988m. Compuccrized spill report for 1988.

ADEC. NRO, 1988n. Ina:mal memo, Re: Hallibunon Update. October. 1988.

A.DEC. NRO, 1988o. Lcncr to VECO. Inc., Re: Oeanup ofVECO fadllties. June 29. 1981.

ADEC. NRO. 1988p. L.cm:r te ARCO Alaska. Re: Wasre Disposal Permit for Pld 3 Oily Wute I.njec:non Facuiry. July 13, 1988.

ADEC. !"{RO. 1988q. Waste Disposal Pennie No. 8736-08024 (Pad 3 Oily Waste Injection Facility). July 13, 1988.

83 ADEC. ~RO. 1988r. Letter to Halliburton, Rc:: A.D.I... Lease 4i660: Pad Cont3trun>~.non. :viarch 7, 1988 .

.-\DEC. ~RO. 1988s. L.c:tcr to Halliburton. Rc: AOL Lease 47660. Pad Conwninac.on . .~pril14. 1988. :\DEC. ="'RO. 1988t. Letter to Halliburton. Re: Ant. Lease 47660. E.,vironmencal Audit/Consulting Contraetcr Selecnon.June 2. 1988.

ADEC. !'-IRO. 1988u. Letter to Ha..llibwton. Re: ADL Le:.t.SC 47660 Da.dhorse. Alaska. Sorice of Violation/Environmental Auciit. Ausust 3, 1988.

ADEC. ='IRQ, 1988v. Repon titled.: ··A Review of Liquid Waste Proc1uction a.nc.t Disposal at Oilfield F~cilities on the North Slope of Alaska.'', Mar:h. 1988.

A.DEC. :-.IRO. Pe:mit So. 8736·BA008. (No date.)

.~laska Depa.nment of Fish and Game CADFG), Habita.t Division. Fairbanks. l986. Letter ro ARCO Alasic.:J.. Rc: Sagavani.J:'Xtok River ~inc Site C. June 16. 1986.

A.DFO. Habitat Division. 1986a. Field Inspection Rcpon • Sapvanirlcto.k River Mine Site C. June 10. 1986.

AD.FO. Habita.t Division. 1987. Lettet with attachments to A.RCO Alaska. Rc: Sag Sit! "C .. Rehabilitation Plan. January 27, 1987.

ADFO. Habiw Division. 1987a. Internal Memo. Re: Kuparuk River Ocad.arm Matenal Site RchabiUtation. September 10. 1987.

AOFG. Habiw Division, l987b. Internal Memo with attachments. Rc: Rehabilitation ot' !'vfine Site Bin the Kuparuk Unit. November 19, 1987.

•~.FG. Habitat Oivision. 1988. Aguatis Habitat Enluarlgn ofFlrqlqt Ngnh Slops OQ:yel Mjne Sjts;s 0986:19871. by Carl Hemming. Technical Report No. 88-1, Aususc. 1988. ADFQ, Habitat Division. 1988L Memo to Office of Management a.n4 Budpt. Re: Renabiliwion of Non.b. Slope Oravel Mine Sites, Octcbcr 24, 1988. ADFO. Habiaz Divtsion. 1988b. Letter to Standard Alaska Prcduction Company, Rc: JCU'pii'Uk Deadarm Onvel Pit • P Pad Project. February 17, I 988.

ADFO. Habi.r:.u Divbioa.. 198&:. lnrcnal Memo. Rc: Meeti.ns with SAPC (Scandani Alaska) on Kuparuk Dadatm, May 9, 1988.

ADFO. Habiw Division. 1988d. Letter to Scanc:lud Alaska Prcducdon Company, Re: Kuparuk Deadarm Mininl Plan, June 3, 1988. .

ADFO. Habital Division. 1988e. Inrema.l Memo, Re: Material [Gravel] Sales Contract, April 8, 1988.

84

~-···~-~------. . I .. ., . ·, ·~ .. :.

A.OfG. Habitat Division. 1988f. InternaL Memo. Rc: Rehabilitation of ~e Site B :u1d D. August 2. 1988. ADFO. Habitat Division. L988g. l.nn:mai Memo. Re: Restoration Plan for Concco Milne Point Oravei ~t. January 12, 1988.

Alia.\l!A4 .Dcpul.ment vf L.t.w, Je.meZ~u. 1987. Lc::uc te ARCO Alaska.l\e: Sag Slte \: 1\ele:1Se and Sc:ulcmcnt•• -\ugu:st 14, 19R7.

Alaska Tc:c:hnic:al Sc:rvu:es. Anc:horaJe. 1988. Loner tO Brad Fri.stoe, Rc: Soticc of Violation on Dc:ad.horsc Hotel. September 26, 1988.

Alaska Tcclmic:.U Servicc::s. Anchorage. 1988a. I..c:nr:rwith attachmentS to Mr. Wilber Thoma.s. Rc: Synop.si$ of work pc:icmned at De3dhorse Hotel Pad.. Octeber 11. 1988.

AM Test Inc .• Redmond. Washington. 1987. Child's Pad sample results, 1987 .

...':\M Tc::n !nc:. i<.c:amona. Washington. 1~l5~. (.;Dua·s l"Ul saznpje resultS, 1988.

Americ:z.n Petroleum Institute (APn. Pe:roicum .Extension Service. University of Texas, Austin. 1969. Pr:nctplcs or drilling fluid. control (12th ed).

ARCO Alaska.. Anchorage, 1987 .. L.cncr wi&h ;;u:tac:hments tO ADEC, Rc: Pinpt P:J.d Qose-Out Plan. February ·9, 1987.

ARCO Alaska. Anchorage. 1987a. Close-out Plan. Pl.ngut Pa.d Solid Oily Waste Process in& Facility. 1987 .

.-\.RCO Alaska. Anchonge. l987b. Letter to ADEC. Re: Child's Pad Oeanup. October-'· 1987.

ARCO Alaska.. Anc:hora&e. 1987c:. Letter to ADFO. Rc: Sag ··c Reservoir 1987 Break· up Erosion. Augus; 3, 1987.

ARCO Ala.ska. Anc=horage, 1988. Letter with au.achmencs to U.S. EPA. Re: EPA Cona"aCtOr Site ViSics, September 29. 1988.

AR.CO Alaska, Ancborap. 1988a. Leuer wilh attachments to ADEC and U.S. Army Corps of Enpeers, Re: Reserve Pit Modiftc:2tion • DS-lE. Sepcembet 12. 1988.

ARCO A''IA: Aachcnp.. 1988b. Lc:acr with aruchmena to ADEC. Re: Pad 3 SoUd w.. Dispo$al.Permit. February 29, 1988.

ARCO Alub. Anchora~ 1988c. Len= with an.achmems to ADEC. Re: Pitlgut Pit Oose-Out Thermistor Dua, May 19, 1988.

ARCO AW.ka. Anchoracc, 1988d. Lcur:r with amchmena to ADEC. R.e: Notice of Violation Drillsite 4 Spill Oeanup, Aucust 2l. 1988. . .. ,..,·" ••~ 6.~r DI •. 1·-.,1

ARCO Alaska Anchotagc. t988e. L..c:ttc:r with anac:hmcntS to ADEC met U.S. EPA, Re: Child.'s Pa.c:l Cleanup· Drum Disposal Plans and Gr:w:l Status. January 13, 1988.

ARCO Alaska. Anchorage, 1988!. Letter to U.S. EPA Region X. Re: Child's Pad sample results. March 1. 1988. ARCO Alaska. AnchOTUge. 1988g. Gravel Conference Minutes, 1988.

ARCO Alaska.. Anchorage, 1988h. l...c:tte' wtt.h aaa.c:hment:s to ADEC, Re: Child's Pad so\.1 samples. Cktobcr 2.5, 1988.

AR.CO Alaska. Anchor:ge, 19881. Letter with atw:hments to U.S. EPA Region X. Re: Applic::.aon for Kupan.&.k .Fieldwidc NPOES Permit, October 4, 1988. Dames and Moore. Anc:horagc. 1978. Drilling Fluid Dispersion and Blciogica1 EffectS Study for the Lower Cook Inlet C.O.S.T. Well. submitted to Arlantic: Richfield Company. Dallas. Texas.

Oowe!l Schiumberger £ncorpor:r.tcd. DA.d.hon;a. 1981. Litter TO Srru:i Fl"i~toe. Re: Nel!iee of Violation. July 20. 1988.

Dowell Schlumbcrger. Oe.adhor:sc. 1988a. Spill repon.s. Oc:ober 7, 1988.

Enscco. Inc .• Arvada. Colota&:ic. 1987. Analytical Results tor ARCO Alaska. (Child's Pad), September 22. 1987.

ER.L (Edgcnon Re:search I..abc:nlory, New England Aquarium), Environmental Rcsc~h Laboratory, Oulf Breeze, Florida. 1984. A survey of the toxiaJlogy and chemical composition of drtllin& muds. submiaea to U.S Environmental Prou:ction Agcnc:y. Rcpon 60013-84471.

Hallibunon. Anc:horap.. 1987. Letter tD ADEC, Rc: Notice of Violation .. Discharling Indu.slZ'ial Wastewater wUhout a Permit • Oeacthorsc. Alaska. Aupll. 1987. fiallibW1Dn. DWlcan. Oklahoma. 1988. Lcuc:: to ADEC. Rc: ADL I..ease 47660- P2d Contamination. April6. 1988.

I Wllbunoa.. .Du,nQn. Oklahoma. 1988a. l..elmr co ADEC. Re: fuJ.ftllment of Obllgations uncia- Noric:e a£ Vlolarion, April 25. 1988.

Halliburraa. Durl:aa. Ok:lahoma. 1988b. Lcaer to A.DEC, Re: ADL Lease 47t.MSO. Choice of Iadcpendcru Consullinl Conuacmr, May 17, 1988.

Uatding l..&wiOil Aslociaccs, Ancbcnp, 1988. Lener to ARCO A1asia. Re: Child•s Pad soil sampiinl and analysis. Sepasmber ll, 1988.

Kcllicut and Jones. Anomeys a Law, Anchorage. 1987. Letter tO lames N. L=ii:. Re: Rauc:man v. Johansen. CL al., Aprill8, 1987. .

Kcllicut and Jones. Attorneys u Law. Anchorage. 1988. Lcacrco ADEC. Re: Noc:ice of Violac:ion. Frahley Pad. September 6, 1988.

86 Kc!licut mci Ione:s. Attorneys at uw, Anchorage. l988a. I..ctter to James N. I..cik. R.c:: Ratterman/ Johansen. September 6, 19R8.

~{J.cion:U Rcsearc:h CounciL 197.5. Pc:rolcum in the Marine Environment. Sationai Academy or' S~icnce,. Washington, D.C.

~atur.U Resources Defense Council. !'few Yorlc, 1988. Letter tO ARCO ALaska. Re: ~ouce of Intent to Sue. rebruuy 16. 1988.

SaNl'lli Resources Defense Council. New York. 1988a. Letter tO Standard Alaska Production Company, Rc: Notice oflna:nt to Sue:, February 16, 1988.

Nonh Slope Borough. Pn.adhoc Bay, 198.5. Memorandum with attaChmentS tO ADEC, Re: Final Report for Oewaterins of Oxbow I..andtill. O<:tober 20, 198.5.

~onh Slope Borough. Prudhoe Bay, 1988. Letter to ADEC. Re; 1988 Delivery Quantiticz (or the Oxbow L.;mdfill. October 6, 1988.

Sor:on. Alies. CW"Uws. t:nivcrsir:y of Ala.sb. FairbankS, 197.5. Ecological reia.tionships of the inlomd tundru avifauna near Prudhoe Say, Alaska. ln: Ecologic:U tnvc:srigations of the Tundra Blome in the Prudhoe Bay Reaian.. Alaska. Spec. Repon No.2. Bioi. Papen. pp. 124-133. University of Alaska. . Schlumbcrger Offshore Services. Ocadhorsc:. 1988. Letter to ADEC. Re: Nerice of Violation. ! ul y 14, 1988. Sch1umberaer Offshore Services. De:sdhorse. 1988a. Spill report. July 8. 1988.

Schlwnbcrgcr Offshore Services, Dc:adhorse, l988b. Letter tO ADEC. Re: Reveactation of spill an:a. September 5, 1988.

Sohio Alaska Petroleum Company (Scandard Alaska), Anchcrqe. 1983. E;m Dock Mud Suam Ejvs Year Monitorial Pmmm Interim Repcm for Yem 1981 Ihmush .wl. Sohio Alaska Petroleum Compa.ay, Anc:honlge. 1984. Lener with amu:hrnent to ADEC. Re: East Dock Reserve Pit Lcalaao. July 27. 1984.

Standard Alaska .P.raduc:Uoa Company. AncJiorap .. 1987. Letter to ADEC. Re: Neace of Vioi1tioa .. J Pad. Ausust 18, 1987.

Standard Alaska Production Company, Anehoraae.. 1988. LAra:t with ar:s:ac:bments to U.S. E.PA. Re: EPA CODU'Kta: site visit. Se;=nbcr. 1988. Sta.ndani Ala.sb Praduetioa Company, Anchorage. 1988L Le:erwim aaachmcnts ro ADEC. Re: Notice of Violacion • W Pad. AUJU&t 1, 1988.

Standard. Alaska Production Company. Anchorap:. 1988b. Lcuer With acta.:hmenu tO ADFG. Re: Kuparuk Deadarm Pit Interim Minina Plan. May 11. 1988.

:17 f"", ~ "" ...... ~ .:~· .. .. ;• ~~...... '. : • Standard Alaska Production Comp;my, Anchorage, 198 8c. Letter with atw;hmcnts to AOEC. Rc:: Eileen West End [W P~J Sclid Waste Disposal Pemua No. 87~6· BA007.July 1.5. 1988.

Trustees for Alaska. Anchorage. 1988. Letter to EPA Region X and commentS on ARCO t.1C Cla.ss I Industrial Waste Injection Permit, June 27, 1988.

Trustees for Aluka. Anchorage. 1988a. Letter to EPA Region X and supplementary c:ommcnu on ARCO Class I tndu~triai Waste DisposaJ Appiicaticn. August l.S, 1988.

Trustees for Alaska. Anchorage. 1988b. L.ctu:r to ADEC and aaached comments on proposed expansion of the Oxbow oily waste pit, November 30, 19!8.

t.:.S. Army Corps of Engineers. Alaska Oisuict. 1986. Public Notice, Rc: Permit mociific:~tion proc:cdure. August 5, 1986.

U.S. Environmental Protection Agency, Washington. D.C.• 1987. Report to Congress: ~!anaceme:u of Wutcs from the E~plorarion. Deveiopmc:lt, and ?reduction of CrJde Oil. ~anltal Gu. and Geothenn:U Energy, Volume l. Office of Solid Waste :md Emergency Response. EPN~:30-SW·88-003.

U.S. Envilonmenw Protection Agency, Washington, D.C.• July, 1988a. Fedeni R~:pJter. "Regu!J.ury Detemlilulion tor OiliWi Oa.t 1M G~merma.l l:xpl~tltk."~· Development and Producuon Wastes", Vol. 53. No. 129, July 6. 1988

'lECO. Inc .. Anchorage. 1988. Draft Repoa ot Indusm3.1 tnssaUarign3 ar peadhoae. A!ask~e June 1988.

West. Snyder-CoM, U.S. Fish and Wildlife Service. Washinston. D.C.• 1987. EffectS of Prudhoe B:sy rexrve pit fluids on waccr ~uality and macroinvenebrates of rundr.l ponds, U.S. Fish and Wildlife Service B1ological Rcpon 87(7) . • Woodward. Snyder-Conn, Riley, and Garland. U.S. Fish and WUdlife Service. National Fi:sheries Contaminant Research Center. Jackson field Station. Jackson. Wyomin1. 1988. ''Drilllq Fluids and rhe Arctic Tundra of Alaska: Assessing Contaminal:ion ot W edands Habitat and the Toxicity to Aqualic Invertebrates and Fish". In: Arch. EnVU'On. Conwn. Toxicol 17,683-697 (1988).