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Home My WebLink About100-109From:McLellan, Bryan J (OGC) To:AOGCC Records (CED sponsored) Subject:Sullivan Strat #1 (PTD 100-109) wellfile Date:Monday, August 12, 2024 2:51:55 PM Attachments:Sullivan 1, Sullivan 2, & Sullivan Strat 1 Report.pdf Please include the attached file in the well file Bryan McLellan Senior Petroleum Engineer Alaska Oil & Gas Conservation Commission Bryan.mclellan@alaska.gov +1 (907) 250-9193 Phillips Petroleum Company Alaska Inactive Reserve Pit Phillips Petroleum Company o--O xt e 7 Productiox 4 '.iM:r1 Prepared by HILL 301 West Northern Lights Blvd. Suite 601 Anchorage, Alaska 99503 F1 -won ,• Section 1 2 3 r 5 6 VA E: 9 10 11 Contents Page Declaration.............................................. 1-1 Summary................................................ 2-1 Closure Study Approach .................................... 3-1 3.1 Preliminary Site Screening ............................... 3-1 3.2 Site Assessment Studies ................................. 3-3 3.3 Qualitative Risk -Screening Procedure ....................... 3-3 3.4 Closure Alternatives and Benefit and Impact Evaluation .......... 3-4 3.5 Closure Report ....................................... 3-4 Waste Site Identification, History and Status ..................... 4-1 4.1 Location ............................................ 4-1 4.2 Landowner .......................................... 4-2 4.3 Operator ............................................ 4-2 4.4 History of Operation ................................... 4-2 4.5 Closure Status ........................................ 4-7 Site Description ........................................... 5-1 5.1 Sullivan #1.......................................... 5-1 5.2 Sullivan #2.......................................... 5-2 5.3 Sullivan Strat #1...................................... 5-5 EnvironmentalSetting ...................................... 6-1 6.1 Geology and Soils ..................................... 6-1 6.2 Regional Hydrogeology................................. 6-5 6.3 Climate ............................................ 6-6 6.4 Natural Resources ..................................... 6-7 6.5 Biological and Ecological Resources ........................ 6-7 6.6 Historical Resources ................................... 6-8 6.7 Human Resources ..................................... 6-8 SiteAssessment ........................................... 7-1 7.1 Sampling Program and Results ............................ 7-1 7.2 Summary of Visual Inspection Observations ................... 7-1 7.2.1 Sullivan #1..................................... 7-1 7.2.2 Sullivan #2..................................... 7-1 7.2.3 Sullivan Strat #1................................ 7-14 7.2 Site Assessment Conclusions ............................ 7-14 7.3 Action Plan ........................................ 7-14 RiskScreening ....................................... 8-1 8.1 Description of Methods ................................. 8-1 8.2 Results of Risk Screening ................................ 8-6 Benefit -Impact Evaluation ................................... 9-1 ActionRecommendation .................................... 10-1 Works Cited ............................................ 11-1 ANC10011DED.WP5 111 Contents (continued) Section Page Appendix A. Interim Site Assessment Guidance for Inactive Drilling Waste Sites Appendix B. Closure Documentation Reports Appendix C. Analytical Results Tables Number Page 7.1 Summary of Visual Inspection for Sullivan #1 ...................... 7-2 7.2 Summary of Visual Inspection for Sullivan #2 ...................... 7-5 7.3 Summary of Visual Inspection for Sullivan Strat #1 ................... 7-7 Figures 3.1 Site Study Plan for Reserve Pit Assessment and Closure ............... 3-2 4.1 Sullivan Wells General Location ................................ 4-3 4.2 Sullivan Wells Location Map .................................. 4-5 5.1 Sullivan #1 and Sullivan #2 Drill Site Locations .................... 5-3 5.2 Sullivan Strat #1 Drill Site Location ............................. 5-7 5.3 Sullivan Strat #1 Well Location ................................ 5-9 8.1 Risk Screening Procedure for Reserve Pit Assessment and Closure ........ 8-2 ANClool IDED.WPS iv Section 1 Declaration On the basis of information contained in this report, the reserve pit locations at the Sulli- van #1, Sullivan #2, and Sullivan Strat #1 wells should be declared non -locatable and no further action should be required by ADEC. The request for no further action is based on the following: • Field personnel were unable to locate the wellheads or reserve pits after searching more than eight staff hours on foot at each site; these structures are no longer identifiable. • The drill sites were located using survey information and a global position- ing system (GPS) device. No indication of stressed vegetation or other visual indications of waste effects on the environment could be detected at the well site locations. • The drill sites are covered with soil and indigenous vegetation • Natural geologic and biologic processes continue to erode or cover the drill sites with soil and deadfall. • Human access to the sites is restricted because the access roads no longer exist and thick vegetation prevents easy access. • Further site delineation or intrusive investigations could cause greater adverse impacts to human health and the environment than leaving the sites alone. ANCI001IDE2.WP5 1-1 Section 2 Summary The Sullivan #1, Sullivan #2, and Sullivan Strat #1 drill sites are located between Cape Yakataga and Icy Cape. The well sites are about 3 miles inland from the Gulf of Alaska. Sullivan #1 and Sullivan #2 are adjacent to the Little River. Sullivan Strat #1 is adjacent to the Big River. Drilling operations and disposal of drilling materials were conducted in accordance with a state -issued drilling permit. All three Sullivan wells were exploratory wells that were never placed into production. Sullivan #1 well was plugged and abandoned on December 28, 1955, Sullivan #2 well on March 21, 1957, and Sullivan Strat #1 well on May 19, 1954. Drilling records indicate that drilling fluids and cuttings at each site were discharged into an adjacent reserve pit. All equipment was removed after the wells were plugged and abandoned. A follow-up reserve pit assessment was completed during the summer of 1993. The follow-up assessment included: • Visual site inspection • Qualitative risk screening The drilling pads and reserve pits were completely overgrown with dense vegetation and could not be located. Reserve pit materials were apparently covered, or may have washed down the river. Geologic and biologic processes continue to change site conditions. An extensive ground search at each site failed to reveal any physical evidence of reserve pit materials or any impacts resulting from their presence. A qualitative risk -screening evaluation estimated that risks posed by the sites are negligible. An impact and benefit analysis of further investigative actions indicate that greater health and environmental risks would result compared to leaving the sites alone. The Sullivan #1, Sullivan #2, and Sullivan Strat #1 sites should be declared closed and no further investigation required. ANCIo011DE3.wP5 2-1 All reasonable steps were taken to locate the reserve pits and no evidence of a well head reserve pit, or impacts thereof could be identified at any of the three Sullivan locations. ANC10011DE3.WP5 2-2 Section 3 Closure Study Approach This section summarizes the approach and methods used to determine closure status. The June 1991 Interim Site Assessment Guidance For Inactive Drilling Waste Sites (Appendix A) was used as a guide in performing the site assessment work presented in this report. The decision framework, used to determine site status and proposed actions, consists of five parts, described as follows: • Preliminary site screening to determine site status • Site assessment studies, including a site visit, sampling, and data analysis • Qualitative risk screening and, if a basis for concern exists, the identification of corrective action alternatives • A benefit and impact evaluation of corrective action alternatives (if a basis for concern exists but the risk is negligible) • Preparation of a report documenting the site assessment findings, risk screening results, and the preferred alternative (if corrective action is warranted) or documentation of adequate closure (if no further action is warranted). Figure 3-1 illustrates a flow diagram of the closure study plan. 3.1 Preliminary Site Screening A preliminary site screening was performed to collect background information that will be evaluated for closure according to ADEC interim guidance. ANC1001 IDE4.WP5 3-1 Inconclusive Data Additional Sampling and Analysis Yes Records Review Background Information Site Visit Visual Inspection Soil & Water Sampling Evaluate Information Basis for Concern Step 1 Risk Significant Risk Risk Screening Negligible Step 2 Develop I Benefits > Impacts I Impact / Benefit Remediation Plan I Evaluation Data Adequate Impacts > Benefits Closure Report No FIGURE 3.1 SITE STUDY PLAN FOR RESERVE PIT ASSESSMENT AND CLOSURE rm-Pgum 3-2 Available company records and AOGCC records, including inspection reports, drill logs, letters, drilling permits, were reviewed to collect background information on the site. Information was collected pertaining to the type of reserve pit materials that may have been generated during drilling and the actions taken to close the site after drilling was completed. 3.2 Site Assessment Studies The purpose of the site assessment is to determine whether leachate, or eroded soil from the reserve pit is posing a threat to human health or the environment by violating Alaska state water quality standards. Existing site conditions and the potential for future violations were addressed. Each reserve pit location was visited and visually inspected on foot. Information was collected on the local environmental setting, a visual inspection was performed to document site conditions. 3.3 Qualitative Risk -Screening Procedure A qualitative risk -screening procedure was used to identify whether a site poses a signifi- cant threat to human health or the environment. The qualitative screening process is used to distinguish those waste sites with negligible risk from sites that have significant risk to human health and the environment. The process is considered to be appropriate for sites where target contaminant concentrations range from non -detectable to low levels. Informa- tion collected during the preliminary screening and site assessment was used to estimate the level of risk at each reserve pit site. A two-step decision process was used in the qualitative risk screening procedure. The first step established whether there was a basis for concern. To establish a basis for concern, evidence of chemical contamination exceeding water quality standards and the presence of potential biological receptors were necessary. The second step established whether the site is likely to present a significant risk to human or environmental receptors. To determine if the level of risk is significant, exposure criteria and consequence criteria were evaluated sequentially. Site -specific data were reviewed to estimate contaminant release mechanisms, ANCIoo11DF4-AVP5 3-3 migration potential, and environmental persistence of contaminants. Human and wildlife use patterns were reviewed at each site to estimate the exposure risk based on duration or frequency of exposure to measured contaminants. If the risk was considered to be significant, conceptual remediation options to reduce the risk were presented. 3.4 Closure Alternatives and Benefit and Impact Evaluation If the risk -screening model indicated that probable risk is negligible, the impact and bene- fits of further action were considered. If it is estimated that the impacts from corrective action would be greater than leaving the site alone, the site could be considered to be adequately closed. 3.5 Closure Report This task involves consolidating the above information into a closure report documenting the findings from the application of the screening procedures at each inactive reserve pit location. This closure report follows the report format recommended in Section V of the ADEC June 1991 Interim Site Assessment Guidance For Inactive Drilling Waste Sites. ANCIOOI IDE4.WP5 3-4 Section 4 Waste Site Identification, History, and Status 4.1 Location The Sullivan #1, Sullivan #2, and Sullivan Strat #1 wellheads are located on lands between the Malaspina Glacier and Cape Suckling in an area referred to as Icy Bay (Figure 4.1). The wells are situated about 3 miles inland from the Gulf of Alaska, adjacent to the Little River (Figure 4-2). A legal description of the Sullivan #1 location follows: Southern half of the northwest quarter of Section 10, Township 22 South, Range 21 East, Copper River Meridian Latitude: 60001' 19.9"N Longitude: 141048'57.5 V A legal description of the Sullivan #2 location follows: Eastern quarter of Section 9, Township 22 South, Range 21 East, Copper River Meridian Latitude: 60001'02.40"N Longitude: 141 °49'01.4 V A legal description of the location is as follows: The northeast corner of the northwest quarter of the northeast quarter of Section 20, Township 22 South, Range 22 East, Copper River Meridian Latitude Longitude: 60°00'04'N 141 °40'57'V ANCIo01 I DE5.wP5 4-1 4.2 Landowner The landowner of all three Sullivan wells is the State of Alaska. 4.3 Operator The operator for all three Sullivan wells was Phillips Petroleum Company. 4.4 History of Operation All three Sullivan wells were wildcat exploratory wells never placed into production. Drilling for the Sullivan #1 well began on June 19, 1954, and was completed on December 28, 1955. The maximum well bore depth was 10,013 feet. Drilling for the Sullivan #2 well began on January 23, 1956, and was completed on March 21, 1956. The maximum well bore depth was 12,056 feet. Drilling for the Sullivan Strat #1 well began on April 11, 1954, and was completed on May 19, 1954. The maximum well bore depth was 4,837 feet. A review of the sites' drilling records indicates that freshwater -based muds were used in the drilling process. The viscosity of the drilling fluid was adjusted on an as -needed basis during the drilling operation. The muds at Sullivan #1 and #2 were spotted with diesel at various depths during the drilling operation to facilitate drill string lubrication. At Sullivan #2, calcium chloride and diesel oil were added to the bentonite muds during drilling, and salt water was added at various phases of operation. The size and location of reserve pits is not mentioned in the drilling records of these sites, although the standard practice at the time these wells were drilled was to excavate a reserve pit within about 100 feet of the well. Sullivan #1 was plugged and abandoned on December 28, 1955, Sullivan Strat #1 on May 19, 1954. Sullivan #2 was plugged and abandoned on March 21, 1957. The top well casing was plugged with 25 sacks of cement and a 4-inch-diameter casing_ marker, extend- ing 4 feet above the ground, was placed above the well. ANCIOOI IDE5.WP5 4-2 'rY .5fios r Fat Gt i 1• a O A �✓ O . pt g N NUT L` , vass6 r 1 Baavw Nislir Oemisl:dn L°dg° Z 0 N a `a P e � � � el .5a00 C2<e ,C°oPca l'155 'ALLLIf 1E PK, �-4C O�one t F .6e5� P t�ao� � .i'��hlsan r . aKoWe . s e Tltln� T av , � clae a] r is 5 eA55. "' L IBOW Cre I LINE f 5\'• n860 G E. L -. .J. �_ A. %�R ower�MS I oso �L SIR> TBnsI a'; V �Ke LNlni(J l t�R I/ �' Dam CIRn g. tell°kovlaS l �Mc PTara6_ a ♦ ` NI a iE 1 L� Tleael Q° 7J9) SPIgR (a _E PI. :.gl a�ns "� r,j'Tt!'�•mner .84 55 WFA., R,'A,T r56f0a11 Aflf 595 Q / � �! M1IT OUEEII 65 ,aJ50 )JJO O0.00VA Yx EROSW�� 1985 i�Ia�TACV 16;/a 1. R� , s Ems/ l,rook 1 -4�'" 13 Sullivan Wells OF I ALASIKA 0 40 80 SCALE IN MILES Glai r/rt: _ /' Knight .85e0 �+ Cr ra f365' FIGURE 4.1 SULLIVAN WELLS GENERAL LOCATION Phillips Petroleum Company Icy Bay, Alaska rune c r 4 i Sullivan #1 1))llit�i��'` 11111i� l Sullivan #2 e - 16 23 za Sullivan #1 Sirat It i3 p GULF OF ALASKA 36 0 1 2 SCALE i 'Lppl n 0 4 ,S i Ytl � 4 Q 31 32 1 0= s OWN/u/ (Sitrli i FIGURE 4.2 SULLIVAN WELLS LOCATION MAP Phillips Petroleum Company Icy Bay, Alaska nF�um 4.5 Closure Status The Sullivan #1 well site was closed in accordance with requirements in existence at the time of closure. The well was closed by cementing it shut. It is believed that excess drilling fluids were discharged down the well before abandonment and the remaining reserve pit solids were covered with soil. The Sullivan #2 well site was closed in accordance with requirements in existence at the time of closure. The drilling records do not mention the use or closure of a reserve pit. The site was closed by cementing the well shut and placing a 4-foot-high marker over the well. The Sullivan Strat #1 well was plugged and abandoned in accordance with closure requirements in existence at the time of closure. The site was closed by cementing the well shut. ANC1oo11DE5.WP5 4-7 Section 5 Site Description 5.1 Sullivan #1 Wellhead Marker The Sullivan #1 wellhead marker and reserve pit(s) could not be located by the field team, either from the ground or from the air (Figure 5.1). A Trimble Navigator Global Positioning System (GPS), a Bering Glacier A-3 quadrangle topographic map, and Brunton field compass were used to establish (with an accuracy of 75 feet) the wellhead location (Figure 5.1). Once this location was established, a sur- rounding 300-foot by 500-foot-square area was searched for remnants of a wellhead, reserve pit, and well site debris. A description of the well site area follows. Well Site Area The Sullivan #1 well site area is situated on a 15-foot-high bluff 200 feet from the Little River, in an area where the river flows into the mouth of a canyon. The well site is about 0.5 mile southeast of the toe of Lare Glacier, the source of the headwater to the Little River. The access road to the well site was washed out about 4 years ago, according to a local resident. The well site area is relatively flat, with large logs and overburden that had been pushed into the riverbed by a bulldozer. The logs were stacked parallel to the river. In addition to the logs, the only physical remnants indicating a former drill site were an old stove pipe, an empty rusted barrel, and a 1.5-inch-diameter steel cable, extending from the river bank to the bluff. Remnants of a Butler building used in drilling operations was found in the vicinity of the drill site locations. The presence of fine-grain backwater deposits and hemlock and spruce trees indicates that this area has been flooded by the Little River in the past. The vegetation consists of hem- lock and spruce trees with 2-inch-diameter trunks, alders more than 10 feet in height, salmonberry bushes, devil's club, and ferns. ANC10011DE6.WP5 5-1 The site is remote. It can be accessed in summer by helicopter and foot travel. 5.2 Sullivan #2 Wellhead Marker The Sullivan #2 wellhead marker and reserve pit could not be located by the field team, either from the ground or from the air (Figure 5.1). References, including GPS, a Bering Glacier A-3 quadrangle topographic map, and Brunton field compass, were used to ascertain (with an accuracy of 75 feet) the wellhead location. Once this location was established, a surrounding 75-foot by 75-foot-square area was searched for visible remnants of a wellhead, reserve pit, and well site debris. Well Site Area According to Phillips correspondence, the Sullivan #2 well was drilled 'only a few feet from Little River, which flows in a south-southeast direction from Sullivan #1" and about 1,280 feet south from Sullivan #1. The area investigated is situated in a low-lying area along the river bank that, based on its position, is probably flooded by the river at least every spring during breakup. The flooding appears to be quite severe as evidenced by a very large tree (with trunk 5 feet in diameter) that was undercut, swept downriver, and deposited below Sullivan #2.). The ground is wet and swampy with ponded surface water throughout the area. According to a local resident, the access road to the Sullivan #1 and #2 sites was washed out about 4 years ago. Vegetation consists primarily of alders less than 8 feet in height in boggy, swampy areas. No physical remnants of drilling were found at the site. The site is remote. It can be accessed in summer by helicopter and foot travel. There are no roads leading directly to the well site. ANC1001IDE6.WP5 5-2 Location of Sullivan #1 and #2, looking north. Approximate search areas are highlighted. Establishing wellhead location for Sullivan #1 by using GPS. FIGURE 5.1 SULLIVAN #1 and SULLIVAN #2 DRILL SITE LOCATIONS JULY 1993 5.3 Sullivan Strat #1 The Sullivan Strat #1 wellhead marker and reserve pit could not be located by the field team. Reconnaissance of the site by air was unsuccessful because of the amount of vegeta- tion covering the site (Figure 5.2). A Bering Glacier A-2 quadrangle topographic map, GPS, and a Brunton field compass were used in searching for the Sullivan Strat #1 wellhead location. The location was established with an accuracy of about 75 feet. A 500-foot by 500-foot-square area was searched for visible remnants of a wellhead, reserve pit, and well site debris. The search area was later expanded to a 0.5-mile by 2-mile area that included the west bank of the Big River. Well Site Area The Sullivan Strat #1 well site area is on an active river floodplain terrace, about 0.5 mile southwest of the toe of Beare Glacier, and 4 miles northeast of the mouth of the Big River (Figures 5.2 and 5.3). The site is bordered to the west and north by the steep slope of an adjoining terrace that rises about 100 feet above the site. To the east and south the site is bordered by the Big River. Big River was formed by glacial runoff from Beare Glacier and rain and snow meltwater from the surrounding mountains. In this case, an artesian spring, found 20 feet from the ice of Beare Glacier, supplies Big River with a constant supply of water, which is supplemented with rain and meltwater. The only visible remnants of drilling activities were an old stove pipe, four lengths of 9-inch-diameter drill rod covered by the forest carpet, and two rusted empty barrels. Active geological processes affecting the well site area include: • Flooding • Landslides from the adjoining ridge No signs of a wellhead marker or reserve pit remain. The drill site access road constructed by Phillips has also been undercut and buried by the Big River. No visible signs of the road were evident. ANC10011DE6.WP5 5-5 The entire area is covered by a thick foliage, which includes hemlock and spruce trees, alder, salmonberry bushes, devil's club, and a forest mat. The largest hemlock and spruce trees (with trunks up to 24 inches in diameter) are located next to the adjoining terrace, with alder and birch cover near the river. This suggests that the area is periodically flooded to the base of the adjoining terrace. The site is remote. Access to the site is primarily by helicopter and foot travel in summer. A logging road is located about I mile west of the site. ANCI001 IDE6.WP5 5-6 Sullivan Strat #1 location, looking north. Beare Glacier in upper right hand corner of photo. Sullivan Strat #1 location, looking north. Approximate area of site is highlighted. Toe of Beare Glacier and FIGURE 5.2 head of Big River in upper right hand corner. SULLIVAN STRAT #1 DRILL SITE LOCATION JULY 1993 Sullivan Strat #1 well site area in trees on first terrace, looking southwest. FIGURE 5.3 SULLIVAN STRAT #1 WELL LOCATION JULY 1993 Section 6 Environmental Setting 6.1 Geology and Soils This section describes the environmental setting of three wells —Sullivan #1, Sullivan #2, and Sullivan Strat #1, which are located near each other in a similar environment. Many geological field investigations have mapped the region surrounding the Sullivan #1, Sullivan #2, and Sullivan Strat #1 drill sites, mainly because of the deposits of oil, natural gas, coal, and hard metals that have been found in the region, and the glaciation found throughout. Relevant sources of information used to describe the geology and soils of the area include G. Plafker, T. Hudson, M. Rubin and K. Dixon (from 1975 to 1980); M. Miller in 1955; L. Yehle (1977); D. Miller (1951); R. Kachadoorian (1963); C. Wahrhaftig (1965); and T. Pewe (1975). Regional Physiographic and Geological Setting The Icy Bay drill sites are in the Pacific Border Range physiographic subprovince, within an informal section called the Gulf of Alaska Coastal section in the Bering Glacier Region. The region is bordered to the north by the Kenai -Chugach Mountain section (extremely rugged ridges rising 7,000 to 13,000 feet, the higher peaks draped with ice fields that feed valley and piedmont glaciers); to the northeast and east by the St. Elias Mountain section (massive, isolated peaks 14,000 to 20,000 feet high, separated by a myriad of narrow ridges and sharp peaks 8,000 to 10,000 feet high that are drained by a network of glaciers); to the west by the Copper River lowland; and to the south by the Gulf of Alaska. The Bering Glacier subregion coastal area is a massive unit of ice and glaciers cut by one major estuary —Icy Bay. Within the subregion, the drill sites are located in a low foreland that ranges in width from 0.5 to about 5 miles at Munday Creek and Icy Cape, respectively. The foreland, immediately backed by the rugged Yakataga Mountain front, consists of a sequence of marine terraces and glacial moraines that rise from sea level to 400 feet within 4 miles. ANCIOOIIE46.WP5 6-1 Bedrock in most of the study area consists of Tertiary- and Holocene -age marine and continental clastic rocks, which range from 1.8 to 65 million years in age, and are broadly divisible into three subdivisions. The subdivisions are (1) an early Tertiary sequence (40 to 65 million years of age) of hard, dense siltstone and sandstone that is variably deformed and highly faulted, and associated volcanic rocks along with shallow marine coal bearing clastic rocks; overlain by (2) a middle Tertiary sequence, (30 to 40 million years of age) composed of mudstone and siltstone; and followed by (3) a late Tertiary through Holocene sequence called the Yakataga Formation, consisting of a marine diamictite characterized by abundant glacial detritus, muddy sandstone, and conglomeratic sand mudstone. The Yakataga Formation reflects deposition adjacent to the intensely glaciated Fairweather Mountains that border the sites; deposition of these strata probably correlates to uplift of these mountains. The Yakataga Formation is also found directly off the shoreline of the study area as a barrier reef called the Yakataga reef. The Icy Bay area is at the continental margin, lying in a tectonically active transition zone between transform and convergent plate motion. The transition zone is informally called the Pamplona zone, a seismic gap that connects the Aleutian trench and volcanic arc to a transform fault system, composed of the Queen Charlotte, Fairweather, and related fault. The transorm fault system was caused by the Pacific plate moving past the North American plate (transform motion). The Aleutian trench and arc were caused by the underthrusting of the Pacific plate beneath the continental margin (convergent plate motion). Visible evidence associated with the convergentent and transform motion includes complex folds and faults and volcanic cones in the Wrangell Mountains, and ongoing uplift of terrane at the rate of about 3 inches per year in the Icy Bay area. Faults in the immediate area of the drill sites include the Fairweather Fault system and related local drag faults such as the Sullivan fault and the Yakataga fault. Uplift of the Yakataga block within the Pamplona zone is at. an average rate of about 3 inches per year. The major faults do not appear to have been active within the past 5,000 years; future extreme uplift of the areas would most probably occur during a major earthquake along the convergent plate margin. However, the area is in a zone of high seismic activity, where many earthquakes greater than 6.0 in magnitude on the Richter Scale, four greater than 8.0, have occurred since 1899 and are likely to continue to occur. ANCIOOI IFA6.WP5 6-2 Several volcanoes located in the region have also been active in the past 100 years. These include Iliamna, Redoubt, Spurr, and Saint Augustine, each of which have the potential of becoming active at any time. Regional Geomorphology and Related Surficial Deposits The Tertiary rocks are overlain with marked angular unconformity by essentially horizontal, unconsolidated deposits of Quartemary age (1.8 millions years of age to present). Deposits are made up of a complex sequence of neoglacial fluvial, lagoonal, beach, and marine terrace deposits. Marine Terrace and Beach Deposits The forelands consist of a sequence of three marine terraces containing beach, barrier island, and backwater lagoonal deposits. The terraces, a product of paleoearthquake uplift, are in evidence from Cape Yakataga to Big River and have elevations of about 50, 75 and 160 feet, rising toward the glaciated Robinson mountains. Terrace beach and barrier island deposits are granular, generally consisting of sand and gravelly sand to pebbly cobble gravel with some boulders. Terrace backwater lagoonal deposits (overlying the beach and barrier island deposits) are fine, chiefly sand, silt and organic silts. The two higher terraces are also mantled by talus, slopewash and alluvial deposits caused by glacial fluctuations of Guyot, Lare, and Bear glaciers, and increased sediment supply caused by uplift. The lowest terrace and the modern shoreline deposits are built principally by waves and longshore currents. Such deposits include barrier beaches, spits, barrier islands, and forelands. Deposits are granular deposits, generally consisting of sand and gravelly sand, to pebbly cobble gravel with some boulders. Glacial Deposits The absence of recognizable marine terraces east of Big River and the broad foreland in the Icy Cape area are primarily the product of repeated glacial advances and retreats over the last 40,000 years. Glacial retreats have resulted in two recognizable topographic ANCIOOI IE46.WP5 6-3 subdivisions: (1) ground moraines, (2) terminal or lateral moraines, and (3) outwash land - forms associated with moraines. Extensive outer and inner terminal moraines were deposited as marine glacial till during the last advance of Guyot Glacier. The moraines, visible as well developed low ridges, extend between Big River and Icy Cape, and northeastward from Icy Cape. These deposits generally consist of till composed mainly of diamicton—a poorly sorted mixture of clay, silt sands, and gravel plus occasional boulders. Well -sorted, discontinuous lenses of sand and sandy gravel are also found throughout. Other principal glacier -related features found in the area are outwash channel deposits, laid down by meltwater within or just outside the bounds of the glaciers. Outwash train and valley train deposits were laid down by meltwater streams that extended beyond the mar- gins of the glaciers either in existing valley streams or in channels newly eroded through the moraines. Outwash channel deposits are mostly bedded sands and gravels. Outwash train and valley train deposits are chiefly well -bedded granular material consisting of sands and gravels. Alluvial and Colluvial Deposits Most nonglacial deposits in the area are recent, having been deposited on top of or cutting through the glacial deposits within the last 100,000 years. These include alluvial, colluvial, and landslide deposits, plus bog, pond, and lake deposits. Alluvial deposits originate by deposition from streams, and most include large quantities or reworked glacial outwash. These deposits include stream valleys within active floodplains and alluvial fans and cones that occur mainly where small streams debouch onto valley floors of major creeks and rivers. Alluvial stream deposits generally consist of granular materials that include well -bedded sands and gravels, with silty sand found in bars and very low terraces subject to continual reworking by the rivers, finally graded at sea level. Stream deposits are generally not covered by vegetation. Some fine silts and sands are found in valley bottoms and low terraces along low -gradient streams. Colluvial deposits, or colluvium, are deposits that have accumulated on or along the flank and base of slopes with the aid of gravity and running water. The source of colluvium is often a combination of eroded morainal or alluvial deposits and underlying bedrock; they ANCI0011FA6VP5 6-4 are generally irregularly mixed fragments of many sizes, unsorted and loose. Colluvium generally occurs as a downslope-thickening wedge of silts and sands, with some gravel, clay, boulders and bedrock fragments. Landslide deposits are developed as immediate, one- time gravitational failures along discrete buried surfaces in soft sedimentary rock or overlying surficial deposits. They occur as single slides along the incised stream valley walls and generally consist of diamicton, relatively minor amounts of clay and some organic material, as well as boulders and relatively large masses of bedrock. Bog, pond, and lake deposits are less well distributed throughout the study area, but where found, often cover other surficial deposits that extend beneath them. These deposits consist chiefly of peat (mosses, sedges, and other decomposing organic debris) and organic silt within minor woody horizons and numerous thin interbeds of tephra ash. Deposits also occasionally include clay and fine sand. Site Soil Information on the soil was obtained from a previous investigations conducted by CH2M HILL personnel, a field investigation in July 1993, and original drilling logs. Generally, site conditions consisted of at least 1 foot of organics and organic silts, and associated active floodplain deposits. These are generally underlain by sands and gravels to depth with an occasional diamicton layer at depth. 6.2 Regional Hydrogeology Little River and Big River are typical of streams found throughout the southern part of the subregion: short and swift glacial -fed streams with large sediment loads reworking alluvial and outwash deposits. Big River starts as an artesian spring at the margin of Bear Glacier; additional water is drained from surrounding mountains as rain and snow meltwater. Little River begins at the margin of Laze Glacier; again additional rain and meltwater is drained from surrounding mountains. Both rivers empty into the Gulf of Alaska, with extensive deltas and channels blocked by longshore transport of sediments running parallel to the beach for varying lengths. ANCI0011FA6.wP5 6-5 Regional groundwater flow predominates in direction from the mountains and glaciers toward the Gulf of Alaska. Regional groundwater flow is evidenced by seeps along the shoreline bluffs of the first marine terrace south of the well sites. 6.3 Climate The principal factors affecting the climate include latitude and geographic position relative to glaciers, large land masses, and the Gulf of Alaska. The Cape Yakataga to Icy Bay area is a maritime climate strongly affected by the Gulf of Alaska. Inland mountains, rising more than 10,000 feet, cause offshore winds to drop their moisture. With no terrain influences involved, annual extremes in precipitation and temperature often occur. These extremes result from outbreaks of extremely cold air in winter and relatively hot air in summer from Interior Alaska. Precipitation The weather station measuring precipitation closest to the Icy Bay well sites is at the Cape Yakataga airstrip on the shore of the Gulf of Alaska. The station is at an elevation of 30 feet. Continuous measurements have been recorded since 1943. Average annual precipitation is 134 inches. Rain, fog, and overcast skies occur on an average of about 80 percent of the days in the summer, although there is great variation between summers of different years. Temperature Seasonal variations are exaggerated because of the reduced number of daylight hours during the winter. January has the lowest monthly mean temperature at 27.7°F. July has highest monthly mean temperature at 53.1°F. Average monthly temperature is 40°F with a daily temperature fluctuations averaging 9.5°F. The monthly mean temperature is almost continuously below freezing for 3 months of the year. Ponds and other stagnant surface water surrounding the site can be expected to be frozen for about 3 months of the year. ANCIOOI W6.WP5 6-6 Wind Winds are generally out of the south in the summer and out of the north in the fall, winter, and spring. Average offshore wind speeds are moderate at 12 to 18 knots; however, winds of 75 to 100 knots can occur over the open water and storms with 50- to 75-knot winds occur every winter with wind speeds of up to 100 knots recorded. Winds are lightest in the summer months. 6.4 Natural Resources The primary natural resources near the well sites that have proven or potential economic value located include logging, commercial fishing, and gold mining. The area near the Sullivan Strat #1 well site has been logged in the past. Additional log- ging to the south and east is currently underway. The area directly surrounding Sullivan #1 and #2 has not been logged because of steep terrain and both wells falling within "buffer zones" around rivers and creeks where logging is prohibited. Icy Bay and the shoreline directly off the well sites contains commercial fisheries that include Pacific salmon and king, tanner, and opilio crab. This information was obtained through firsthand observations of fishing boats plying the waters off Yakataga Reef in the Gulf of Alaska, Icy Bay, and the Copper River drainage. The Icy Bay area has also been the site of limited placer gold mining activity (especially to the north along the White River) and extensive exploration since the turn of the century. Placer gold has been found in all three terraces in past investigations by personnel currently employed by CH2M HILL. Much of the land in the area is closed to mining. 6.5 Biological and Ecological Resources The area surrounding the well sites is densely forested. Because of the steep topography in much of the region, the forest is confined to a relatively narrow strip bordering most of the coastal areas and extending up the valleys and terraces. Mountain hemlock is the major constituent of most of the coniferous forest, although Sitka spruce is also common. ANC1OO11E46.WP5 6-7 Western hemlock, Alaska cedar, cottonwood, aspen, white spruce, and paper birch are also present in the area. The forest understory includes a variety of shrubs such as alder, blueberry, lingonberry, huckleberry, mountain ash, devil's club, red -berried elder, copper - bush, and salmonberry. Ground cover is dominated by mosses, and there is a wide variety of herbs, ferns, mosses, dwarf dogwood, twisted stalk, goldthread, and five -leaved bramble. Invertebrates, such as nematodes, protozoans, and earthworms, inhabit soil and forest litter. Spiders and insects are common in the area. Mosquito and other insect larvae develop and feed in freshwater ponds and puddles. Moose, brown and black bear, and Sitka blacktail deer are common in the Icy Bay region. Bears feed in coastal grass and sedge flats or forage along the beaches in the spring and early summer. As summer progresses, the bears congregate along streams to feed on salmon. Other terrestrial mammal species found in the area include mink, land otter, wolverine, red fox, wolf, coyote, lynx, beaver, muskrat, marten, weasel, red squirrel, and snowshoe hare. A variety of sport fish can be found in nearby streams, including arctic char, Dolly Varden, and lake trout. Also, all five species of Pacific salmon spawn in the various clearwater streams of the Icy Bay region. 6.6 Historical Resources There are no known historical resources within 1 mile of the well sites. 6.7 Human Resources The well sites can be reached by helicopter or by walking at least 2 miles from a logging road that runs from the White River (near the community of Cape Yakataga), which is about 20 miles west, to the Sullivan Logging Camp at Icy Bay, about 10 miles east of the site. There are fewer than 50 residents in Cape Yakataga and, according to the camp manager, Sullivan Logging Camp will have fewer than 100 residents during peak produc- tion. There are also a few barricaded, abandoned and overgrown logging spur roads in the ANC10011E46.WP5 6-8 vicinity of the area where the Sullivan Strat #1 well site was located. Hunters sometimes travel these roads in the Icy Bay region. ANCI001 IE46.WP5 6-9 Section 7 Site Assessment Site visits were conducted to provide support documentation for reserve pit closure. A visual inspection of the site was conducted to satisfy requirements of the Qualitative Risk Screening Procedure. The results of the site visit are described below. No sampling was conducted at the Sullivan well sites. 7.1 Sampling Program and Results No visible remnants of wellhead markers, pads, or reserve pits were found in the areas where Sullivan Strat #1, Sullivan #1, and Sullivan #2 were thought to have been located. Because no reserve pit areas could be located, it was deemed inappropriate to sample soil or surface water. 7.2 Summary of Visual Inspection Observations 7.2.1 Sullivan #1 On July 19, 1993, a three -member CH2M HILL field team spent about 4 hours trying to locate the Sullivan #1 well site in heavy foliage near the Little River and Lare Glacier. The following day, a survey conducted from the air was unsuccessful in locating the former well site area. Inspection results and observations are summarized in Table 7.1. 7.2.2 Sullivan #2 On July 19, 1993, a three -member CH2M HILL field team spent about 3 hours trying to locate the Sullivan #2 well site in heavy foliage near the Little River and Lare Glacier. Although visible remnants of the well head or reserve pit were never found on the ground, from the air, or in aerial photographs, CH2M HILL conducted a site inspection for ANC10011E4EMP5 7-1 Table 7.1 Summary of Visual Inspection for Sullivan #1 ]of2 Page 1 Parameters Yes/No Comments Evidence of reserve pit materials No No apparent evidence of drilling muds or formational cuttings, or even of reserve pit location. Plus, according to drilling records, drilling wastes were injected downhole for disposal. Evidence of leakage through NA impoundment dike walls Evidence of leakage or seepage through cover, such as: I. Damp/wet spots 1. No 1. No apparent wet/damp spots, entire area investigated was part of a floodplain. 2. Areas of dead or lush 2. No 2. No unusual vegetation patterns noted, vegetation extreme vegetation throughout area. 3. Aquatic vegetation in 3. No 3. No seeps therefore no aquatic vegetation in perennial seeps seeps. Evidence of leakage or seepage NA through the dikes. Evidence of impoundment No No apparent evidence of impoundment overflow overflow, such as: denuded duectly related to reserve pit seen downgradient areas, insufficient freeboard, erosion of dikes or downstream area Vegetation stress No No apparent stressed vegetation in well site area observed from ground or during aerial inspection Excessive erosion No No excessive erosion observed during ground or aerial inspection Slope instability NA Uniform subsidence or differential NA settling Surface ponding or standing liquid NA on cover Effects of natural events Yes Entire well site area within a floodplain. Several such as floods, landslides, etc. inches of floodplain deposits found throughout. Evidence of animal activities that NA may have damaged impoundment dike walls or covers ANC1001I829.WP5 7-2 Table 7.1 Summary of Visual Inspection for Sullivan #1 Page 2 of 2 Parameters Yes/No Comments Potential for surface water Minimal potential; well site area is gaining cover contacting waste material (floodplain deposits) Evidence of surface debris Yes Rusted barrel, old tin stove pipe, and a 1.5-inch- diameter steel cable running from the site to the Little River was found. In addition, several lengths of 5-inch-diameter drill rod were found downstream of the well site, but upstream of Sullivan #2. Evidence of stained soils No No apparent staining in well site area. ANC10011829.wP5 7-3 conditions suggested in the ADEC guidelines. Inspection results and observations are sum- marized in Table 7.2. 7.2.3 Sullivan Strat #1 On July 19, 1993, a three -member CH2M HILL field team spent about 5 hours trying to locate the well site for Sullivan Strat #1 in heavy foliage near the headwaters of the Big River and Beare Glacier. An attempt was also made to locate the site from the air. Although visible remnants of the wellhead or reserve pit were never found on the ground, from the air, or in aerial photographs, CH2M HILL conducted a site inspection for specific conditions suggested in the ADEC guidelines. Inspection results and observations are summarized in Table 7.3. 7.3 Site Assessment Conclusions Because the drill sites could not be located, no surface soil or surface water samples were collected or analyzed at Sullivan #1, Sullivan #2, or Sullivan Strat #1. Visual inspections did not identify any evidence of reserve pits or impacts thereof. No evidence of a well head or reserve pit could be identified at the reported location of the Sullivan wells. 7.4 Action Plan Action plans were not prepared for the Sullivan well sites because the available site data indicate negligible risk to human health and the environment due to reserve pit materials. Any action at these sites would require mobilization and demobilization of personnel and equipment, thus posing greater risks to human health and the environment than the no further action alternative. ANC100I1E4EMP5 7-4 Table 7.2 Summary of Visual Inspection for Sullivan #2 Page 1 of 2 Parameters Yes/No Comments Evidence of reserve pit materials No No apparent evidence of drilling muds or formational cuttings, or even of reserve pit location. Plus, according to drilling records, drilling wastes were injected downhole for disposal. Evidence of leakage through NA impoundment dike walls Evidence of leakage or seepage through cover, such as: 1. Damp/wet spots 1. No 1. No apparent wet/damp spots, entire area investigated was part of a floodplain. 2. Areas of dead or lush 2. No 2. No unusual vegetation patterns noted, vegetation extreme vegetation throughout area. 3. Aquatic vegetation in 3. No 3. No seeps therefore no aquatic vegetation perennial seeps in seeps. Evidence of leakage or seepage NA through the dikes. Evidence of impoundment No No apparent evidence of impoundment overflow overflow, such as: denuded directly related to reserve pit seen. downgradient areas, insufficient freeboard, erosion of dikes or downstream area Vegetation stress No No apparent stressed vegetation in well site area observed from ground or during aerial inspection Excessive erosion No No excessive erosion observed during ground or aerial inspection Slope instability NA Uniform subsidence or differential NA settling Surface ponding or standing liquid NA on cover Effects of natural events Yes Majority of well site area within active floodplain. such as floods, landslides, etc. Rest of well site area would lie in what is now the Little River stream channel. Evidence of animal activities that NA may have damaged impoundment dike walls or covers ANCI001182C.wP5 7-5 Table 7.2 Summary of Visual Inspection for Sullivan N2 Page 2 of 2 Parameters Yes/No Comments Potential for surface water Minimal, area has been extensively reworked by contacting waste Little River in the last 39 years since drilling. Evidence of surface debris Yes Several lengths of 5-inch-diameter drill rod were found downstream of the well site. Several pieces of siding from Butler building found downstream. Evidence of stained soils No No apparent staining in well site area. ANC 1001182C NP5 7-6 Table 7.3 Summary of Visual Inspection for Sullivan Strat #1 Page 1 of 2 Parameters Yes/No Comments Evidence of reserve pit materials No No apparent evidence of drilling muds or formational cuttings, or even of reserve pit location. Plus, according to drilling records, drilling fluids were injected downhole for disposal. Evidence of leakage through NA impoundment dike walls Evidence of leakage or seepage through cover, such as: 1. Damp/wet spots 1. No 1. No apparent wet/damp spots, entire area investigated was part of a floodplain. 2. Areas of dead or lush 2. No 2. No unusual vegetation patterns noted, vegetation extreme vegetation throughout area. 3. Aquatic vegetation in 3. No 3. No seeps therefore no aquatic vegetation in perennial seeps seeps. Evidence of leakage or seepage NA through the dikes. Evidence of impoundment NA overflow, such as: denuded downgradient areas, insufficient freeboard, erosion of dikes or downstream area Vegetation stress No No apparent stressed vegetation in well site area observed from ground or during aerial inspection Excessive erosion No No excessive erosion observed during ground or aerial inspection Slope instability NA Uniform subsidence or differential NA settling Surface ponding or standing liquid NA on cover Effects of natural events Yes Entire well site area within a floodplain. Several such as floods, landslides, etc. lengths of 9-inch-diameter drill rod buried by several inches of floodplain deposits Evidence of animal activities that NA may have damaged impoundment dike walls or covers ANC10011828.WP5 7-7 Table 7.3 Summary of Visual Inspection for Sullivan Strat #1 Page 2 of 2 Parameters Yes/No Comments Potential for surface water Minimal potential; well site area is gaining cover contacting waste material (floodplain deposits) and colluvial deposits from debris slides off of adjoining steep - sloped ridge. Evidence of surface debris Yes Found four lengths of 9-inch-diameter drill rod, an old tin stove pipe, and three -rusted out, empty barrels. Evidence of stained soils No No apparent staining in well site area. ANC100I1828.WP5 7_8 Section 8 Risk Screening 8.1 Description of Methods This section describes the methods used for performing the qualitative risk screening and describes the results of the process. Qualitative risk screening was used to identify whether a site is likely to have a significant impact on human health or the environment. A two-step decision process was used in the qualitative risk screening procedure. The first step established whether there was a basis for concern of a risk. The second step estab- lished whether the waste site is likely to present significant risk to human or environmental receptors. The risk screening process is summarized in Figure 8.1. To determine if a basis for concern exists, the information from the visual inspection and sampling program was reviewed. A basis for concern was determined to be present if a biological receptor was located within the zone of chemical contamination and either of the following was true: • Evidence of release of chemical contamination at the waste site was in excess of Alaska water quality standards for one or more target compounds • A mechanism for release of waste or byproducts of the waste was present If either the mechanism for potential release or the proximity to biological receptors risk factors is not present at a site, there is no basis for concern and the site should not require further study or corrective action. If the mechanism for potential release exists at the site and biological receptors risk factors are present, there is a potential risk and the risk screening progresses to the second step. If a basis for concern exists, it must be determined whether the risk is significant. The level of risk is determined by the extent of exposure and the potential consequence of that exposure. ANC10011E55.wP5 8-1 m Receptor exposure is considered to be likely when the following apply: • Contaminant release mechanisms are estimated to be significant • Contaminant migration is estimated to be significant • One or more contaminants are environmentally persistent Contaminant release mechanisms were considered to be significant if target compounds associated with a waste site were found in higher concentrations in adjacent water and soil than in background locations, or if other physical characteristics of a site indicated that waste could be released. Visual evidence of physical release mechanisms may include erosion, unstable areas, flooding, or exposed waste. The type, quantity, and age of the waste are important factors that may effect the release potential of a site. The contaminant migration potential can be measured directly if sampling data are available for offsite locations downgradient from the reserve pit. If no direct evidence of migration is available, the migration potential was assessed indirectly by evaluating the likelihood that a mechanism exists to mobilize the soluble constituents from the source. The migration mechanisms of greatest interest at reserve pits are surface water movement and the percolation or channeling of surface waters through soil to groundwater. Topography exerts an obvious influence on surface water movement, and in many settings is an easily observed migration mechanism. Wind action and freeze and thaw cycles may also influence surface water movement from reserve pits. Hydrogeology and soil conditions affect groundwater travel times and attenuation. Environmental persistence is evaluated in terms of the current levels of contamination relative to the age of the pit, or natural persistence in the environment. Factors contributing to persistence include resistance to biological or chemical degradation. If exposure is found to be unlikely, there is no need to evaluate the consequence criteria that follows. A finding of negligible risk is made on the basis of absence of a likely expo- sure term. The action plan is then evaluated in Section 9 under the impact and benefit evaluation. If any one of the exposure criteria are satisfied, a finding is made that exposure is likely. Screening continues to evaluate the potential consequence of exposure. ANCI0011E55.WP5 8-3 Adverse consequences of exposure to constituents from reserve pits are considered to be likely when the duration or frequency of exposure is sufficient to cause adverse health or environmental effects and either of the following apply: • The quantity or concentration of one or more contaminants exceeds pertinent federal or state water quality criteria or standards protecting health or the environment • One or more contaminants exhibit high acute toxicity The likelihood that exposure duration or frequency would be sufficient to cause adverse health or environmental effects is evaluated by reviewing human and wildlife use patterns at a given waste site, waste site accessibility, and ground and surface water uses. If the assessment of migration potential indicates that there is a potential for target contaminants to move to a surface or groundwater resource, the evaluation of this duration and frequency criterion will be used to estimate the extent to which the potentially affected water resource is used by human or environmental receptors. For migrating or nomadic receptors, the availability of other similar water resources will be considered. The potential for exposure through direct ingestion of reserve pit contents will be evaluated and will include estimates of the frequency and duration of ingestion episodes as well as biological uptake characteristics of the target compounds. For the quantity and concentration criteria, measured contaminant concentration in the water will be compared with health and environmental standards and criteria for each target compound to identify whether the concentration exceeds established water quality standards. When human populations are at risk, health criteria are used. When the populations at risk are nonhuman, such as fish, wildlife, and vegetation, environmental criteria and standards are -used. The NIOSH toxicity rating system (NIOSH 1974) will be used to identify contaminants that are highly toxic to mammals. This information will be used to determine whether a target compound exhibits acute high toxicity. The system ranks substances according to acute toxicity estimates, which is the customary method used to determine the toxicity of a chemical. LD50 is the dose, either oral or dermal, at which 50 percent of the exposed population will die. Several designations of toxicity are generally recognized by toxicity specialists. The designations include unknown, non -toxic, slight, moderate, and severe. An unknown designation means insufficient data are available to enable a valid assessment. ANCIOOI IESS.WP5 8-4 Chemicals designated as non -toxic produce no toxic effects under normal use or require overwhelming doses to produce toxic effects in humans. Slightly toxic chemicals may produce effects that are reversible when the exposure ceases. Moderately toxic chemicals can cause reversible or irreversible changes, but they are not necessarily severe enough to cause serious physical impairment or threaten life. Highly toxic chemicals are those that can threaten life or cause permanent physical impairment over continuous low-level expo- sure or by a single exposure. Highly toxic substances are those with an oral LD50 value equal to or less than 50 mg/kg, a dermal LD50 equal to or less than 100 mg/kg, or an inhalation LC50 equal to or less than 43 ppm. A similar ranking system has not been developed for aquatic organisms; however, 1 mg/L is often the LC50 value used as a criteria for identifying chemicals highly toxic to aquatic life. In addition to this evaluation of acute toxicity, the waste site data will be evaluated to identify the potential for biological concentration of contaminants in the food chain to reach acute toxic levels. If the duration and frequency of exposure is insufficient to cause adverse effects, there is no need to evaluate the other two consequence criteria, and a finding of negligible risk is made. The action plan is then evaluated in Section 9, Impact versus Benefit Evaluation. If the duration and frequency of exposure is determined to be sufficient to cause adverse effects and either of the other two consequence criteria are satisfied, then a finding is made that adverse consequences are likely, and the risk at a waste site is estimated to be signifi- cant. If the screening indicates that risk is significant, the development of a corrective action plan is warranted. The results of applying the risk -screening model will be summarized in a table showing the criteria applied, the result of the application. (yes, the criterion was met, or no, the criterion was not met), the reason for meeting or not meeting the criterion, and the outcome of the screening step (whether a basis for concern exists; whether risk is significant). The waste site will fall into one of three categories: • No further action required (there is no basis for concern) • Risk is negligible (a subsequent evaluation will be made to determine if corrective action is desirable) • Risk is significant (corrective action is necessary) ANCl00llE55.WP5 8-5 To support a conclusion that there is no basis for concern or that the risk at a waste site is negligible, a list of key findings at a waste site will be prepared. 8.2 Results of Risk Screening The following sections provide a summary description of risk screening results for each site evaluated. The results for each site are summarized in a table. Risk -screening conclusions are presented for each site. A complete risk screening evaluation of the Sullivan well sites cannot be performed because the reserve pits cannot be located. The Sullivan #1, Sullivan #2, and Sullivan Strat #1 wellheads could not be located with certainty because of site erosion and thick vegeta- tion. The sites have been ecologically restored through natural processes. A ground search by foot, which required at least 8 staff hours per site, found no evidence of a drill site or signs of a reserve pit. A basis for concern exists because the fate of the reserve pit material is unknown, but the level of risk may be considered to be negligible because there is no evidence of a reserve pit or the drill site at these locations. The environment does not appear to be impacted or threatened due to reserve pit materials. Natural erosion processes of the glacial rivers and landslides have either washed the sites away or buried them in sediment. Risk may be considered negligible because the reserve pit material, if still present at the sites, is more than 30 years old and the quantity of soluble constituents is limited. It is probable that leachable contaminants have already been released and dispersed by this time and the remaining material is relatively inert. Exposure to biological receptors is not likely. No exposed mud could be found at the sites. The sites are practically inaccessible to humans because of dense vegetation and non- existent access roads. Considering these factors, the risk of exposure and adverse effects to human health and the environment is negligible. ANC10011E55.WP5 8-6 Section 9 Benefit -Impact Evaluation An action plan is not recommended for the Sullivan sites because the risks associated with implementing an action plan are greater than the potential risks that could be reduced through corrective action. The purpose of this evaluation is to estimate whether the benefits of implementing an action plan would be greater than the impact of implementing the plan. The general philosophy behind this evaluation is that if an action plan can be implemented to reduce an already "negligible" risk and not cause any greater problem, then such an action plan should be taken. ANCIOOI1E5B.WP5 9-1 Section 10 Action Recommendation No further action is recommended for the Sullivan well sites. The findings of a benefit and impact evaluation estimated that the impacts of implementing an action plan would exceed the benefits of an action plan. No further action is warranted because actions implemented to reduce an already negligible risk would create more risks to human health and the environment than the no action alternative. ANCIo01IE5E.W P5 10-1 Section 11 Works Cited America North/Emcon. Summary of Investigations into the Need for RCRA Corrective Actions at Drill Sites 3 and 17 Reserve Pits in the Prudhoe Bay Unit --Eastern Operating Area. North Slope Borough, Alaska. 1992. Angeloni, Linda M. et al. Map and Tables Showing Preliminary Rock Geochemical Data, Port Moller, Stepovak Bay, and Simeonof Island Quadrangles, Alaska. U.S. Geological Survey Open -File Report 85-470. 1985. Arbogast, B. F. et al. Analytical Results and Sample Locality Maps of Stream -Sediment, Heavy -Mineral -Concentrate, and Rock Samples from the Port Moller, Stepovak Bay, and Simeonof Island Quadrangles, Alaska. U.S. Geological Survey Open -File Report 87-502. 1987. Arco Alaska, Inc. Crude Oil Topping Unit (COTU) Tube Bundle Sludge Containment Enclosure/Cleaning Station. Investigation Plan. December 1992. B & B. Environmental, Inc. Drill Cuttings Baseline Report. 1991. Bruns, T. R. Structure and Petroleum Potential of the Continental Margin Between Cross Sound and Icy Bay, Northern Gulf of Alaska. Menlo Park, California: U.S. Geological Survey Open -File Report 82-929. 1982. CH2M HILL. Draft. Crude Oil Topping Unit (COTU) Pad Remediation. 1992. Church, S.E. et al. Analytical Data and Sample Locality Map for Aqua-Regia Leachates of Stream Sediments Analyzed by ICP from the Port Moller, Stepovak Bay, and Simeonof Island Quadrangles, Alaska. U.S. Geological Survey Open -File Report 88-437. 1988. Cobb, Edward H. Summary of References to Mineral Occurrences (Other Than Mineral Fuels and Construction Materials) in the Bering Glacier, Icy Bay, Middleton Island, and Yakutat Quadrangles, Alaska. U.S. Geological Survey Open -File Report 79-1246. 1979. ANC10011E62.WP5 11-1 Gough, L. P. et al. Element Concentrations in Soils and Other Surficial Materials of Alaska. U.S. Geological Survey Professional Paper 1458. 1988. James M. Montgomery Inc. North Slope Gravel and Soil Baseline Characterization. December 1991. Kachadoorian, Reuben. Engineering Geology Bearing on Harbor Site Selection Along the Gulf of Alaska from Point Whitshed to Cape Yakataga, Alaska. U.S. Geological Survey Trace Elements Investigations Report 642. 1963. Karlstrom, Thor N. V. Quaternary Geology of the Kenai Lowland and Glacial History of the Cook Inlet Region, Alaska. Washington: U.S. Geological Survey Professional Paper 443. 1964. Magoon, L. B. et al. Map Showing Geology, Wildcat Wells, Tertiary Plant Fossil Locali- ties, K-AR Age Dates, and Petroleum Operations, Cook Inlet Area, Alaska. U.S. Geological Survey Miscellaneous Investigations Series. 1976. Magoon, Leslie B. and George E. Claypool. Petroleum Geology of Cook Inlet Basin —An Exploration Model. Official File Number 79-548. Odum, Jack K. et al. Lithological, Geotechnical Properties Analysis, and Geophysical Log Interpretation of U.S. Geological Survey Drill Holes IC-79, 2C-80, CW 81-2, and CE 82-1, Tyonek Formation, Upper Cook Inlet Region, Alaska. U.S. Geological Survey Bulletin 1835. 1988. Petroleum Possibilities in the Yakataga District, Alaska, Assessed. U.S. Department of the Interior Information Service. May 22, 1953. Pewe, Troy L. Quaternary Geology of Alaska. U.S. Geological Survey Professional Paper 835. 1975. Plafker, G., et al. Holocene Marine Terraces and Uplift History in the Yakataga Seismic Gap Near Icy Cape, Alaska. 1980. ANC100I IE62.WP5 11-2 Schmoll, Henry R. et al. Guide to Surficial Geology and Glacial Stratigraphy in the Upper Cook Inlet Basin. Anchorage, Alaska: Alaska Geological Survey. 1984. Schmoll, Henry R. and Lynn A. Yehle. Generalized Physiography and Geology of the Beluga Coal Field and Vicinity, South -Central Alaska. . Surfcial Geologic Map of the Northwestern Quarter of the Tyonek A-4 Quadrangle, South -Central Alaska. U.S. Geological Survey Miscellaneous Field Study Map. 1987. Scully, David R. et al. Hydrologic Reconnaissance of the Beluga, Peters Creek, and Healy Coal Areas, Alaska. Anchorage, Alaska: U.S. Geological Survey Water -Resources Investigations 81-56. 1981. Selkregg, L. L. et at. Alaska Regional Profiles, Arctic Region. University of Alaska Arctic Environmental Information and Data Center, Anchorage, Alaska. 1975 . Alaska Regional Profiles, Southcentral Region. University of Alaska Arctic Environmental Information and Data Center, Anchorage, Alaska. 1975 Thomas and Berryhill. Reconnaissance Studies of Alaskan Beach Sands, Eastern Gulf of Alaska. U.S. Geological Survey. The United States Geological Survey in Alaska. Accomplishments During 1983. U.S. Geological Survey Circular 945. 1984. Wahrhaftig, C. Physiographic Divisions of Alaska. U.S. Geological Survey Professional Paper 482. 1965. Walker, D.A. et al. Geobotanical Atlas of the Prudhoe Bay Region, Alaska. U.S. Army Corps of Engineers Cold Regions Research and Engineering Laboratory. Hanover, New Hampshire. CRREL Report 80-14. June, 1995. Wilson, Frederic H. et al. Brief Descriptions of Mines, Prospects, and Mineral Occurrences in the Port Moller and Stepovak Bay Quadrangles, Alaska Peninsula. Anchorage, Alaska: U.S. Geological Survey. Open -File Report 88-666. 1988. ANCI001IE62.WP5 1 1-3 Wilson, Frederic H. et al. Generalized Geologic Map of the Port Moller, Stepovak Bay, and Simeonof Island Quadrangles, Alaska Peninsula, Alaska. U.S. Geological Survey Miscellaneous Field Studies Map. 1991. Yehle, et al. Preliminary Surfacial Geologic Map of the Southeastern Part of the Tyonek B- 5 Quadrangle, South -Central Alaska. Reconnaissance Engineering Geology of the Yakutat Area, Alaska, With Emphasis on Evaluation of Earthquake and Other Geologic Hazards. U.S. Geological Survey Profes- sional Paper 1074. ANCIOOI 1E62.WPS 11-4 Sullivan Strat 1 - PTD 100-109, Blowout from overpressured water flow. Drillpipe blown out of the hole. Sullivan Strat 1 - PTD 100-109, Blowout from overpressured water flow. Drillpipe blown out of the hole. o>r r • THE STATE Department of Environmental 011-1LASKL'1 GOVERNOR SEAN PARNELL RECEIVED FEB 0 7 2014 February 4, 2014 A0GCC Certified Mail, Return Receipt Requested Article No.: 7012 2210 0002 1216 2391 Wayne Svejnoha BLM — Division of Resources 222 W 7th Ave, #13 Anchorage, Alaska 99513 Conservation Division of Spill Prevention and Response Contaminated Sites Program File: 320.38.010 SCANNED 0 2 2014 Re: Potentiall Responsible Party Notice Letter and Information Request NPRA Legacy Wells - General Hazard ID: 26125 Ledger Code: 14339387 Dear Mr. Svejnoha: 610 University Ave. Fairbanks, Alaska 99709-3643 Main: 907.451.2181 Fax: 907.451.5105 This letter is to advise you that the Alaska Department of Environmental Conservation (ADEC) has identified the 136 legacy wells within the National Petroleum Reserve in Alaska (NPRA) as potential contaminated sites. Some of these wells require extensive cleanup of oil and other hazardous substances released to the environment. Since you are identified as a current or past owner and/or operator of these sites, please be advised you may be financially responsible or liable for the investigation and /or cleanup of any hazardous substance contamination that might be present. Alaska Statute 46.03.822 establishes who is liable for contamination. Records available to the ADEC indicate that you meet one or more of the following criteria: » owned or controlled the hazardous substance at the time of its release; » own(ed) or operate(d) the property or facility from which the release occurred; » owned or operated property at which the hazardous substance came to be located; and » arranged for transport, disposal or treatment of hazardous substances that were released. Site History From 1944 through 1982 the US Government drilled 136 wells to explore for oil and gas resources in the NPRA. It is our understanding that other federal agencies and some private companies may have operated or managed these sites in the past. We have also been informed that 23 of these well have been conveyed to public and private entities. The ADEC currently lists 14 of the 136 legacy wells on our database of contaminated sites. The Bureau of Land Management (BLM) is identified as the responsible party for the following sites. Wayne Svejnoha 0 2 February 4, 2014 • BLM Cape Halkett Drill Site (File # 300.38.108) • BLM East Simpson #2 (File # 300.38.109) • BLM East Teshekpuk Drill Site (File # 300.38.110) The U.S. Army Corps of Engineers, under the Formerly Used Defense Sites program, is working with ADEC under the Defense States Memorandum of Agreement on cleanup actions at the 11 Umiat test well sites. BLM is identified as the landowner in our records, and as such is identified as a potentially responsible party in addition to the Department of Defense: C Umiat Test Wells 1-11 (File # 335.38.001) The information contained in these files is part of the public record. Our databases are accessible on the Internet at: http://dec.alaska.gov/spar/csp/db_search.httn Additional Actions Needed ADEC sent a letter on July 11, 2013, identifying an additional 15 legacy well sites with confirmed releases (enclosed). As stated in the letter, ADEC recommends that BLM develop a plan to address known, suspected, and unknown releases at the legacy well sites, in coordination with the appropriate regulatory agencies. We expected a response to this letter before now. Please respond to this letter within 30 days. After we receive and review your response we will determine what additional actions will be taken regarding each site with known or suspected contamination. In addition, with your response, please complete and return the enclosed questionnaire requesting more information about past operators. In accordance with Alaska Statute Title 46, ADEC is authorized to provide regulatory oversight for any contamination response efforts initiated by the responsible party. However, if response actions by the responsible party are not satisfactory to ADEC, we may then assume the lead role in the investigation and cleanup efforts. In the event that State response actions are necessary, the responsible parties may be held financially liable for any response actions taken by the State. Alaska Statutes 46.04.010 and 46.08.070 establish cost recovery procedures for certain costs, including oversight activities, incurred by the State in responding to pollution incidents. If you are determined to be a responsible or liable party, ADEC may bill you at a later date for our expenditures associated with this pollution incident. Expenses for which we may seek reimbursement include: Staff time associated with general or technical assistance; work plan review; project oversight; general project management; legal services; interest; travel; equipment and supplies; and any contracting costs. Pursuant to Alaska Statute 46.08.075, the State may also file liens against all property owned by a person who is responsible or liable for State expenditures. Please respond in writing within thirty (30) days from the date of this letter addressing your intended actions with respect to this pollution incident. If you believe someone else is responsible for this pollution incident (e.g., a past owner or operation of the site) or if you have any questions concerning this matter, please contact Mr. Fred Vreeman at (907) 451-2181. The attached "ADEC Information Request" describes the minimum information expected in your response. Additional information may needed to evaluate the risks and responses required at each legacy well site. Sincerely, Fred Vreeman Environmental Program Manager G:\SPAR\CS\Contaminated Site Files (38)\320 National Petro Reserve Area\320.38.010 NPRA Legacy Wells General\2-2-2014 Letter\PRP Letter All Wells.docx Wayne Sveinoha Enclosure: 0 3 • ADEC Information Request Concerning Contaminated Sites BLM Legacy Wells Dispute letter date July 11, 2013 February 4, 2014 cc: Bud Cribley, Director, Bureau of Land Management Steven Cohn, Deputy Director, Bureau of Land Management Jolie Pollet, Branch Chief, Bureau of Land Management Robert Brumbaugh, Geologist, Bureau of Land Management Michael McCrum, Environmental Engineer, Bureau of Land Management Larry Hartig, Commissioner, Alaska Department of Environmental Conservation Lynn Kent, Deputy Commissioner, Alaska Department of Environmental Conservation Kristen Ryan, Director, Alaska Department of Environmental Conservation Lori Aldrich, Program Manager, Alaska Department of Environmental Conservation Steve Bainbridge, Program Manager, Alaska Department of Environmental Conservation Jennifer Roberts, Program Manager, Alaska Department of Environmental Conservation ADEC Response Fund Administration GASPAR\CS\Contarr nmted Site Files (38)\320 National Petro Reserve Area\320.38.010 NPRA Legacy Wells General\2-2-2014 Letter\PRP Letter All Wells.docx 0 0 ADEC INFORMATION REQUEST Concerning a contaminated site(s) Re: Legacy Well Sites in and near the National Petroleum Reserve, Alaska (NPRA) Please precede each answer with the number of the question to which it corresponds. Please direct any questions concerning this information request to Fred Vreeman, Contaminated Sites Program, 610 University Avenue, Fairbanks, AK 99709; Phone: 907-451-2181. Thank you for your cooperation. 1. Provide name and company affiliation of the person answering the questionnaire. 2. Provide copies of all studies, reports, and supporting information (including preaquisition assessments and work done on behalf of other parties) which you have knowledge of which address past and/or present environmental conditions at the site. Identify the name, title, address, and phone number of the party(s) who are responsible for preparing the studies or information. Information which has been previously submitted to ADEC need not be submitted again (unless specifically requested in a subsequent communication) if you can provide the name of the office (and name and title of the DEC officer if known) to whom the report was previously provided. 3. Provide a description of any ongoing or planned investigations or cleanup work at the site. Identify the names, titles and phone numbers of the individuals responsible for preparing the studies or information. 4. Provide a description of known releases at the site (date of occurrence, quantity released, type of substance released, etc.) and a description of corrective measures that were taken. Provide information on any suspected releases which may have or are occurring. 5. Describe the nature of past and present operations at the site. In particular, any actions that may have caused the release or threat of release at the site. Describe the physical characteristics of the site including major structures, water wells, fuel or waste storage systems, drainage or septic systems, etc. 6. Provide a list of any permits issued by the Department which relate to activities at the site and a list of RCRA identification numbers (U.S. EPA identification numbers) which may be held. 7. Identify persons to whom you leased all or a portion of the property and describe the nature of their operations. 8. Identify the person(s) who used the site for disposal of substances deposited there, if any. 9. Provide copies of manifests for any hazardous waste and/or petroleum contaminated materials taken to or from the site. 10. Provide a list of persons and their phone numbers and addresses of persons who have knowledge about the use of hazardous substances at the site. 11. Provide information regarding the existence of insurance coverage for damages resulting from releases of hazardous substances and copies of all such insurance policies, both currently in effect and in effect during the periods of activity in question. 12. Describe the acts or omissions of any person, other than your employees, agents, or those persons with whom you had a contractual relationship, that may have caused the release or threat of release of hazardous substances at the site. a. In addition, describe all precautions that you took against foreseeable acts or omissions of any such third parties. 13. Describe the care you exercised with respect to the hazardous substances found at the site. 14. Describe the physical characteristics of the site including structures, wells, drainage systems, etc. THE STATE July 11, 2013 'ALASKA GOVERNOR SEAN PARNELL Wayne Svejnoha Supervisory Minerals & Energy Specialist 222 W 7th Avenue, #13 Anchorage, Alaska 99513 Re: BLM Legacy Wells Dispute Dear Mr. Svejnoha: Department of Environmental Conservation Division of Spill Prevention and Response Contaminated Sites Program 610 University Ave. Fairbanks, Alaska 99709-3643 Main: 907.451.2181 Fax: 907.451.2155 The Alaska Department of Environmental Conservation (ADEC) — Contaminated Sites has reviewed the National Petroleum Reserve in Alaska: 2013 Legacy Wells Summary Report dated February 2013, containing updated information on the status of the 136 Legacy Wells located in the National Petroleum Reserve — Alaska (NPR -A), and the draft National Petroleum Reserve in Alaslm. 2013 Legacy Weiss Strategic Plan dated May 2013. ADEC has also reviewed the response by the Alaska Oil and Gas Conservation Commission (AOGC). We concur with the response by ACIGC and have no further comment regarding the priorities. We do have comments about the investigation and cleanup plans presented in the report. With this letter we arc outlining regulatory requirements related to the environmental work that is proposed and required as part of these cleanups. ADEC is concerned that the 2013 Legacy Wells Strategic Plan prepared by the BLM does not include either assessment of the contingency for assessment of known, likely, or unknown but possible contaminant releases. In addition, BLM plans for surface cleanup of these wells should be made clear in the plan. At least one of these legacy wells has extensive PCB contamination and has resulted in a multi-year cleanup totaling tens of millions of dollars. At others, solid waste disposal practices have resulted in releases to the environment with estimated cleanup costs in the hundreds of millions. Known releases documented in the records we reviewed include crude oil, gasses, refined oil and fuel, drilling fluids that include various organics, metals, and other chemicals, and unknown contaminants from drums and other containers observed to be damaged and abandoned at the various well sites. There are 13 legacy well sites with known releases currently on the DEC contaminated sites list. Many of these are in the process of being addressed, cleaned up, and closed. From our Waited records review there are 15 additional legacy well sites with confirmed releases. These should be prioritized for initial records reviews and then added to the BLM contaminated sites list under our cooperative agreement. Suspected releases include fuel releases from operations, storage, and fuel spills at the sites, impacts to various surface water bodies from spilled fluids during drilling and breaches of containment at reserve and flare pits, continued surface runoff from drilling fluids uncontained at several sites, and down -hole substances that were ejected from the holes over time or during blowouts or drilling operations. 1 Wayne Sve noha ? July 11, 2013 Y The.BLN-1 plan to address these known, suspected, and unknown releases at legacy well sites is notably absent from the documents presented to date. The three primary regulatory agencies that need to be involved in the plan are ADEC — Contaminated Sites, Alaska Oil & Gas Conservation Commission, and ADEC — EH/Solid Waste. Other agencies will need to be consulted. as well. Below we provide recommendations for a coordinated plan using the Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP) that will involve all of the regulatory agencies in one coordinated manner. This will allow BLM to address these sites in a consistent and coordinated project which fulfills all of the regulatory requirements so that the sites do not need to be re -visited in the fu=e xvhen they are closed after this project. Attached are our comments on each specific well. The acronyms used on the list include terms that are typically used in a CERCLA type investigation however they are also suitable for investigations conducted under the State of Alaska cleanup rules. These include the following; Historical Records Review (HRR) 'chis is recommended for almost all of the well sites. Much of the information required for these reviews is already contained in various reports and appendices or in BLM files. The Historical Records Review should document the type of releases that might have occurred from drilling operations as well as historical use of the site, and should capture all available information on the drilling fluids used and any product produced or released. Preliminary Assessment (PA) This is recommended for almost all of the well sites. A Preliminary Assessment is a limited scope investigation that provides an assessment of information about a site and its surrounding area to distinguish between sites that pose little or no threat to human health or the environment and sites that require further investigation. The PA is a CERCLA defined document and typically does not require sampling. Site Inspection (SI) If the PA recommends further investigation, then an SI is necessary. The SI is a CERCLA defined document, and it is analogous to an initial report of contamination under state cleanup rules. On some legacy well drillings sites it is evident now that an Sl is required just from a review of the reports. An SI investigation typically includes the collection of samples to determine what contaminants are present at the site and whether they are being released into the environment. An approved site specific workplan is required under both CERCL-A and 18 AAC 75 prior to SI sampling. The SI typically is not intended to develop a full site characterization, but is limited to determining the presence or absence of a release. If contamination is found after completion of the HRR, PA, and SI then a RI/FS under CERCLA, or a Site Characte-rizatiowlteportandcleanup-Alas,under-l-fi-AAC7iis`required. -- ----- - -- — --------- - DEC recommends that BLM incorporate into the strategic pian the processes outlined in this letter. A team of agencies composed of AOGC, DEC -CS, EPA as required, and DEC -EH should address regulatory and technical requirements for these well closures. By cooperating and working together with the regulatory agencies BLM will save time and expense, and regulatory uncertainties will be avoided. The strategic plan should reference a project to prepare a generic workplan. DEC suggests that BLM utilize the generic UFP-QAPP workplan format for the required environmental work. If properly prepared, the workplan could encompass most of the investigations and cleanups required at these sites over multiple years. At other multi -site projects we have found this to be an effective way to reduce uncertainties and risk in these types of investigations. A very small site specific FSP could then be developed as BLM approaches each drilling site. Regulatory decisions made during workplan development would provide more certainty in the planning process for cleanups. G:\SPAR\CS\federal F2cilitie3\Ci%ih2n 1-cdcrrt Agr=ics\DOl\B[.nl\1'roiens\lxgAey Wells\7 11 13 Luter to KIN on lxbxy wells.doex Wayne Svejnoha 3 0 July 11, 2013 Please review the attached list of specific sites. If you have any questions, please do not hesitate to call me at 907-451-2181 or by email at fred.vreeman@alaska.gov. I look forward to working with you as the Federal Government fulfills its requirement to clean up these well drilling sites in Alaska. Sincerely, y' Fred Vreeman Environmental Program Manager Enclosure: SPAR Response with Legacy Wells cc: Bud Cribley, State Director, Bureau of Land Management Steven Cohn, Deputy State Director for Resources, Bureau of Land Management Jolie Pollet, Branch Chief, Bureau of Land Management Robert Brumbaugh, Geologist, Bureau of Land Management Michael McCrum, Environmental Engineer, Bureau of Land Management Cathy Foerster, Commissioner, Alaska Oil and Gas Conservation Commission Larry Hartig, Commissioner, Alaska Department of Environmental Conservation Kristen Ryan, Director, ADEC Division of Spill Prevention and Response Steve Bainbridge, Program Manager, ADEC Contaminated Sites Program Jennifer Roberts, Program Manager, ADEC Contaminated Sites Program GASI'AR\CS\Fedcrrl Fo61ibLy\Gvi6n Falctul AgcnnCs\DOI\BI.N1\Proitcts\lA'6.1' q W03\7 11 1314tur to Aim\I on Ug2cy Wclls.doex Well Name operator I RP I Land Simpson Core Test #5 1! Na 1 BLM Simpson Core Test #6 US Na I BLM Simpson Core Test #7 us Na 1 Bl. M Sin son Core Test 98 US Navy 113LM Si son Core Test #9 U5 Na I BLM Sinwson Core Test #1f) U.S Navy! BLM Core Test #11 AOGCC Subsurlaca I BLM Core Test #12 FUSNa a I BLM Core Test #16 a 18LM Core Test #17 US Na 1 BLM Core Test 018 US Na I BLM Core Test #19 US Na 1 BLM t Core Test #20 US Navy 1 BLM i Gore Test #21 2S Na 1 BLM I Core Test #22 US Na 111•LM I Core Test dnlf fluids left in hole i BLM Core Test �#2vy I BLhA n CareTest #25 US Na Y I BLM K Core #1 US Navy i BLM 1 -t- *1 SPAR Response with Legacy Wells Lisl.xlsx 2013 Risk Ity CSP Status I Fito tllHazid Rolea5e7 Nnne None IYOMWil Low RNooe ane Nona Unused, Unused. I None Unused, i None Uncased, None None None None (None Unknown Unknown Page 1 of 14 •I AOGCC Subsurlaca AOGCC Surface SPAR W arkgroup Notes Status Status Need HRR, PA, S1 no data no data Need HRR. PA. SI no data no data Need PA ind drill fluid assessnsenl & workplan drillin 11uids left in hole no data Need PA ind drill fluid assessment & work an drilling fluids left in hole no data Need PA incl drill Ifusd assessment & work Ian dnlf fluids left in hole no data Need PA nc drill fluid assessmcnf &work Ian dnllxs fluids left rn hale no data well skc-lch provided by Need PA ind drill fluid BLM not consistent with assessment & work Ian AOGCC or BLM data no data Need PA ind drill fluid assessment & work Ian dnflin fluids left in hole no data Need PA and 51 ind 13611 fluid assessment. workplan rid sampling stressed debfis, partially as blowout and fire rove elated site areas Need PA incl drill fluid assessment & workplan dn lling fluids left in hole no data geed PA ind drill fluid assessment & wOTk Ian drij I ing fluids teff in hole no data Need PA incl dfifl nutd assessment & work Ian drillin fluids left m holo no data Need PA incl drill fluid assessment & work Ian drillin ituids left in hole no data Need HRR. PA, SI no data no data Need PA incl drill fluid assessment & work Ian drillin fluids felt in hole ria data Need PA incl dnll fluid assessment & work larx drillin fluids left in hole no data Need PA incl drill fluid assessment & work Ian drillin fluids Teff in hole no data Need PA ind dnll fluid drflfing fluids and ball assessment & work len peen hammer left in hole no data overshot, drill collar, rock revegelated —131 Need HRR, PA bit, and N -reds left in hole can't find it Review Report as PA. No evidence of sheen, stressed veg, or drilling Not abandoned, waste on surface. Veg ----_— , ,raw,, plunaed to surface site not cleared •I SPAR Response with Legacy Wells LisLxlsx Page 2 of 14 is • vi nce o BLM 2013 Risk Historic AOGCC Subsurface AOGCC Surface Well Name Operator I RP I Land Mgr Priority CSP Status file #IHazid Release? SPAR Workgroup Notes Status Status plugging operations inadequate and Wellhead tell as Umiat 43 US Navy I BLM I FUDS None pending dos 335.38.00113092 Yes. see file 'Plugged by BLM in 2004 incomplete historic site? plugging operations inadequate and Wellhead left as Umiat #4 US Navy I BLM / FUDS None pending dos 335.38.001!3079 Yes, see file Plugged by BLM in 2004 incomplete historic site? plugging operations inadequate and Wellhead left as Umial 98 US NaMy I BLM I FUDS None pendinq dos 335.38.001/3D81 'Yes, see_ _file Plugged BLM in 2004 incomplete historic sile? plugging operations inadequate and Wellhead left as Umiat #1'0 US Navyj BLM_I FUDS None pendingdos 335.38.00113082 Yes, see fila Plu ed by BLM in 2004 incomplete historic site? Need HRR, PA, SI with sampling. Drilling mud assessment. Surface Plugged to 7868'. Drilling Cleanup. Photos - evidence mud and diesel to Awuna #1 USGS I BLM Medium None None Yes of erosion into lake surface. > 100 _Pylons Need HRR, PA, SI with sampling. Drilling mud Wood , metal, assessment. Surface Plugged to 2039'. Diesel plastic debris. Fast Simpson #1 USGS I BLM Low None None Yes Cleanup. to surface. >10D Pylons Need HRR, PA, SI with Wood and metal Drilling mud assessment debris. Pylons - Photos straw areas of no Plugged to 2047'. Diesel Tankage for lk ' #1 USGS / 8LM Low None None Yes ve elation. to surface. flammable fluids Need HRR. PA, SI wdh sampling. Drilling mud assessment. Surface Plugged to 1400'. Drilling Wood and metal Koluktak #1 USGS I BLM Low None None LYes Cleanup. mud & diesel to surface debris Pylons Need HRR, PA, SI with sampling. Drilling mud assessment. Surface Plugged to 1894'. Diesel Wood and metal Ku am 91 USGS I BLM Low None None Unknown Cleanup. to surface debris. Pylons Need HRR, PA, Sl with sampling_ Drilling mud assessment_ Surface Plugged to 4464'. Drilling Wood & metal Kuyanak #1 USGS I BLM Low None None Yes Clean mud & diesel to surface debris. Pylons Need HRR, PA, SI with sampling. Drilling mud assessment. Surface Cleanup. Photos show Plugged to 1840'. Diesel Plastic and metal Lisburne 41 USGS I BLM Low None None Yes stained soil to surface debris. Need HRR, PA, SI with sampling. Drilling mud assessment. Surface Plugged to 8192'. Drilling Wood and metal North Iii ok $1 USGS I BLM Low None INone Yes Cleanup. mud & diesel to surface debris - Page 2 of 14 is • Well Name Peard South Meade #1 1 RP 1 Land 1BLM BLM #1 4USGS ! BLM SPAR Response with Legacy Wells Usl.xlsx ;013 Risk &W CSP Status File XlHazkl T Page 3 of 14 AOGCC Subsurface AOGCC Surface WAR Workgroup Notes Status r Status � deed HERR, PA SI with iampling. Dining mud rssessment- Surface ;leanup. Site photos show areas of stressed iegetalion. No issues Plugged to 2232'. Diesel Wood and metal soled in USGS re ort. to surface debris. Pylons Need HRR, PA, SI with sampling_ Drilling mud assessment Surface Plugged to 2026'. Diesel Wood and metal Cleanup. to surface debris. P Ions Add to She list. Need HRR, PA, SI with sampling. Drilling mud assessment. Surface Cleanup. Od reported bubbling to the surface within reserve pit in 1982. Oily residue and sheen observed adjacent to east side of reserve pil, down hole material at the Plugged to 1875. Diesel Wood and metal surface to surface debris. P ons Add to Site list. Need HRR, PA, S) with sampl'uig. Drilling mud assessment - Surface Cleanup. Reserve pit berm had breaches anowirrg water to exit. Oil - stained sediment was observed above the Plugged to 1478'. Diesel Wood and metal waterline of the I. to surface debris. Site photos may show hydrocarbon sheen on Plugged to 2600'. Drilling Wood and metal water in well cellar mud & diesel to surface debris. Pylons Add to Site list. Need HRR, PA, SI with sampling. Drilling mud assessment. Surface Cleanup. Berms have been breached an allow water to flow out of reserve piUllare pit. Rising bubbles of ail observed in Hare pit 1484. Photos Show Plugged to 1825'. Diesel Metal debris. ra.. v-1 v.nnnralinn to Surface ... 0 •I SPAR Response with Legacy Wells Lisl.xlsx Page 4 of 114 0 0 vi encs o BLM 2013 Risk Historic AOGCC Subsurface AOGCC Surface Well Name Operator 1 RP f Land Mgr Priority CSP Status File #fHazld Release? SPAR Workgroup Motes Status Status Need HRR, PA, Sl wrlh sampling. Drilling mud assessment Surface Cleanup. Breaches in bemi allow water to flow into and out of reserve pit, sheen on Plugged to 2700' Diesel Wood and metal West Dease #1 USGS l BLM Low Nona None Yes surface water in well cellar to surface debns. Pylons Add to Site list. Need HRR,. PA, SI with sampling. Drilling mud assessment. Surface Cleanup. Water flows into the pits through breaches on the eastern berm and out of the pits through breaches on the northern and western berms. Downhole material Plugged to 228'9'. Drilling Wood and metal South Harrison Bay #1 USGS f BLAB Low None None es Present at surface mud & diesel to surface debris. Add to Site list. Need HRR, PA, SI with sampliing. Drilling mud assessment. Surface Cleanup. Stressed vegetation noted and apparent in site pholos. Plugged to 2443'. Drilling West Fish Creek #1 USGS 1 BLM Low None None Yes Drilling mud around well mud & diesel to surface Pylons Need HRR, PA, SI with sampling. Drilling mud assessment, Surface Cleanup. High TPH Plugged to 1977'_ Drilling wellhead sticking concentrations underneath mud under plugs. Diesel up. Wood debris. Fast Simpson #2 USGS 1 BLM I Low _ Active 300.38.10912691 Yes, see file the rig inundation to surface Pylons South Barrow 94 US NavyiNorth Slope Bono None None None Unknown Need Surface Status completed gas well - no data South Barrow #5 USAF - BLM Unknown None None None. Unknown Need Surface Status completed gas well no data South Barrow #& US Na /Norlh Sto Burg None None None Unknown Need HRR, PA, St no data no data South Barrow #9 US NavyfNarih Slop2 Boro None None None Unknown Need HRR, PA, Sl no data no data _ South Barrow #10 US Navyfflorlh Sto Bora None None None Unknown Need Surface Status com ted gas well no data South Barrow It12 US Na /North Slope Baro None None None Unknown Need HRR, PA. Sl no data no data BLM well skMh not consistent with AOGCC South Barrow #14 US NavyMorth Sloe Boro None None one Unknown Nsed HRR. PA, St data no data Need PA ind drill fluid well left filled with drilling South Barrow #16 US NavyiNotih Slope Bora None None None Unknown assessment & workplan mud and diesel no data Need PA incl drill !turd tubing in well. no perfs, Soulh Barrow 017 US Na /North Sloe 13ora None None None jUnknown assessment & work fan I unknown fluid, I no data Page 4 of 114 0 0 SPAR Response with Legacy Wells Lisl.xisx Page 5 of 14 •I E CYfuu .v v AOGCC Subsurface A Surlaco TEHILM T013 Risk CSP Stilus File #IHaaid Historic Rekeasa7 SFAR YUnrkgroup Nates 5latus at US $1<ntus Well Name flperatar f RP f Land Mgriority Unknown Need Surface Status corn feted as well no data 5aulh Barrow #18 US Na INorlh Slo a Bora None None None Unknown Need HRR, PA, St no data no data Walak a #1 USGS! Unknown None None None rsg 890`. Multiple cement plugs of unknown volume. Shallowest None None Unknown _ Need HRR, PA, SI SOD' no dada Gubik #1 US Na d Ur#cnown Low Add to Site list. Need HRR. PA. SI with sampling. csg Q SOD' Well blowout Drilling mud assessment. from zone al 1SOT during Surface Cleanup. Photos plugging operations show disturbed/ slashed Plugging never completed after blowout. no data Gub* #2 US Na ! Unknown Low None Nora es areas two downhole Dement plugs of unknown depth Mone None Unknown Need MR. PA. Sl and volume no data Grandstand #1 US Navy 1 Unknown None Add to Site list. Need HRR. PA, SI with sampling. Dnliing mud assessment. Surface Cleanup Sediment from the reserve pit was excavated and spread over the pad to drill a 2nd well at this location, Upon completion of the 2nd well. the sediment was pushed back into ft reserve pit.. Area does not appear to be revegetaling. perhaps from the presence property plugged but no of drilling mud at the data on abandonment None None Yes surface status no data W 7 Foran #1 " USGS I Unknown Low on Site list. Need HRR, PA, SI with sampling. Drilling mud assessment. Surface Cleanup. Slressed vegetation, photos show plugged, but not open csg; metal & Active 306.3$.108f2689 Yes. see file site underwater abandoned at surface corwsele debris under 5' of water, Cape Halken #1 " US Na (Unknown Low None Unknown !Need HRR, PA. SI es to 27' open C_s Min a Veloei #1 U5 Na f t3LM one None csg @ 31" 280' of drill pipe, drill collar, and Core Unknown Need HRR. PA, SL barrel left rn hole. rove etaled Ournalik Core #i US Na / BLM None -No obsery None !None Page 5 of 14 •I E SPAR Response with Legacy Wells Lisi.xlsx Page 6 of 14 • • WI F3nCe Q BLM 2013 Risk Historic AOGCC Subsurface ADGCC Surface Well Name Operator t RP I Land Mgr Priority CSP Status File #IHazid Release? SPAR Workgroup Notes Status Status Need HRR, PA, Workplan for St with Sampling. Drilling Mud Assessment. Surface Cleanup. Photos show debris, stressed No csg. 15' of drift pipe Oumalik Caro #2 US Navy 1 ULM Low None None yes ve elation and rock hit left in hole. no data Need HRR, PA, Workplan for Si with Sampling open csg & other Drillip) Mud Assessment. piping sticking out Surface Cleanup_ Reports of ground; wood, of debris, drilling muds on melat, conciele Oumalik Core 011 US Navy 1 BLM Low None None Yes surface (__q to 9', debris open csg sticking out of ground; wood & metal 0umalik Core #12 US Navy I BLM Low None None No Need HRR, PA, SI no data —__—debris _„ debris buried by landslide. Need HRR, PA, St, Well not no dala on Sentinel Hill #1 US Navy 1 BLM Low None None Unknown ap panent in site Rholos Csq to 3t1'. underwater status Need IQR, PA, SI. No evidence of sheen, open crag slightly stressed veg, or drilling above ground waste on surface. Veg 37' of csg, drilling fluids level; wood and S imp son Core Test #1 US Navy 1 BLM Low None None No appears healthy lett in hole metal debris Need HRR, PA, St. No evidence of sheen, stressed veg, or drilling waste on surface_ Veg 76'01 Csg, drilling fluids Simpson Core Test #2 US Navy I BLM Low None None No appears healthy left in hate no data Need HRR, PA, Sl. No evidence of sheen, stressed veg, or drilling waste an surface. Veg 61' of csg, drilling fluids Sim sun Core Test #3 US Navy I BLM Low None None No appears healthy left in hole no data Need HRR, PA, St. No evidence of sheen, stressed veg, ordrilling waste on surface. Veg --60' of crag, drilling fluids Sim eson Core Test #4 US Nayy t BLM Low Norse None No apecars healthy left in hole no data Need HRR, PA, St. No evidence of sheen, stressed veg, or drilling waste on surface. Veg csg cemented @25% open csg sticking Songsoncore Test #13 US Na 1 BLM Low None None No appears health dritin fluids IeR in hole_ out of round Need HRR, PA, SI. Vegetated, no evidence of crag cemented @2D'; open csg sticking Simpson Core Test #14 US Navy ! BLM Low None None No release. drillin fluids left in hole out of ground Page 6 of 14 • • SPAR Response with Legacy Wells Lisl.xlsx ism son Core Fest #26 t=vrdence or Medium AOGCC Subsur(aen ADGGC Surface 13LM 2013 Risk CSP Status File WHazid Historic Retease7 SPAR Wwkgroup Notes Status Status Well Name operator r RP 1 Land Mgr Priority Unko Need HRR, PA. SL US Na ! $LM open casing None Nave Vegetated. no ev4dence of cog set shallow; drilling slicking nut of Low No release- fluids left in hole round Simpson Core Teri #14a US Na !BLM Low None None & weilhead slick Need HRR. PA, SI crude nil left in hole open casing Need HIR, PA, Workplan Vegetated, no e+wdence of csg cemented 12181; slicking out of openregd ng No release. drillingfluid left in hole round Simoson Care Tesl #15 US Na !BLM Low None None d wooden Oellar, Need HRR, PP, SL Sate a9 r�110'. dolling fluids wood 8 metal ism son Core Fest #26 US Na ! BLM Medium None None res Sim sen Core Test 027 US Na J 13LM IJone None None Unko Sim son Gore Test #28 US Na ! $LM Low None Nave Yes clmnnnn Core Tesl #29 US Navy! BLM Low Norte No No Simpson Core Test 030 US Na 1 !BLM Core Test #30a JUS,Navy 1 BLM Low `None Prone n Gore Test #31 JUS Navy/ BLM None Page 7o(14 photos appear to show oil at surface, from a natural csg Q 350'. Completed in oil seep, seep, also drilling mud in oil well Open perfs. At 1welhead sticking sacks on the tundra one lime capable of up_ metal debris PI u ed b BLM in 2004. unassisled flow. and rustingbarrels 'Need HRR, PA, St. Site photos appear to show Oil csg cemented at surface, from a natural @i02;dnllutg fluids nn oily ground; csg seep- Plugged by BLM in including diesel and & weilhead slick vin 20014 crude nil left in hole out of ground Need HIR, PA, Workplan for Sl with Sampling- openregd ng ❑rilling Mud Assessment . out grouunnd in Surface Cleanup. Site d wooden Oellar, photos appear to show a p le of drilling mud about a9 r�110'. dolling fluids wood 8 metal 160 feel tram the welt tell in hole debris. Solid waste Need HRR, PA, Sl_ No evidence of sheen, stressed veg, or dri" waste on surface. Veg csg cemented at 1S2'; open csg. Wood a ears healthy dnknq fluids lett in hole and metal debris Need HRR, PA, SI. frilling mud at surface. but well is also in the middle of a large in oil seep; Open oil seep and surrounded by cog sticking up; pooled oil. Plugged by BLNI csg cemented A150'; wood & metal ser Holes in 20514- drillin fluids left in hole detail on oily ground; tog Need HRR. PA, Sl. Well is wellhead slick in the middle of a large oil seep and surrounded by csg cemented at 100% out of ground. pooled oil. Plugged by 131. dulling mud left in hole. wellhead leaking see noses in 2004 gas blowout at 423' gas Need HRR, PA, St. Leaky valve replaced in 2001, little evidence of contamination following valva on city ground; reg replacement- Plugged by csg cemented at 100'; & wellhead stick see notes BLM in 20174 iddifing fluids, left in hole out o1 round SPAR Response with Legacy Wells List.xlsx Page 8 of 14 • • yr enco o BLM 2013 Risk Historic AOGCC Subsurface AOGCC Surface Well Name Operator f RP f Land Mgr Priority CSP Status File glHasid Release? SPAR Workgroup Notes Status Status Need HRR PA, Workplan csg Cemente=d al for Sl with Sampling. 1028', cement plugs a1 Drilling Mud Assessment. 6387' and 5520'. Fish in Surface Cleanup. Drilling hole, drilling fluids Iefs in No data. Open Simpson Test Welt #1 ak US Navy1 BLM Low None INone yes muds near wellhead hale casing Need HRR, PA, Workplan for Sl with Sampling. Dolling Mud Assessment. Surface Cleanup Also Wellhead sticking evidence of a natural seep- above ground, Tar sheens in the summer ST from 2552 to 3018. wood, melel, and months. BLM is concerned csg @2915. Slotted liner concrete debris. Fish Creek #1 US Navy I BLM Medium None None Yes about exposure to wildlife to TO. Completed oil well Rusting barrels Need HRR, PA, Workplan for SI with Sampling. rasing cemented at 48; Drilling Mud Assessment. gas 0mv and explosion Surface Cleanup. Small gas while drilling at 863'; hole leak in wellhead flange, will Filled with fresh water to Wolf Creek 91 US Navy f BLM Low None Nano No flow if the valve iso en 330' No data. csg cemented a[ 53';hole left tilted with fresh water, Wolf Creek 02 US Navy 1 BLM Low Noire Nona No Need HRR. PA. Sl. fish in hole csg cemented at 107'; No data bridge plugs from 1447 to 1735 and from 554 to Wolf Creek #3 US Nayy I BLM Low None None No Meed HRR, PA, SI. 661, No data Add to Site list. Need HRR, PA, SI with sampling. csg slicking out of Drilling mud assessment ground with wood Surface Cleanup. Sheen on plug on top; solid surface water in well cellar, csg cemented at 30'; drill waste; wood hundreds of drums indicate pipe, drilling mud and debris; about 200 Skull Cliff Core iesl #1 US NaMy I BLM High None None Yes polential for cornlamrna[ion diesel left in hole nisling barrels Need HRR, PA, SI. Two open csg, wood drums are floating on a building; pylons; pond near the well. csg cemented at 1000', wood & metal Kaolak 01 US Navy 1 BLM t ow None jNone lNo Potential for hurried landfill. fdriltingluidsieftin hole debris Page 8 of 14 • • SPAR Response with Legacy Wells Lisl.xlsx 181-11119013 Risk Well Name Operator f RP ! land Mgr Priorlty CSP Status File 1NHazid #1 1 U Navy 19LM #1 JUS Navy/ umatik Ill US Na I BLM Low None None as[ Oumalik #i US Na !BLM Low None None #1 N East Topagoruk #1 USN l BLM Kniteblade #1 US Navy l BLM Page 9 of 14 Subsurface `AOGCC Surface SPAR Workgroup Notes Status Add to Site list. Need HRR, PA, SI with sampling. open flange Q Drilling mud assessment. Surface Cleanup. Drilling Gas well. Open ports. ground level. Mud pile overgrown with Drilling fluids and Metal & wood v , etallon and lichen tubulars lett in hole debris Need HRR, PA, SI. No evidence of sheen, stressed veg, or drilling csg cemented at 502'; open casing slicking out of waste on surface. Veg plug at 3470 to 3511'; ground. Wood appears heall drilling nuids left in hole debris. Open casing below Add to Site list. Need HRR, ground level. PA, SI with sampling- Revegetated. Drilling mud assessment. Numerous metal Surface Cleanup. Debris csg partially cemented at I support structures and drilling muds. Stressed 2762'. Plug at 2543% slicking up. vegetation Dridin mud left in hole Concrete debris, plate welded to pipe: l' of pipe rsg cemented at 1100'. sticking up - Need HRR. PA. SI. Drig fluids left in hole Wooden debris. Add to Site list. Need HRR, PA, SI with sampling. Driving mud assessment. open csg broken Surface Cleanup. Downhole material present csg cemented at 6073'. off and sticking up: at surface, area mostly original hole drilled to wood, metal, revegetated. Diesel still 7154'& junk len; concrete and other occupies the ground sidetrack hole left wilh debris. rusting dreulatioir lines. drillina fluids barrel Add to Site list. Need HRR, PA, SI with sampling. Dolling mud assessment. Surface Cleanup. Pile of tsg 10 1100'; pkig al open casing drilling muds is next to the 1049% drilling mud below sticking up. Wood, teller. No offical reserve pit plug: unknown fluids in metal, and glass noted o en hole debris. open casing Need HRR, PA, SI. BLM sticking up. Wood, stales that there was no metal, and glass debris at this site in 2012. csg cemented at 420% debris - •I 0 SPAR Response with Legacy Welts Lisl.xlsx Paye 10 of 14 0 0 w once a BLM 2013 Risk Historic AOGCC Subsurface AOGCC Surface Well Name Operator I RP f Land Mgr Priority CSP Status File #IHazid Release? SPAR Workgroup Notes Status v F Status open casing sticking up. Wood, metal, & concrete debris rusting Need NRR, PA, SI. Reports barrels. One indicate solid waste csg cemented to 45';fish marked flammable Knileblade #2 US Navy I BLM Low None None No drums in hole hazard. open casing slicking up; metal & Krideblade #2a US Navy 1 BLM Low None None No Need HRR, PA, SI. csq cemented at 38% concrete debris Need HRR, PA, SI including learning assessment. Site partially No wellhead. submerged intermittently csg cemented at 80; Metal. Solid waste North Simpson Test Wel 4 US N2n I BLM Low None None No during the summer dri0ing fluids left in hole ? No dala crude wellhead. Need HRR, PA, St. Surface csg cemented at 685'; Wood and metal Umiat 01 US Navy J BLM I FUDS Medium Cleanup co 335.38.00113090 Yes, see file Cleanup drillinq fluids left in bole debris No wellhead. Gravel pad partially csg cemented a1486; revegelaled wood Need HRR, PA, SI. Surface cement plug from 440 to debris and pipe Umiat #i t US Na I BLM I FURS Low pending dos 335.38.00113083 Yes, see file Clea 490'; sticking u csg cemented at 7206'; vVefNwad- Gravel various plugs from 8250' pad revegetaled 7 South Sirnpson 01 US Navy I BLM Low None None Yes Need HRR, PA, SI. to surface No data Add to Site list. Need HRR, PA, SI with sampling. Drilling mud assessment. Surface Cleanup. Large quantifies of ferrous oxide, zinc oxide, zinc carbonate, and barium sulfate were added to drilling muds. Stains apparent in photos. BLM field camp an site. Walls between the reserve and Pare pits have eroded. Wellhead and Water flows into surface gravel pad. ? No Wook #1 USGS I BLM Low lNone Name Yes water during break22L no data data Paye 10 of 14 0 0 SPAR Response with Legacy Wells Lrsl.xlsx BLM 2x13 Risk Well Name 10porator I RP I Land Mgr Priority CSP Status I File #IHazid Arca- Barrow Cure #1 US Na l til.M Avak 01 US Navy I BLM Barrow Bi R' #1 US Na I BLM Barrow Cafe Rig Test 91 US Na I BLM #2 I US Navy I BLM #1JUS N,a I BLM H' h NOr1e None Test Well #1 US Test Well #2 US Barrow Test Wetl #31115 Na IN©r1h Slo c Bora IAedium None None Unknown Page 11 of 14 Subsurface -FAOGCC Surface SPAR IWorkgfoup Notes Status _ ___ araiu5 Need HRR, PA, SI. Surface Cleanup, Photo CIMG0218 csg cemented at 53` shows area of disturbed tubing hung to 708': hole open casing vegetation that should be heft filled with drilling mud slicking up; wood & investi algid durin Sf and diesel metal debris open casing Need HRR. PA, St. Surface csg cemeoled at BIF. sticking up; wood & Cleanu-. lu set at 1348' metal debris Not abandoned, site not cleared, Need HRR, PA, SI. Surface open easing 7? No Cleanup no data data Not abandoned, site not eteared, Need HRR. PA, SI. 'Surface open casing 77 No Cteanu no data data Need HRR, PA, St with sampling. trilling mud assessment. Surface Cleanup. Drilling Muds on Not abandoned, site -slowly revegelatmg site not igred, More information on drilling open casing 7? No mud specifics rs being researched no data data Need 1lRR, PA, SI wdh sampling. Drilling mud wellhead leaking assessment. Surface cemented Csg to gas!? Wood & Cleanup- Cellar does not 1270;slotted liner to metal debris. Area retain water 1956': tbg to 1939 affected 50'x50' Need HRR, PA. SI. Drilling Csg cemented at mud assessment. Surface 441'.hole Iell willed with open pipe; metal & Cleanup- On mads stem water concmie debris Need HRR, PA, Sl. Drilling Csg cemented al 2260'; mud assessment- Surface periorated liner to TD. wood, metal & Cleariu . fln road s stem lin Completed well. Conerete debris Need HRR, PA, SI with sampling and workplan. Drilling mud assessment. Surface Cleanup. Drilling +csg cemented at 10461: open c5g slinking mud at surface. Sheen on hole left filled with drilling up; wood & metal surface wafer in well cell larQuids and wafer. de" 0 SPAR Response with Legacy Wells Lisl.xlsx Well Flame Operator I RP I Land Mgr BLM 201$ Risk Priority CSP Status File #ltiazid yr once oF— Historic Release? SPAR Workgroup Notes AOGCC Subsurface Salus g AOGCC Surface Status no data. Likely revegetaled. Removed from our list of wells of concern in < 50', no csg, no API#, October, 2012 Oumalik Foundation Tess A US Navy I BLM None-uncased hc None None lUnknown Need HRR, PA. not in AOGCC database Monlht Meeting no data. Likely revegetated. Removed from our fist of wells of concern in < 50', no csg, no API#, October, 2012 Cumalik Foundalion Test b US Navy I BLM None-uncased hC None jNane Unknown Need HRR. PA, not in AOGCC database Monthly Meeting no data. Likely revegetated. Removed From our irsl of wells of Concern In < 50', no csg. no API#, October, 2012 Oumalik Foundation Test A US Navy I BLM None-uncased hc None lNone Unknown Need HRR. PA, not m AOGCC database Monthly Meeting no data. Likely revegetated. Removed from our list of wells of concern in < 50', no c5g. no APF#. Odubut. 2012 Oumalik Foundation Test A US Navy I BLM None-uncased ht Nune lNone Unknown Need HRR, PA, nal in AOGCC database Monthiv Meetin no data. Likely revegetaled. Removed from our Ilst of wells of con cam in < 501, no csg, no APi#. October, 2012 Oumatik Foundation Test 0 US NavyI BLM None-uncased hc None None Unknown Need HRR. PA, not in AOGCC database Moral Meeting no data. Likely revegetaled. Removed from our list of wells of concern in < 50', no csg. no API#, October, 2012 Ournalik Foundation Test 4US Navy I BLM None4xwased h_j None None Unknown I Need HRR. PA, not in AOGCC database Month Meetin Page 12 of 14 0 Page 13 of 14 SPAR Response with Legacy Wells LrsLxisx Well Name BLM 2013 Risk Operator f RP I Land Mgr Priority Historic CSP Status Fife #IHazld Rslease7 AOGCC subsurface Status �__ - -_-�� . A013CC Surface Status no dala. Likely SPAR 1Norkgroup Nates revegelaled. Removed from our list of wells of concern in < 50'. no csg, no AP IN, October, 2012 Oumalik Foundation Test US Na!q BLM None -encased h None None Unknown Need HRR. PA. not w AOGCC database MonthlyMeetin no data. Likely revegelated. Removed from our list of wells of concern in < 501. no csg, no API#, October, 2012 Oumalik Foundalion rest U5 Na I BLM None -encased h None None Unknown Need HRR, PA, not in AOGCC database Monihl lAeeli no data. Likely revegetaled. Removed from aur fist of wells of concern in 0urn alik Foundation Test US Na 18 LM None -encased fi None None ilnknown Need HRR. PA, < 50', no csg. no API#, not in AOGCC database October, 2012 Month! Meetin no data. Likely revegetated. Removed from our list of wells of concern In < 50', no csg, no API#, October, 2012 Oumalik Foundat'Gon Test US Na I BLM None encased h Nome None Unknown Need HRR, PA, not m AOGCC database Month! Meeting property abandoned per then -applicable South Banow #7 US NEILM 2LI None None Unknown Need HRR. PA, ro erl lu ed re s no data to support proper Um -Qt 02 US N Noire Pendin Clo 335.30.001/3078 Yes, see file Plu d to surface abandonment no data to support proper Uncal #5 Ummt #9 Urrval A66 Umial #T Atiaaru Point#1 U5 US US Na I BL M US Na I BLM USGS/BLM None Pendin Hi h -PCB cleanu Active None Pendia None tPendi Mane Clo 3L5 313.00113079 335.38.00113093 Cao 335.3$.00113080 Clo 335 38 001I3091 None Yes, see file Yes, see file Yes, see file Yes. see lite No Plu ed E4 surface property plugged and abandoned pfupedy plugged and abandoned property plugged and abandoned Need HRR. PA,Plugged by properly plugged and BLM in 2009. abandoned abandonment suriaoe site rcmediated surface site remediated suriacx V le remediated surface site re medialed Page 13 of 14 SPAR Response with Legacy Wells LrsLxlsx Page 14 of 14 0 vrcTon`ce o BLM 2813 Risk Historic AOGCC Subsurface AOGCC Surface Well Name Operator i RP 1 Land Mgr Priority CSP Status File #fFlaxid Releases SPAR Workgroup Notes Status Status Add to Site list. Need HRR, PA. SI with workplan and sampling. Chilling mud assessment. Surface Cleanup. Two large breaches on the south side of the berm allow water out of the reserve pit. Plugged properly plugged and surface site Drew Point #1 USGS 1 BLM None None None Yes by BLM in 2410. abandoned remedialed On Site list Need HRR, PA, 51 with workplan and sampling. [frilling mud assessment. Surface Cleanup. In 1976 the reserve pit berm failed and dolling muds/cutlings were released onlo the Poe of Teshekpuk Lake. Plugged by BLM in 2008. Solid waste from camp aril drilling operations buried on northern portion of pad. Erosion has exposed solid properly plugged and surface site East Teshek uk #1 US Navy 1 BLM None Active - waits 3Q0.38.11012652 Ycs, see file waste. abandoned remediated Threatened by erosion. properly plugged and surface site J. W. Dalton $P USGS f BLM None None None No Plu ed b BLM in 20fl5. abandoned rernediated properly plugged and surface site South Barrow #8 USAF 1 BLM None None None Unknown Need HRR, PA, abandoned remediated properly plugged and surface sile South Bartow 911 US Na INorih Slope Bono None None None Unknown Need HRR, PA, abandoned remedialed properly plugged and surface site South Barrow 013 US Na lNerlh Slope Boro None None None Unknown Need HHR, PA, abandoned remedialed properly plugged and surface site South Barrow #15 US Na !North Sloe Boro None None None Unknown Need HRR, PA, abandoned remediated properly plugged and surface site South Barrow #19 US Na 1Nrarlh Sloe Baro None Nana None Unknown Need HRR. PA, abandoned remediated Properly plugged and surface site South Barrow 1x20 US Na Worth Slope Bora None None None Unknown Need HRR, PA, abandoned remedialed Need HRR, PA, dolling mud assessment, containment assessment, possible releases. Breaches allow wafer to flow into and aul of property plugged and surface site Watakpa #2 USGSI BLM None None lNone lyes I reserve and flare pits. labandoned irernediated Page 14 of 14 0 lc-apfm 10Jan95 LOCATION CLEARANCE REPORT State of Alaska OIL AND GAS CONSERVATION COMMISSION PTD No. ~O-/O9 Memorandum To File: API No. Spud: Note casing size, wt, depth, cunt vol, & procedure. Long Csg: . Well N~e S~{~;~ E~~ Operator ~T~ ~- kerf TD: ~T f , ~g Release Liner: Perf intervals - tops: Review the well file, and comment on plugging, well head status, and location clearance - provide loc. clear, code. Marker post or plate: Location Clearance: Code ~ ~' Signed Date , Closure Report 1.s Phillips Petroleum l'Company Alaska Inactive Reserve Pit NMU T#r' i i [it "IM North Americai d i (a'1. * i 'i,- Prepared by HILL 301 West Northern Lights Blvd. Suite 601 Anchorage, Alaska 99503 Contents Section Page 1 Declaration .............................................. 1-1 2 Summary ................................................ 2-1 3 Closure Study Approach .................................... 3-1 ANC10011DED.WP5 111 3.1 Preliminary Site Screening ............................... 3-1 3.2 Site Assessment Studies ................................. 3-3 3.3 Qualitative Risk -Screening Procedure ....................... 3-3 3.4 Closure Alternatives and Benefit and Impact Evaluation .......... 3-4 3.5 Closure Report ....................................... 3-4 4 Waste Site Identification, History and Status ..................... 4-1 4.1 Location ............................................ 4-1 4.2 Landowner .......................................... 4-2 4.3 Operator ............................................ 4-2 4.4 History of Operation ................................... 4-2 4.5 Closure Status ........................................ 4-7 5 Site Description ........................................... 5-1 5.1 Sullivan #1 .......................................... 5-1 5.2 Sullivan #2 .......................................... 5-2 5.3 Sullivan Strat #1 ...................................... 5-5 6 Environmental Setting ...................................... 6-1 6.1 Geology and Soils ..................................... 6-1 6.2 Regional Hydrogeology................................. 6-5 6.3 Climate ............................................ 6-6 6.4 Natural Resources ..................................... 6-7 6.5 Biological and Ecological Resources ........................ 6-7 6.6 Historical Resources ................................... 6-8 6.7 Human Resources ..................................... 6-8 7 Site Assessment ........................................... 7-1 7.1 Sampling Program and Results ............................ 7-1 7.2 Summary of Visual Inspection Observations ................... 7-1 7.2.1 Sullivan #1 ..................................... 7-1 7.2.2 Sullivan #2 ..................................... 7-1 7.2.3 Sullivan Strat #1 ................................ 7-14 7.2 Site Assessment Conclusions ............................ 7-14 7.3 Action Plan ........................................ 7-14 8 Risk Screening ....................................... 8-1 8.1 Description of Methods ................................. 8-1 8.2 Results of Risk Screening ................................ 8-6 9 Benefit -Impact Evaluation ................................... 9-1 10 Action Recommendation .................................... 10-1 11 Works Cited ............................................ 11-1 ANC10011DED.WP5 111 Contents (continued) Section Page Appendix A. Interim Site Assessment Guidance for Inactive Drilling Waste Sites Appendix B. Closure Documentation Reports Appendix C. Analytical Results Tables Number Page 7.1 Summary of Visual Inspection for Sullivan #1 ...................... 7-2 7.2 Summary of Visual Inspection for Sullivan #2 ...................... 7-5 7.3 Summary of Visual Inspection for Sullivan Strat #1 ................... 7-7 Figures 3.1 Site Study Plan for Reserve Pit Assessment and Closure ............... 3-2 4.1 Sullivan Wells General Location ................................ 4-3 4.2 Sullivan Wells Location Map .................................. 4-5 5.1 Sullivan #1 and Sullivan #2 Drill Site Locations .................... 5-3 5.2 Sullivan Strat #1 Drill Site Location ............................. 5-7 5.3 Sullivan Strat #1 Well Location ................................ 5-9 8.1 Risk Screening Procedure for Reserve Pit Assessment and Closure ........ 8-2 ANC1001IDED.WP5 iv Section 1 Declaration On the basis of information contained in this report, the reserve pit locations at the Sulli- van #1, Sullivan #2, and Sullivan Strat #1 wells should be declared non -locatable and no further action should be required by ADEC. The request for no further action is based on the following: • Field personnel were unable to locate the wellheads or reserve pits after searching more than eight staff hours on foot at each site; these structures are no longer identifiable. • The drill sites were located using survey information and a global position- ing system (GPS) device. No indication of stressed vegetation or other visual indications of waste effects on the environment could be detected at the well site locations. • The drill sites are covered with soil and indigenous vegetation. • Natural geologic and biologic processes continue to erode or cover the drill sites with soil and deadfall. • Human access to the sites is restricted because the access roads no longer exist and thick vegetation prevents easy access. • Further site delineation or intrusive investigations could cause greater adverse impacts to human health and the environment than leaving the sites alone. ANC100IIDE2.WP5 1-1 Section 2 Summary The Sullivan #1, Sullivan #2, and Sullivan Strat #1 drill sites are located between Cape Yakataga and Icy Cape. The well sites are about 3 miles inland from the Gulf of Alaska. Sullivan #1 and Sullivan #2 are adjacent to the Little River. Sullivan Strat #1 is adjacent to the Big River. Drilling operations and disposal of drilling materials were conducted in accordance with a state -issued drilling permit. All three Sullivan wells were exploratory wells that were never placed into production. Sullivan #1 well was plugged and abandoned on December 28, 1955, Sullivan #2 well on March 21, 1957, and Sullivan Strat #1 well on May 19, 1954. Drilling records indicate that drilling fluids and cuttings at each site were discharged into an adjacent reserve pit. All equipment was removed after the wells were plugged and abandoned. A follow-up reserve pit assessment was completed during the summer of 1993. The follow-up assessment included: • Visual site inspection • Qualitative risk screening The drilling pads and reserve pits were completely overgrown with dense vegetation and could not be located. Reserve pit materials were apparently covered, or may have washed down the river. Geologic and biologic processes continue to change site conditions. An extensive ground search at each site failed to reveal any physical evidence of reserve pit materials or any impacts resulting from their presence. A qualitative risk -screening evaluation estimated that risks posed by the sites are negligible. An impact and benefit analysis of further investigative actions indicate that greater health and environmental risks would result compared to leaving the sites alone. The Sullivan #1, Sullivan #2, and Sullivan Strat #1 sites should be declared closed and no further investigation required. ANCIo011DE3.wP5 2-1 All reasonable steps were taken to locate the reserve pits and no evidence of a well head reserve pit, or impacts thereof could be identified at any of the three Sullivan locations. ANC1001 IDE3.WP5 2-2 Section 3 Closure Study Approach This section summarizes the approach and methods used to determine closure status. The June 1991 Interim Site Assessment Guidance For Inactive Drilling Waste Sites (Appendix A) was used as a guide in performing the site assessment work presented in this report. The decision framework, used to determine site status and proposed actions, consists of five parts, described as follows: • Preliminary site screening to determine site status • Site assessment studies, including a site visit, sampling, and data analysis • Qualitative risk screening and, if a basis for concern exists, the identification of corrective action alternatives • A benefit and impact evaluation of corrective action alternatives (if a basis for concern exists but the risk is negligible) • Preparation of a report documenting the site assessment findings, risk screening results, and the preferred alternative (if corrective action is warranted) or documentation of adequate closure (if no further action is warranted). Figure 3-1 illustrates a flow diagram of the closure study plan. 3.1 Preliminary Site Screening A preliminary site screening was performed to collect background information that will be evaluated for closure according to ADEC interim guidance. ANCIOO11DE4.WP5 3-1 Inconclusive Data Additional Sampling and Analysis Yes Records Review Background Information Site Visit Visual Inspection Soil & Water Sampling Evaluate Information Basis for Concern Step 1 Risk r ificant Risk Risk Screening Negligible Step 2 Develop I Benefits > Impacts IImpact /Benefit Remediation Plan I Evaluation 3-2 Data Adequate Impacts > Benefits Closure Report No FIGURE 3.1 SITE STUDY PLAN FOR RESERVE PIT ASSESSMENT AND CLOSURE nPUum Available company records and AOGCC records, including inspection reports, drill togs, letters, drilling permits, were reviewed to collect background information on the site. Information was collected pertaining to the type of reserve pit materials that may have been generated during drilling and the actions taken to close the site after drilling was completed. 3.2 Site Assessment Studies The purpose of the site assessment is to determine whether leachate, or eroded soil from the reserve pit is posing a threat to human health or the environment by violating Alaska state water quality standards. Existing site conditions and the potential for future violations were addressed. Each reserve pit location was visited and visually inspected on foot. Information was collected on the local environmental setting, a visual inspection was performed to document site conditions. 3.3 Qualitative Risk -Screening Procedure A qualitative risk -screening procedure was used to identify whether a site poses a signifi- cant threat to human health or the environment. The qualitative screening process is used to distinguish those waste sites with negligible risk from sites that have significant risk to human health and the environment. The process is considered to be appropriate for sites where target contaminant concentrations range from non-detectable to low levels. Informa- tion collected during the preliminary screening and site assessment was used to estimate the level of risk at each reserve pit site. A two-step decision process was used in the qualitative risk screening procedure. The first step established whether there was a basis for concern. To establish a basis for concern, evidence of chemical contamination exceeding water quality standards and the presence of potential biological receptors were necessary. The second step established whether the site is likely to present a significant risk to human or environmental receptors. To determine if the level of risk is significant, exposure criteria and consequence criteria were evaluated sequentially. Site-specific data were reviewed to estimate contaminant release mechanisms, ANCIo01 IDE4.wP5 3-3 migration potential, and environmental persistence of contaminants. Human and wildlife use patterns were reviewed at each site to estimate the exposure risk based on duration or frequency of exposure to measured contaminants. If the risk was considered to be significant, conceptual remediation options to reduce the risk were presented. 3.4 Closure Alternatives and Benefit and Impact Evaluation If the risk -screening model indicated that probable risk is negligible, the impact and bene- fits of further action were considered. If it is estimated that the impacts from corrective action would be greater than leaving the site alone, the site could be considered to be adequately closed. 3.5 Closure Report This task involves consolidating the above information into a closure report documenting the findings from the application of the screening procedures at each inactive reserve pit location. This closure report follows the report format recommended in Section V of the ADEC June 1991 Interim Site Assessment Guidance For Inactive Drilling Waste Sites. ANCIOO11DE4.WP5 3-4 Section 4 Waste Site Identification, History, and Status 4.1 Location The Sullivan #1, Sullivan #2, and Sullivan Strat #1 wellheads are located on lands between the Malaspina Glacier and Cape Suckling in an area referred to as Icy Bay, (Figure 4.1). The wells are situated about 3 miles inland from the Gulf of Alaska, adjacent to the Little River (Figure 4-2). A legal description of the Sullivan #1 location follows: Southern half of the northwest quarter of Section 10, Township 22 South, Range 21 East, Copper River Meridian Latitude: 60001'19.9"N Longitude: 141048'57.5V Vd A legal description of the Sullivan #2 location follows: Eastern quarter of Section 9, Township 22 South, Range 21 East, Copper River Meridian Latitude: 60001'02.40'N Longitude: 141049'01.4V A legal description of the location is as follows: The northeast corner of the northwest quarter of the northeast quarter of Section 20, Township 22 South, Range 22 East, Copper River Meridian Latitude: Longitude: 60°00'04'N 141040'57'V ANC10011DE5.WP5 4-1 4.2 Landowner The landowner of all three Sullivan wells is the State of Alaska. 4.3 Operator The operator for all three Sullivan wells was Phillips Petroleum Company. 4.4 History of Operation All three Sullivan wells were wildcat exploratory wells never placed into production. Drilling for the Sullivan #1 well began on June 19, 1954, and was completed on December 28, 1955. The maximum well bore depth was 10,013 feet. Drilling for the Sullivan #2 well began on January 23, 1956, and was completed on March 21, 1956. The maximum well bore depth was 12,056 feet. Drilling for the Sullivan Strat #1 well began on April 11, 1954, and was completed on May 19, 1954. The maximum well bore depth was 4,837 feet. A review of the sites' drilling records indicates that freshwater -based muds were used in the drilling process. The viscosity of the drilling fluid was adjusted on an as -needed basis during the drilling operation. The muds at Sullivan #1 and #2 were spotted with diesel at various depths during the drilling operation to facilitate drill string lubrication. At Sullivan #2, calcium chloride and diesel oil were added to the bentonite muds during drilling, and salt water was added at various phases of operation. The size and location of reserve pits is not mentioned in the drilling records of these sites, although the standard practice at the time these wells were drilled was to excavate a reserve pit within about 100 feet of the well. Sullivan #1 was plugged and abandoned on December 28, 1955, Sullivan Strat #1 on May 19, 1954. Sullivan #2 was plugged and abandoned on March 21, 1957. The top well casing was plugged with 25 sacks of cement and a 4 -inch -diameter casing_ marker, extend- ing 4 feet above the ground, was placed above the well. ANCI00IIDE5NP5 4-2 SKULL RK , ?Va RIMDALL - v '694p •M1 ',. Tellln RV C 1 g4pL�. e�i5� ,,,,55lele Cree Cm < t et l8a o. orlhwil^Jc �'JDOer Slal¢la• SSA LaslT¢ll nVrt � 1 'pL+�iesB Va , Pa son 'oUemPs¢Y - •I .5^605 yC(¢ ' .S,Pro0v �ol°lsaim➢aa n Lc6rAdyg¢1 IAe3, F¢Sal "nTA6, 'BNOY3P/ .�.leN nIrCA 1(NeiG•(� iJ s y pt1 q 500• MEN7t1ST^/ 14 W6:11 nt 4 l �5{d4hfd @,na LodB¢ ''P�.r �PZk L3- i> N UT Z LL 4966 1 Sir r h8h ( `Yo. 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The well was closed by cementing it shut. It is believed that excess drilling fluids were discharged down the well before abandonment and the remaining reserve pit solids were covered with soil. The Sullivan #2 well site was closed in accordance with requirements in existence at the time of closure. The drilling records do not mention the use or closure of a reserve pit. The site was closed by cementing the well shut and placing a 4 -foot -high marker over the well. The Sullivan Strat #1 well was plugged and abandoned in accordance with closure requirements in existence at the time of closure. The site was closed by cementing the well shut. ANC1oo11DE5.WP5 4-7 Section 5 Site Description 5.1 Sullivan #1 Wellhead Marker The Sullivan #1 wellhead marker and reserve pit(s) could not be located by the field team, either from the ground or from the air (Figure 5.1). A Trimble Navigator Global Positioning System (GPS), a Bering Glacier A-3 quadrangle topographic map, and Brunton field compass were used to establish (with an accuracy of 75 feet) the wellhead location (Figure 5.1). Once this location was established, a sur- rounding 300 -foot by 500 -foot -square area was searched for remnants of a wellhead, reserve pit, and well site debris. A description of the well site area follows. Well Site Area The Sullivan #1 well site area is situated on a 15 -foot -high bluff 200 feet from the Little River, in an area where the river flows into the mouth of a canyon. The well site is about 0.5 mile southeast of the toe of Lare Glacier, the source of the headwater to the Little River. The access road to the well site was washed out about 4 years ago, according to a local resident. The well site area is relatively flat, with large logs and overburden that had been pushed into the riverbed by a bulldozer. The logs were stacked parallel to the river. In addition to the logs, the only physical remnants indicating a former drill site were an old stove pipe, an empty rusted barrel, and a 1.5 -inch -diameter steel cable, extending from the river bank to the bluff. Remnants of a Butler building used in drilling operations was found in the vicinity of the drill site locations. The presence of fine-grain backwater deposits and hemlock and spruce trees indicates that this area has been flooded by the Little River in the past. The vegetation consists of hem- lock and spruce trees with 2 -inch -diameter trunks, alders more than 10 feet in height, sahnonberry bushes, devil's club, and ferns. ANC10011DE6.WP5 5-1 The site is remote. It can be accessed in summer by helicopter and foot travel. 5.2 Sullivan #2 Wellhead Marker The Sullivan #2 wellhead marker and reserve pit could not be located by the field team, either from the ground or from the air (Figure 5.1). References, including GPS, a Bering Glacier A-3 quadrangle topographic map, and Brunton field compass, were used to ascertain (with an accuracy of 75 feet) the wellhead location. Once this location was established, a surrounding 75 -foot by 75 -foot -square area was searched for visible remnants of a wellhead, reserve pit, and well site debris. Well Site Area According to Phillips correspondence, the Sullivan #2 well was drilled 'only a few feet from Little River, which flows in a south-southeast direction from Sullivan #1" and about 1,280 feet south from Sullivan #1. The area investigated is situated in a low-lying area along the river bank that, based on its position, is probably flooded by the river at least every spring during breakup. The flooding appears to be quite severe as evidenced by a very large tree (with trunk 5 feet in diameter) that was undercut, swept downriver, and deposited below Sullivan #2.). The ground is wet and swampy with ponded surface water throughout the area. According to a local resident, the access road to the Sullivan #1 and #2 sites was washed out about 4 years ago. Vegetation consists primarily of alders less than 8 feet in height in boggy, swampy areas. No physical remnants of drilling were found at the site. The site is remote. It can be accessed in summer by helicopter and foot travel. There are no roads leading directly to the well site. ANCI001IDE6MP5 5-2 Location of Sullivan #1 and #2, looking north. Approximate search areas are highlighted. Establishing wellhead location for Sullivan #1 by using GPS. FIGURE 5.1 SULLIVAN #1 and SULLIVAN #2 DRILL SITE LOCATIONS JULY 1993 5.3 Sullivan Strat #1 The Sullivan Strat #1 wellhead marker and reserve pit could not be located by the field team. Reconnaissance of the site by air was unsuccessful because of the amount of vegeta- tion covering the site (Figure 5.2). A Bering Glacier A-2 quadrangle topographic map, GPS, and a Brunton field compass were used in searching for the Sullivan Strat #1 wellhead location. The location was established with an accuracy of about 75 feet. A 500 -foot by 500 -foot -square area was searched for visible remnants of a wellhead, reserve pit, and well site debris. The search area was later expanded to a 0.5 -mile by 2 -mile area that included the west bank of the Big River. Well Site Area The Sullivan Strat #1 well site area is on an active river floodplain terrace, about 0.5 mile southwest of the toe of Beare Glacier, and 4 miles northeast of the mouth of the Big River (Figures 5.2 and 5.3). The site is bordered to the west and north by the steep slope of an adjoining terrace that rises about 100 feet above the site. To the east and south the site is bordered by the Big River. Big River was formed by glacial runoff from Beare Glacier and rain and snow meltwater from the surrounding mountains. In this case, an artesian spring, found 20 feet from the ice of Beare Glacier, supplies Big River with a constant supply of water, which is supplemented with rain and meltwater. The only visible remnants of drilling activities were an old stove pipe, four lengths of 9 -inch -diameter drill rod covered by the forest carpet, and two rusted empty barrels. Active geological processes affecting the well site area include: • Flooding • Landslides from the adjoining ridge No signs of a wellhead marker or reserve pit remain. The drill site access road constructed by Phillips has also been undercut and buried by the Big River. No visible signs of the road were evident. ANC10011DE6.WP5 5-5 The entire area is covered by a thick foliage, which includes hemlock and spruce trees, alder, salmonberry bushes, devil's club, and a forest mat. The largest hemlock and spruce trees (with trunks up to 24 inches in diameter) are located next to the adjoining terrace, with alder and birch cover near the river. This suggests that the area is periodically flooded to the base of the adjoining terrace. The site is remote. Access to the site is primarily by helicopter and foot travel in summer. A logging road is located about 1 mile west of the site. ANCIOOI IDE6.WP5 5-6 44VA, 4 :Iom Sullivan Strat#1 location, looking north. Beare Glacier in upper right hand corner of photo. area of site is highlighted. Toe of Beare Glacier and head of Big River in upper right hand comer. FIGURE 5.2 SULLIVAN STRAT #1 DRILL SITE LOCATION JULY 1993 Sullivan Strat #1 well site area in trees on first terrace, looking southwest. FIGURE 5.3 SULLIVAN STRAT #1 WELL LOCATION JULY 1993 Section 6 Environmental Setting 6.1 Geology and Soils This section describes the environmental setting of three wells—Sullivan #1, Sullivan #2, and Sullivan Strat #1, which are located near each other in a similar environment. Many geological field investigations have mapped the region surrounding the Sullivan #1, Sullivan #2, and Sullivan Strat #1 drill sites, mainly because of the deposits of oil, natural gas, coal, and hard metals that have been found in the region, and the glaciation found throughout. Relevant sources of information used to describe the geology and soils of the area include G. Plafker, T. Hudson, M. Rubin and K. Dixon (from 1975 to 1980); M. Miller in 1955; L. Yehle (1977); D. Miller (1951); R. Kachadoorian (1963); C. Wahrhaftig (1965); and T. Pewe (1975). Regional Physiographic and Geological Setting The Icy Bay drill sites are in the Pacific Border Range physiographic subprovince, within an informal section called the Gulf of Alaska Coastal section in the Bering Glacier Region. The region is bordered to the north by the Kenai -Chugach Mountain section (extremely rugged ridges rising 7,000 to 13,000 feet, the higher peaks draped with ice fields that feed valley and piedmont glaciers); to the northeast and east by the St. Elias Mountain section (massive, isolated peaks 14,000 to 20,000 feet high, separated by a myriad of narrow ridges and sharp peaks 8,000 to 10,000 feet high that are drained by a network of glaciers); to the west by the Copper River lowland; and to the south by the Gulf of Alaska. The Bering Glacier subregion coastal area is a massive unit of ice and glaciers cut by one major estuary—Icy Bay. Within the subregion, the drill sites are located in a low foreland that ranges in width from 0.5 to about 5 miles at Munday Creek and Icy Cape, respectively. The foreland, immediately backed by the rugged Yakataga Mountain front, consists of a sequence of marine terraces and glacial moraines that rise from sea level to 400 feet within 4 miles. ANCIOOI IE46.W P5 6-1 Bedrock in most of the study area consists of Tertiary- and Holocene -age marine and continental clastic rocks, which range from 1.8 to 65 million years in age, and are broadly divisible into three subdivisions. The subdivisions are (1) an early Tertiary sequence (40 to 65 million years of age) of hard, dense siltstone and sandstone that is variably deformed and highly faulted, and associated volcanic rocks along with shallow marine coal bearing clastic rocks; overlain by (2) a middle Tertiary sequence, (30 to 40 million years of age) composed of mudstone and siltstone; and followed by (3) a late Tertiary through Holocene sequence called the Yakataga Formation, consisting of a marine diamictite characterized by abundant glacial detritus, muddy sandstone, and conglomeratic sand mudstone. The Yakataga Formation reflects deposition adjacent to the intensely glaciated Fairweather Mountains that border the sites; deposition of these strata probably correlates to uplift of these mountains. The Yakataga Formation is also found directly off the shoreline of the study area as a barrier reef called the Yakataga reef. The Icy Bay area is at the continental margin, lying in a tectonically active transition zone between transform and convergent plate motion. The transition zone is informally called the Pamplona zone, a seismic gap that connects the Aleutian trench and volcanic arc to a transform fault system, composed of the Queen Charlotte, Fairweather, and related fault. The transorm fault system was caused by the Pacific plate moving past the North American plate (transform motion). The Aleutian trench and are were caused by the underthrusting of the Pacific plate beneath the continental margin (convergent plate motion). Visible evidence associated with the convergentent and transform motion includes complex folds and faults and volcanic cones in the Wrangell Mountains, and ongoing uplift of terrane at the rate of about 3 inches per year in the Icy Bay area. Faults in the immediate area of the drill sites include the Fairweather Fault system and related local drag faults such as the Sullivan fault and the Yakataga fault. Uplift of the Yakataga block within the Pamplona zone is at an average rate of about 3 inches per year. The major faults do not appear to have been active within the past 5,000 years; future extreme uplift of the areas would most probably occur during a major earthquake along the convergent plate margin. However, the area is in a zone of high seismic activity, where many earthquakes greater than 6.0 in magnitude on the Richter Scale, four greater than 8.0, have occurred since 1899 and are likely to continue to occur. ANCIOo1IF46.WP5 6-2 Several volcanoes located in the region have also been active in the past 100 years. These include Iliarnna, Redoubt, Spun, and Saint Augustine, each of which have the potential of becoming active at any time. Regional Geomorphology and Related Surficial Deposits The Tertiary rocks are overlain with marked angular unconformity by essentially horizontal, unconsolidated deposits of Quarternary age (1.8 millions years of age to present). Deposits are made up of a complex sequence of neoglacial fluvial, lagoonal, beach, and marine terrace deposits. Marine Terrace and Beach Deposits The forelands consist of a sequence of three marine terraces containing beach, barrier island, and backwater lagoonal deposits. The terraces, a product of paleoearthquake uplift, are in evidence from Cape Yakataga to Big River and have elevations of about 50, 75 and 160 feet, rising toward the glaciated Robinson mountains. Terrace beach and barrier island deposits are granular, generally consisting of sand and gravelly sand to pebbly cobble gravel with some boulders. Terrace backwater lagoonal deposits (overlying the beach and barrier island deposits) are fine, chiefly sand, silt and organic silts. The two higher terraces are also mantled by talus, slopewash and alluvial deposits caused by glacial fluctuations of Guyot, Lare, and Bear glaciers, and increased sediment supply caused by uplift. The lowest terrace and the modern shoreline deposits are built principally by waves and longshore currents. Such deposits include barrier beaches, spits, barrier islands, and forelands. Deposits are granular deposits, generally consisting of sand and gravelly sand, to pebbly cobble gravel with some boulders. Glacial Deposits The absence of recognizable marine terraces east of Big River and the broad foreland in the Icy Cape area are primarily the product of repeated glacial advances and retreats over the last 40,000 years. Glacial retreats have resulted in two recognizable topographic ANC10011FA6.WP5 6-3 subdivisions: (1) ground moraines, (2) terminal or lateral moraines, and (3) outwash land - forms associated with moraines. Extensive outer and inner terminal moraines were deposited as marine glacial till during the last advance of Guyot Glacier. The moraines, visible as well developed low ridges, extend between Big River and Icy Cape, and northeastward from Icy Cape. These deposits generally consist of till composed mainly of diamicton—a poorly sorted mixture of clay, silt sands, and gravel plus occasional boulders. Well -sorted, discontinuous lenses of sand and sandy gravel are also found throughout. Other principal glacier -related features found in the area are outwash channel deposits, laid down by meltwater within or just outside the bounds of the glaciers. Outwash train and valley train deposits were laid down by meltwater streams that extended beyond the mar- gins of the glaciers either in existing valley streams or in channels newly eroded through the moraines. Outwash channel deposits are mostly bedded sands and gravels. Outwash train and valley train deposits are chiefly well -bedded granular material consisting of sands and gravels. Alluvial and Colluvial Deposits Most nonglacial deposits in the area are recent, having been deposited on top of or cutting through the glacial deposits within the last 100,000 years. These include alluvial, colluvial, and landslide deposits, plus bog, pond, and lake deposits. Alluvial deposits originate by deposition from streams, and most include large quantities or reworked glacial outwash. These deposits include stream valleys within active floodplains and alluvial fans and cones that occur mainly where small streams debouch onto valley floors of major creeks and rivers. Alluvial stream deposits generally consist of granular materials that include well -bedded sands and gravels, with silty sand found in bars and very low terraces subject to continual reworking by the rivers, finally graded at sea level. Stream deposits are generally not covered by vegetation. Some fine silts and sands are found in valley bottoms and low terraces along low -gradient streams. Colluvial deposits, or colluvium, are deposits that have accumulated on or along the flank and base of slopes with the aid of gravity and running water. The source of colluvium is often a combination of eroded morainal or alluvial deposits and underlying bedrock; they ANC100IM6.WP5 6-4 are generally irregularly mixed fragments of many sizes, unsorted and loose. Colluvium generally occurs as a downslope -thickening wedge of silts and sands, with some gravel, clay, boulders and bedrock fragments. Landslide deposits are developed as immediate, one- time gravitational failures along discrete buried surfaces in soft sedimentary rock or overlying surficial deposits. They occur as single slides along the incised stream valley walls and generally consist of diamicton, relatively minor amounts of clay and some organic material, as well as boulders and relatively large masses of bedrock. Bog, pond, and lake deposits are less well distributed throughout the study area, but where found, often cover other surficial deposits that extend beneath them. These deposits consist chiefly of peat (mosses, sedges, and other decomposing organic debris) and organic silt within minor woody horizons and numerous thin interbeds of tephra ash. Deposits also occasionally include clay and fine sand. Site Soil Information on the soil was obtained from a previous investigations conducted by CH2M HILL personnel, a field investigation in July 1993, and original drilling logs. Generally, site conditions consisted of at least 1 foot of organics and organic silts, and associated active floodplain deposits. These are generally underlain by sands and gravels to depth with an occasional diamicton layer at depth. 6.2 Regional Hydrogeology Little River and Big River are typical of streams found throughout the southern part of the subregion: short and swift glacial -fed streams with large sediment loads reworking alluvial and outwash deposits. Big River starts as an artesian spring at the margin of Bear Glacier; additional water is drained from surrounding mountains as rain and snow meltwater. Little River begins at the margin of Lare Glacier; again additional rain and meltwater is drained from surrounding mountains. Both rivers empty into the Gulf of Alaska, with extensive deltas and channels blocked by longshore transport of sediments running parallel to the beach for varying lengths. ANC10011F46.wP5 6-5 Regional groundwater flow predominates in direction from the mountains and glaciers toward the Gulf of Alaska. Regional groundwater flow is evidenced by seeps along the shoreline bluffs of the first marine terrace south of the well sites. 6.3 Climate The principal factors affecting the climate include latitude and geographic position relative to glaciers, large land masses, and the Gulf of Alaska. The Cape Yakataga to Icy Bay area is a maritime climate strongly affected by the Gulf of Alaska. Inland mountains, rising more than 10,000 feet, cause offshore winds to drop their moisture. With no terrain influences involved, annual extremes in precipitation and temperature often occur. These extremes result from outbreaks of extremely cold air in winter and relatively hot air in summer from Interior Alaska. Precipitation The weather station measuring precipitation closest to the Icy Bay well sites is at the Cape Yakataga airstrip on the shore of the Gulf of Alaska. The station is at an elevation of 30 feet. Continuous measurements have been recorded since 1943. Average annual precipitation is 134 inches. Rain, fog, and overcast skies occur on an average of about 80 percent of the days in the summer, although there is great variation between summers of different years. Temperature Seasonal variations are exaggerated because of the reduced number of daylight hours during the winter. January has the lowest monthly mean temperature at 27.7°F. July has highest monthly mean temperature at 53.1°F. Average monthly temperature is 40°F with a daily temperature fluctuations averaging 9.5°F. The monthly mean temperature is almost continuously below freezing for 3 months of the year. Ponds and other stagnant surface water surrounding the site can be expected to be frozen for about 3 months of the year. ANC100I IE46.WP5 6-6 Wind I Winds are generally out of the south in the summer and out of the north in the fall, winter, and spring. Average offshore wind speeds are moderate at 12 to 18 knots; however, winds of 75 to 100 knots can occur over the open water and storms with 50- to 75 -knot winds occur every winter with wind speeds of up to 100 knots recorded. Winds are lightest in the summer months. 6.4 Natural Resources The primary natural resources near the well sites that have proven or potential economic value located include logging, commercial fishing, and gold mining. The area near the Sullivan Strat #1 well site has been logged in the past. Additional log- ging to the south and east is currently underway. The area directly surrounding Sullivan #1 and #2 has not been logged because of steep terrain and both wells falling within "buffer zones" around rivers and creeks where logging is prohibited. Icy Bay and the shoreline directly off the well sites contains commercial fisheries that include Pacific salmon and king, tanner, and opilio crab. This information was obtained through firsthand observations of fishing boats plying the waters off Yakataga Reef in the Gulf of Alaska, Icy Bay, and the Copper River drainage. The Icy Bay area has also been the site of limited placer gold mining activity (especially to the north along the White River) and extensive exploration since the turn of the century. Placer gold has been found in all three terraces in past investigations by personnel currently employed by C112M HILL. Much of the land in the area is closed to mining. 6.5 Biological and Ecological Resources The area surrounding the well sites is densely forested. Because of the steep topography in much of the region, the forest is confined to a relatively narrow strip bordering most of the coastal areas and extending up the valleys and terraces. Mountain hemlock is the major constituent of most of the coniferous forest, although Sitka spruce is also common. ANC100111316.WP5 6-7 Western hemlock, Alaska cedar, cottonwood, aspen, white spruce, and paper birch are also present in the area. The forest understory includes a variety of shrubs such as alder, blueberry, lingonberry, huckleberry, mountain ash, devil's club, red -berried elder, copper - bush, and salmonberry. Ground cover is dominated by mosses, and there is a wide variety of herbs, ferns, mosses, dwarf dogwood, twisted stalk, goldthread, and five -leaved bramble. Invertebrates, such as nematodes, protozoans, and earthworms, inhabit soil and forest litter. Spiders and insects are common in the area. Mosquito and other insect larvae develop and feed in freshwater ponds and puddles. Moose, brown and black bear, and Sitka blacktail deer are common in the Icy Bay region, Bears feed in coastal grass and sedge flats or forage along the beaches in the spring and early summer. As summer progresses, the bears congregate along streams to feed on salmon. Other terrestrial mammal species found in the area include mink, land otter, wolverine, red fox, wolf, coyote, lynx, beaver, muskrat, marten, weasel, red squirrel, and snowshoe hare. A variety of sport fish can be found in nearby streams, including arctic char, Dolly Varden, and lake trout. Also, all five species of Pacific salmon spawn in the various clearwater streams of the Icy Bay region. 6.6 Historical Resources There are no known historical resources within 1 mile of the well sites. 6.7 Human Resources The well sites can be reached by helicopter or by walking at least 2 miles from a logging road that runs from the White River (near the community of Cape Yakataga), which is about 20 miles west, to the Sullivan Logging Camp at Icy Bay, about 10 miles east of the site. There are fewer than 50 residents in Cape Yakataga and, according to the camp manager, Sullivan Logging Camp will have fewer than 100 residents during peak produc- tion. There are also a few barricaded, abandoned and overgrown logging spur roads in the ANC100I1FA6.WP5 6-8 vicinity of the area where the Sullivan Strat #1 well site was located. Hunters sometimes travel these roads in the Icy Bay region. ANCIOOL1H46.WP5 6-9 Section 7 Site Assessment Site visits were conducted to provide support documentation for reserve pit closure. A visual inspection of the site was conducted to satisfy requirements of the Qualitative Risk Screening Procedure. The results of the site visit are described below. No sampling was conducted at the Sullivan well sites. 7.1 Sampling Program and Results No visible remnants of wellhead markers, pads, or reserve pits were found in the areas where Sullivan Strat #1, Sullivan #1, and Sullivan #2 were thought to have been located. Because no reserve pit areas could be located, it was deemed inappropriate to sample soil or surface water. 7.2 Summary of Visual Inspection Observations 7.2.1 Sullivan #1 On July 19, 1993, a three-member CH2M HILL field team spent about 4 hours trying to locate the Sullivan #1 well site in heavy foliage near the Little River and Lare Glacier. The following day, a survey conducted from the air was unsuccessful in locating the former well site area. Inspection results and observations are summarized in Table 7.1. 7.2.2 Sullivan #2 On July 19, 1993, a three-member CH2M HILL field team spent about 3 hours trying to locate the Sullivan #2 well site in heavy foliage near the Little River and Lare Glacier. Although visible remnants of the well head or reserve pit were never found on the ground, from the air, or in aerial photographs, CH2M HILL conducted a site inspection for ANC10011F4E.WP5 7-1 Table 7.1 Summary of Visual Inspection for Sullivan #1 Page 1 of 2 Parameters Yes/No Comments Evidence of reserve pit materials No No apparent evidence of drilling muds or formational cuttings, or even of reserve pit location. Plus, according to drilling records, drilling wastes were injected downhole for disposal. Evidence of leakage through NA impoundment dike walls Evidence of leakage or seepage through cover, such as: 1. Damp/wet spots 1. No 1. No apparent wet/damp spots, entire area investigated was part of a floodplain. 2. Areas of dead or lush 2. No 2. No unusual vegetation patterns noted, vegetation extreme vegetation throughout area. 3. Aquatic vegetation in 3. No 3. No seeps therefore no aquatic vegetation in perennial seeps seeps. Evidence of leakage or seepage NA through the dikes. Evidence of impoundment No No apparent evidence of impoundment overflow overflow, such as: denuded directly related to reserve pit seen downgradient areas, insufficient freeboard, erosion of dikes or downstream area Vegetation stress No No apparent stressed vegetation in well site area observed from ground or during aerial inspection Excessive erosion No No excessive erosion observed during ground or aerial inspection Slope instability NA Uniform subsidence or differential NA settling Surface ponding or standing liquid NA on cover Effects of natural events Yes Entire well site area within a floodplain. Several such as floods, landslides, etc. inches of floodplain deposits found throughout. Evidence of animal activities that NA may have damaged impoundment dike walls or covers ANC10011829.WP5 7-2 Table 7.1 Summary of Visual Inspection for Sullivan #1 Page 2 of 2 Parameters Yes/No Comments Potential for surface water Minimal potential; well site area is gaining cover contacting waste material (floodplain deposits) Evidence of surface debris Yes Rusted barrel, old tin stove pipe, and a 1.5 -inch - diameter steel cable running from the site to the Little River was found. In addition, several lengths of 5 -inch -diameter drill rod were found downstream of the well site, but upstream of Sullivan #2. Evidence of stained soils No No apparent staining in well site area. ANC1001 I829.WPS 7-3 conditions suggested in the ADEC guidelines. Inspection results and observations are sum- marized in Table 7.2. 7.2.3 Sullivan Strat #1 On July 19, 1993, a three-member CH2M HILL field team spent about 5 hours trying to locate the well site for Sullivan Strat #1 in heavy foliage near the headwaters of the Big River and Beare Glacier. An attempt was also made to locate the site from the air. Although visible remnants of the wellhead or reserve pit were never found on the ground, from the air, or in aerial photographs, CH2M HILL conducted a site inspection for specific conditions suggested in the ADEC guidelines. Inspection results and observations are summarized in Table 7.3. 7.3 Site Assessment Conclusions Because the drill sites could not be located, no surface soil or surface water samples were collected or analyzed at Sullivan #1, Sullivan #2, or Sullivan Strat #1. Visual inspections did not identify any evidence of reserve pits or impacts thereof. No evidence of a well head or reserve pit could be identified at the reported location of the Sullivan wells. 7.4 Action Plan Action plans were not prepared for the Sullivan well sites because the available site data indicate negligible risk to human health and the environment due to reserve pit materials. Any action at these sites would require mobilization and demobilization of personnel and equipment, thus posing greater risks to human health and the environment than the no further action alternative. ANC100I1FAE.WP5 7-4 Table 7.2 Summary of Visual Inspection for Sullivan #2 Page 1 of 2 Parameters Yes/No Comments Evidence of reserve pit materials No No apparent evidence of drilling muds or formational cuttings, or even of reserve pit location. Plus, according to drilling records, drilling wastes were injected downhole for disposal. Evidence of leakage through NA impoundment dike walls Evidence of leakage or seepage through cover, such as: 1. Damp/wet spots 1. No 1. No apparent wet/damp spots, entire area investigated was par of a floodplain. 2. Areas of dead or lush 2. No 2. No unusual vegetation patterns noted, vegetation extreme vegetation throughout area. 3. Aquatic vegetation in 3. No 3. No seeps therefore no aquatic vegetation perennial seeps in seeps. Evidence of leakage or seepage NA through the dikes. Evidence of impoundment No No apparent evidence of impoundment overflow overflow, such as: denuded directly related to reserve pit seen. downgradient areas, insufficient freeboard, erosion of dikes or downstream area Vegetation stress No No apparent stressed vegetation in well site area observed from ground or during aerial inspection Excessive erosion No No excessive erosion observed during ground or aerial inspection Slope instability NA Uniform subsidence or differential NA settling Surface ponding or standing liquid NA on cover Effects of natural events Yes Majority of well site area within active floodplain. such as floods, landslides, etc. Rest of well site area would lie in what is now the Little River stream channel. Evidence of animal activities that NA may have damaged impoundment dike walls or covers ANC1001182C.WP5 7_5 Table 7.2 Summary of Visual Inspection for Sullivan #2 Page 2 of 2 Parameters Yes/No Comments Potential for surface water Minimal, area has been extensively reworked by contacting waste Little River in the last 39 years since drilling, Evidence of surface debris Yes Several lengths of 5 -inch -diameter drill rod were found downstream of the well site. Several pieces of siding from Butler building found downstream. Evidence of stained soils No No apparent staining in well site area. A NCloot ts2C.wr5 7.-6 Table 7.3 Summary of Visual Inspection for Sullivan Strat #1 Page 1 of 2 Parameters Yes/No Comments Evidence of reserve pit materials No No apparent evidence of drilling muds or formational cuttings, or even of reserve pit location. Plus, according to drilling records, drilling fluids were injected downhole for disposal. Evidence of leakage through NA impoundment dike walls Evidence of leakage or seepage through cover, such as: 1. Damp/wet spots 1. No 1. No apparent wet/damp spots, entire area investigated was part of a floodplain. 2. Areas of dead or lush 2. No 2. No unusual vegetation patterns noted, vegetation extreme vegetation throughout area. 3. Aquatic vegetation in 3. No 3. No seeps therefore no aquatic vegetation in perennial seeps seeps. Evidence of leakage or seepage NA through the dikes. Evidence of impoundment NA overflow, such as: denuded downgradient areas, insufficient freeboard, erosion of dikes or downstream area Vegetation stress No No apparent stressed vegetation in well site area observed from ground or during aerial inspection Excessive erosion No No excessive erosion observed during ground or aerial inspection Slope instability NA Uniform subsidence or differential NA settling Surface ponding or standing liquid NA on cover Effects of natural events Yes Entire well site area within a floodplain. Several such as floods, landslides, etc. lengths of 9 -inch -diameter drill rod buried by several inches of floodplain deposits Evidence of animal activities that NA may have damaged impoundment dike walls or covers ANC10011828.WP5 7-7 Table 7.3 Summary of Visual Inspection for Sullivan Strat #1 Page 2 of 2 Parameters Yes/No Comments Potential for surface water Minimal potential; well site area is gaining cover contacting waste material (floodplain deposits) and colluvial deposits from debris slides off of adjoining steep - sloped ridge. Evidence of surface debris Yes Found four lengths of 9 -inch -diameter drill rod, an old tin stove pipe, and three -rusted out, empty barrels. Evidence of stained soils No No apparent staining in well site area. ANC100I1828.WP5 7-8 Section 8 Risk Screening 8.1 Description of Methods This section describes the methods used for performing the qualitative risk screening and describes the results of the process. Qualitative risk screening was used to identify whether a site is likely to have a significant impact on human health or the environment. A two-step decision process was used in the qualitative risk screening procedure. The first step established whether there was a basis for concern of a risk. The second step estab- lished whether the waste site is likely to present significant risk to human or environmental receptors. The risk screening process is summarized in Figure 8.1. To determine if a basis for concern exists, the information from the visual inspection and sampling program was reviewed. A basis for concern was determined to be present if a biological receptor was located within the zone of chemical contamination and either of the following was true: • Evidence of release of chemical contamination at the waste site was in excess of Alaska water quality standards for one or more target compounds • A mechanism for release of waste or byproducts of the waste was present If either the mechanism for potential release or the proximity to biological receptors risk factors is not present at a site, there is no basis for concern and the site should not require further study or corrective action. If the mechanism for potential release exists at the site and biological receptors risk factors are present, there is a potential risk and the risk screening progresses to the second step. If a basis for concern exists, it must be determined whether the risk is significant. The level of risk is determined by the extent of exposure and the potential consequence of that exposure. ANCIOOI IE55.WP5 8-1 Em Receptor exposure is considered to be likely when the following apply: • Contaminant release mechanisms are estimated to be significant • Contaminant migration is estimated to be significant • One or more contaminants are environmentally persistent Contaminant release mechanisms were considered to be significant if target compounds associated with a waste site were found in higher concentrations in adjacent water and soil than in background locations, or if other physical characteristics of a site indicated that waste could be released. Visual evidence of physical release mechanisms may include erosion, unstable areas, flooding, or exposed waste. The type, quantity, and age of the waste are important factors that may effect the release potential of a site. The contaminant migration potential can be measured directly if sampling data are available for offsite locations downgradient from the reserve pit. If no direct evidence of migration is available, the migration potential was assessed indirectly by evaluating the likelihood that a mechanism exists to mobilize the soluble constituents from the source. The migration mechanisms of greatest interest at reserve pits are surface water movement and the percolation or channeling of surface waters through soil to groundwater. Topography exerts an obvious influence on surface water movement, and in many settings is an easily observed migration mechanism. Wind action and freeze and thaw cycles may also influence surface water movement from reserve pits. Hydrogeology and soil conditions affect groundwater travel times and attenuation. Environmental persistence is evaluated in terms of the current levels of contamination relative to the age of the pit, or natural persistence in the environment. Factors contributing to persistence include resistance to biological or chemical degradation. If exposure is found to be unlikely, there is no need to evaluate the consequence criteria that follows. A finding of negligible risk is made on the basis of absence of a likely expo- sure term. The action plan is then evaluated in Section 9 under the impact and benefit evaluation. If any one of the exposure criteria are satisfied, a finding is made that exposure is likely. Screening continues to evaluate the potential consequence of exposure. ANC10011E55.WP5 8-3 Adverse consequences of exposure to constituents from reserve pits are considered to be likely when the duration or frequency of exposure is sufficient to cause adverse health or environmental effects and either of the following apply: • The quantity or concentration of one or more contaminants exceeds pertinent federal or state water quality criteria or standards protecting health or the environment • One or more contaminants exhibit high acute toxicity The likelihood that exposure duration or frequency would be sufficient to cause adverse health or environmental effects is evaluated by reviewing human and wildlife use patterns at a given waste site, waste site accessibility, and ground and surface water uses. If the assessment of migration potential indicates that there is a potential for target contaminants to move to a surface or groundwater resource, the evaluation of this duration and frequency criterion will be used to estimate the extent to which the potentially affected water resource is used by human or environmental receptors. For migrating or nomadic receptors, the availability of other similar water resources will be considered. The potential for exposure through direct ingestion of reserve pit contents will be evaluated and will include estimates of the frequency and duration of ingestion episodes as well as biological uptake characteristics of the target compounds. For the quantity and concentration criteria, measured contaminant concentration in the water will be compared with health and environmental standards and criteria for each target compound to identify whether the concentration exceeds established water quality standards. When human populations are at risk, health criteria are used. When the populations at risk are nonhuman, such as fish, wildlife, and vegetation, environmental criteria and standards are -used. The NIOSH toxicity rating system (NIOSH 1974) will be used to identify contaminants that are highly toxic to mammals. This information will be used to determine whether a target compound exhibits acute high toxicity. The system ranks substances according to acute toxicity estimates, which is the customary method used to determine the toxicity of a chemical. LD50 is the dose, either oral or dermal, at which 50 percent of the exposed population will die. Several designations of toxicity are generally recognized by toxicity specialists. The designations include unknown, non-toxic, slight, moderate, and severe. An unknown designation means insufficient data are available to enable a valid assessment. ANCIOOIIWS.WP5 8-4 l Chemicals designated as non-toxic produce no toxic effects under normal use or require 1 overwhelming doses to produce toxic effects in humans. Slightly toxic chemicals may produce effects that are reversible when the exposure ceases. Moderately toxic chemicals can cause reversible or irreversible changes, but they are not necessarily severe enough to cause serious physical impairment or threaten life. Highly toxic chemicals are those that can threaten life or cause permanent physical impairment over continuous low-level expo- sure or by a single exposure. Highly toxic substances are those with an oral LD50 value equal to or less than 50 mg/kg, a dermal LD50 equal to or less than 100 mg/kg, or an inhalation LC50 equal to or less than 43 ppm. A similar ranking system has not been developed for aquatic organisms; however, 1 mg/L is often the LC50 value used as a criteria for identifying chemicals highly toxic to aquatic life. In addition to this evaluation of acute toxicity, the waste site data will be evaluated to identify the potential for biological concentration of contaminants in the food chain to reach acute toxic levels. If the duration and frequency of exposure is insufficient to cause adverse effects, there is no need to evaluate the other two consequence criteria, and a finding of negligible risk is made. The action plan is then evaluated in Section 9, Impact versus Benefit Evaluation. If the duration and frequency of exposure is determined to be sufficient to cause adverse effects and either of the other two consequence criteria are satisfied, then a finding is made that adverse consequences are likely, and the risk at a waste site is estimated to be signifi- cant. If the screening indicates that risk is significant, the development of a corrective action plan is warranted. The results of applying the risk -screening model will be summarized in a table showing the criteria applied, the result of the application. (yes, the criterion was met, or no, the criterion was not met), the reason for meeting or not meeting the criterion, and the outcome of the screening step (whether a basis for concern exists; whether risk is significant). The waste site will fall into one of three categories: • No further action required (there is no basis for concern) • Risk is negligible (a subsequent evaluation will be made to determine if corrective action is desirable) • Risk is significant (corrective action is necessary) ANC100I IE55.WP5 8-5 To support a conclusion that there is no basis for concern or that the risk at a waste site is negligible, a list of key findings at a waste site will be prepared. 8.2 Results of Risk Screening The following sections provide a summary description of risk screening results for each site evaluated. The results for each site are summarized in a table. Risk -screening conclusions are presented for each site. A complete risk screening evaluation of the Sullivan well sites cannot be performed because the reserve pits cannot be located. The Sullivan #1, Sullivan #2, and Sullivan Strat #1 wellheads could not be located with certainty because of site erosion and thick vegeta- tion. The sites have been ecologically restored through natural processes. A ground search by foot, which required at least 8 staff hours per site, found no evidence of a drill site or signs of a reserve pit. A basis for concern exists because the fate of the reserve pit material is unknown, but the level of risk may be considered to be negligible because there is no evidence of a reserve pit or the drill site at these locations. The environment does not appear to be impacted or threatened due to reserve pit materials. Natural erosion processes of the glacial rivers and landslides have either washed the sites away or buried them in sediment. Risk may be considered negligible because the reserve pit material, if still present at the sites, is more than 30 years old and the quantity of soluble constituents is limited. It is probable that leachable contaminants have already been released and dispersed by this time and the remaining material is relatively inert. Exposure to biological receptors is not likely. No exposed mud could be found at the sites. The sites are practically inaccessible to humans because of dense vegetation and non- existent access roads. Considering these factors, the risk of exposure and adverse effects to human health and the environment is negligible. ANC1001ffiSSMPS 8-6 Section 9 Benefit -Impact Evaluation An action plan is not recommended for the Sullivan sites because the risks associated with implementing an action plan are greater than the potential risks that could be reduced through corrective action. The purpose of this evaluation is to estimate whether the benefits of implementing an action plan would be greater than the impact of implementing the plan. The general philosophy behind this evaluation is that if an action plan can be implemented to reduce an already "negligible" risk and not cause any greater problem, then such an action plan should be taken. ANCIOOI IE5B.WP5 9-1 i Section 10 Action Recommendation No further action is recommended for the Sullivan well sites. The findings of a benefit and impact evaluation estimated that the impacts of implementing an action plan would exceed the benefits of an action plan. No further action is warranted because actions implemented to reduce an already negligible risk would create more risks to human health and the environment than the no action alternative. ANC10011E5E.WP5 10-1 Section 11 Works Cited America North/Emcon. Summary of Investigations into the Need for RCRA Corrective Actions at Drill Sites 3 and 17 Reserve Pits in the Prudhoe Bay Unit --Eastern Operating Area. North Slope Borough, Alaska. 1992. Angeloni, Linda M. et al. Map and Tables Showing Preliminary Rock Geochemical Data, Port Moller, Stepovak Bay, and Simeonof Island Quadrangles, Alaska. U.S. Geological Survey Open -File Report 85-470. 1985. Arbogast, B. F. et al. Analytical Results and Sample Locality Maps of Stream -Sediment, Heavy -Mineral -Concentrate, and Rock Samples from the Port Moller, Stepovak Bay, and Simeonof Island Quadrangles, Alaska. U.S. Geological Survey Open -File Report 87-502. 1987. Arco Alaska, Inc. Crude Oil Topping Unit (COTU) Tube Bundle Sludge Containment Enclosure/Cleaning Station. Investigation Plan. December 1992. B & B. Environmental, Inc. Drill Cuttings Baseline Report. 1991. Bruns, T. R. Structure and Petroleum Potential of the Continental Margin Between Cross Sound and Icy Bay, Northern Gulf of Alaska. Menlo Park, California: U.S. Geological Survey Open -File Report 82-929. 1982. CH2M HILL. Draft. Crude Oil Topping Unit (COTU) Pad Remediation. 1992. Church, S.E. et al. Analytical Data and Sample Locality Map for Aqua -Regia Leachates of Stream Sediments Analyzed by ICP from the Port Moller, Stepovak Bay, and Simeonof Island Quadrangles, Alaska. U.S. Geological Survey Open -File Report 88-437. 1988. Cobb, Edward H. Summary of References to Mineral Occurrences (Other Than Mineral Fuels and Construction Materials) in the Bering Glacier, Icy Bay, Middleton Island, and Yakutat Quadrangles, Alaska. U.S. Geological Survey Open -File Report 79-1246. 1979. ANC10011E62MPS 11-1 Gough, L. P. et al. Element Concentrations in Soils and Other Surficial Materials of Alaska. U.S. Geological Survey Professional Paper 1458. 1988. James M. Montgomery Inc. North Slope Gravel and Soil Baseline Characterization. December 1991 Kachadoorian, Reuben. Engineering Geology Bearing on Harbor Site Selection Along the Gulf of Alaska from Point Whitshed to Cape Yakataga, Alaska. U.S. Geological Survey Trace Elements Investigations Report 642. 1963. Karlstrom, Thor N. V. Quaternary Geology of the Kenai Lowland and Glacial History of the Cook Inlet Region, Alaska. Washington: U.S. Geological Survey Professional Paper 443. 1964. Magoon, L. B. et al. Map Showing Geology, Wildcat Wells, Tertiary Plant Fossil Locali- ties, K -AR Age Dates, and Petroleum Operations, Cook Inlet Area, Alaska. U.S. Geological Survey Miscellaneous Investigations Series. 1976. Magoon, Leslie B. and George E. Claypool. Petroleum Geology of Cook Inlet Basin—An Exploration Model. Official File Number 79-548. Odum, Jack K. et al. Lithological, Geotechnical Properties Analysis, and Geophysical Log Interpretation of U.S. Geological Survey Drill Holes IC -79, 2C-80, CW 81-2, and CE 82-1, Tyonek Formation, Upper Cook Inlet Region, Alaska. U.S. Geological Survey Bulletin 1835. 1988. Petroleum Possibilities in the Yakataga District, Alaska, Assessed. U.S. Department of the Interior Information Service. May 22, 1953. Pewe, Troy L. Quaternary Geology of Alaska. U.S. Geological Survey Professional Paper 835. 1975. Plafker, G., et al. Holocene Marine Terraces and Uplift History in the Yakataga Seismic Gap Near Icy Cape, Alaska. 1980. ANC10011E62.WP5 11-2 Schmoll, Henry R. et al. Guide to Surficial Geology and Glacial Stratigraphy in the Upper Cook Inlet Basin. Anchorage, Alaska: Alaska Geological Survey. 1984. Schmoll, Henry R. and Lynn A. Yehle. Generalized Physiography and Geology of the Beluga Coal Field and Vicinity, South -Central Alaska. . Surficial Geologic Map of the Northwestern Quarter of the Tyonek A-4 Quadrangle, South -Central Alaska. U.S. Geological Survey Miscellaneous Field Study Map. 1987. Scully, David R. et al. Hydrologic Reconnaissance of the Beluga, Peters Creek, and Healy Coal Areas, Alaska. Anchorage, Alaska: U.S. Geological Survey Water -Resources Investigations 81-56. 1981. Selkregg, L. L. et at. Alaska Regional Profiles, Arctic Region. University of Alaska Arctic Environmental Information and Data Center, Anchorage, Alaska. 1975 . Alaska Regional Profiles, Southcentral Region. University of Alaska Arctic Environmental Information and Data Center, Anchorage, Alaska. 1975 Thomas and Berryhill. Reconnaissance Studies of Alaskan Beach Sands, Eastern Gulf of Alaska. U.S. Geological Survey. The United States Geological Survey in Alaska. Accomplishments During 1983. U.S. Geological Survey Circular 945. 1984. Wahrhaftig, C. Physiographic Divisions of Alaska. U.S. Geological Survey Professional Paper 482. 1965. Walker, D.A. et al. Geobotanical Atlas of the Prudhoe Bay Region, Alaska. U.S. Army Corps of Engineers Cold Regions Research and Engineering Laboratory. Hanover, New Hampshire. CRREL Report 80-14. June, 1995. Wilson, Frederic H. et al. Brief Descriptions of Mines, Prospects, and Mineral Occurrences in the Port Moller and Stepovak Bay Quadrangles, Alaska Peninsula. Anchorage, Alaska: U.S. Geological Survey. Open -File Report 88-666. 1988. ANC10011E62NP5 11-3 Wilson, Frederic H. et al. Generalized Geologic Map of the Port Moller, Stepovak Bay, and Simeonof Island Quadrangles, Alaska Peninsula, Alaska. U.S. Geological Survey Miscellaneous Field Studies Map. 1991. Yehle, et al. Preliminary Surficial Geologic Map of the Southeastern Part of the Tyonek B- 5 Quadrangle, South -Central Alaska. Reconnaissance Engineering Geology of the Yakutat Area, Alaska, With Emphasis on Evaluation of Earthquake and Other Geologic Hazards. U.S. Geological Survey Profes- sional Paper 1074. ANC100I 1E62.WP5 11-4 DEI~r. OF EN'~;IRONMENT.%L CONSEI1V:~TION DIVISION OF SPILL PREVENTION AND RESPONSE . . . .nausu-v Prer~edness and Pieei:ne lx~iorat:on. Production & Refiner.' Sec:ion _:55 Cordova St. .%qchoraae..AK. 9950 ! 996 TONY KNOWLES. GOVERNOR ~hont,:; c0-')-269-7679 F'ax i 00"1-269-7649 , ~v ~ 0~ ~~ t .T~ ' File ~: ~00.~5.~ Mr. J. A. Landrum Kenai Profit Center Manager Phiilios Petroleum Comnanv Drawer 56 Kenai..-'Z4 99611 Dear .",Ir. Landrum: Approval f~r Closure - Inactive Drilling Waste Sites The .Alaska Department of Environmental Conservation fADEC'~ has evaluated your corresoondence, dated February 14. !996. requesting closure of six Phillips Petroleum,Company ~Phillips) disposal facilities. Surface evaluations were =erformed at the sites in !992: ~e closure 2ians were delivered to ADEC bv Mr. J. S de Albuquerque and Mr. S. Free,myer on February !E. 1996. This correspondence describes our review procedures, puts forward the Deaartment's ,~nmngs. and takes action upon the closure request. iUne six facilities were assessed ="~,., Philliss P'--'oieum.,, in accordanca '.vith :he A_DEC rnterim Site .Assessment Guidance. for tnac::ve Driilinz Waste Sites. June i99~. The new Alaska Solid Waste Regulations. ~8 ,<AC 60. became effec~ve Janu~v 28. 1996 and contaim a chapter on inactive reserve pit closures ~18 .~AC 60.~0~. 2e closure criteria in the ne,,v rezulatio~ y..,,~, the ........ ~he ~ ~,o~ure 991 Ga:dance ~,,~-, ,,-$ ,~ .... ;~,,, ~,~,~, .... ¢ ,~,;,~ ~ discussion of the risk - ~ - ' f , ~c,e.mn. assessment as required in the 1991 document. Briefly ~e significance or' risk ro locaI recep[ors is evaluated t~ough study of contaminant reiea~, exposure criteria, and co~equence criteria. SITES CONSIDERED FOR CLOSLT~E Based upon field criteria from the June. 1991 iNTERLM SITE ASSESSMENT GUIDANCE FOR INACTIVE DRILLING WASTE SITES. and closure criteria specified in Alaska Solid Waste Regulations 18 ,<-kC 60.440. ~e facilities listed below with ,th.,eir respective locations have been reviewed for closure: ,, ~ -., ~ , Y, lr. J. A. Landrum July 1. 1996 .,&K Peninsula- Stepovak Bay Area Bi~ River No. A1 '?~,-o~ North Slope - Mikkelsen Bay Area North Staines River No. 1 7e/-o~ ? Cook Inlet- Trading Bay Area North Tyonek State No. l · · : "' SOutheast ,M<;- Icy Bay Area Sullivan No. 1 o - os-t · Sullivan No. 2 o - · . Sullivan Strat No. 1 o - conSideratic~n of the sites for closure approval were based on Il 1) a review of the submitted inactive drilling waste site assessment document listed below by the ADEC Spill Prevention and Response I'SP,~LR) Division and the Alaska Department of Natural Resources - Division of Land (ADNR-DOL') staff. (2) public response to the closure request during the the 30 day review process, and (3) site visits by ADEC and ,M3NR-DOL staff tO the North Staines River No. i site. ,. . Title: Closure Report for Phillips Petroleum Company Alaska Inactive Reserve Pit Assessment Program Submitting Persons: J. S. de Albuquerque and S. Freemyer: Phillips Petroleum Covered Facilities: Location: Above Named· Facilities Statewide , Synopsis of Closure Procedure: C L OSL'RE .-kPPROVAL Closed as is. No further action is needed for the drilling waste facilities at the referenced locations. (or) Conditionally closed. Further investigative action is required, as noted, for the drilling waste facilities at these.locations. The Deparumntal decision upon the request for CloSure Submitted by Phillips Petroleum Company is to approve for closure the below-referenceddrilling waste disposal facilities, effective July 1. 1996. and to declare the five facilities "Closed As Is". This decision ' is supported by ADNR-DOL for the sites located on State land: the decision is also supported by the Mental Health Trust Land Office of ADNR ('D. Thomas) for the three Sullivan wells near Icy Cape. No objections or other, issues were put forth by the public during the 30 day review process. While July i. i996 '~-,,,e,e- is a basis for concern at the remote sites where driliinz_ mud was disposed in a sensitive environment, there is no standina water in contact with the waste, and therefore, neziimble risk. Conseauentlv, anv corrective action warranted at the sites is not required bv the ADEC. realizing_ ~.hat the impact of the corrective ac:ion would be much greater than the benefits received. The sites have revegetated, and any corrective measures would impact the established plant species at :ine locations. The facilities are 'Closed ,-ks is'. as provided under the authority, of the 1~ AAC 60.4-*0 Solid Waste Reguiations. Closed A~ I~ Big River No. A1 North Tvonek State No. 1 Sullivan No. 1 Sullivan No. 2 Sullivan Strat No. 1 Closure conditions were placed on the beiow-named facility, rbllowing the site visit and closure package evaluation. These conditions must be met prior to issuance of f'mal closure approval rbr the reserve pit facilirv, ti'he decision of the ADEC is to declare the following site ~Conditionallv Closed" until information required to address the conditions is provided to the Department. Conditionally Closed North Staines River No. 1 Diesel (DRO) concentrations of'4.0 and 2.1 rog/1 were reported in ponds WA-02 ~d WA- 03. respectively, along the resetwe pit perimeter. Field investigations revealed heavily iron- stained pond sediments in WA-02 and in other shallow ponds on the west ,side of tlae pad. Disturbance of the sediment produced an immediate sheen on the surface water. A strong diesel odor was present in the sediment and oily residues remained on the skin after handling. The iron- stained and presumably contaminated ponds were adjacent to the reserve pit. Although drilling wastes at the site appear to be-properly contained within the capped reserve pit, the source of the apparent contamination must be identified. Third party, reports suggest that fluids may have leaked from the well. Final closure will be granted after it is demonstrated to the ADEC that drilling.._wastes within the pit are not the source of contamination and have not been adversely affected bv leakage from the ',veil or from historic spills on the pad. Please provide the supplementary, information To this office. The apparent contamination has been reported to the ADEC Contaminated Sims Section for review, as required uncier Article ! of the rbllowing "Terms and Conditions" section. .~.[r. f. A. Landrum 4 July 1. 1996 In addition. ADNR reserves the right to fur~er evaluate both pad and reserve pit at the time of ,5.tll site closure. TEl:CMS .&ND CONDITIONS 2~ ,MI of the above closure approvals are subject to the following terms and conditions: Reserve Pit Facility Closure: The approval granted bv this letter is for the inactive drilling waste reserve pit facility, only. as required under !8 .~C 60.440. Closure for the pad as a whole must be coordinated bew,'een the owner:operator and the appropriate state (ADNR, .4Z3F&G. AOGCC5. or federal (EL'vi) agency. Additionailv. should any contamination from historic saills, be found on the Dad outside the a,"-4Alm=' ~, waste sire {'reserve pit area>, notificaticn needs to be made to the 92DEC Contmminatec Sites Section ~269-76<95. New Information: Should additional in-tbrmation concemin~ environmental conditions at the faciiit-v make ~5.rther actions necessary to ~, ~' ~rote~ human ineatth or the environment, the Deoarrment reserves the n~qt to re,quire additional investigation, assessment, moruronng, or remediation at the facititw. If you have any timber questions, please fee! flee to contact Jim Chatham at 269-7679 of this o~ce. SincereN. Tom Cinappie " Program Manager TC,'j rc ~. £O-CLER'JCHATHAM~965CLOS.~p CC: Stephen de Albuquerque. Phillips Petroleum. Beltaire, TX Steve Freemyer, Philips Petroleum. Kenai AOGA. A. nchorage ' Nancy Welch. ADNR. Fairbanks Al Orr. A_DF&G. Fairbanks Joe Saumer. ADEC..<nchora_oe Jim Haynes, ADNR. Anchorage Jack Mores. Bristol Bay Native Corporation. Anchorage '1 I O ~ OPERATOR: PHILLi~ .i FARM: STATE: Alaska ,, COUNTY: ,lakata~a.. ELEVATION FIELD: · DATE STATUS SPUD: 4-11--5~ COMPL: A-1l-;/~ D bloc sha]e- T.D. ]hq CAS!NG: ...... a-~ T,D, 205: rn~ 16" cs~ ...... 4-13 WO01 16" csg l~ded 198' ....... .. ~ ~?~ ....... · : ........ ~ODU~!~.M~: ..... ~ TD 205 W~ ~ iNITIAL PRODUCTION: 715 TD 287~ dr~~ , , ~-17 WOC'C3/~ csK landed 798' cm%d ~280 sx molli~ type C cm%; plug ~o~ " L., -18 nippl~K up; add ~ previous ~epo~%s .... ~.~ follm-;inK s%raiEh% hole ~o%s !/& ~ ..... ~ 250 .one O 600 & one & 1/~ ~ 810 ~-21 TD 1043; drlE. lposely consortia%ed .... sd~ c ~-860~ ~ec. 1' 5re~ silt; c 1027-10~3~ no rec. . , ~ec. 1~~ ~ay sd~ go~ ~uorescence . , poor cut; c 1316-1325 ~ ~ec. 1' . - sd; o~tted_from p~vious report . totco .l~ ~ 1033 ~L23 ~ 1567; drlg silt & sd; ~%co 3~ ~50; c ~Sl-l&Tl~ rec. ~' gray silts~ne ...... ~-2~ TD 1657, cor~g; for~ti~ sd cut 5 cores [~ an W/ practically no ~c. hole 2~ G 16lO; mud weight ll.5, viscosity &l, sd 13~ " ~-25 TD 18~; fo~ation sd & silt;~ cor~ 1657-167~." ' ' , ,,, ..... '& 1701~17~, no' ~C.; totco 4° ~ 1690 ',?" & l~° ~ 1751; weight ll.6 viscosity_38 WL 16.8 . ' . 4-26" TD 1996: ~~: totco 1800 1~ 1875 1.3/A 1950 1 ,, ~-27 TD ~48 drlg silt & 'sd tot6-0 2030 l, 2090 1~, · 2157 l~ stop weight ~ viscosity 42 ~% 20.4 ~-28 ~D 2519: drl~ sd; totco 2280 .1 3/&. 2340 1 2490 1. C 2458-2468, no rec. ~ ll.8 viscosit~ ~5 wl 25 , 4-29 TD 29~; drlK sd totco 2666 totco 2792 1/2 stop ~_. we~ht ll.2 viscosity 39 wl 38 sd 21~ ........ ~-30 TD 32~8 ~ totco .2980 1/2; cored 2936-29~7-. no .rec. 5~2 ~/26~O, cori~ ~ 9 cores cut using various comb~'tions ..~ ~x,~ weight ~d prespure w/ no satisfactO~ recover~ . . / 7 REMARKS.. ,6000~ test . i i i ii *,,. i i , ii OPERATOR [err-McGe e- P~illips FARM Sullivan Strat __.WELt #1 LOCATION , NE/, NW/~ N-'~/,_ Section 20-22S-22E~ CRM STATE. Alaska · ... COUNTY . Yakataga Pm, m .:1069 4-S3 None : 2 1027-$3 .., l~ feet 3 _ .i2~6-130a .. _ None a inches i inches inches .inches' ~nohes 3 in'ches _ None ' 2 inches 3 inches None N6ne 2 feet 2 feet 2 inches ~ i.~'h 1~ feet' None L;one inch inches inches 4 ._~ 14gl-. ~0 5 _ 145'1-71 6 1618-28 , Il I · 7 8. 1638-A8 9 '~ 16 4.8-5 2 10 1652-57 11 16.57-6 ~- 12 16~4-74 13 1700-02 14 1996-°~ 15 2458.-68 16 2936.41 17.2941-47 .. . 18. 3/.16-2o 19_ 3A20-30. 20 ~' 17.-24 21 3528-36 23 3546-A8 24.~ 3548-51 25 .... '~551-55. 26 3555-58 27 3~$-61 28 3628 ,-3~, 29 ~_6 38,41 _ 30 3~/:1-~:5-- 31 36A5,6 5 ,~ , _ Siltst,gry,ooorlv consol. ,sI..~as odor.si fluor· Sst.~'~v.f.z v~ith s-'~'t ban,~s¢*l Pos~bl~ reft- _~ . . ~ ~ ~.- _ · _ ~ _ Fair ..... ~ . _ s,o~ued f!~or Door oil aut.~o b~dd~n~ Sst;s~.m.e.. as above but..Y.~i'c.Z.~._~l. H/25 odor s~t~ered: fluor with strong H/~M ~o~ ~iltst.dri~ry,.to blk,with si. ~-2$ odor..& .spot-·- or' fluor :'-. -'-' ...... " ' . ~--~.; ~ .; ~. ~-- ~ -~. . .... - Ss~,gr~.r,f_ _ . ,~.~,_.sl l~mev_ .~.,,~" ~&P.. with_ quarter inch vero~.~ ~:~ band dow:. _.':~he center,tr, fluor Sst,~,ry;.f.A..,vert. g .... it bands . (Burned in ',,~t~tt~ for the first time in S~-~-'- -"'-'- ~P with si~icia 0~ cuo~tz band Sst arv f ~..,~:_ ;_ _ .~ 0~ . ---- -- . '~-- , ed: prob~bl_v dn reft. DO..~;_iL2. :>n ,, 3~'Sst.hard :f.g. ~o m.g.:_...~ gry;:':ith d~k- .. gry silt band-' .Vert bed'~in~ very Prq.r noune~d l&'~ .... ,~ ~'~' :~ sl.~ilty ,, - _ ~, ;~-~~~ ......... .~: E LEVAT! 0 N DATE TOPS 5-1. TD 3500 sd'totco ~_~30'3/h stop c 3~15-j~20 2' dk gray siity.shale', rec. c 3~20-3~30 2' hd gray silt;,~ 'sdsto~e rec. 5-2 TD 3630 coring sd stop, 9 cores cut u~ing, various c~'~binations RP~ weight and p~es~ure ~i~ no satis~'acto~ reco.very ' · · ~-3· -TD '37~6 cored w/ convention~ ................. barrel 3645-3665~ rec._~'_..!ite grey silty_~ ~5-~ TD 3~ sd toteo 3770 ~ .... · 2L.cor~ 376.-3783 no rec. 5-5 TD 4132 totco ~0~6 1~ cored 39~$-3958, rec. 3' very silty s~stone 5-7 rD ~837; ,dr~.cored .832-~837. rec. l' friable sd.,, ' 5-7 ~ ,837; '~ . ~O orders , , ' , 5-8 TD ~37; cond. ~m~ & repairing mud lines and prepar~g to kill ~r flow 5'10 ~TD ~837; orep. to~'crill bridge '~o~ 700' ~ csg ' 5-17 ~s~aary report 5/10 th~ 5/17 TS ~837, e~xco~ter~ hea~ ~r flow ~d '~lew mud fro~ hole stop muile goi~ ~ hole to, ,condition mud we~ blew' ~2 Joints' dr~ pipe OUt stop no ~jor d~ge stop ~lowed well to bridge ~hen cleared'~ebris &' washed to 590' ~d spotted 25 sack plug s~p no · [_~.~.~t ~.~ka~ 'a,'t~r ~'~ ~o~, .to~ ~ot,~d ~O ~ ~ ~ ,~' ,~to~ ....... I~'~O .orders , . ......... . .... . . ........... .......... ~ · . , , O. ~stons ! Ii f D 2060 PECOVER],]D -~ I feet ,, ,, . · · · , : · · , . . · · · , , , , ,, , , , , , ,, ~ . ! , · · - , ,i DEPTH · DF~TH, ....... Est :gry f,~...;;'ith ~ drk-gry ~.ood...v.ert, _ b~nds.Best 'core sho:vin~ vertical beddin~ silt _ .. ,, .'..-..' report oonteined ~: ~al~'oeroentage o~ " muscovite ~nd biotite m~cn and n black --'.: .... 8mo~ts, Glauconi.~e ~':as f~i~ly co.on '- ~nd some ovrite could be found. In Me~- ' :'- . eral.the sandstone %?ss loosely consoli- - ..... dated,poorly sorted~sUbangular %vith the · '.'.- - priory mineral bein~ ·quartz and the . . cementin~ ~t~ri21 m~sinly silt although . some of the sand contained ~ s~ll amour . · of calcium..ca~bon~te, The silt consisted chiefly of mica.