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Home My WebLink AboutAEO 010 · e AQUIFER EXEMPTION ORDER #10 NORTH FORELAND, COOK INLET ALASKA 1. March 15,2004 Rozak Engineering Application for AEO 2. April 9, 2004 e-mail from DEC to various 3. April 21, 2004 Notice of Hearing, Affidavit of Publication and Bulk Mailing Address 4. April 23, 2004 Notice of Hearing, Affidavit of Publication and Bulk Mailing Address 5. ------------------ Questions brought to operator re: application 6. June 10, 2004 Sign in sheet for Hearing 7. June 10,2004 Transcript 8. June 10, 2004 e-mail from operator to Steve Davies 9. June 29, 2004 Ltr from operator to AOGCC re: responses to Questions 10. August 4, 2004 letter to Ciri from Kirk McGee, VP 11. --------------- Post hearing e-mails 12. October 12, 2004 Ltr to Thor Cutler re: submitted of Envirotech's Application 13. October 15, 2004 AOGCC Ltr to Rozak Engineering re: minor Changes to AEO 10 14. ----------------- inter-office e-mails 15. November 2, 2004 Ltr from AOGCC to Rozak Engineering 16. November 2, 2004 Ltr to Thor Cutler re: produced water disposal 17. --------------------- Various e-mails 18. October 6 2004 AEO #10 19. November 22, 2004 US EP A DENIAL of Application NO ORDER WAS ISSUED-OPERATOR REQUESTED FOR AOGCC TO HOLD ~87""~ i ^ ~ <.% :D i \ ~ ""'-4( PRO'tt-v<:' UNITEITATES ENVIRONMENTALPROTECTIOAENCY REGION 10 1200 Sixth Avenue Seattle, WA 981 01 Reply To Attn Of: OCE-082 NOV 22 2004 Mr. John K. Norman, Chairman Alaska Oil and Gas Conservation Commission 333 W. 7th Avenue, Suite 100 Anchorage, Alaska 99501-3539 Re: Disapproval of Aquifer Exemption No. 10, Shallow, Unconfined Glacial Soil Aquifer in the Vicinity of the Envirotech LLC North Foreland Facility, Western Coastline of the Cook Inlet, Alaska Dear Mr. Norman: The Environmental Protection Agency (EP A) Region 10 - Office of Compliance and Enforcement has received and reviewed a copy of the Alaska Oil and Gas Conservation Commission's (AOGCC) decision on the above-referenced Aquifer Exemption No. 10 (dated October 12,2004), along with the Commission's entire record of this case, including the application, the public notice, and the public hearing transcript. Based upon a review of the submitted information, EP A Region 10 is hereby disapproving the request for aquifer exemption for the above-referenced application. The criteria for exempted aquifers as identified in 40 CFR 146.4 have not been met. Supporting information for our conclusion is presented in the enclosure. This concludes the disapproval of the aquifer exemption. If you have any questions regarding this matter, please call Thor Cutler at (206) 553-1673. Sincerely, d~ Office of Compliance and Enforcement Enclosure cc: Sharmon Stambaugh, ADEC (Enclosure) Ronald T. Rozak, Rozak Engineering (Cert. Mail, Enclosure) o PI1nted on Røcycl«J Paper e e Disapproval of Aquifer Exemption Order No. 10 - Shallow, Unconfined Glacial Soil Aquifer, North Foreland Facility Decision Document Introduction On October 12, 2004, the Alaska Oil and Gas Conservation Commission (AOGCC) submitted to Region 10 of the U.S. Environmental Protection Agency (EP A) its decision granting the above- referenced aquifer exemption. EPA received the submission on October 19, 2004. Pursuant to 40 C.F.R. § 144. 7(b )(3), EP A hereby disapproves this designation for the reasons set forth in this decision document. The disapproval decision constitutes final agency action for purposes of judicial review. Background In March 2004, Envirotech LLC (a subsidiary of Tyonek Native Corporation) submitted an application for an aquifer exemption to AOGCC. Copies of the aquifer exemption application were also sent to EP A Region 10 and Alaska Department of Environmental Conservation (ADEC). A public hearing was held on AOGCC's own motion on June 10,2004, and Envirotech's consulting engineer presented testimony. Additional information was submitted by the applicant. The AOGCC issued Aquifer Exemption Order No. lOon October 6, 2004. This order was amended by notice dated October 12,2004 and submitted to EP A by certified mail on this same date. Records included with the application indicate that Envirotech began accepting and disposing of the produced water without an engineered plan approval or permit from the state. Envirotech was also operating an incinerator without the proper permits from ADEC. ADEC entered into a Consent Order By Consent (COBC) with Envirotech, and under this COBC, Envirotech is currently disposing of the produced water by a vaporization method utilizing the incinerator. This is a temporary disposal method and Envirotech has since been searching for permittable alternate methods of treatment and disposal. Envirotech applied for an National Pollution Discharge Elimination System (NPDES) permit in 2002 for discharge of the produced water, after treatment, to Cook Inlet (from a shoreline facility from a dock and not from a platform). EP A denied the application, stating that 40 C.F.R. § 435.32 prohibited the discharge of waste waters from onshore oil and gas facilities to waters of the United States. Envirotech's aquifer.exemption application requested that AOGCCissue an aquifer exemption beginning at the ground surface for purposes of Class II disposal of treated, produced water utilizing a wastewater drainfield installed at Envirotech's North Foreland Facility Site. The application describes the facility as being approximately 600 feet from Cook Inlet and approximately 1.75 miles southwest of the community of Tyonek, Alaska. The application describes the subject aquifer as being an unconfined groundwater aquifer consisting of unconsolidated glacial soils classified as being part ofthe Nancy-Kashwitna Complex. Neither the lateral nor vertical extent of the aquifer is described in the application, and the AOGCC -1- e e exemption order notes that the AOGCC has no direct evidence to support the existence of a confining layer beneath the project site. The AOGCC's aquifer exemption order granted an exemption for "[t]he aquifer occurring between the ground surface and the base ofthe near-surface unconsolidated glacial soils within a one-quarter mile radius of the existing Envirotech Facility drain field." As amended, the order is effective upon approval by EP A or December 6, 2004, whichever is earlier. Legal Basis for Disapproval The criteria governing this aquifer exemption decision are found at 40 C.F.R. § 146.4. In relevant part, this regulation states: An aquifer or portion thereof which meets the criteria for an "underground source of drinking water" in § 146.3 may be determined. . . to be an "exempted aquifer" if it meets the following criteria: [1] It does not currently serve as a source of drinking water; and [2] The total dissolved solids content of the ground water is more than 3,000 and less than 10,000 mg/l and [3] it is not reasonably expected to supply a public water system. 40 C.F.R. § 146.4(a) and (c). 1 As described below, the record available to EPA is insufficient to support the conclusion that any of these three exemption criteria are met in this case. Current use of the aquifer as source of drinking water: Envirotech's application states that the subject aquifer "does not currently serve as a fresh water source of drinking water." The application also states, without supporting documentation, that "[0 ]nly one well is within one- half mile of the drainfield" and that this well is not currently used to supply potable water. AOGCC's exemption order further states that the "nearest water well listed in the Alaska Department of Natural Resources' Water Resource database lies 4 miles to the northeast." This information is insufficient for EP A to conclude that this first aquifer exemption criterion is met. As an initial matter, the statements in Envirotech's application are unsupported by any area-wide surveyor other inherently reliable information source. The Alaska Department of Natural Resources (DNR) database cited in AOGCC's exemption order identifies only those wells for which the landowner has applied for legal recognition ofthe right to use ground water under the Alaska Water Use Act, and cannot, standing alone, establish the absence of drinking water use.2 This is particularly true, where, as here, the subject aquifer is surficial and readily tapped. AOGCC's submission contains no information on the lateral extent ofthe subject aquifer. It is 1 The alternative aquifer exemption criteria found in 40 C.F.R. § 146.4(b) do not appear to have any relevance to this aquifer exemption request, and the record provides no indication that Envirotech was seeking an exemption on these grounds. 2 The community of Tyonek's appropriation of surface water does not appear on DNR's water resource database, highlighting the unreliability of this data source for establishing the absence of drinking water wells in the vicinity of the Envirotech facility. -2- e e clear from the record, however, that the subject aquifer is surficial, unconfined, and in an unconsolidated formation. As a result, it would be expected that the lateral extent ofthe subject aquifer is far greater than the area addressed in Envirotech's application. In fact, without additional supporting information, EPA cannot conclude that the nearest well listed in DNR's water resource database does not itself draw from the subject aquifer. Concentration of total dissolved solids (TDS) in the aquifer: In support of this criterion, Envirotech's application includes laboratory analysis results for a single sample of groundwater collected in December 2003 approximately 300 feet from the center of the exempted aquifer at a depth of25-30 feet. This sample contained a TDS concentration of3,300 mg/l. This single data point is insufficient to characterize the salinity of that portion of the subject aquifer proposed for exemption. The application indicates that salt water intrusion from Cook Inlet is the sole cause of the salinity (and thus elevated TDS concentration) in this aquifer. As described above, the subject aquifer is unconfined and exists in unconsolidated glacial soils. The record for this matter does not establish the lateral or vertical extent of the unconsolidated aquifer, nor is there any indication that the salt water intrusion would extend more than 1/4 mile inland from Cook Inlet. A single sample indicating a TDS concentration 10 percent above the regulatory threshold cannot, under these facts, suffice to establish that the TDS content of the groundwater in the aquifer is above 3,000 TDS. Reasonable expectation that aquifer will supply a public water system: In support of this criterion, Envirotech's application states that the subject aquifer "will not in the future serve as a source of drinking water, because it is so highly contaminated with saltwater from Cook Inlet that recovery of water for drinking water purposes is economically infeasible." This statement is not supported by the record in this matter. First, EP A disagrees that a single sample indicating a TDS concentration of 3,300 mg/l renders an aquifer "highly contaminated." Surveys conducted by EP A as long ago as 1981 revealed that "the use of water containing up to 3,00.0 mg/l TDS is fairly widespread [arid] ground water containing as much as 9,000 mg/l TDS is currently supplying public water systems." See, e.g., 46 Fed. Reg. 48,245 (October 1, 1981). In addition, in promulgating UIC regulations, EP A has long noted that surficial aquifers, like the aquifer here, "are normally used for human consumption" and that "virtually every surficial aquifer in the United States currently serves as a source of drinking water." See 44 Fed. Reg. 23,743 (April 20, 1979). In light of this, EP A cannot conclude, in the absence of compelling economic analysis to the contrary, that the surficial aquifer at issue in this matter cannot reasonably be expected to supply a public water system in the future. The EP A "Guidelines for Reviewing Aquifer Exemption Requests" state that any exemption request submitted under 40 C.F.R. § 146.4(c): must analyze the potential for public water supply use of the aquifer. This may include: a description of current sources of public water supply in the area, a discussion of the adequacy of current water supply sources to supply future needs, population projections, economy, future technology, and a discussion of other available water supply sources within the area. See EP A UIC Guidance No. 34. Other than an assertion that the nearby community of Tyonek, Alaska currently obtains its drinking water from an inland lake, Envirotech's application contains none of the type of information necessary to analyze the potential for public water supply use of -3- -- e the subject aquifer. The record contains no information about: the adequacy of surface water supply sources to supply the future needs of Tyonek; the likelihood of future timber operations at the North Foreland site (or where such operations would obtain drinking water); the demographic or ecçmomic projections for the area; or the costs necessary to make water from the subject aquifer potable. The lack of data and analysis on these points is particularly troubling in light of the fact that the Alaska Department of Commerce, Community, and Economic Development (DCCED) reports that Tyonek is currently seeking to supplement its drinking water supply with a groundwater source. See DCCED RUBA Status Report for Community of Tyonek, Oct. 10, 2004, available at www.commerce.state.ak.us/dca/ruba/report/Ruba _Print.cfm?rID=821. Because EP A disagrees that the sampling data indicate that the aquifer is "highly contaminated" and finds that the record does not support a conclusion that drinking water recovery is "economically infeasible," EP A cannot conclude that this aquifer exemption satisfies the third criterion. For all ofthe foregoing reasons, the exemption designation embodied in AOGCC Aquifer Exemption Order No. 10 is hereby disapproved pursuant to 40 C.F.R. § 144.7(b)(3). Signed this22,^,~ay of November, 2004, /? 0?~ Michael A. Bussell, Director Office of Compliance and Enforcement Region 10, U.S. Environmental Protection Agency -4- ~tg · e STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 Re: THE REQUEST OF) Aquifer Exemption Order No. 10 ENVIROTECH LLC for an Aquifer ) Exemption Order for their North ) Shallow, Unconfined Aquifer at the Foreland Facility, Sec. 14, TllN, ) Envirotech LLC North Foreland Rll W, Seward Meridian, Cook Inlet ) Facility Basin, Alaska. ) ) October 6, 2004 IT APPEARING THAT: 1. Rozak Engineering on behalf of Envirotech LLC ("Envirotech"), a subsidiary of Tyonek Native Corporation, submitted an application, dated March 15, 2004, requesting the Alaska Oil and Gas Conservation Commission ("Commission") issue an aquifer exemption beginning at the ground surface for purposes of Class II disposal of treated, produced water using a waste-water drain field installed at Envirotech's North Foreland Facility site. 2. Notice of opportunity for a public hearing was published in the Anchorage Daily News on April 21, 2004 in accordance with 20 AAC 25.540. A supplemental notice of public hearing was published in the Anchorage Daily News on April 23, 2004. 3. The Commission did not receive any protest or request for a public hearing. 4. The Commission has jurisdiction in this matter under AS 3l.05.030(h), 20 AAC 25.440, and 40 CFR 147, Subpart C - Alaska. 5. Rozak Engineering provided copies of Envirotech's Aquifer Exemption application to the U.S. Environmental Protection Agency, Region 10, and to the Alaska Department of Environmental Conservation. 6. A public hearing was held at Commission request on June 10, 2004. The hearing record was held open until June 25, 2004 to accommodate submittal of additional information requested by the Commission and through several extensions the record remained open until it closed on September 1, 2004. 7. In response to Commission requests, Rozak Engineering and Envirotech submitted additional information on June 29, June 30, and August 30,2004. Aquifer Exemption Order Ie Envirotech LLC North Foreland Facility October 6, 2004 e Page 2 of6 FINDINGS: 1. Location and Facility Description Envirotech's North Foreland Facility ("Envirotech Facility") is located on the west side of the Cook Inlet, approximately 1-3/4 miles southwest of the village of Tyonek. Coordinates ofthe proposed disposal site are: 61002' 33.5" Nand 151009' 50.6" W. This facility consists of several workshop and industrial structures that were utilized and then abandoned by a Japanese timber company in the 1980's. During 2002, Envirotech constructed a wastewater drain field consisting of three, 40-foot lengths of 4-inch diameter perforated pipe that are spaced 10 feet apart. These pipes lie five feet below ground surface, atop six feet of 3-inch minus drain rock. The drain rock is underlain by soil described as gravelly sand. This drain field lies approximately 14 feet above the unconfined ground water aquifer, and about 500 to 600 feet from the western shoreline of the Cook Inlet. The nearest oil or gas well is Moquawkie #44-8, which is three miles to the northwest of the Envirotech Facility. There are no water supply wells within one-quarter mile of the drain field. The nearest water well listed in the Alaska Department of Natural Resources' Water Resource database lies 4 miles to the northeast. The village of Tyonek, located 1-3/4 miles to the northeast, obtains drinking water from an inland lake. There is a shallow well at the Envirotech Facility that is estimated to be 25 to 30 feet deep, and is equipped with a submersible pump. The water from this well is not used as drinking water. 2. Geology and Ground water Hydrology The Envirotech Facility is situated on an alluvial terrace composed of unconsolidated glacial soils that are classified by the US Department of Agriculture's Natural Resources Conservation Service as being part of the Nancy-Kashwitna Complex. These soils were deposited over a thick sequence of Tertiary-aged, coal-bearing rocks. The ground surface at the project site slopes gently southeast, toward the Cook Inlet. Ground water is expected to flow to the southeast from the drain field toward the Cook Inlet, parallel with the surface gradient. There are no well logs or soil descriptions for the shallow geologic section in the vicinity of the project area. An experienced drilling contractor suggests that a dense silt layer may occur between 30 and 75 feet below ground surface, but until monitor wells are drilled, the Commission has no direct evidence to support the existence of this layer beneath the project site. Topographic maps indicate the closest approach of nearby Tyonek Creek to the drain field is about 900 feet to the southwest. This point of closest approach lies at about the same elevation as the drain field, and it occurs at a location where the creek channel makes an abrupt course change toward the southwest, away from the drain field. Aquifer Exemption Order 1_ Envirotech LLC North Foreland Facility October 6, 2004 e Page 3 of6 3. Formation Water Salinity Petrophysical logs, soil descriptions, or drilling records are not available for the shallow, non-potable water well at the Envirotech Facility. Envirotech collected water samples from Cook Inlet, from the shallow water well, and from nearby Tyonek Creek. A commercial laboratory analyzed these samples for total dissolved solids ("TDS") and chlorides using EP A-approved methods. The analytical results are: Sample Site Cook Inlet Shallow well Tyonek Creek TDS (mg/l) 17,000 3,300 1,500 Chlorides (mg/l) 9,740 1,710 868 4. Applicable Regulations Regulations 20 AAC 25.440 (a)(l)(B) and (a)(2) provide that the AOGCC can grant a fresh water aquifer exemption if "the total dissolved solids content of the ground water is more than 3,000 and less than 10,000 mg/l, and it is not reasonably expected to supply a public water system." 5. Subsurface Ownership The subsurface at the Envirotech Facility is owned by Cook Inlet Region Inc. ("CIRI"). A letter of formal agreement between Envirotech and CIRI stating that CIRI has no objections to this disposal project was provided to the Commission by Envirotech on August 30, 2004. CONCLUSIONS: 1. The shallow aquifer occurring below the ground surface at the Envirotech Facility does not currently serve as a source of drinking water 2. The formation waters of the shallow, unconfined aquifer are more than 3,000 ppm TDS in the vicinity of the shallow well near the Envirotech facility. 3. The shallow aquifer occurring below the ground surface within the unconsolidated glacial soils and lying within a one-quarter mile radius of the existing Envirotech Facility drain field cannot reasonably be expected to supply a public water system. 4. The shallow aquifer occurring below the ground surface and within one-quarter mile radius of the Envirotech Facility drain field qualifies as exempt fresh water aquifer under 20 AAC 25.440(a)(2). Aquifer Exemption Order Ie Envirotech LLC North Foreland Facility October 6, 2004 e Page 4 of 6 NOW, THEREFORE, IT IS ORDERED THAT The aquifer occurring between the ground surface and the bas~f the near-surface, unconsolidated glacial soils within a one-quarter mile radius of t Ie ~xisting Envirotech Facility drain field is exempt under 20 AAC 25.440. . DONE at Anchorage, Alaska, and dated Oc 11/> r AS 31.05.080 provides that within 2 with the Commission an applicati the date of the order, or ne w application in whole or in period. An affected perso order upon rehearing, both , a person affected by it may file Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 Kelly Valadez Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Kay Munger Munger Oil Information Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 James Gibbs PO Box 1597 Soldotna, AK 99669 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 . Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Schlumberger Drilling and Measurements 2525 Gambell Street #400 Anchorage, AK 99503 Ciri Land Department PO Box 93330 Anchorage, AK 99503 Jack Hakkila PO Box 190083 Anchorage, AK 99519 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 Cliff Burglin PO Box 70131 Fairbanks, AK 99707 North Slope Borough PO Box 69 Barrow, AK 99723 - David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 John Levorsen 200 North 3rd Street, #1202 Boise, ID 83702 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 David Cusato 200 West 34th PMB 411 Anchorage, AK 99503 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Darwin Waldsmith PO Box 39309 Ninilchick, AK 99639 Penny Vadla 399 West Riverview Avenue Soldotna, AK 99669-7714 Bernie Karl K&K Recycling Inc. PO Box 58055 Fairbanks, AK 99711 Various Orders e e lof2 10/10120042:52 PM Various Orders e e 20f2 10110120042:52 PM - e STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage Alaska 99501 Re: THE REQUEST OF ENVIROTECH ) LLC for an Aquifer Exemption Order ) for their North Foreland Facility, Sec. ) 14, TUN, RUW, Seward Meridian, ) Cook Inlet Basin, Alaska. ) ) ~ The Commission has found the following No. 10, issued October 6, 2004, which \..J ,Chao A aska Oil and Gas Conservation Commission 0~ Daniel T. Seamount, Jr., Commissioner Alaska Oil and Gas Conservation Commission Errata AEO 10 - - 10f2 10/15/20048:19 AM Errata AEO 10 e e 20f2 10/15120048:19 AM Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 Kelly Valadez Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Kay Munger Munger Oil Information Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 James Gibbs PO Box 1597 Soldotna, AK 99669 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 e Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 e David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 John Levorsen 200 North 3rd Street, #1202 Boise, 10 83702 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 Schlumberger Drilling and Measurements 2525 Gambell Street #400 Anchorage, AK 99503 David Cusato 200 West 34th PMB 411 Anchorage, AK 99503 Ciri Land Department PO Box 93330 Anchorage, AK 99503 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Jack Hakkila PO Box 190083 Anchorage, AK 99519 Darwin Waldsmith PO Box 39309 Ninilchick, AK 99639 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 Penny Vadla 399 West Riverview Avenue Soldotna, AK 99669-7714 Cliff Burglin PO Box 70131 Fairbanks, AK 99707 Bernie Karl K&K Recycling Inc. PO Box 58055 Fairbanks, AK 99711 North Slope Borough PO Box 69 Barrow, AK 99723 ¡{ a \ \,,0\."1 . )^' I lUllS 0'1 #17 Envirotech North Foreland Facility - Origin of Samples Used to Test... . . Mr. Davies, The source of the influent water samples is produced water from gas wells in the area. Envirotech expects that this water is representative of the produced water that Envirotech proposes to treat. Please do not hesitate to contact us for any further questions you may have. Regards, Derek Maat Envirotech LLC Ron Rozak wrote: Mr Davies called this morning and asked about the source of water samples. I thought it was produced water provided by Aurora, but was not sure. asked him him to email his question(s) so I could forward to you folks for accurate answer. He would appreciate an answer for a meeting this afternoon. Please respond directly to Mr. Davies and copy me and Alan Kukla. Ron --- Original Message ----- From: "Stephen Davies" <steve davies@admin.state.ak.us> To: <ronrozak@alaska.net> Sent: Wednesday, November 17, 200410:34 AM Subject: Envirotech North Foreland Facility - Origin of Samples Used to Test Treatment Process > Mr. Rozak, > > Envirotech LLC's application to the Alaska Oil and Gas Conservation > Commission entitled "Freshwater Exemption for Underground Disposal of > Treated Oil Field Wastewater, Envirotech Facility at North Foreland, > Cook Inlet, Alaska" dated March 15, 2004 contains laboratory analytical > results for influent and effluent water samples in Table 2. Could you > please tell me the source of the influent water sample? Does Envirotech > consider these samples to be representative of the produced water that > Envirotech intends to treat and dispose in the drain field at the North > Foreland Facility? If not, could you please provide me a general > salinity range for the produced water that Envirotech intends to treat > and dispose? > > My apologies for requesting a quick response, but a rapid reply will > help facilitate our discussions with other agencies. > > Thank you, > > Steve Davies > Petroleum Geologist > Alaska Oil and Gas Conservation Commission > 907-793-1224 > I of 1 1l/17/2004 11 :33 AM Envirotech North Foreland Facility - Origin of Samples Used to Test... . . Mr. Rozak, Envirotech LLC's application to the Alaska Oil and Gas Conservation Commission entitled "Freshwater Exemption for Underground Disposal of Treated Oil Field Wastewater, Envirotech Facility at North Foreland, Cook Inlet, Alaska" dated March 15, 2004 contains laboratory analytical results for influent and effluent water samples in Table 2. Could you please tell me the source of the influent water sample? Does Envirotech consider these samples to be representative of the produced water that Envirotech intends to treat and dispose in the drain field at the North Foreland Facility? If not, could you please provide me a general salinity range for the produced water that Envirotech intends to treat and dispose? My apologies for requesting a quick response, but a rapid reply will help facilitate our discussions with other agencies. Thank you, Steve Davies Petroleum Geologist Alaska Oil and Gas Conservation Commission 907-793-1224 I of! 1l/17/200410:36AM [Fwd: Preparing DIO for AOGCC AEO -'0] . . All, Attached are a message and memo from Ron Rozak regarding the continuing "process" for the Envirotech AEO and potential AIO matter. Ron is requesting some guidance with regard to the process. Does he contact DEC or AOGCC or both?? How does EP A still figure in?? When does their 45 day review period expire?? After receiving comments from you all, I will draft a message to Sharmon Stambaugh at DEC. She was copied on our letter to Rozak/Envirotech. We have had conversations regarding setting up an agency meeting, however she has not come back with time proposal. I will pursue that later today. Thanks, Tom Jody, please place in the file. -------- Original Message -------- Subject:Preparing DIO for AOGCC AEO No. 10 Date:Sun, 14 Nov 2004 22:50:43 -0900 From:Ron Rozak <ronrozak@alaska.net> To:Thomas Maunder <tom maunder@admin.state.ak.us> CC:Gerry Allen <gdallen@gci.net>, Derek Maat <derekimaat.hmm@sympatico.ca>, Mike Wicker <mwicker@ptialaska.net> Tom, I have discussed with Envirotech representatives the unclear regulatory situation. Right now it seems like we are trying to hit a moving target with submittals and have no idea how long the process could take. We want to resolve these issues before proceeding and thing a meeting of the affected team member would be productive at this time. Please forward my memo (attached) to the appropriate parties for input. Ron Content-Type: applicationlmsword Content-Encoding: base64 1 of 1 1l/16120041l:00AM . . # ROZAK ENGINEERING Civil, Construction & Environmental Consulting P. O. Box 350 Kenai, Alaska 99611 (907) 283-5640 (907) 283-0747 Date November 14, 2004 MEMORANDUM To Tom Maunder, Petroleum Engineer tom _ maunder@admin.state.ak.us Alaska Oil & Gas Conservation Commission (AOGCC) (907) 793-1250 333 W ih Avenue #100 Anchorage, AK 99501-3539 From Ronald T. Rozak, P .E. ronrozak~alaska.net Environmental Consultant, Kenai, AK (907) 283-5640 Re Preparing Disposal Injection Order for AEO No. 10 Envirotech Facility at North Forelands, Cook Inlet, AK Commissioner Norman's letter dated November 2, 2004, addressed some of my questions about the ongoing regulatory process for the underground disposal for treated oilfield wastewater at the referenced facility. In addition to the aquifer exemption order (AEO No. 10) granted to Envirotech, we understand an application must be submitted to the Commission for a disposal injection order (DIO), apparently after the end of a 45-day period for EP A's review and comment on AEO No.1 O. When does the 45-day comment period end? How soon afterward will AOGCC provide any decision or comments? Commissioner Norman's letter stated that Envirotech's application for an AEO included most of the types of information required for a DIO application, however, additional information will be required (specifically mentioned, thickness and lithology of the disposal and confining zones). We anticipated that the collecting of detailed information about the aquifer and confining layer would be required for obtaining an industrial wastewater (WW) discharge permit from Alaska Department of Environmental Conservation (ADEC). If that is true, the WW permit should be addressed before the DIO, unless the DIO has a condition for this information to be provided with the WW permit. We understand our proposal for treatment and underground disposal of oilfield wastewater oil is not typical, and our approach crosses regulatory boundaries between AOGCC, ADEC, and possibly USEP A. It appears the decision to proceed may depend on the results ofEPA's review, but I am not sure how to proceed with future submittals. We want to address all the regulatory requirements, but without duplication and delay. Toward this goal, it would be helpful if we could have a workshop-type meeting with all the appropriate regulatory agency representatives to address concerns for precedent, clarify the regulatory and submittal requirements, other concerns or requirements, and develop a project timeline. I would appreciate your help setting up the meeting. Weare available to meet in Anchorage at a date and location convenient to agency representatives. Please let me know if this is agreeable with the other parties and what dates are available. [Fwd: Re: Drainfield References, et al] . . Sorry, I meant to forward this to you all. Jody, this is for the file. Tom m__m Original Message mum Subject:Re: Drainfield References, et al Date:Thu, 04 Nov 200407:43:53 -0900 From:Thomas Maunder <tom maunder@admin.state.ak.us> Organization:State of Alaska To:Stambaugh, Sharmon <Sharmon Stambaugh@dec.state.ak.us> References:< 1 BF4608CC85BF549 ADBD042142F3DDOF3186E9@ANC-EXCHANGE.dec.state.ak.us Sharmon, Thanks for the reply. The Rozak Engineering application letter of}vbrch 15,2004 included water analy.;is information. Some was as simple as just TDS, but there are two pair of sarI1Jles labeled influent and effluent that report JIDre complete analysis. Do you have a copy of that March 15 application? The letter shows to have been copied to Oran. Also do you have the record of our public hearing?? I don't remember if I had forwarded that to you earlier. Please message or call back. Tom Maunder Stambaugh, Sharmon wrote: Steve Mulder at AG office called me today and he is looking through those West Fork records. We are at DEC as well. Thanks for sending! Today we got a HUGE box of docs from the Soldotna office on Envirotech and Alan Kukla is going through those. I specifically asked him to look for water quality data to tell us if any of our water quality standards (besides TDS which is exempted in your action) are going to be a problem. We are initiating a plan review, but at this point, I don't want to issue a discharge permit. If necessary, I will put restrictions on discharge as part of the plan review requirements under 18 AAC 72. DEC is willing to meet and I think Steve Mulder will agree, but EPA's participation is essential to know whether they want this facility to inventory as a Class V facility. Thanks. -----Original Message----- From: Thomas Maunder [mailto:tom maunder@admin.state.ak.us] Sent: Wednesday, November 03, 2004 4:33 PM To: Sharmon M Stambaugh Cc: Steve Davies Subject: Re: Drainfield References, et al Sharmon, 100 11/4/2004 11 :06 AM [Fwd: Re: Drainfield References, et al] . ... . I presume you got my message to Thor and the e copies of the West Fork information. Has anyone else contacted you regarding your earlier message regarding a potential meeting?? Commissioner Seamount has asked me to check with you and see what we might be able to set up. There is also a hard copy of a letter we sent to Mr. Rozak headed your way. Looking forward to talking with you tomorrow. Tom Thomas Maunder wrote: Thor, Enclosed are the documents from the AOGCC files with regard to drainfield disposal that was done at the West Fork field on the Kenai Peninsula during the early 1990s. This information is provided per your request in a teleconference with myself and Steve Davies as well in a follow up email. Please call or message with any questions. Hard copies with be coming in the mail. Tom Maunder, PE AOGCC 20f2 11/4/2004 11 :06 AM #16 e ~~~~E (ill} ~~fÆ~~~~ . AI#A.SIiA. OIL AND GAS CONSERVATION COMMISSION November 2, 2004 FRANK H. MURKOWSKI, GOVERNOR 333 W. 7'" AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 Mr. Thor Cutler Ground Water Protection Unit US EP A Region 10 1200 Sixth Avenue, OW-137 Seattle, W A 98101 Re: Aquifer Exemption Order (AEO) 10 North Foreland, Alaska Envirotech, LLC Dear Mr. Cutler: Attached, per your email request, are copies of the information from the AOGCC files regarding produced water disposal at the West Fork Field on the Kenai Peninsula. The correspondence covers October 1991 through July 1993. In your email message, you posed several questions and made several observations. I have copied the text of your message below and offer some comments/clarifications. One observation we make is that it is important to keep the issues with regard to the AEO separate from any disposal application. The present Commission action is only with regard to the aquifer exemption. In your message, you stated: "I understand you say the operator, Aurora Energy (Contractor Envirotech) has proposed to AOGCC (1425 program) to use a shallow drainfield (sounds like a shallow Class V drainfield construction, without an ability to perform MIT) that is planned in the future to be constructed (not yet constructed, right?) in a underground source of drinking water (less than 10,000 TDS) salt water intrusion onshore former Timber camp site (one water sample shows about 3100 TDS at 25 fiet below the surface), to dispose treated gas/oilfield generated fluids (fluids that are up from down hole only, commonly injected into a Class II well under 1425 program) to be injected into a shallow unconfined aquifer that is hydologically in communication with Cook Inlet (saltwater intrusion from the ocean) , a State of Alaska salt water body, which is NPDES permit territory with zero discharge limits. " e . Aquifer Exemption Order (AEO) 10 November 2, 2004 Page 2 of2 1. Aurora Energy has not been party to any of the discussions with regard to Envorotech's application for the aquifer exemption order (AEO). Envirotech, LLC is the operator of the facility. Envirotech is a subsidiary of Tyonek Native Corporation (TNC). TNC is a "village corporation" under the Alaska Native Claims Settlement Act (ANCSA) and owns the surface estate in the subject area. Cook Inlet Region, Inc. (CIRI), a regional native corporation established under ANCSA, owns the subsurface estate. TNC is a "member" ofCIRI. Aurora does operate several gas wells in the general area. 2. According to the information in the application and earlier correspondence with staff of the Alaska Department of Environmental Conservation (ADEC), the drainfield has already been constructed. 3. According to the water analysis information supplied in the application, the TDS of the well water sample was 3300 ppm, rather than 3100 ppm. 4. According to the information available to the Commission, the only waste water handled will be from gas wells. No oil production exists onshore in this region of Cook Inlet. 2~ ~"Mj~ Thomas Maunder, PE - ~-( Sr. Petroleum Engineer Attachments cc: Sharmon Stambaugh, DEC [Fwd: Request info re: previous action referenced yesterday] e e Subject: [Fwd: Request info re: previous action referenced yesterday] r- From: Rob Mintz <robert_mintz@law.state.ak.us> Date: Fri, 22 Oct 2004 12: 1 0:06 -0800 1== Jl . . To: dan _ seamount@admin.state.ak.us, john_ norman@admin.state.ak.us, tom _ maunder@admin.state.ak.us CC: jack _ hartz@admin.state.ak.us, jim _regg@admin.state.ak.us, steve _ davies@admin.state.ak.us I am interested in Thor's theory that this is not a Class II well because of its construction. I don't see that distinction in EP A's regulations, but I'd like to know more. »> Thomas Maunder <tom_maunder@admin.state.ak.us> 10/22/2004 11:25:26 AM »> All, Here is a message Steve and I received from Thor regarding a call he placed yesterday. Steve and I talked with him in regard to AEO 10 (Envirotech). Thor's questions basically have him where we have been and extending the AE request to a request for a DIO. We stated that the only item we were addressing with the documents he has was the AEO and that we felt the available information met the regulatory requirements and that issuing the exemption was warranted. As you can see from his message, he points out various issues including the small number of samples and the hydraulic connection to the Inlet which he believes links this action to NPDES. During our conversation he also made a statement that "a Class II fluid, if treated might not still remain a Class II fluid". He made mention of some regulation in RCRA, however he was not specific. He also stated that, in his opinion, this installation would be a Class V well and (under current regime) would be regulated by EP A. He further stated that the construction would control the well type, not the fluid that was disposed. We did discuss that historically such a disposal method was authorized in the early 90s for CIRI's West Fork gas well on the peninsula. In response to an earlier request from Sharman Stambaugh I had copied a series of documents prior to my departure for Erie which I left with Jim. I would propose to copy those documents and send them to Thor. Steve and I believe that this is a topic for the Sr. Staff Meeting if not sooner. Any comments will be appreciated. Tom -------- Original Message -------- Subject:Request info re: previous action referenced yesterday Date:Fri, 22 Oct 200408:37:24 -0700 From:Cutler. Thor@epamail.epa.gov To:tom maunder@admin.state.ak.us, steve davies@admin.state.ak.us Steve, Tom, Good Morning, Thank you for talking with me about the the Aquifer Exemption No. 10, a shallow unconfined glacial in the vicinity of North Foreland Facility, Tyonek, Alaska. I note a reference to a 45 day timeline for Federal Comment. In our phone conversation, you mentioned an example of a site in the 1990's (West Fork Gas Field, Kenai). Please help me out. Please provide to me at your earliest convenience (Fedex overnight would be appreciated) a copy of the file so that I can understand what you were referring to over the phone yesterday, Oct 21, 2004. As you mentioned yesterday, this is a unique aquifer exemption application. I understand you say the operator, Aurora Energy (Contractor Envirotech) has proposed to AOGCC (1425 program) to use a shallow drainfield (sounds like a shallow Class V drainfield construction, without an ability to perform MIT) that is plannedin the future to be constructed (not yet constructed, right?) in a underground source of drinking water (less than 10,000 TDS) salt water intrusion onshore former Timber camp lof2 10/25/20042:10 PM Re: Thor transmittal letter e e Subject: Re: Thor transmittal letter From: Rob Mintz <robert _ mintz@law.state.ak.us> Date: Mon, 25 Oct 2004 10:54:06 -0800 To: tom_maunder@admin.state.ak.us It looks OK. I don't know in will be able to make it there today, though. »> Thomas Maunder <tom_maunder@admin.state.ak.us> 10/25/2004 10:45:57 AM »> Rob, Here is my initial stab àt a transmittal letter to Thor. I know I have mixed tense and person. At this point I don't know ifthe letter is for John's signature or mine. The key point I see here is that the only action we have out there right now is the AEO. Thor makes observations and questions that clearly go to a disposal order. Will you be over today to look at the documents I have. Jack has also looked at them and he is not aware of any others that we might have. Further observations/information I have: 1. Original well drilled in early 1991. Production fIrst reported September 1991. 2. 2nd well drilled in June 1992 and completed in 2 Sterling zones. 3. Original well P&Aed in early 1994 and redrilled. 4. Redrill completed in 2 Sterling zones in May 1994. 5. Last reported production from either well February 1995. 6. Marathon recently was made operator by CIRI. Look forward to talking with you. I will be heading for the SPE lunch for 1130. Tom I of I \ v ç, l~ 10/25/2004 2:09 PM ~ e e Settlement Act (ANCSA) and owns the surface estate in the subject area. Cook Inlet Region, Inc. (CIRI), a regional native corporation established under ANCSA, owns the subsurface estate. TNC is a "member" of CIRI. Aurora does operate several gas wells in the general area. 2. According to the information in the application and earlier correspondence with staff of the Alaska Department of Environmental Conservation (ADEC), the drainfield has already been constructed. 3. According to the water analysis information supplied in the application, the TDS of the well water sample was 3300 ppm, rather than 3100 ppm. 4. According to the information av~~'~hle to the Commission, the only waste water handled will be from ~~~_wells. No oil pwuuc c. va oxlo. 0 ~uuk_'" C., ....~ _ _'" J i.... --( "'é<1o,-)nl et . Thor Cutler 206-553-1673 fax 206-553-0151 ~ ~ e e ........., , ....... ~II¡~IF~ ~ULJ"UUb ! r--.. - II"" 1""- 'I : I ¡ L. I !) . ~U Ii\ ~ ¡~ ~ r« fi\ G'ïJ ~ Ißj ~ If\1 Lrù ; i / / / WALTER J. HICKEL. GOVERNOR ALASKA. OIL &'0) GAS CONSERVATION COMJIISSION December 4, 1991 3001 PORCUPINE DRIVE ANCHORAGE. ALASKA 99501-3192 PHONE: (9<J7) 279-1433 TELECOPY: (9<J7) 276-7S42 Karen Wood Alaska Center for the Environment 519 West 8th Ave, Suite 201 ~~~~:',.~.~~,:~.:~ 1 ó'" I ýJ (fie: West Fork 1-21, wast~r Disposal Permit , '. Dear Ms. Wood: Thank you for forwarding a copy of your November 22, 1991lener to Mr. Dolan concerning the West Fork 1-21 well. I want to take this opportunity to c1earup certain miconceptions you have concerning AOGCCs "recommendations" to CIR1 to pursue sUIface disposal. Because of the geotechnical considerations, an injection option in the area of the West Fork 1-21 well may not be certain. Accordingly, we suggested that COO consult with the Department of Environmental Conservation about surface disposal. Given the low TDS content of the produced waters reponed by CIRI, sUIface disposal may be pemrissible under ADEC regulations. We believe it is prudent for any operator to consider all alternatives before committing to an injection program, which may not be . necessary in this case if the produced waste stream meets freshwater standards. S~ould ADEC determine that surface disposal is acceptable, d:ri.llfug a designated injection well would prove unnecessary. Commission stamtes defme the drilling of unnecessary wells as waste under AS 31.05.170(14)0). Should injection prove to be the only feasible disposal option, Commission oversight will help insure that no underground sources of drinking water are endangered and that injected fluid does not escape to the surface. To date, there have been no documented instances of contamination of freshwater aquifers due to Class n injection. While ACE may not have confidence in our ability to adequately monitor and regulate injection activity, our track record speaks for itself. Since achieving primacy for the state's mc Class II program in 1986, the . Commission has worked closely with the U. S. EDvironmental Protection Agency to develop a sound and responsible program. EP A's annual reviews have concluded that we administer an effective program with considerable technical expertise. In the future, should you have any question concerning our position, I encourage you to contact us directly. cc. Roben Dolan, DEC Eric Opstad, CIRI e e ,.r'-. .--.......\ fI' .~,. .2..:.aJ. ) .. 'u~ . 1971-1991 Alaska Center for the Environment 519 West 8th Ave. #201 · Anchorage. Alaska 99501 · (907) ~¿:2"1.·'~_ November 22, 1991 ~-O--_·~.s .-' MM ·.£fES ENG fj-- SR ENG A!# i.SR ENG 8 i ENG ASST 'ENG ASST - .?R GEOL C-/' GEOL ASS í'~~E!- ASST Ih ¡STAT TECW-.. [g~ËC-.r-: -. - .__1 The Alaska Center for the Environment finds the surface discharge of produced waters by CIRI Production Company, as proposed in the West Fork 1-21 Wastewater Disposal Permit application to be an unacceptable disposal method for the following . reasons: . Mr. Robert Dolan Alaska D.epartment of Environmental Conservation RE" Southcentral Regional Office eEl V ~D 3601 C Street fJ Anchorage, AK 99503 . NOV 26 J99' SUBJECf: we~tF¡;Tk(l-iíW,¡s~j>atét(!>i~~~~ Cons. CommIaiIItn 40 -lý3· . -lIagq. . Dear Mr. Dolan: ( 1) discharging produced waters into a wetland area, especially one located on the Kenai National Wildlife Refuge, poses unacceptable risk to the flora, fauna and habitat of the area when other, options with potentially less impact (injection) are available; 2) the permit application does not provide crucial information needed to evaluate the potential impact of the produced water discharge on the affected pond/wetlands; 3) the proposed discharge will potentially cause the pond/wetlands water to exceed state water quality criteria; 4) ACE feels the U.s. Fish 'and Wildlife Service has had inadequate time to evaluate the impact of the proposed discharge on the Refuge. ACE recommends that at the very least, DEC extend the comment period to allow USFWS time to comment thoroughly and to allow CIRI and DEC the opportunity to resolve the outstanding concerns explained below. Surface Disèharge vs. Underground Injection It is not clear why the Alaska Oil and Gas Conservation Commission (AOGCC) recommended that CIRI discharge the produced water resulting from the West Fork 1- 21 gas well onto the surface instead of reinjecting it. Especially when the CIRI lands to be developed are surrounded by the Kenai National Wildlife Refuge, protection of the surface lands, waters, and habitat is critical. Is it a cost factor that caused CIRI to pursue surface disposal? AOGCC's recommendation assumes that the characteristics of the produced water will remain the same throughout the duration of the drilling project. This is an unsafe assumption given the variability of reservoir pockets and the cumulative impact of extraction on weB conditions (for example, changing gas to water ratio). While ACE does not have full confidence in the ability of the AOGCC to 'adeq~ately monitor and re.te the produced water reinjece process, injecting the water seems less risky biologically than surface disposal. Incomplete Permit Application The permit application does not include information on several of the chemical and physical properties required under 'IK. Characteristics of Waste Flow" of the permit application, specifically temperature, dissolved oxygen, color, metals, total hydrocarbons, and total aromatic hydrocarbons (ACE recognizes that some testing for specific hydrocarbons is included). ACE recommends that the Department of Environmental Conservation (DEC) require that all of the parameters specified in the regulations be analyzed by CIRI and evaluated by DEC before the Department grants the permit. Potential Impact of Discharge on PondjWetlands Secondly, it appears that the produced water, with the chemical and physical properties for which CIRI provided analysis, may cause the pond and wetlands water to exceed the water' quality criteria established in 18 AAC 70.020 at the rate and duration of discharge. ACE requests information on the size and volume of water in the tlsmall, contained perched pond" targeted for discharge and expects the Department to delay issuing of a permit until that information is known and used to evaluate the impact on water quality. The volume of water in the discharge area is critical data for evaluation of impact. As a pond and wetlands area within the Kenai National Wildlife Refuge, the discharge area meets two of the protected fresh water use classes, secondary recreation and growth and propagation of fish, shellfish, other aquatic life, and wildlife [18 AAC 70.020 (a)(I)(B)(ii) and (C)]. Therefore, as per the regulations, the most stringent criteria of the two classes applies [18 AAC 70.030 (1)]. Several of the levels of contaminants in the produced water raise concern at this time. Total dissolved solids in the wetlands water, for example, were measured by CIRI to be 50 mg/I. Analysis of total dissolved solids in the produced water showed ranges from 2380 to 2660 mg/I. The water quality criteria state that . Total dissolved solids shall not exceed a maximum of 1,500 mg/I including natural conditions. Increase in TDS shall not exceed one-third of the concentration of the natural condition of the body of water. After ten years of discharge at a rate of 1-2,000 gallons per day, 365 days per year, a substantial increase in TDS levels in the wetlands/pond waters seems quite likely. ACE is also concerned about the 500+ mg/I chloride levels in the produced water. Has DEC or CIRI determined if the chloride released in the proposed produced water discharge would remain as free ions or be attached to cations? Which cations and what concentrations of them are present in the produced water and the pond/wetland waters? If the chloride was to remain in free ion form, the pH of the pond could rise. causing the pond water to become much more alkaline. This would impact the vegetation and other organisms living in the pond/wetlands. Or alternatively, if the chloride was attached to cations, the produced water discharge could be toxic (either e e .-"--', " --...... ." ,.J immediately or cumulatively) to the freshwater communities present in the pond/wetlands through direct toxicity to an organism or through habitat degradation. The impact of the discharge on the p~md/wetlands pH is quite important. The water quality criteria for pH state that the it "shall not be less than 6.5 or greater than 9.0. Shall not vary more than 0.5 pH unit from natural condition." Because the pH of the wetlands water was measured as 4.85, ACE assumes the second statement regarding variance from the natural condition applies. ACE is also concerned about the proposed discharge's impact on the dissolved oxygen levels, temperature, and color of the pond/wetlands water. USFWS Involvement ACE was disturbed to learn that the U.S. Fish and Wildlife Service at the National Wildlife Refuge had not been notified of this permit application until late last week. Notably, it was a concerned local resident who brought the issue to USFWS attention --not DEe or CIRI. Mr. Dolan told ACE the permit application was sent by fax to the Wildlife Refuge on the morning of November 22, leaving USFWS less than one working day to evaluate and comment. ACE feels this is inadequate time allowed to the keepers of the Refuge for determination of the discharge's impact on the Refuge. Monitoring ACE recommends that at the very least, DEC require monthly testing of the produced waters and quarterly testing of pond/wetland waters. Mr. Dolan stated on the telephone his intention to require quarterly testing of the discharge waters and annual testing of the pond/wetland waters. ACE regards the latter schedule as highly inadequate, given the varia,bility in contaminant levels of produced waters. ACE also recommends that if DEC decides to grant a wastewater discharge permit, it be .granted for one year only. The wisdom of allowing the produced waters to be discharged into tbe wetlands/pond area should be reevaluated by DEC and AOGCC each year, depending upon actual measured impact on the pond from the discharge to date, and the produced water contaminant load. Thank you for the opportunity to comment. Please forward a copy of CIRJ's solid waste disposal permit to ACE when available. ACE looks forward to DEC's response to the above questions and concerns abo1,.lt the wastewater discharge permit. Sincerely, 1(~ ¿J~ Karen Wood Waste Reduction Specialist cc: AOGCC e e II./vlvuy1 ....=1... ..' :COMM - , '} iCOMM . , I ~ES ENG ,~ \ SR ENG 14.. II~GE~~~! L:N~~~~-=- - - CIRI PRO~~~~·.··.. . PANY . CEOl. AS.~ L· '.' -. '." . . f=r. " C:'-')'P" ..'1;.. I .., ..' , ¡ . rAT TFf'H I 'r~ T rr:CH; I (;~, f:' ". .. .! 1. _ ~ ~ November 12;' 1991" . ..---.... Ms. Joan Miller Alaska Oil & Gas Conservation Commission 3001 Porcupine Drive Anchorage, AK 99501 Dear Ms. Miller: Per our conversation this morning, I am writing to you to clarify that the West Fork Gas '1 Field is operated by ClRI Production Company. Therefore, the operator's name should "T" be CIRI Production Company (or (PC in short). Please make the necessary changes where needed. Sincerely, CIRI PRODUCTION COMPANY /'11:1 ~ Menggui Zhang rJ Operations Engineer MZ:rc:047 RECEIVED NOV 1 4 1991 Alaska Oil & Gas Cons. Commission Anchorage CIRI BUILDING 2525 "C" STREET P.O. BOX 93330 ANCHORAGE. ALASKA 99509·3330 (907) 274·8638 TELECOPIER (907) 279'8,836 TELEX 090-26-465 -- ~¡¿¡'~~P-- I(ð /' ;;/. ~/ CIRI PRODU 10 COMPANY October 31, 1991 Mr. Robert Dolan Alaska Department of Environmental Conservation Southcentral Regional Office 3601 C Street Anchorage, Alaska 99503 SUBJECT: West Fork 1-21 Wastewater Disposal Permit ADEC File No. 9123-D8012 Dear Mr. Dolan, You have requested additional information regarding CIRI Production Company's (CPC) application for a permit to discharge produced water from the CIRI West Fork 1-21 natural gas well onto a surface location adjacent to the well site. Specifically, you have asked why CPC decided to pursue surface disposal rather than annular injection. When CPC first experienced produced water at the West Fork 1-21 well, we discussed the situation with the Alaska Oil and Gas Conservation Commission (AOGCC). On September 24, CPC representatives met with commissioners Johnston and Douglas. Based on this discussion and a review of the facts surrounding the West Fork gas field, AOGCC recommended that CPC make application to ADEC for a permit to discharge the produced water on the surface. AOGCC offered CPC several reasons for their recommendation. First, 20 MC 25.252(b) states that the Operator (in this case CPC) "has the burden of demonstrating that the proposed disposal or storage operation will not allow the movement of fluid into sources of fresh water. II Since the West Fork 1-21 annulus is largely open for over one thousand feet, injected produced water could migrate into any number of fresh water aquifers. While it is possible that CPC could be granted a Freshwater Aquifer Exemption (20 MC 25.440), the criteria for such an exemption requires injection into a specifically confined zone. Given the nature of the West Fork 1-21 well and subsurface geology, we would have no control over which zone, or combination of zones might accept the injected water. Thus we would need multiple exemptions. AGOCC does not favor granting such multiple exemptions. Second, 20 MC 25.412(a) states that IIwells that inject fluids for...disposal of non- hazardous oil field waste fluids...must be cased with safe and appropriate casing and be tubed to prevent leakage, and must be cemented to protect oil, gas and freshwater CIRI BUILDING 2525 "C" STREET P.O. BOX 93330 ANCHORAGE, AlASKA 99509-3330 (907) 274·8638 TELECOPIER (907) 279-8836 TELEX 09Q.26·465 \. ~................. ...._"" , ". . Mr Robert Dolan Octoberr 31, 1 991 Page 2 sources.1I West Fork 1-21 is a production well and can not be simultaneously used an an injector for an extended period of time, even though one time annular injection of drilling fluids is allowed under EPA exemption. e Upon consideration of a variety of factors, including the nature of the West Fork reservoir, the West Fork 1-21 well, state and federal regulations, the costs and impacts of drilling a separate deep disposal well, and the apparent quality of the produced water from West Fork 1-21, AOGCC reached its recommendation that CPC pursue surface disposal through application to ADEC for a Wastewater Discharge Permit. If you have any further questions, please contact Ch ip Dennerlein at 274-8638. Sincerely, CIRI PRODUCTION COMPANY e Kevin A. Brown Vice President CD:092 ---, e """"a~' ~ ."" .' ~. ',,' ,<"':< \.. ~ (00". ~ ,~ ~ i' ;:,,, ... v/'" if ,;/Vl.. "" I !) ,i", . !1~ Po. <" ¿... .a~ c..!,,¡;~... '7 & ,.' "I ~,~~ ~ ~~4~ :~?l., C9/ -£,. IJ!1 ;>"~1J::" . <ff,. "(. ^....':I~. , ':;ð~lj~è~pUCTION COMPANY 1\.4,~~:_ October 22, 1991 Mr. Robert Dolan Alaska Department of Environmental Conservation Southcentral Regional Office 3601 C Street' Anchorage, Alaska 99503 SUBJECT: West Fork 1-21 Wastewater Disposal Permit! Additional Tests ADEC file No. 9123-DB012 Dear Mr. Dolan, CIRI Production Company (CPC) acknowledges receipt of the letter of October 15 from ADEC Regional Administrator Svend Brandt-Erichsen requesting additional analysis of the produced water from the CIRI West Fork 1-21 natural gas well. Water samples have been taken and the tests for the metal ions listed in 18 AAC 080 (a) (1) are being accomplished. In addition, pursuant to your October 17 phone conversation with Chip Dennerlein, CPC has also requested the lab to test the produced water for Ammonia. Test results should be available from the lab by October 25. CPC will transmit the test results to you as soon as we receive them. If you have any further questions, please call. Sincerely, CIRI PRODUCTION COMPANY -----..-. Kevin A. Brown Vice President KAB:CD:088 cc: Chip Dennerlein Eric Opstad File 061,300.024 CIRI BUILDING 2525 "C" STREET P,O. BOX 93330 ANCHORAGE. ALASKA 99509·3330 (907) 274·8638 TELECCP!ER (')07) 279·8836 TELEX 090·26-465 '. -, \.0 " .; e· -RL-CEIVED OCT - 9' 1991 / DEPARTMENT OF ~VIRONMENTAL CONSERVATION SeRe CIRI PRODUCTION COMPANY October 9, 1991 ~ Mr. Robert Dolan Alaska Department of Environmental Conservation Southcentral Regional Office 3601 C Street Anchorage, Alaska 99503 . . l~~ SUBJECT: West fork 1-21 Wastewater Disposal Permit Dear Mr. Dolan, With this letter, and the enclosed permit application forms and attachments, CIRI Production Company (CPO hereby makes application for a permit to discharge produced water from the CIRI West Fork 1-21 natural gas well onto a surface location adjacent to the well site. When CPC first experienced produced water at the West fork 4":21 well, we discussed the situation with the Alaska Oil and Gas Conservation Commission (AOGCO. Based upon the apparent quality of the produced water, AOGCC staff recommended that rather than injection back down the well, CPC obtain permission from DEC to dispose of the water on the surface. Subsequently, Chip Dennerlein contacted you to discuss the appropriate steps to obtain such approval. Scientific testing has confirmed the fresh water quality of the produced water from West fork 1-21 and CPC is proceeding with the permit process. Pursuant to your recommendations, we are submitting both the DEC permit application form and the Coastal Project Questionnaire and Certification Statement. We plan to dispose of the produced water into a small, contained perched pond and seasonal wetland area adjacent to the well site on private property under the control of cpc. The Division of Habitat, Department of fish and Game has reviewed the proposed discharge location and determined that the wetland is not connected via drainage pattern to other water bodies and does not appear in the anadromous fish catalogue. ADF&G has advised CPC that a Fish Habitat Permit is not required for this project. I believe that we have included all pertinent information necessary for review and approval of our permit request by DEC. Should you have any further questions regarding our application, please contact Chip Dennerlein or me at 274-8638. Thank you for your prompt attention to our application. Sincerely, ~~MPANY Kevin A. Brown Vice President CD:080 cc: File 061,300.024 CIRI BUILDING 2525 "C" STREET P.O. BOX 93330 ANCHORAGE, ALASKA 99509-3330 (907) 274-8638 TElECOPIER (907) 279-8836 TELEX 090·26·465 " ," ."- . ,.. STATE OF ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION APPLICATION FOR WASTEWATER DISPOSAL PERMIT In accordance with Alaska Statutes, Title 46, ."Water, Air, and Environmental ConservationN, Chapter 03, Section 46.03.100, and rules and regulations promulgated thereunder, the following application is made: Name of APPucant: PIIoM Number: C.rQ{ PlZoDÙc:ïI00 COW\,PAJ0Y Left:,) 27q-<66~<6 Addreu: SIrMt 2. ç Z, r; é S !l¿f:;Ç ( CItr Ât0Ck!Df!AtÆ Stde ZIp Code Ate:=. qqL?D3 TYPE OF INDUSTRY/OPERAnON: tJA--rù~L- GA~ ûJ6/.,L LOCAnON OF WASTE DISCHARGING FACIU1Y: General:3..'l5 V1t1Lt...G"S fVðRJ1..{ oF S(E«UA.J6-) k.ÐJÄ{ fÐJirJSCLA) ALI1Ç((A UgaI: ~(A)4 fù£ l.f SS::fiðù ÃI '-6~ ~q t.AJ S"M ALA<;f:;.A / LOCAnON OF WASTE DISCHARGING FACIU1Y: Generü - Leg": LOCAnON OF WASTE DISCHARGING POINT{S): o.neraa: UNAVV\£o P£1<Cf.{EP f'OrvD i- W£T£...Ót0D tAg..: 5W 4 tJ£L¡ 56"C1lorV Zl i6fV fZ.<1W 5W1 4Ll6k.-A. WASTE DISCHARGE VOWME: DOMESnC WASTEWATER INDUSTRIAL WASTEWATER COOUNG WATER Mulmum (pllona{day): Dally Average (gaIIoM{clay): RAW WATER SUPPLY: 2.0::0 61lL- ., 000 GoAL Source: ~ ~ßH (JAí€R R<cM GAS tùet.L.." Volume: ~(Jt£) -- 2CfX) G-f'þ NAME OF ReCEMNG .WATERfTYPB OF RECEMNG AREA: cav~((vEÞJ ~WtAU.., p'e-eCflED mt0D >UK'ebUI\JÞED rsy CO!\JíA1UW W~¿..4tVD .f- çeASQf0AL wETtAt'0D 18-0312 (Revised 8/89) e e .-. Page 2 of 3 I. OFR~RIPTlON Qf ~nl JRCFR: Give a detailed description of the sources of aU industrial/domestic wastes within your facility. Include a schematic flow diagram showing the sources of all wastes and their flow pattern. Submit this information with your application as exhibit 1. J. WA!ì.TFWATFR TRF4TMFNT: Describe waste treatment practices used on this discharge with 8 brief narrative ~.e. primary, secondary, cooling, oil/water separator, etc.). Include the disposal method for any sludge generated by the treatment system. Submit this information with your application as Exhibit 2. K. PHARAr;p:RI~C~ nF WA~ FJ OW: Describe in detail the chemical and physical properties of the efftuent to be discharged to State waters ~nctuding but not limited to te~perature. pH, dissolved oxygen, calor, total dissolved solids, suspended solids, BOD.. COD, oils, phenols, metals, chlorinated hydrocarbons, blocid., total hydrocarbons, total aromatic hydrocarbons, alkalinity, etc.) and the flow quantities of all wastewater streams associated with each of these contaminants. Also include a description of sampling and analytic methods used to derive this information. Submit this information with your application as exhibit 3. L PI 4NT OPF=RATlON: Days per Year - Average 36 S Maximum ~c; M. RAW MATJ=RIAI ANO ~HFMICA' ~ U~Fn IN PRn~FR~F~~: Brand Name Chemical, Scientific or Actual Name Quantity Used per Day* Average Maximum f\J! A - tvOtv e A'e ---, e Page 3 of 3 N. PRonUCT PRonUCF'l: Quantity Produced Per Day· . Item Average Maximum I\JA Tù eAt.- GAS 3 VVlWfC+ 5V\.1vr1cf PRODUCt;D ~t<e-;+{ wAlEe '000 6-AL- 2fXX) GAL *Please specify units (f.e. Tons per day, pounds per day, barrels per day, etc.). o. ~F~snNAI VARIATION: Explain any seasonal variation in waste discharge volumes, plant operations, raw materials, and chemicals used in processes and/or production. fJðtJE. P. ~YSTfM pi ~N APPROVAL: "01'=: It .S not rewllred that th, appllcsant submit pfans for - wastewater . system with tht. permit application. HOWEVFR. recelDt and approval at plans." the Department I. reqf.'rerf prlør tft construction. alteration. or opel'ltlon of any wrstewater collection. tre-tment. or disposal system. as provttt.... Ilnrler 18 AA~ 7'. The information given on this application is complete and accurate to the best of my knowledge. rO(q(C;( "DALre. kEVtrv A· ßR0c.0J Printed Name ViCE '(g~S(D61\.Jt J (PC Title .-" CIRI PRODUCTION COMPANY WASTEWATER DISPOSAL PERMIT APPLICATION EXHIBIT 1 e The facility supports a single natural gas well (West Fork 1-21) which is currently in production. The primary product of the facility is natural gas which is produced through a dehydration unit and odorization unit into a natural gas pipeline connected to the well site. A secondary¡roduct of the operation is produced water associated with the gas well. The produce water currently flows into a storage tank on site. Granting of this permit would allow the water to be piped from the storage/settling tank via pipeline to a surfac. discharge location within a small, contained perched pond surrounded by wetland ancJ seasonal wetland areas. While there will be no permanent caretaker facilities, a small office structure will be located on the site. Human wastes generated by use of this facility will be handled by containment and removal or by a separately permited septic system. No wastes of any kind will be co-mingled with the produced fresh water stream which is the subject of this perm it appl icati on. ----e "-. e CIRI PRODUCTION COMPANY WASTEWATER DISPOSAL PERMIT APPLICATION EXHIBIT 2 The produced water, while technically a "wastell resulting from gas well operations, is extremely clean, as documented by the test results included as Exhibit 3 with this permit application. The water does exhibit slight discoloration due to the suspended solids (primarily clay) in the water. The water will be produced directly into a large capacity holding tank where some primary settling of suspended solids will occur. From the holding tank, the water will be routed through an earthen/sand filtration unit to provide clarification of the water and removal of remaining suspended solids. The clarified water will then be piped to a secondary settling basin constructed on site. This basin will have approximately 40,000 gallon capacity and will be lined with an impermeable membrane and bermed. In addition to providing secondary settling the basin will also serve as a source for fresh water if needed for future operations and as a water source for enhanced fire suppression capabilities. As a final stage in the water disposal process, water from the basin will be drawn off and conveyed via pipe or spillway directly to the surface discharge site. Settling of the water will result in very small amounts of inert clay material being produced over a period of time. Periodically, as needed, any accumulated material solids will be removed and disposed of in an approved solid waste disposal facility permitted for the gas well project. A simplified schematic of the system appears below. (PRODUCED WATER SOURCE) - >- HOLDING TANK ~ NATURAL GAS WELL EARTHEN/SAND .. ,,~ J J~ . ~J ~INED SETTLING BASIN I FILTRATION UNIT :~!.~~.f".l) ~." ....~:. t( > ~SURFACE DISPOSAL AREA £J ..... . ~ I '--', CIRI PRODUCTION COMPANY WASTEWATER DISPOSAL PERMIT APPLICATION EXHIBIT 3 - PAGE 1 e Prior to water sampling, the sampling process, including the specific tests required were discussed with the Alaska Department of Environmental Conservation. Water samples were taken directly from the well head into standard water analysis bottles by a registered geologist (Alaska Registration no. AA 183). The bottles were stamped anctt sealed and sent to Analytical Laboratory Service, Inc. for analysis. The projected produced water volume stream will be generally between 1000 gallons and 2000 galfons per day. The water quality test results appear as Exhibit 3, Pages 2 and 3. , . ¡:ROI1 TLlLRBS e lEI.04.1991 e P. 2 .ANALYTICAL LABORATORY SERVICE, INC. 12051 RVERA ROAD. SANTA FE SPRINGS, CA 90670-2289 l'EL.EPHONE (213) 591J..OOS6 FAX (213) 696-1021 LABORATORY ANALYSIS REPORT AROMATIC VOLATILE ORGANICS EP A Method 602 ===================ð~======~ \-======-==-~--==-~=======.----~===- Client Project # : eIRI Production company : West Fork Gas Field Pile Number : 42439 Date Reported : 10/04/91 ===============================-----========================~=-====== Sample ID : CPC-9127001 CPC-9127002 Lab ID · C3353 C2567 Blank · Ma.trix · Water Water · Da.te sampled : 09/27/91 09{27{91 Da.te Reoeived: 10/02/91 10/02{91 Dat.e Analyzed: 10/03/91 10{03/91 10/03/91 PARAMETER~ ~ESU~'l'S DF(T. LIMI'¡' (uq/L) - ppb (ug/L) Benzene ND ND ND 0.5 Toluene ND ND ND 0.5 Chlorobenzene ND ND ND 0.5 Ethylbenzene ND ND ND 0.5 l,3-Dichlorobenzene ND ND ND 0.5 1,4-Dichlorobenzena ND ND ND 0.5 1,2-Dichlorobenzena ND ND ND 0.5 Xylenes, Total ND ND ND 1.5 ND - Not Detected EXHIBIT 3 - PAGE 2 fRO/1 TWLRBS . 10.04.J991 e P. 3 ANALYTICAL LABORATORY SERVICE, INC. 12D51 RIVERA ROAD, SANTA FE SPRINGS, CA 90670·2289 TELEPHONE (213) 096·0066 FAX (213) 000-1021 LABORATORY ANALYSES REPORT ~-=~=------------~~-~----_____~===Þ==~~==D==P"Q=~===~==========_____ Client : Project : Matrix CIRI Production Company West Fork Gas Field File Number : Date Received: Date Analyzed: Date Reported: 42439 10/02/91 10/02-03/91 10/04/91 Water ------_.__==__þ===_==_-==c====~===========a=====~=ø==aD_=_=~__________ Sample ID: Lab ID: CPC-9127001 CÞC-9127002 C3352 C3353 UNIT DETECTION LIMIT METlIOD -_-=~~~øR_a~==c=:g==~=========~=====c===~===_=~~==_~-==____________m= pH 7.50 7.53 EPA 9040 Total Dissolved 2660 2450 mg/L 4.0 APHA 209A Solids Total Suspended 30 10 mg/L 2.0 APHA 209C Solids Chloride !541 510 mg/L 5.0 EPA 325.3 Conductanoe 4080 3770 umhos/em 1.0 APHA 205 -----~=ØKc==~==~~=~==C========~==~C===~====~==DB=m_~=_______________~ ;;2~91F EXHIBIT 3 - PAGE 3 ......EHO...... CIRI PRODUCTION COMPANY W ASTEW A TER DISPOSAL PERMIT APPLICATION 17 IG 15 i4 20 ~ .) r ) ~- I.--r'" . c:-\c~u· PRODJCED ~'{CDISPOSAL AREA ~ . ~£VOO¡( : ...41 WEST FOnK '-21" LAKe ~-'''' EbL ...nQ n ~e- t:) o QAVIfA ¡Alft' 23 ~ $IIItKCN ,StANOI G L~Kt' o . ..- . + ,. \.' EXHIBIT 4 13 )e 24 + / 29 28 27 26 /TO 25 e STEALING {~ r3 HIGHWAY + -1- -1- ~ - 0 .5 I I a.. SCALE IN MILES 3: OJ a: ~ARA /J LAKf: T6N :n . rt 33 34 35 . 36 LOCATION MAP, CIRI PRODUCTION COMPÄNY ·CIRI WEST FORK 1-21~ , . ! .; , 'J . - - - - - - -- e -e. ---~- - . .... . ~ -. .- NQV Ø¡ '91 Ø4'e~PM P,T,; ., .. .. .. , .. .. I ,. . .'111' ......"'..' J ."''''' .._.\J"'''' ,.~. :t..,..""r. . (l)ANAI.Y4'ICAL LABORATORY ¿.~. SERV1CÈ. iN'" ~ -; ,. ~t-. ,zœ11MT'A ACW\ ~ Æ sPl'IJNOi. cA!IOB7O-22n 'l'lUFHClœ (t1~ IØ-OOII F'XII t:!1S ....1~ ';. W01tATORY ANALY8IS REPORT PlUOBlTYPOLLUTANJ'S BPA.~681onOOO p,v~ "'. , .--.-... ........-. . .,. EAt) RI.Jß /II ¡¿.r Cj) _-_..----- 11&.....-................. - - ' '.. \.~__ -~ - ~ 0:.- .- - ,. ....--.. cli.n~ I CZU !'reduction COJ\SPUI)' Cat. 8111pl84 I 10/16/91- PrQjaøt' ~ w..~ Vo~k Ga. r1e14 Date K.Q.1v~1 ~0/22/91 ?il0 ~~~.~~ 4;474 ~A~. Analyz$d¡ ~1/01¥04/91 Ka't:tx I Water Datt Repei"tod r 11/04/91 .-.....--......---......_~_...--=..._._--.--_...._.......- ,. sa.1IIple It) t ; ",-911016-0& Lab %t) I (;) t ,d C350' :Î;'~ : y (t t.C- J øV ~='f) _____c _' _cAfI"æ_,...:a.'=V-· --_..~.... .,,-- ~ ~i..olv·Ø DB'1'ECTXOl{ XiIMI'1' (m;/L) MtTHOP ..-..-------- Antlmøn:.r J\r..nJ.e B8~U.1W11 caö1um ChrOllJ.um C:aþp.:o Lead xercuJ:Y . JU,I;kel Selen;!.WQ $Uvar ~halUua Un", NO ND liD NÞ ND 0.03 0.13 SD wt) 1m Nn ND 0.04 JlD Nt) NO WD liD HI) NU t(D NO X1) ND HD 0.04 0.04 0.02 0.0:) 0,02- 0.03 0.02 0.04 0.01 0.02 0.02 0.015 0.31 0.02 ¡FA 6010 ISlA G010 SPA 6010 B~A 6010 ¡fA 6010 EP~ 6010 BfA 6010 If A '1470 IrA 6010 I1'A 6010 SPA 8010 !fA 6010 IIPA 6010 ND - Not Þetect~ ....._.__.._c=___.....=_...___c_.==--....""_~_..=··G_II.IS.=:: - .-4 - - - $ub1IIi ttod By: : 144 li£' /~- _ ~~da H. ~ ~.':IOCI sI.oð.I.llJ.~ ~~- -- -. ..,- --- - -IJoIMI ~JIOØII ~.- - t-: C<.g;(. ~~NOHi~ ~~~ ::1 ==-=-- ·n:.~~.\;JL~~~· 1--- . -- .. ~'.l- ~:NoaQ;)T -- - - - ..:3:.t ~ l.:" 3"¡NOI1~Ot tr--:'l-- .,c",~~cr:wo.u --- \~~:;Jv7\oor:-83";Ol ~!!>Vdj~ U:;~~~Wij' "'1·\..~~.as..,.a ,..,..,~ XtlJ S.....,.;.".,.".Þ,~#III;#""'*'I'I~"4W.I~i~'N'~"'..,,~I"P~¡,'..ø~lþlf/'>ll""I~~'~I',.,~""".,..,.",IN";",~,."".,µ",,,..¿ e L~\LABORATOP< ~ SERVICE. INC. e 12051 RIVERA'ROAD, SANTA FE SPRINGS, ( 10-2289 TELEPHONE (213) 698-0086 FAX (213) 696-1021 ¡(e(fl'v~~ /Je/r:øJ..- LABORATORY ANALYSES REPORT /YSI/~/ -========~-=====================================-=~========~:======= Client: Project Matrix : CIRI Production Company West Fork Gas Field File Number : Date Received: Date Analyzed: Date Reported: 42474 10/22/91 10/22-30/91 10/30/91 Water _========__========:================z===ce===============~============ Sample ID: Lab ID: ~~ WF-911016-04 C3503 V.d'~ P/Á WF-911016-06 C3505 DETECTION UNIT LIMIT METHOD --====-==============-=-=---=--===========================-===-===þ=== pH 9.80 4.85 EPA 9040 Total Dissolved 2300 50 mq/L 4.0 APHA 209A Solids Chloride e 46.3 "9/L 5.0 SPA 325.3 --====~=_=__=e===============_=.=_==~=======_====s__========__a======= Sample ID: Lab ID: WF-911016-05 ~I/~~ UNIT DETECTION LIMIT METHOD --===-==========~c~=====__s=====-__==c=============c=.====_=========== Total Dissolved Solids 2380 mq/L 4.0 APHA 209A Ammonia ND mq/L 0.1 EPA 350.2 ~==----=======_=_=_=_S_D=======~========_==_=========a===:~==_=_==_=_= ND - Not Detected su~~ted ~yt (7, ~_.rtu " He da M. Espiritu ¿r?- 3 -------------------------------------------------------------------- '" ·r Coastal Projec.~uestionaire and Cer -!ation Statement 1 Please answer an questions. To avoid a delay in processing, please can the agency iI you answer "yes" to any of the questions related to that dep8rtment. Include maps or plan drawings with your packet. An w~ IfIIIStiDnPIIIÌm mIlY b~ rtturrwl and will delay tM rmeœ of your padcet. · APPUCANT INFORMATION 1. Cr RL f'RDDOCI1DN caWtPA~Y NJIM 01 AppIaB& :2...525 C 5~ET AcSdNa ArJŒO~AG-€ ALASM QQ5ó3 Clt)' St.- ZIp Cod. (CfC>l) Z14 - <¡G/!JtØ .,.,... f'haN 2.f<£Vt0 8f(OlJJI'-J CcmI8a P_ 7... S 2. S C STREET ~ AlJCJtD~A~~ ALA5f<A q~qb3 a~ sea. ZIp eøca. (qD7") Z7l.( - <66"!:;<¡ èÃó75 271 - <8<i36 TeIMøpy N..... · PROJECT INFORMATION 1. Provide a brief description of your entire pmject and ALLassodated fa(Ílites (caretakerfadllties, waste disposalsite5,etc.) WE:S, Fo~k (-;l..l IJATùRAl- ~ WELl-) LLXAífD Où 6-~All£L DRILL PAD w¡ A~S-DC(A.'"(E:D F74.c.lLlTrPS (I\JC,lDE;f0T 1b Ft2D~71DrvJ I~, !?EHF1X{l6tV UVlT) goCC-ER ,ðí?DerZA1ið0 UJÙrí +-I/RllL cumtJç..5 V(S"fè1iAL ¡~g date for pmject: DEe... 1<1 '1 D Ending date for project: ~ 2CC>1 · PROJECT LOCATION 1. Please give location of project (inclu.d~ nt:IZrtst community or identifÜlb16 body of land or rJ/dUr). 375 W111.£S tJðlrot Dr: $íe.t2LJf0G- !®vA.l PE/Vlf\);UU ALASkA ) ) ToWNhip 6 N RaIIp "f vJ Mertcliatl ç£iJJ Section;1..1 AUquot Puts'5W" ~1þscs Map 2. The project is on: 0 State land 0 Federal land ~Private land 0 Munidpalland 3. The project is located in which region (see attached map): 0 Northern ~50uthcentral 0 Southeast 1. Do you currently have any State or federal approvals for this project? Note: Apprrmø1 means permit or any other fonn of authorization. If "yes." please list below. APPROVAL Twr A!'PROV.u It ExPrRA rrON 0 A 'Œ A06-CL Dl2lLW~ PEI<M Cí f..J(): qo - (43 COtJ111J6-ervcy PL-Ar-J â1£C) . FEDERAL APPROVALS 1. WUl you be placing structures or fills In any of the following: tidal (ocean) waters, streams, lakes or wetlands-? ·'1 you are not cutain whetheryourpropo~d prOTe,:t is in a wetúmå. contact the U.S. Corps of E1Iginærs, RtguWory Branch at (907) 753·2720 for II WftÚJnds tUœrmination (outside 1M .A"ncho'a~ area, call toll frtt Z·800-478-2712.J If yes, have you applied for or do you intend to apply for a U.S. A~y Corps of Engineers (COE) permit? If "yes," give date of submittal: to( A -1- · CURRENT APPROVALS [Ø No o STATE REvIEW [D' N!A. SAtJ. ~ ( IQ'13> J Yes o [if Yes o No o :..::. ~YC T\IU .pp~ ¡;gr.. ur "A"'~ &Ao--.& LV -1"t"&.1. ....&.. - "'..... ~&'~~ - - Agenc:yNatiøna1Pol1utfD'~EUminationSystem<NPDP"-'~? (Note: For information regarding th... ~,eed for a NPDES permit.. amta..&. E. . at (907) 271-5083.) Please indfœte at right and give date of submittal: 3. Have you appUld far, or cia you intend to apply for, permits from any other federal agency? If "ye~ p'.....1ist below. AcrNc:t ArPROVAL TwI DADSIJIIMmID (ORINI'ENDTO SUIMIf) . DEPARTMENT OP NATURAL RESOURCES APPROVALS 1. Is the propoaed project on State-owned land or wm you need to cross State 1aIIds for aa:essl Nøtc bral4ilitm tlJ St.4&-...... _.ß..",.,... tl. s'*.. jr&rist&túmflfllr".",."".,..ørrlbulrylâ". .... fiM of""".""', lda. - - hip tiå liM SftØØIIIrIi for t...... ftIIåI. 2. Is any portion of your project pJaced below the ordhwy high water 1irIe of a streaD1. river, lake or mean high water line of a saltwater body? 3. Will you be dredging? If yes, location of dredging is: ToWlllldp Ran.. M...... !_ .. - Location of disposal site for dredged materials (ÛJcribøJ: ToWMltip Ran.. M-dIQ·. !'~tI: 4. Will you be ðJBng with rock, sand, or gravel? If "yes," éIIIICJ1Iftt! Location of source: Township Rafts- M-t"'·. ~._ '__11 Location of fill site: ToWftlblp RillS- M-ri"'··. SeI:døP s. Do you plan to use any of the following State-owned resources: . Timber Will you be harvesting timber from 10 or more acres? If "yes," amount: Location of source: Township . Other materials? Rlllge Merittb!, Secl1ol1 U "yes," what material? (peat. bwJding.tone. silt. 0V8'burden. etc.) Location of source: Township Range Merttfl,.n SecttOIl 6. Are you planning to use any fresh water? U "ye," amount (gallons per day): 7. Will you be building or altering a dam? 8. Do you plan to drill a geothermal well? Source: 9. Will you be exploring for or extracting coal? 10. Will you be exploring for or extracting minerals on State-owned land? 11. Will you be exploring for or extracting oil and gas on State-owned land? -2- õf2( õ~ oø oßt' olif o cst o~ og' o~ o[s( Og O~ Og Og/ ·Ii. Will you be investigaän~emoving historù:ai or aråw!ologic.¡f' . Les Oft State- owned land? 13. Will the project be located in a unit of the AJaska State Park System? If you answencI-No'" to ALL questions in this sectfOIlr you do not need m approval from the þa ....þ D"'''buent of Natural Resources (DNR). Continue to next section. If you answend ""tW' to ANY questiOftl in tJUssection, contact DNR to identify and obtain neces..,. appUcatfon formL Based on your dJscu.ssion with DNIt please complete the following: AwIDv AI.. T'tPE NEEDED DATE stJBMm'ED (OR INTEND TO SUBMIT) Have you paid the ftUng fees required for the DNR permits? If you are not applying for DNR permits, indicate reason below: o a. (DNR CDntIzct) to1å me on (thúe) that no DNR approvals or permits were required on this project. o b. Other: . DEPARTMENT OF FISH &: GAME APPROVALS õrø O~ Yes No o 0 N/A. @/õ 1. Will you be worldng in, or pJaång anything in, a stream, river, or lake? (This includes work in numing water or on ic:e, within the active flood plain, on islands, the face of the banks, or the stream tideJands down to mean low tide.) Name 01 stn!lln orriwr: Name of lake: Uf0tlYYlW PÒt0D/ WEiLA!\)D Will you be doing any of the following: a) Building a dam, river training structure or fnstream impoundment? b) Using the water? c) DfvertiDg or altering the natural channel stream? d) Blocking or damming the stream (temporarily or permanently)? e) Changing the water flow or the water channel? f) Pumping water out of the stream or lake? g> IntrDducmg5Üt, gr.avel, rode, petroleum products, debris, chemicals or wastes of any type into the water? (, peODUCEr:;J ~e5H. WA.TEr¿) h) Using the stream as a road (even when frozen), or ao5sing the stream with tracked or wheeled vehicles, log-dragging or excavation equipment (backhoes, bulldozers, etc.)? .-' i) Altering or stabilizing the banks? j) Mining or digging in the beds or banks? k) Using explosives? I) Building a bridge (including an ice bridge>? -3- Yes ~ 0 0 ~ 0 rg/ 0 ~ 0 ~ O¡:g/ ~D 0 0 0 cg/ 0 ~ 0 ~ 0 n) ----07. -e- CoDIb..Lb~a weir· .e ...- 0) Othe.rin-dti1lMft strw:ture not rr..mtJo&.œ above? 2. Is your pmjeà Ior-~ in a designated State Came Refuge, CritfaLl Habitat Area.. or State Game ~'.'Y? 3. Does your project include the construction and operation of a sahnon hatchery? 4. Does your project affect, or is it related. to, a previously pemùtted salmon hatchery? 5. Does your project include the construction of an aquatic farm? If yøa aaawerecI"No" to ALL questions in thissectt_ JU1Ido natneed aa.f)pl'..y.1 .frmD.th, Alaska DeputlDent of FISh and Came (DFC>. Coatlmle to next sectfØIL If YØII aaawerecI "Yeti' to AN\' questions under 1 - Z, amtac:t the .eølaaaI DFC Habitat DIYisioD Office for ÜIfDrIII.tfon aad appJlnffCJft 1nIooI~ If you aaawerecI "Yell' to questlans3, 4 or 5, contacttbe DFG at the F.B.E.D. dlviaiDII headqaøtea _ iDionaatIan and application fanu. Based on your dJscussion with DFC, please complete the foDowing: AwlDvAl. TmENEEDID DATl5UIMInID(oalNtlND'laSUlMll') ..- --.,¡ O~ DG?" DGY D~ O~ o [if u y~ ~ not applying for permits, indicate reason below: [Sf a. WAyrvŒ ÞOu:::z..ÂL (DFGccmtact) told me on to(<6{Gï { (date} that no D~C approval or permits were required on this project. o b. Other: . DEPARTMENT OF ENVIRONMENTAL CONSERVATION APPROVALS ~ DNa 1. Will a discharge of wastewater from industrial or commen:ial operations occur? ~ (See #2 in "Federøl ApprWlÚS" section.) 2. Do you intend to construct, install or modify any part of a wastewater' <sewage or greywater) disposal system? 3. If llyes," will the discharge be SOO gpd or greater? 4. Do you expect to request a mixing zone (or your proposed project? tlyourTl1tlltl:rl1tlldisdfllrgewill eztztdAlas/œ 'tk'ater qwzlity sta7UÜmis. you ".,.,ny fora mixing zone. If so. pluse œnttu:t DEC to dist:rlSl infr1rtrullion relfuired under i8 ,"\..\C :-0.032. 5. Will the project result in dredging or disposal fill in wetlands or placement of a structure in waterways? (Note: Your appliClltiDn for this Ilct:::ity to th4 Carps of Enginørs rui1l also $41'Was yaur applialtilm lø DECJ 6. Will your project produce any domestic or mdustrial solid waste? 7. Will your project require the application of oil or pesticides to the surface ot the land? -4- olif go ocg/ D~ g"C D~ e ,grtaúrtlumfiw tØJIS ," 8. a. DoYOUhave.laciIit)~wülgenerate~~fnm\praœ per hour of materiall b. Do you haw aneor more units of fuel burning equipment with a heat input rating of 50 milliDn Bm ,., 1IIIIIr or""".1 c. Do you haveanindrleratol'with a rated capacity of l,/JOOpormds ptrhaurormore, or do you incinerate sludge' d. Do you have any of the following processes: asphalt plant, petroleum retineJy, coal preparation facility, or portland cement plantl e. Does your fac:iJity meet any of the following cnteria: 1. Use the fOUOWÙ1gequipment: di4Hl electric gmmmng tqfIipmÐú Ctotalcapadtyot1750 .. Iålor.DIJtf);gøs firttl boilers (tow heat input raâng of ZOO millüm 8tu perhDur);ail fitrtl bøilm (total heatmput ratfngof 65 million 8tu ptr /unu); amrbustitm bubbrll (total rated power output 018000 Hp)l 2. Bum mare than the foUowingperyearfn stationary equipment: 1.oooJJOO gøl1D"'affud oil; 900 milUtm cubic ¡- of ntlturøl gas; or 35.000 tørø of œøn f. II you haveanswered"'yes- to any of the above questions, have you installed, repIaœd 01' mocWïed any fuel burning or processing equipment since 19m 1\1/ A 9. wm you be altering a public water system? 10. Win yo1Ø'project reqaireoHshore drilling or vessel transport of oil or othe!rpetroleum products as carso, or include onshore facilities with an effective stomp capacity of greater than 10,000 barrels of such products? 11. wm you be subdividing lands into two or more lots (parcels)? If you auwerec1 NO to ALL questions in this section, you do Dot lleed a permit or .ppranl lrom the Alaska Department of Environmental COnserYatiOll (DEO. Please continue to the Certification Stateua&l1t. If you answered YES mANY of these questioDS (see'5 note), contact the DEC RegionalOffiee for information and appUcatioll forms. Based on your discussion with DEC, please complete the {ollowing: APPROVAL T'tPE NEEDED WAS15"WAíeK DISPOSAL PE2Mlí DATESUBMm'ED (OR INTEND TO SUBMIT) rð{ct(Cfl If you are not applying for pennits, indicate reason below: o a. (DEC contact) told me on (date) that no DEC approval or permits were required on this project. o b. Other: -5- DB og' D~ oEif og' O~ 00 O~ 09 o~ o 0 o 0 e .. ;.-..., :r . e (' Cm:tification SÞteftlftt The1nformadon·::AIë, - . henm is trueaJld complete to the bestofmylcnowledge.lcertlfythat the proposed activity comp1f8 ~aad wiD .. cønducted in a maIIIIII' CO..wu.4 With, the AJasIca Coastal Management l'mgrçL /ò{q 'q { Date Note ThII....UI('.....l\AIf.. - v "tilarequinmentforfecUnJ pennitappÜCIntLFed.ü-p-'-amducdnIUl.cdvitythat wiIlcUncdy.......C'OIIIÛZDM..mquired IØ submit a c.r.a1"O"elrJ'. 'T..... ..J".'lðJ\ pIIr t5a:R930.SubputC. . To c:DIIIplle.JOIII'pacbt" p..... attach you State pamitappll('StlOftl iIIICI cop_ ofyalll' &deal p~ appll....... to tIdI qa.tto-.n. ·::"',...':::iilo: ~-=~:: . . ."S.~r,. - ã=-~ -- .. ........-~. ..,... .. ,. .. , ~~ , -'. 1cfW ~ _eo ... --- .. + ~~.:", ~ /» ~v..: - - .....,._ oJ ..~. . .' "rW....... ..-. ~ ....._..~ ·.iIVø ..:1 ....J....'ii ..J.:.~.:~,., . .... 6190 NI'ERII CXU1JL ZONE BOtNMES OF ALASKA ... 411 ... AID ..... &.WI ... IIaIICT 1D ......... LGCtL ..... .... \ \ I ; \ I --- ,...-----.-- -- - ....---- -- ~O' ~~~1i . . . 1 ~~I;:- ~.. í' r . ' . . ~ I I I SR ENG I SR ENG I \Et~fGASSTI ~ËNG A~~ 88 SEOl I 73EOL ASST\ ì .~r-¡;;;ï-AS§fI .1...V~ --.-!__ STÄT TECH L_ STAT TEC\-Í!,_ : d:~¡r~ ____.". . vOMM c~OMM COMM RES ENG . .. ~ ,. v~~\Õo Sì4¡-",<5' ~. ft ~ ~.~ o '" "to '" ~ ~ '}l:.¡¿ PR01<'C,'\~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue Seattle, Washington 98101 Reply to Attn of: -JOt 1 6 1993 WD-133 David Johnston, Chairman Alaska oil and Gas Conservation commission 3001 Porcupine Drive Anchorage, Alaska 99501-3192 Re: Report of FY93 Mid-Year Review, Class II Injection Well Program Dear Mr. Johnston: Thank you for your timely and helpful comments upon the draft report of our recent FY93 mid-year review of the Underground Injection Control (UIC) Class II injection well program. We have incorporated most of your comments verbatim into the enclosed final report. Overall, we are pleased with the,AOGCC's operation of the Class II injection well program, and have noted many areas of strength. The only area which we identified for improvement is the continued need for progress on the bonding issue. Thanks again for the time which you, Russ Douglass, and your staff spent with us at the mid-year review. We found it both informative and interesting. If you have questions concerning the mid-year report, please contact our Ground Water section Chief, Roger Mochnick, at (206) 553-1216. Sincerely, r~~~s Ground Water and Dr~ Water Branch Enclosure RE(!EIVED JUL 1 9 1993 Alaska Oil & Gas Cons. commiSO'Printed on Recycled Paper Anchorage .. tit . ., , . " " FY 1993 KID-YEAR REVIEW OF THE ALASKA OIL AND GAS CONSERVATION COMMISSION'S UNDERGROUND INJECTION CONTROL PROGRAM INTRODUCTION The FY 1993 mid-year review of the Alaska oil and Gas Conservation Commission (AOGCC) Underground Injection Control (UIC) Program for Class II wells was held in Anchorage, Alaska on March 22-23, 1993. Those in attendance at various times were: AOGCC David Johnston, Chairman Russ Douglass, Commissioner Blair Wondzell, Senior Petroleum Engineer Bob Crandall, Senior Petroleum Geologist Jack Hartz, Petroleum Reservoir Engineer Environmental Protection Agency (EPA) Kerrie Schurr, Environmental Engineer Roger Mochnick, Chief, Ground Water section Dan Robison, Chief, Field Operations Section, Alaska operations Office The review was carried out in three parts. On the morning of March 22, EPA met with Blair Wondzell to discuss technical aspects of the program and reporting requirements. In the afternoon, EPA met with David Johnston and Russ Douglass to discuss policy issues. Finally, Kerrie Schurr and Roger' Mochnick returned on the afternoon of the 23rd for a technical presentation by Bob Crandall, Jack Hartz, and Russ Douglass on the confinement zone study. PROGRAM OVERVIEW organization: The AOGCC is headed up by three commissioners, who serve 6-year terms. Their terms are staggered every 2 years, and there are no term limits. Commissioners are appointed by the Governor and confirmed by the Legislature. One commissioner must be a geologist and another a registered engineer. There are no professional requirements for the third position, which was vacant at the time of the review. As of June 1, 1993, this position was filled by Tuckerman A. Babcock. One of the commissioners also serves as the chairman of the AOGCC. The chairman serves for four years, and may not serve consecutive terms. The AOGCC has a staff of 22 people for fiscal year 1993, including five inspectors (up from three last year). An organization chart was provided during the review. RE~EIVED JUL 1 9 1993 Alaska Oil & G as Cons. Commission Anchoraop. '. ,~' .. . ! ~ , . ' - 2 - Responsibilities: The AOGCC has a variety of other responsibilities related to oil and gas industry operations on federal, state, and private lands. They provide permits for all drilling operations, except those on Indian lands (Metlakatla tribe) or offshore in federal outer continental Shelf (OCS) areas. The AOGCC also administers the UIC Class II permit program. They do not, however, have responsibility for Class II injection wells on Indian lands. The AOGCC also reviews drilling proposals for compliance with appropriate statutes, regulations and conservation orders. These include: diverter systems; blowout preventer systems; mechanical integrity tests; safety valve tests on production wells; well bore plugging (deep and surface); location clearance (when wells are plugged and abandoned); and metering. Their metering authority ends at Pump station No. 1 on the Trans-Alaska Pipeline (Prudhoe Bay field), or at the first custody/lease point (if the oil reaches that sooner for a given field). They now have five inspectors, who work stints of 7 days at a time (12 hrs/day). The schedules overlap, such that the only gaps are on Tuesdays from about 8 am to 4 pm. Inspections may occur any time of day or night, depending on when activity to be inspected is scheduled to occur. UIC Wells and Reporting: At the time of the mid-year review, there were approximately 688 Class II injection wells. The numbers fluctuate due to the conversion of production wells to injection wells. The wells are not counted as injection wells until the injection equipment is actually installed and reported to the commission. Most of the injection wells are on the North Slope. Most have either no underground source of drinking water (USDW) nearby, or the aquifer is exempt. In the Cook Inlet area, the aquifers are usually exempt. The potential for contamination of drinking water is not large in any case, given the three layers of protection in well construction (tubing & packer unit, production string, and surface casing). On the North Slope, the wells are relatively new and have good tubulars. Thus, leaks are relatively rare. Leaks are more common in the older Cook Inlet wells. The major operators have been cooperative and voluntarily report UIC failures. If the well casing is intact, the AOGCC will usually allow the company to defer repairs until the summer, when work is easier. Increased monitoring is required in the meanwhile. The AOGCC witnesses about 50-60% of all the mechanical integrity tests (MITs), not just the 25% which is required. They also require tests once every four years, which is more frequent than the national requirement. The companies usually do about " .# ,. . ' -- . '. - 3 - 1.5 times more tests than are required. The number of tests witnessed by the AOGCC in a year includes about 25% of the existing wells, plus all new wells (20 to 50) and the majority of work overs that affect the mechanical integrity of injection wells. Most tests occur in the spring, summer, and fall, with a few in the winter. The AOGCC does not rely on fines to bring companies into compliance. Rather, the agency uses its ability to withhold approval for all new wells and repair work as leverage in getting problems addressed. The AOGCC counts the cost of repairing a well ($700,000 - $1 million) as the cost of compliance for reporting purposes. This approach works well since they deal primarily with only six or eight large companies who are generally both knowledgeable and cooperative. Budget: The AOGCC's budget outlook is good. They feel that this is helped by their responsibility for office and field verification of oil and gas industry activities, which is seen by others (especially the Legislature) as important. The EPA grant pays only for salaries (no overhead or travel, etc.). The EPA dollars go to the general fund and are allocated to the AOGCC. The AOGCC's remaining $1.4 million comes from the state general fund. The Commissioners discussed the oil and gas conservation tax, which dates to the 1950's and was originally a dedicated fund. It was repealed in the 1970's, but brought back 2 years later. However, the dedicated nature of the fund was lost in the process. They would like to get the fund re-dedicated to their agency to avoid future budget problems in lean years. This tax brings in $2.3 million, which would cover their current budget of $1.8 million, with some left over for studies and other purposes. There may be some action on re-dedication of the tax fund in the Legislature this year. The commissioners mentioned that a letter from EPA supporting this concept might be helpful. ISSUES DISCUSSED EPA-AOGCC Working Relationship: The AOGCC was satisfied with the Memorandum of Agreement (MOA) and Compliance Assurance Agreement (CAA) with EPA, and they were not aware of the need for any changes to these documents. EPA will check with Harold Scott regarding the need for an update to the CAA which was noted in last year's report. The AOGCC has not experienced any problems with the current system for workplan negotiations. Bonding Issue: They are making progress toward a better system of ensuring that sufficient funds are available to pay for plugging and abandonment of wells in cases where an operator '. ..... -- -- ,I - 4 - walks away from its responsibilities. They have solicited comments (which were due January 15) from their mailing list and all operators in an effort to determine a good system. They are still evaluating the comments. This has taken longer than expected since the AOGCC is minus one commissioner. Bob Crandall will take the lead on this issue after the confining zone study is done. While the simplest system is to raise the bonding amount, this is politically sensitive since it is tough for small operators. Another possibility is to have a tiered system with different bond amounts, depending on the number of wells an operator has. Yet another is to have a state plugging and abandonment fund, such as some states in the Lower 48 have. Bonds would be used only until the fund reached a certain size. The likelihood of needing to use such a fund would be high in the Lower 48, but very small in Alaska (less than 1% of the cases) . Naturally-Occurring Radioactive Materials (NORM): These occur in the scale which forms in production wells. It is cleaned out mechanically, and then ground up and re-injected with the fluids. It is regulated the same as any other Class II fluid. The AOGCC is working with the Alaska Department of Environmental Conservation (ADEC) on worker safety and transportation issues relating to NORM wastes. ADEC is considering a general permit or similar mechanism to deal with these wastes now, and the development of regulations later. The AOGCC will deal only with injection of the wastes. Confining Zone study: The AOGCC's computer system is now in full operation. They wanted to do this study as a learning tool for themselves, as well as a way to show EPA the capabilities of their system. The study looked at onshore disposal in the Cook Inlet area, where there is a potential concern for cross- formation migration of wastes from the injection zone to drinking water aquifers. They looked only at disposal wells, since enhanced oil recovery wells are much deeper and monitored in a different way. The study looked at what amounts of fluid the formations have taken, whether the fluids are being confined or not, and what shape the confining zones are in. A draft report has been prepared, and will be finalized by the end of FY93. A copy of the draft report was given to EPA at the mid-year meeting. (Note: AOGCC has not met the deadlines for the study as outlined in the grant workplan. However, they were surprised when EPA originally included this in the workplan since it was something that the AOGCC had voluntarily offered to do.) Class I Primacy: One of the issues discussed with the Commissioners was whether it would be possible for the AOGCC to take on primacy for Class I wells. (They were definitely not , -- . J - 5 - interested in primacy for Class V wells after hearing a brief description of the types of wastes and their disposal mechanisms.) The Commissioners feel that their agency has the expertise to work with operators on getting deeper and better- constructed Class I wells. They can do MITs, hold hearings, administer permits, etc. Given the small number of Class I wells currently, this would not be a large additional workload. In addition, the AOGCC could probably process applications faster than EPA has been able to in the past, which might encourage more operators to apply for permits. More Class I wells for waste disposal would fit with the general agreement by both industry and environmental groups that underground injection is the preferred way to solve many waste disposal problems of the oil and gas industry. When EPA mentioned that it has a contractor to help with an upcoming Class I application, the AOGCC asked whether EPA could direct funds toward AOGCC for Class I work, rather than to a contractor. It seemed unlikely, but EPA said it would check. EPA said that HQ has a very strong preference for states to take primacy for all wells, or for Class II only, but not an odd combination such as Class I and Class II. Russ Douglass said that he had spoken with Francoise Brassier and others from HQ at the Ground Water Protection Council meeting, and that despite their current feelings, Class I was historically allowed to be separate. EPA said that it would pursue this further with HQ. EPA also said that there is some question as to whether AOGCC or ADEC should have primacy, since ADEC is the lead on all other environmental programs. EPA has been encouraging ADEC to consider primacy for the rest of UIC, but they have not shown a lot of interest so far. If the HQ discussions are unfruitful, the AOGCC may wish to encourage ADEC to take on primacy of the rest of UIC (other than Class II), then have an agreement with ADEC to run the Class I portion. Class II Regulation Revisions: EPA mentioned that HQ is working on revisions to the Class II regulations. Some of the changes mentioned would not affect the AOGCC, since they already have more stringent requirements than does EPA. In general, they have no problem with new requirements if EPA can explain why they are needed. The AOGCC needs this information to sell the need for changes to the Legislature. Class I ARCO and BP Issues: EPA gave AOGCC a brief update on the status of ARCO's requested permit modifications, and BP's pending application. Comprehensive State Groundwater Protection Proqram (CSGWPP): EPA discussed its approach in working with states to establish Comprehensive State Groundwater Protection Programs. In Alaska, J . . . - 6 - ADEC will be the lead agency on this effort. The AOGCC expressed interest in working with ADEC and other agencies as needed to develop a CSGWPP for Alaska. EPA also pointed out that CSGWPP would be a vehicle for the state to achieve primacy on all programs, including UIC. Wastewater Disposal Issue, West Fork: The question of whether this well should be classified as a Class II or a Class V injection well was discussed. The AOGCC initially told the operator that since the produced fluid is basically fresh water, disposal in the shallow subsurface might be allowed by ADEC. ADEC approved emplacement in the shallow subsurface via a leach field, and alerted the operator that this would be considered a rule-authorized Class V injection well by EPA. However, EPA told the operator that it was considered a Class II injection well according to the federal UIC regulations, which define Class II injection wells solely upon the basis of fluid origin. The AOGCC would prefer to see EPA focus upon well construction rather than on the type of fluid emplaced in the subsurface. EPA pointed out that the current regulations would make this difficult, but promised to look into the matter further. EPA's current regulations place AOGCC in the unusual position of having a Class II injection well in their inventory (solely on the basis of fluid origin) whose construction is like that of a Class V injection well. Because of its atypical construction, state and federal UIC requirements for Class II injection wells cannot be sensibly applied. De Minimis Disposal: The commissioners said that one of their concerns is tqe way in which operators must dispose of certain de minimis wastes because of the language in the UIC regulations. For example, the rinsate from empty drums of acid cannot be injected under a waste disposal permit since it never went downhole, yet the undiluted acid may be injected in the same well as part of a planned workover. PROGRAM STRENGTHS The review found several significant program strengths as follows: The AOGCC commissioners and staff bring considerable expertise and experience to the job of running the Class II program. The staff now includes five field inspectors, up from three last year. No problems are anticipated with the funding level provided for in the state budget. The AOGCC is dedicated to securing legislative support for making all funds collected from the state's oil and Gas Conservation Tax available for commission use. ~ . ç . . .' _... " I t " '. ... ~ . . ~ - 7 - The AOGCC routinely exceeds mandated program requirements for the number and frequency of mechanical integrity tests (MIT) witnessed and inspections performed. The agency also meets all regular reporting requirements, including timely submittal of quarterly reports. Their computer system is now in full operation. This has enabled them to undertake the confinement zone study, which should prove useful in evaluating past disposal practices in the Cook Inlet area. The AOGCC is working with ADEC to address the disposal of naturally-occurring radioactive materials (NORM) wastes. SUGGESTED PROGRAM IMPROVEMENT The review indicated one area where additional progress is needed: Bondinq (Financial Assurance) Issue: The AOGCC has made some progress toward improving upon its current system of ensuring that adequate financial resources are available to properly plug and abandon Class II injection wells. However, progress has been slower than the deadlines in the workplan, due in part to the vacancy in the third Commissioner position. EPA encourages the AOGCC to continue making progress as quickly as possible, to ensure that this issue is resolved in the near future. e - David W. Johnston, Ch¡¡irman Alaska Oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501-3192 ICOMM ~ I !COMM 1 i i'~:OMM LI b'1ES ENG :..\ : SR ENG ¡' :-SR ENG I ¡ Et-jGÄSS"n- i"EÌ'!G ASST I I "I~ {;¡¡::ülT-¡ CIRI PRODUCTION~~~_.__ . :"'EOL ASST; \ STAT TECH I . r~A.:: TEC'r:-- ;~\LE . ---.'.. March 10, 1993 Subject: Wastewater Disposal, West Fork Cas Field ADEC Permit No. 9123-D8012 Dear Chairman Johnston: On February 5, 1993 CIRI Production Comp;Hl}' ((pc¡ WJS issued th~ ,1bove referenced permit by the Alaska Department of EnvironmentJI Cunserv.ltiol1 (ADECJ for subsurfJce disposal of produced water from natural gas wells at the West Fork gas fi~ld. IssuJnc~ of the permit WJS the result of a rigorous permitting process spanning ne;¡rly two ye¡¡rs. A copy tJf the p~rl11it is illt¡¡ched ¡'or )'UUr review. As you will note, upon issllance of the permit. CPC WJS ,1dvised to submit documentation regarding the wastewater disposal filcílity [0 the U.S. Environmenl¡¡1 Protection Agency tEPM as a Class V injection well to be placed on the Er'r\ national in \'l:'n tory. ep( promptly complied. Last week, however, CPC was verbally informed by Mr. )(II1,1IhJI1 W;liarns (EPA, Sr:attle) that EPA h;¡d miswkenly advised ADEC of the facility's Class V s[,¡lvls. epc WJS tokl th.1\. llpun reflection, EPA considers the West Fork dr¡¡in field tu be a CI.1SS " injeC'tio:l well .111(/, .1S such, tlw 1.1Cility should be approved by AOGCC. Mr. Williams also ilclvis'~cI (1'( :11;1( !'!:: L"t.¡IJLKWC! ;'..11'. BI.1i,- W(J!l7.~dl reg;¡,-ding lhis matter. while the West Fork w;¡stewilter elispos.!i lilL:ility 11\.1:, lIr 1[1,1)' not be ol Cldss " injection well by virtue of its h.;¡ndling of tr,"at,,,d pr(JduCt:d w.Il<.'( J'fJlH .1 g;',s \\l;lI.. the 1lll'.lI"1S or tilspus,¡1 b not one which would normally be regul;\led b): AOCCC. Given the n:Hure of the oµer;¡tion, permitting and regulation by ADEC seems Inost Jpp(()pri.m~. HO"-(!\'N, if tht: f;lCiiity is dl,termil1ed to be a Class II injection well, epc is concerned about the sl.1tuS of ¡hi:: bcility under 20 AAC 25.2.'>2. EPA agrees the real issue is one of regul¡¡tory conrusion Jnd pJperwork, rathee than substantive environmental concern, <1nd no une hils sugge"ted epc undergo ,lnother permit process. Moreover, it is (PC's position that, following ne.1r1y two yc.lrs 01,1 rigorous permitting proc:ess, (PC is conducting wastewater disposal op~r<1tions ;\1 tht, 'Nest Fork C.1S Fi<:-leI in .-!((ord.1nce with applicable law pursuant to a permit properl)' issued by AD[;C. I'Jo\</(:v(;',-, epc is willing to t;¡ke wllJtever steps may be reasof1aoiy n~ce5sar>' [0 c):,siSi th~ \'~H;OLIS ~t~Ht.: ;"ii,: r"C'1.:k·:'..i1 ~~t;t:n~:¡(:~ ::-1 c!~~)r!ng up the present situation. If you have Jny questions, ple.lst' c.ont,¡( :\-Ir. Chip Dl'nnerlein Jt 2ï4-R63H, Sincerely, ClRI PRODUCTION COi'vlPANY REEEIVED Kevin A. Brown Vice President MAR 1 6 1993 . f' A!aska Oil &.Gas Cons. CommlsS\O Anchorage CIRI BUILDING 2525 "C" STREET P_O. BOX 93330 ANCHORAGE. ALASKA 99509·3330 (907) 274-8638 TELECOPIER (907) 279·6836 TELEX 09Q.26-465 ,.1 '.. . . CIRI PRODUCTION COMPANY March 9, 1993 Mr. Svend Brandt-Erichsen, Regional Administrator Alaska Department of Environmental Conservation South-central Regional Office 3601 C Street, Suite 1334 Anchorage, Alaska 99503 Subject: Wastewater Disposal Permit No. 9123-08012 West Fork Gas Field Dear Mr. Brandt-Erichsen, The above referenced permit was issued to ClRI Production Company (CPC) by the Alaska Department of Environmental Protection (ADEC) on February 5, 1993. Your cover letter which accompanied the permit advised CPC that the wastewater disposal facility is considered a Class V injection well by the U. S. Environmental Protection Agency (EPA) and must be placed on the EPA inventory. CPC forwarded the appropriate inventory form to the EPA regional office in Seattle, together with certain additional information which EPA requested regarding the facility. Last week, Mr. Jonathan Williams (EPA, Region 10) contacted CPC by phone to advise CPC that EPA had incorrectly determined the West Fork facility to be a Class V injection well. CPC was informed that, upon reflection, EPA has determined the West Fork facility to be a Class II injection well and, as such, the facility requires a permit from the Alaska Oil and Gas Association (AOGCC). In addition, EPA contacted AOGCC and forwarded the information previously sent to EPA by cpe. Upon receiving this information, CPC immediately contacted AOGCC to discuss the matter. In the opinion of Mr. Blair Wonzell, while the West Fork faciiity may be a Class Ii injection well by virtue of its handling of water produced from a gas well, the means of disposal is not one which would normally be regulated by AOGCe. Mr. Wonzell agrees that permitting and regulation of the facility by ADEC seems most appropriate. However, if the West Fork drain field is determined to be a Class 1\ injection well, a question may arise as to the status of the facility under 20 AAC 25.252. EPA and AOGCC appear in agreement that the issue is one of regulatory confusion and paperwork, rather than substantive environmental concern. Mr. Wonzell is pursuing the matter with AOGCC and has tentatively suggested CPC may need to request the Commissioners take some action to recognize the ADEC permit. There may also be a RE€EIVED CIRI BUILDING 2525 "C" STREET P.O. BOX 93330 ANCHORAGE, ALASKA 99509.3330 MAR 1 6 1993 (907) 274·8638 TELECOPIER (907) 279·8836 TELEX 090·26·465 Alaska 011 & Gas Cons. Gomm\ Anchorage ;.., . .. . . March 9, 1993 Svend Brandt-Erichsen Letter Page 2 need for some form of agreement between AOGCC and ADEC. No one has suggested CPC be required to undergo another permit process. CPC is willing to take whatever steps may be reasonably necessary to assist the various state and federal agencies in clearing up the present situation. However, it is CPC's position that, following nearly two years of a rigorous permitting process, CPC is conducting wastewater disposal operations at the West Fork Gas Field in accordance with applicable law pursuant to a permit properly issued by ADEC. Sincerely, CiRi PRODUCTION COMPANY Kevi n A. Brown Vice President cc Blair Wonzell, AOGCC Robert Dolan, ADEC/SCRO Jonathan Williams, EPA Chip Dennerlein, Consultanc epe REéEIVED MAR 1 6 1993 Alaska Oil & Gas Cons. GommlssiOP Anchorage . . . ~. . .ró,.t;. 1-.1 kI fÃ}-~ SjrlrøÞt Æ ~-'1"'~ ~~eo S7'-'l1'... ." 'is' ~ ^ r, $~fá~ ~ ... ~ ð 1-...,( PRO\'i.v'\~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue Seattle, Washington 98101 Reply To Attn Of: WD-133 MAR 8 1993 Blair Wondzell Alaska oil and Gas Conservation Commission 3001 Porcupine Drive Anchorage, Alaska 99501 Dear Mr. Wondzell: This letter confirms the February 26th telephone conversation between you and Jonathan Williams regarding the Ciri Production Company produced water disposal system, located in the West Fork Gas Field of the Kenai Peninsula. We have enclosed the information sent to us by Ciri Production Company for your use. The plans we received show that the subsurface drainfield disposal system is to be constructed similarly to a number of large domestic wastewater treatment/disposal systems which the EPA Underground Injection Control (UIC) Program has defined as a type of Class V injection well. In Alaska, these systems are also regulated by the state under the Department of Environmental Conservation (ADEC). It is understandable, therefore, that ADEC would regulate the system, and also refer Ciri Production Company to EPA. However, since this subsurface disposal system is to receive water produced from natural gas wells, we think that it is by definition (see CFR 144.6) a Class II injection well. Although the proposed drainfield system is technically considered a Class II injection well, we agree that it makes sense to utilize the particular expertise of ADEC for this situation. Further, we understand that the proposed drainfield disposal system is subject to ADEC regulation apart from state and federal regulations promulgated in response to the Safe Drinking Water Act. ¿ In summary, please include this gas production wastewater disposal system in your Class II injection well inventory, and regulate it as legally required. We trust that this can be accomplished in a manner which both meshes with and utilizes the regulatory responsibilities of ADEC. Sincerely, REfEIVED ~ ~ <. ""~ MAR 11 1993 Rog r K. Mochnick, Ch&t9$a Oil.& Gas Cons. Commission Ground Water section ~nchOfagø OPrinted on Recycled Paper Pleaoe print Ie with an ELITE typewriter in the .haded area only, INSTRUCTIONS ON REVER. &EþA U.S. ENVIRONMENTAL PROTECTION AGENCY OFFICE OF DRINKING WATER INVENTORY OF INJECTION WELLS (This information is collected under the authority of the Safe D,inkinll Wate, Act.) Fo"" Approved OMS NO..R017~ III. TRANSACTION TYPE ('X' one) . . LII. DELETION 82. FIRST TIME ENTRY 03. CH!,NGE OF ENTRY t3 IV. FACILITY NAME AND LOCATION C A. NAME 011 wi EtSITI IFiðglkl IGtAlsl IFlt I£I~DI II 1 I I I I I I II II r I II 1 I I I I I I 1 I II I I I I I I I .' 4 t ~ '6 - 70 C B. STREET ADDRESS OR ROUTE NUMBER 'Õì2-slotJ II<IEI~ þ: Is It. lAIN Ivl Rþ \Alp 1 I I I 1 I I I I 1 I I '4 15 '6 45 c . C. CITY OR TOWN D.ST. E. ZIP CODE F. COUNTY 013 kIEiN\4\1 I IMEII-JI, NI~I(jIYAI I II I II II I ~k III I 1415'6 - 40414Z43 - V. LEGAL CONTACT: TYPE, NAME, PHONE, MAILING ADDRESS, AND OWNERSHIP C A. TYPE (ma,k 'X') B. NAME (last, /i,st, & middle ini/ial) '.~ Ç~;¿;N:r>:RATOR gl~IOI~NllkIEIVI\INIIAIIVltIGIEIIf?ltzIEf;I' Ivl£~tri 1IIIIIII111 qlðlîl~11L18161312' 141~ 17 18 - B75a - 87 C . D. ORGANIZATION 015 ell glll IFigoç¡ulcr-ltlc>llJl IC6MfIAlNIYI I I I I I I I I I I 1 I I I 1 I '4'518 - 55 C E. STREET OR P.O. BOX '016 2-Islzlsl lei l<;rrlg£It:~1 Irlol 13Þ~1 1'1131313101 I I. I .u-1..~ ) 6 - 45 C F. CITY OR TOWN G. ST. H. ZIP CODE ~lNG]Hlol~1416-/f1 II I I I I I II I II I I I Ak.orlqlsÞIC( 14 15 1 (, _ 40 41 42 43 - 47 C. PHONE (area code & no,) A. CLASS B. TOTAL C AND TYPE NO. OF WELLS UC AC TA PA AN ~~ tB I ! I I. J _124251_117 J -'303' I J.. J -'36 THI<> ($ ~OT A'1J tfVY£Q1DW W£U.-. I~<;TE.D ArVDíf<fA1ID ~ j, --,a I ! 121' 221- L JJ272a'_13Ó3,1_133341- L P120DUCÆ:f) WA-rt:e. R?6W\ ~vJÔ I0ATÙ~l- GAS UJEl..(.s.; 15' ·l[-,-I-q-m----l--r II II II I I . . Ï4 I~ if. 17 18 _ 21- 22 _ 24 25 _ 272a _ 3031 _ 3334 _ 36 þlÇpŒED QÇ" VIA AJJ otJ <;fTE ~LJgc;()RFACE DRAr/Ù ïfï--·j------rr- ~L II II rT II i4 i.. ir. 17 iML _ ~1 22 _ 24 25 _ 272ft _ 30,31 _ 33 34 _ 36 f=l E)..Q ft;£SUAt0T 1õ 4 PERWl n- l$S"cJt=:D gy l11f i]2n I -- ·----r-r-I-· - -rr -n--lT --TT-Tl--- t.~ li¡L!.~l-I" u..r, - 2425 - ," '" - '"" - "" -" S17.\.ït CF ALASl:A) Þ,'E"r. ()Ç ENu/1<6fJW\UJíL\L ïl~ --_L~--LL - I -r I I I I I I I I ' ... r< u:"rL t. - f'- <" - '" >, - ,,'" - '"" - '" " - '" CotVsB1l//.tI1ó0 - DF'ERA-norJ INu..v¡::es í".¡(WI0;)WA1B2. ~. ~ --- =c -- -- --IT I I I . I I - I I I I r r- \ I2 - ~" 1(- 17 U - 2\ 22 - Z4 ZS _ Z7 ze - :!O 31 - 3334 _ 36 MoOt\) TC>«I~ ~ 4¡Iv\ C. WELL OPERATION STATUS I. OWNERSHIP('X' one) o M_ PUBLIC U O. OTHER (specify) 52 52 n F. FEDERAL VI. WELL INFORMATION WELL OPERATION STATUS: UC = UNDER CONSTRUCTION AC = ACTIVE T A = TEMPORARIL Y ABANDONED PA = PERMANENTLY ABANDONED AND APPROVED BY STATE AN = PERMANENTLY ABANDONED AND NOT APPROVED BY STATE D. COf.ll1ENTS (optional,) c: PAC: ,..,... 7 ~nn ,AA () I 70\ . " t, , " .. FP .. )[tt ... FPEfltŒN ENGINEERS. JIC. -- lID"" 3#N, ... _ '::::"'-.:0 - ~ 1~ - . I; i~ 5 i~ - .. - - - .. - IQ/IIJII .... - -111- -- 4t'. ~r_D""'1'R ~ ~'\: I I' / >.->/ t:L L._ :% . ~ '0' 7~ ~ ).v/ .. 'l;.~ ~~ ::: ~ ....../ 0 Nf. ,/ /'< ~ 0 I A ., 0 . . o '/ '0' '^ W-+ ~'\. '«.%~~, (3"\ ~A'ßON IAI DET&· V 110 sc.u cisøaw /f'''''' o · ..... 1"'\ ..- &..I Z ",' ~ O:;O~: <- W ('I") ;;> (; C"'}C rn> 5!! (1.)5 '-'_ -0 Ww I.t") >c:: c: -C) Ü <".I 0-- f cc a::ffi <: W I.LJ w~ F,- f'r" LL. L- s: U u.. ~C) ....z :s:v m /== «~/ -- #~ . cijr"-(III)CllftO f.--RL ....._MI: {J. &--tf~:= I I:i I · · .nJ~--1 ~ N ~ . y · I : r....DM : -- . .". nP. - -.. -E9 ¡_1IIICt: -..... .... SEC1Df IT\ I:,~ fII=In V NO sew: C) Jl~ ¡:t:1D filM EfØIEn' ÐI:Sœt" ,Of \ __-......21"__,._ V' .. CII.. ~ ... IJIO ... I/f.. ~ IUIW _ .... -. ..... I - If rID....._1W IICIIL ~)-I/Ç"I- Hi'll) ...... J- 11." _......... - __ ., ..... __lID PlIo'" _ _ II' _ I J1' ~ !-lit' IUI. )-11t' auur. r _ _1L8 -IOU __ ""'WI.. ~ =' .¡lr...:-: :"':licr. ~ .ïa.~?'cuG''' r_lI.u_-___ IL 1M'" - _ ~ IC. _ ~ IUIA!IIIC ~ - _ILU_lIoIy__rra.w:'1.1111lD1111F ____111_ _..._n.__1IÐ. -- -- :;.... ç- )-11t'- 111 WØlIIIJ. -E9I.. C) ~ WA~ ~~lURff I: ~ PlPNG S'JS1f'4 .. ,;'--;·':-t" ._.' _. ,,_C.,:,-,,_, _"_"__ -'_,'., '. '-.' "', "_' c, TELEPHONE: (907) 274-8638 fACSIMILE: '. (901) 27'-8836 ,,', .',- ", 'i.; ';.;''''',-:.',:;.. .I, .,,;-:/ '_._". ,_ '",''-'-,'_' '-.r~--"/'_c -'-, , <'"'j-> -i ,;-., .,¡-"."."..,',-' . -,. "'.,.,..'\ "é .,'~" ',..- ''''.. '''",.; INLET REGI9N, INC.····· 2525 C Street, ~Uitêi~·?8·..0f t. Q AnchO~~~; ~~x ~~5:~3330 R ~~ p'J ' . "~i7-~ GaS cons. ÇA~ fAX COVER SHEET ~'Ø:\>\\& ~I',....- Z¿s.~£ [a;~¿i~~!"'!!"·i! ':Ø:'-;':f:J:i~l~}tl~m~'1f&f:J6Ji~ih, :,i~~~;;ifj:~: Œ DENNERL£I _::'\}~~-:;) - ~;),<; " '" ,;,-;:-~,*:,.,;,-- ,., Message/speciallnstruc~ions: . -g ( ~_~ o.ib¿f¿d ~ 0- ~. %-li....tt.. lÆY1d.... ..1lwdtk- JA.... (AtJ/HAA;J ßi'~ ~ rm.J2 . fiÆ ~ (""VV'~.~I .. -. '. ~ I -. ~W,~K -K.e APeG .~ t£>11RA- . ('t?~~) ~ ~+.~~ ~~6K.,~,~~(t}:~ ~ . -..-:" /J':' .."'i,C· ,. . , . '."-'" . ¡<h!:/<>:,¡:,:.:~:P:;j:.'.2"': ·..·f_',. ''.., CCtw4~__. y~ eoJß· < .~... ~ ~:> --t k~k< ' Date: '3{ l Î Operator Name: Jevsð¡.) 0. it of Pages (including Cover Page): 12- NOTE: If you do not receive the correct number of pages, please call as soon as possible. , . - - --,------- ~'.:. ;....i~~-'-"~4,.-,...::;.·L~".:.~~~-..;,;"'O~~· ,-___-<-__..l.o_-;:_;~,:_-_",."__- ?~~-t7-93WED 15:22 é· COOK.1;~,GION IHe :' ". ... IØ'-""_ .~ .-... - - DEPT. OF ENVIRONMENTAL CONSERVATION SOUTHCENTRAL REGIONAL OFFICE 3601 C ST., SUITE 1334 ANCHORAGE, AK 99503 [;03-0529 CERTIFIED MAIL RFTt IRN RECEIPT REQUESrED P 054 972 105 . Kevin Brown CIRI Production Co. 2525 C Street Anchorage, AK. 99503-3330 Dear Mr. Brown: ,REß9.'\VED· '<r~MAR 1171993 t'Ôi1ÎL Gas Çons. CommlsS\on ~~8iøfiorage RE: Waste Disposal Permit Application ALJI::.c..; I-1le NO. ~1 ¿::!-UB01 2 The Department of Environmental Conservation has reviewed your Waste Disposal Permit Application for the disposal of treated produced water to a subsurface drainfield. Based on our evaluation, Permit No. 9123-08012 is hereby granted and found to be consistent with the Standards of ttlt:! A¡:i~ki:H I Coastal Management Program, 6 AAC 80. Please note the conditions in Appendices A, 8, and C. . This permit expires FebrLllary 1, 1998 and must be renewed by that date for continued operation of the facility. Department regulations require that renewal rtjqutj:;;l~ lJe received' at least 30 days prior to expiration of a wastewater disposal permit. Requests not received prior to this date cannot be renewed and must be reissued as a new permit, this process takes a minimum of 60 days during which time the facility may be prohibited from nrAr~tinn. Appendix C is the form to be used when reporting discharge monitoring results; copies snould be made from the original. . This facility is considered a class V injection well and must be placed on the U.S. Ënvironmental Protection Agency Class V injection well inventory. Please fill out the attached inventory form and return it to the U.S. EPA Region '0 Office in Seattle. washington. If you have any questic.m;:t rf:Jf;ar ding tl1is inventory form, you should contact Jonathan Williams at (206) 553·1369. Kevin Brown ·{~~·N~ i ~~J2.~ 1ž"'It ;~"ð"'·t1AR-t.7':'93'}JED 15:22··· '::--",- >', -"-~. - : f'/9r~~;\~-:'>·:,r 'r'-t-~ - ,: ~_>;)_-J ._' '-"'f >:-;"", '. ,-, ~. " Dopartment of Environmontal Conservation regulations provide that any person who disagrees with any portion Of this decision, may request an adjudicatory hearing in accordance with 18 MC 15.200-S20. The request should Uti mailed to the Commissioner of the Alaska Department of Environmental Conservation, Pouch 0, Juneau, Alaska 99811-1800, or delivered to his office at 410 Willoughby, Juneau. Please send a copy of any such requests to the undersignarf. YnlJ arp. reminded that, even if an adjudicatory hearing has been requested and granted, all permit conditions reQ1ai.n intulltorce and effect Failur~ to submit ahearingreque:st within thirty (30) ·.dà\ls;of/èëêiPtofth,isIette~ shall,co~stitutea waiver, of that·· ersOn's ri ht to judicia '.. revièw of this? decisiórî;'i~:b':¡';¡'JC~'i';i;r~,,; þ~.~. >~ Since~;IY, .(;~,.~:' ....:.......'1;:; \.' . . Lí'··~ ....,... .)!L/ft .' Svend Brandt-Erichsen Regional Administrator RDjji (SCROjWNT)9123-012.pmt ENCLOSURES cc: (wjENCLOSURES) Kenai District Office, ADEC ~ Mary Pearsall, -Kenai Peninsula Borough . Daniel Doshier, Kenai National Wildlife Refuge Gary Wheeler. U.S. Fish & Wildlife Service/Anchorage Valerie Haney. EP At Anchorage Elaino Pistoresi, ^DEC/SCRO . -;... ,. ~~c.~\\!~~ 1 \~~ ... lO~ W\t:-.~ \. '~, 'i çpf\$-'. \ \)~ !t. !.('hG. .~. ~ ~'ò.~"Ø " ~"":- '. ~ri;~1" 'MAR-t, 7 -sf WED!:)5,i'23 . ) ':-::::::-;{li';1-~'/--~S~1ti~~~~>':_- -/ . ., STATE OF ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION ,,~ . SOUTHCENTRAL REGIONAL OFFICE 3601 C STREET, SUITE 133'1" ANCHORAGE; ALASKA 99503 Kevin Brown CIRI Production Co. ~f¡~!i r. StrAAt Anchorage, AK. 99503-3330 This permit is issued to CIRI ProdÜction Co. for the subsuriace disposaìof treated.~:" produced water from natural gas wells at the West Fork Unit located 3.75 miles..north of Sterling, AK.; SW1/4, Ne1/4, Section 21, T6N, R9W, Seward Meridian. This permit. is subject to the conditions contained in Appendices A, B, and C which are incorporated herein by reference. . . - . . - ." H.H' ." - """-. This permit is issued under provisions of Ala:ska Statutes 46.03, the Alaska Administrative Code as amended or revised, and other applicable State laws and regulations. This permit is effective on issuance and expires February 1, 1998 unless superseded before that time by State Certified NPDE$ pormit. It may be terminated or mOdified in accordance with AS 46.03.120. ¡;,£~ ç !qfj1 Dåte' Issded ~Ul/-t¿ . Svend Brandt·Erichsen ............. Regional Administrator .... PERMIT NO. 9123·D8012 APPENDIX A - OPER~TION A. APPL-ICATION COMPLIANCE The Permittee shall comply with all parts of their perrfWi~~n~~f'"'' dated 10/9/91 and as amended on 10/28/92 except ~~ ~r>A~ VfAOfWI~p.fWi~e in this permit. .~-'-., ..:',.:',', ,"': '. SITE' OPERA TION'~s:' ,. The produced water will be treated by particulate and carbon filters prior to discharging to the drainfield. The discharge flow will be monitored a totalizer meter. <,', 3. The Permittee will submit a plan far the disposal of any radioactive materials. such as filters. to the Kenai District for review/approval within 45 days of issuance of the permit. Disposal of radioactive materials must be În Ðccordance with the provisions of 18 MC 85. 4. Plan approval by the Kenai DistrIct Office of treatment and assoeÎCiteu appurtances must be obtained prior to discharging the produced water. The study "Hydrologieallnvestigation and Chloride Modeling" must be to the Department's satisfaction and adequately addresses their concerns prior to discharging the produced water. 5. During the first year that the permit is in effect groundwater elevations the monitoring wells #1-4 will be determined at each quarterly period and reported with the sampling results in required in Part C 6. There shall be no discharge of floCitiny ~ulicJs garbage, grease, foam, oily waste or wastewater containing a visible sheen or which may produce a film, sheen or coloration on surface waters. 7. The discharge shall not cauSe contamination of surface waters, and shall nut Gt1use a violation of the Alaska Water Quality Standards (18 AAC 70). 8. The disposal shall not cause adverse effects on aquatic or terrestrial plant or anim:;¡llifA, thAir rAf')roduction. or habitat. <~;V?\:'....'<-. .~- -:_,<:,·,'"-:-"r,,:'; ; ~',: .;. MAR-17-93 WED 15:24 v" , ,__ > , ,'f'~-~-; coof INLET REGION' INC,\\i '" . FAX NO.· 9072798836 .......... ,'"'''''' ';.". .. _. ..'__. .. .... :._ __"".:<')'::"/":-:' . .. ,,0,- _.'. >',-:"'/:':'" ..' ~ . . , .::,-' PERMIT NO. 9123·DBØ12 APPENDIX A - OPERATION, C. LIMITATION;; AND MONITORINJ~ 1. Unless otherwise specified in this permit, during the period beginning on the effective date to the expiration date, the Permittee is AIJthnrized to discharge in accordanoe with the following limitatîons and monitoring Flow (gallons/day) 2,OOOavg. Quarterly Meter 10,OOOmax. Total Arum~lÌf,;(µy/J) 10 EPA 002 Quarterly Grab Hydrocarbons ,. ChlorirlA (moll) N/A Quarterly Grab Radioactivity (pCijl) Alpha N/A Quarterly Grab Beta N/A Quarterly Grab WEl_L MONITORING3 Fffli JAnt Effluent Monitoring Requirements Characteristics Limitation Method Frequency Sample Types Chloride (mg/I) 250 Quarterly Grab 'This monitoring applies to the treated prOduced water prior to discharging to the drainfield. 2AII quarterly sampling required in [hiS section will be performed during the months of January, April. July and Oomber. ;)The wells Identified as monitoring wells # 1 -4 in tne stuay "HydrologiCal Investigation and Chloride Modeling" will be monitored as indicated. ~rior to discharging produced water to the dranifield background chlorIde levels in all wells wi([ be determined and submitted wnh the first quarterly sampling resu[s· PERMIT NO. 9123-08012 2. The Department will review the monitoring data and determine if the nRture of the discharge has significantly changed, and will the discharQe be able to continue to meet the effluent limitations in this section. The Department will notify the Pcrmittoe in writing if additional monitoring, treatment and/O,ralternative c diSP?S,a1r:n"è'thods are required.... .... . ..... ". ,',~-, - .-, - ,; - ',- ., - -' - ',; - '-, ": ' . ...->. - - .-". ,-', -:'. - -- "-")' It,the pern1itteé·~~ô·r)tð·~$.~Q~:·~~lû~At.~h~~åct~rìstiC·icJentifieº)ñ)hiS:·i~',. p~rmit,.I"ore,fr~queritly,tháñ.:reqUirêd;'thê"rësúltsof'sÚc~,monltorirìg "S be incíudòéfirrthê~êaloulati6ñ~ åncf}épòrting otth'è'values required in'the monitoring repÒrt (Part Dr Such increased frequency shall also be· indicated.,,~" ' 4. Test procedures for the anaiysis of pOllutants shall conform to methods cited in 1 S AAC 70.020. The Permittee-may substitLlte alternatiVE! methods of monitoring or analysis upon receipt of written approval from the Department. ,. 5. All records and information resulting from the monitoring activities required by this permit. including all rar.:orrl~ of RnFilY5Bs performed, calibration and maintenance of instrumentation, recordings from t.;u/llinuous monitoring in5trumentation, and any addition or modification Of the facility, shall be retained at the facility for observation by the Department for three years. Upon request from the Department, the Permittee shall $uhmit C':Artified copies of such records. D. REPORTING 1. Monitoring results as required in Part C shall be summarized each quartAr Ann ~IJhmittAd along with the laboratory data to the following' offices no later than 45 days following the monthly sampling or 15 days after receipt of the laboratory results: Alaska Department of Environmental C;onservation Southcentral Regional Office 3601 C Street, Suite 1334 Anchorage, AK 99503 (907) 563·6529 lt93 WED\lf,;5~t:TèOOK~í l~T!: ~G~~;iNC r:t~~;2~t'91~127138: . . /"~, PERMIT NO. 9123-D8012 APPENDIX A - OPERATION Alaska uepartment of Environmental Conservation Kenai District Office 35390 Kalifomsky Beach Rd., 5te. 11 Soldotna, Alaska 99669 (907) 262-5210 ;: Kenai National Wildlife Refuge P.O. Box 2139 Soldotna;AK. ~~f)R9-2139 (907)262.7021 2. If for any reason the Permittee does net comply with or will be unable to comply with any effluent limitations specltled in this permit, the Permittee shall report the noncompliance to the Department within 24 hours of becoming aware of such condition by telephone, telegraph, or in the absence of both, by meil. A written follow ·up report shall be submitted to the Department within 7 days of the non-compliance. The report shall contain, but not IJe limited to: a. Times and dates on which the event occurred and, if not corroeted, the anticipated time the non·compliance is expected to continue; b. A detailed description of the event inciuding quantities and types of materials involved; C. details of any damage to the reoeiving environment; d. details of actions taken or to be taken to correct the oauses of the event; and e. details of aotions taken or to be taken to correct any damage resulting from ttle evr:mL 3. For purposes of this permit, a violation of this permit, or oontamination of surface or grOllndwater~ ~h~1I hA defined as any of the following: "¡ij"r'~7~~ÌON" ¡HO 1~/FAX <~~~': 9~i2.8;" ,.~»,--'-':-\ ',' :/;;':<'-i:_t,\f~~'-!:?,;-;~~;- ,. r.,'-.-;,:,,)~, " Page 6 APPENDIX A - OPERATIQN a. DIscharging Wé.\:st~wl:ilt;r oll1er than authorized. b. Discharging wastewater to an area other than authorized. c. Surface or groundwater contaminate levels exceeding levels specified in 16 AAC7D 0/Vater Quality Standards). ffA?-!J-93 WED 15:26 COOK INLET REGION IMC . FAX NO. 907274iþ36 P.lO PERMIT NO. 9123-0B012 Page I APPENDIX B - GENERAL A. Access and Insp6QJipn The department's representatives shall be allowed access to the permittee's facilities to conduct schedulAd nr lIn~~heduled inspections or tests to determine compliance with this permit and State laws and regulations. - B. AvaiLaþility of Records Fxcept for ÎnformAtion rAlatAd to confidential processes or methods of manufacture, all application materials and records and reports submitted in accordance with the terms of this permit shall be é:1Vé:1i1o.blc for public inspection at the department's Southcentral Regional Office. C. Loc~tion of Permit and Application The permitteo shall mElintain a copy of this permit and facility plans at the disposal facility or, jf that is not feasible, at tbe permittee's or operator's place of business. D. Civil and Criminal Lia'þjlit~ Nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance, wrletrl~r ur rlul such noncompliance is due to factors beyond his control, including but not limited to accidents, equipment breakdowns) or labor dispute. E. Adverse Impacts The permittee shall take all necessary means to minimize any adverse impact to the receiving waters or lands resulting from a violation or noncompliance with any limitations specified in this permit, inr.luning any additional monitoring needed to determine the nature and impact of the activity in noncompliance. The perruiU~~ sltall clean-up and restore all areas adversely impacted by the noncompliance. F. Cultural or ~,~leontoloçiC81 Resourcp..!; SlluuhJ cultural or paleolltological resources be discovered as a result of this activity, work which would disturb such resources are to be stopped, and the Office of History and Archaeology, Division of Parks and Outdoor Hecreation, r:>F.nArtment of Natural Resources, is to be notified immediately (907)561-2020. -e . COOK iET REGION ¡NC FAX NO. 90727~6 P. 11 . "8AR-17-93 WED 15:26 , -~ ~ . . PERMIT NO. 9123 DB012 Page B AfJPENDIX B - GENERAL G, Property RiOhts The issuance of this pen nil uues not convey any property rights in either real or personal property, nor does it authorize any damage to private propèrty. H. MOdifjcations or Chan9@.~ . Thi~ pormìt authorizes only that operation sJt:c.;ified in the application and permit. Any alteration, installation, expansion or modification which was not submittea asa component of the permitted facÎlity plan will rsquire a written plan approval or permit amendment prior tn implementation. Any expansion, modifioation, or other change in a facility process or operation which may result in an increcase in omissions or discharges or may cause olh~r detrimental environmental impacts from the permittee's facility requires a new permit. I. Applications for .Permit RenewJâl. Amendmen.lor PIRn A 0f"1roval Application for a renewal of or amendment to a permit will be treated in It I~ same manner as the initial application¡ except that public notice or hearing will Tlot be required for applications for renewal or amendment. Application for renewal Or amendment or plan approval must be made no later than :10 r1~ys before the expiration of .the permit or the planned effective date of the amendment or change. J. Trf:if1~r~rs Should operation of the facility be contracted or a change in contractors be made, the new contractor shall be notified of the existence of the permit and its conditions. The permittee may request to transfer this permit to another proposed permilte~. TtlE:1 written request must inClude a certltled signed affidavit from the proposed new permittee stating that they accept this permit in its entirety. This department reserves the sole discretion to transfer this permit. K. Termination This permit terminates upon the expiration date. The department has the authority to terminate a permit upon 30 days written notice if the department finds that there has hARn A vÎ(')lation of the conditions of the permit. .~ .- , .. ~ HAR-17-93 WED 15 ... . t'Hl\ NU,'~UI~I~OOJO . r I lC, . nl~r.HARc'1Ç, MONITORING REPORT - APPENDIX C QU ARTERL Y MONITORING PERMIT NUMa~: 9123·DB012 COMJ'AN)" J'fAMElADDR!!.$3 rrln Prntl"I:IÎnn C':n. 2525 CSt. Anchorage, AK. 99503·3330 274-8638 SAMPLE PERIOD ¡::ROM: TO; Wç~1 FVII. }-oI..I""al C.ts Unil CON CENTRA TION I' IU~.Q U bN <.:)' OF SAMPLE P....RAMETER !o.lín,mum Av~,.:~ Maxi,num tlr-ITrs ....NALySIS TYPE SlImp. Rnur, Flew P~tII1ill~d 2,000 10,000 Ipd q\lal1~rl) mCL.:r Sampl" RC$IJII TI)lal ACI)omi.: Hydrc~arbon$ P...rn\III~( :0 ¡.¡¡¡/I "."'rU tWi I 1,_ &t~1> SIIII\)I.: Result Chl,'n¡l., cTN~\"d WIIICr) Pennincd r~p~'¡1 m~/1 q\1lUi~r\y ¥,':¡.h Sample Rcsull AlphQ RodiO~livity Permin~d report pc.:l!! q\Ulrlcrly :....1'1 £:;."'p[" Ruu/l BIIIII R."dioacliv¡ty Pcrn1in~u report pCil1 quancrl)' gt;lh Sl\mp!~ R~~ult ... Potm\Ìlh:d $~",,,l.. ~.....h Chlol;\!" (Well ;1) P.:nnil:cd 250 mgfl quarterly gtab Sample R.:~ult Chl.>"¡d~ (WoU .r~) P.:rmilh,,1 2$1> m.fl qllQn.:rly ,,,,b ,~.rnplot K~SUII P.:rIIÜU.:d 2$0 mlffl Slmpl" R..,,,h . CIII.'rh~ tW-:U .....¡) I',¡tmiIlJ.J l;;ú m::/¡ 'par":r!)· ¡'tub Slmpl., R"~llIl Porn,lnocl Sal'l'pl.: R~~uIL P.:rmill':u T)ope ,,, Print Nan¡.: Ind Tille or Prinçipal Ex.."uliv,: Offic.:r or Aulhoñz:.d ^!!~¡\I: DATE: S ION ATtJ~E:__ #15 e ~~fÆ~E (ill F fÆ~fÆ~~~fÆ e / FRANK H. MURKOWSKI. GOVERNOR A",~SIi& OIL AND GAS CONSERVATION COMMISSION 333 W. 7'" AVENUE. SUITE 100 ANCHORAGE. ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 November 2, 2004 Ronald T. Rozak, Principal Rozak Engineering P.O. Box 350 Kenai, Alaska 99611 Dear Mr. Rozak: Your e-mail dated October 18, 2004, raised questions about the ongoing regulatory process regarding the proposed underground disposal of treated oilfield wastewater at the Envirotech LLC ("Envirotech") North Foreland Facility ("Facility"). Central to this proposed project is the operation of a drain field to accept Class II fluids in support of area drilling and production activities. The Alaska Oil and Gas Conservation Commission ("Commission") received Envirotech's application for aquifer exemption dated March 15,2004 (received March 17, 2004), and granted the application on October 6, 2004. The focus of your questions appears to be the relationship between the aquifer exemption process and the process to obtain a disposal injection order. As provided by 20 AAC 25.252(a), the underground disposal of oil field wastes is prohibited except by a Commission order authorizing such disposal under that section. (An order authorizing disposal in a single well is called a Disposal Injection Order.) As provided by 20 AAC 25.252(b), the Commission will not authorize the disposal of wastes into sources of freshwater. "Freshwater" is defined as including water that has a total dissolved solids concentration ofless than 10,000 mg/l, and occurs in a stratum "not exempted under 20 AAC 25.440" (reference 20 AAC 25.990(27)). A person wishing to dispose of oil field wastes that will not move into freshwater does not need to obtain an aquifer exemption but does need to obtain an order authorizing underground disposal under 20 AAC 25.252. Envirotech, on the other hand, wishes to dispose of oil field wastes in an aquifer that qualifies as freshwater unless and until it is exempted under 20 AAC 25.440. Consequently, Envirotech needs to obtain both an aquifer exemption and an order authorizing underground disposal under 20 AAC 25.252. In other words, an aquifer exemption is a necessary but not the only condition for the proposed underground disposal operation. Under 20 AAC 25.252(i), the process for authorizing underground disposal must include public notice of the disposal application and opportunity for a hearing. The application submitted by Envirotech to the Commission on March 17, 2004, clearly stated that it was a request for an aquifer exemption in accordance with 20 AAC 25.440. The infonnation provided on pages 2 to 4 of Envirotech's application was clearly identified as infonnation submitted in support of the application for an aquifer exemption. Therefore, the public notice issued by the Commission infonned the public of an application for aquifer exemption, not an application for authorization of underground disposal. The Commission cannot consider issuance of an order authorizing underground disposal until it receives, and issues the appropriate public notice of, an application for such an order. You are correct in noting that Envirotech's application for an aquifer exemption included most of the types of infonnation required in support of a Disposal Injection Order as required by 20 AAC 25.252. Accordingly, Envirotech may wish to incorporate such infonnation by reference, rather than e e Ronald T. Rozak November 1,2004 Page 2 of2 duplicating it, in submitting an application for a Disposal Injection Order. However, it should also be mentioned that additional infonnation will be required beyond what was included with the application for an aquifer exemption. Specifically, the latter lacks specific descriptions of the thickness and lithology of the disposal and confming zones, which are key components in the decision process used to grant Disposal Injection Orders. At present, the thickness, or even the existence, of any intervals capable of receiving the intended amounts of disposed fluids, or confming them to prevent migration upward to the ground surface, downward, or laterally beyond the specified area within the aquifer exemption is unknown. Additional subsurface infonnation must be supplied to the Commission. It should also be mentioned that other interested agencies may not yet have reached a final position as to whether authorization for the proposed disposal operation may be required from the Alaska Department of Environmental Conservation ("ADEC"), the Environmental Protection Agency Region 10 ("EPA"), or both, in addition to or instead of authorization from this Commission. As you know, pennitting the proposed project appears to cross established regulatory boundaries, and substantial discussions have occurred among Envirotech representatives and these three agencies. As Envirotech noted in its aquifer exemption application and testimony, the drain field project is a non-standard approach to disposal of Class II fluids. Complicating the agency discussions are (1) the construction of Envirotech's drain field (typical of Class V disposal activities regulated by ADEC and EPA); (2) Envirotech's proposal to dispose of Class II fluids regulated by the Commission under a program subject to EP A approval; and (3) communication of the receiving aquifer with the navigable waters of the Cook Inlet. The decisions ultimately made by these agencies as to classifying and regulating the operation of the disposal drain field will set precedent, and as such, each is proceeding carefully to ensure the proposed project is reviewed and regulated properly. In the meantime, to further clarify the status of the aquifer exemption process for your infonnation, you should understand that the process involves both this Commission and EP A. Envirotech provided sufficient infonnation allowing the Commission to issue AEO No. 10 on October 6, 2004. Under federal regulations, the Commission has the delegated authority to grant an aquifer exemption order ("AEO"), but EPA has ultimate authority over each AEO. EPA has a 45-day period to review, comment, accept, reject or let stand without comment AEO No. 10. EPA was provided all public records associated with the AEO on October 19,2004. The Commission will notify you at the end of EP A's 45-day comment period, and relay any decision or comments they may have. We realize that the regulatory process is complex and is taking some time; however it is clearly in everyone's best interest to proceed thoughtfully, discuss this project thoroughly with the other affected agencies, and carefully decide the best course of action. Proceeding diligently will develop a defensible public record and help avoid potential future litigation. If you have any questions, please contact Tom Maunder or Steve Davies at 907-793-1250 or 907-793- 1224 respectively. cc: Thor Cutler US EP A Shannon Stambaugh, DEC e e Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501-3539 Phone: (907) 279-1433 Fax: (907) 276-7542 Fax Transmission The information contained in this fax is confidential and/or privileged. This fax is intended to be reviewed initially by only the individual named below. If the reader of this transmittal page is not the intended recipient or a representative of the intended recipient, you are hereby notified that any review, dissemination or copying of this fax or the information contained herein is prohibited. If you have received this fax in error, please immediately notify the sender by telephone and return this fax to the sender at the above address. Thank you. r' . To: \è.o" RC:f"Z... G.. \.L Fax#: d~~-Ü~~\ From: ·To K ~~Sk \ t\S.~-\d s:C) Date: . . L" WO~ d,"d--OO \ Phone #: Subject: Pages (including cover sheet): ~ Message: Qc 0>.. \ k~(c 'ì: '> -\-k ~~ç'., ~ c.O~~~~ k-"')t_ ~ p~~~~~+ ·-\-.o\~~·e\ 'S~(MOt!\ ~~ If you do not receive all the pages or have any problems with this fax, please call for assistance at (907) 793-1223. DATE,TIME FAX NO./NAME DURATION PAGE(S) RESULT MODE e JOB STATUS REPORT 11/132 15: 136 1913728313747 1313:132:55 133 OK STANDARD ECM e TIME NAME FAX# TEL # SER.# 11/132/213134 15:139 AOGCC 9072767542 BR02J2502370 Drainfield References e - Thor, Enclosed are the documents from the AOGCC files with regard to drainfield disposal that was done at the West Fork field on the Kenai peninsula during the early 1990s. This information is provided per your request in a teleconference with myself and Steve Davies as well in a follow up email. Please call or message with any questions. Hard copies with be coming in the mail. Tom Maunder, PE AOGCC Content-Type: applicationlmsword Content-Encoding: base64 - West Content-Type: Content-Encoding: base64 1 of 1 1112/20042:24 PM #14 [Fwd: [Fwd: RE: tyonek leach field -- ENVIROTECH]] e . cc: file -------- Original Message -------- Subject:[Fwd: RE: tyonek leach field -- ENVIROTECH] Date:Mon, 01 Nov 2004 12:10:03 -0900 From:Thomas Maunder <tom maunder@admin.state.ak.us> Organization:State of Alaska To:Daniel T Seamount JR <dan seamount@admin.state.ak.us>, John Norman <john norman@admin.state.ak.us> CC:Steve Davies <steve davies@admin.state.ak.us>, John D Hartz <jack hartz@admin.state.ak.us>, Jim Regg <jim regg@admin.state.ak.us>, Robert Mintz <robert mintz~law.state.ak.us> All, Here is a message I received a bit ago from Sharmon Stambaugh. The possibility of a meeting or teleconference had been mentioned before (I think prior to the GWPC trip) but I am not aware that anything came of it. There appears to be a bit more urgency in this note. The information does clarify that the leach field is in place, however it is/has not been connected to the "plant/tank". If I don't hear anything from Sharmon by about 1 :30, I will give her a call. Please advise with any comments or concerns. Tom -------- Original Message -------- Subject:RE: tyonek leach field -- ENVIROTECH Date:Mon, 01 Nov 2004 11 :41 :06 -0900 From:Stambaugh, Sharmon <Sharmon Stambaugh@dec.state.ak.us> To:Kukla, Alan <Alan Kukla@dec.state.ak.us>, steven mulder@law.state.ak.us CC:Cutler, Thor <cutler.thor@epa.gov>, Johnson, David <David Johnson@dec.state.ak.us>, 'Tom Maunder (E-mail' <tom maunder@admin.state.ak.us>, Keiser, Gretchen <Gretchen Keiser@dec.state.ak.us> Alan -- AOGCC did approve the aquifer exemption. It does NOT exempt out of Alaska Water Quality Standards, but only addresses TDS. Steve Mulder at AG's office had TENTATIVELY determined that the discharge was a Class II fluid so under AOGCC's jurisdiction. I had a questions about l)whether AOGCC's aquifer exemption allows them to discharge Class II fluids to a different aquifer at a different depth than the source fluids¡ 2) Whether AOGCC's aquifer exemption exempts other Alaska Water Quality Standards such as TAR/TaqH or any other applicable fresh water use criteria in 18 AAC 70.02¡ Ion 1113/20043:55 PM [Fwd: [Fwd: RE: tyonek leach field -- ENVIROTECH)) e e 3) Whether EPA Class V rules apply to the injection aquifer¡ and 4) If DEC is NOT involved in permitting this facility, if a plan review of the actual engineering is required. This Envirotech project has cost a LOT of ADEC's valuable staff time and it is precedent setting for other similar disposal companies that take on oil and gas wastes from a source distant from the injection point. Before we categorically tell the applicant he isn't under jurisdiction from DEC, I believe AOGCC, EPA UIC, and DEC, and AG office need to agree on a plan of action. Obviously the applicant wants to do some construction before total freeze-up, which judging from the weather outside, could be TODAY. Alan, ask Mike Wicker to send engineering plans for his leach field hook up IMMEDIATELY. We can at least entertain a plan review approval for the immediate work. All --- when can we have a teleconference to resolve the permitting authority questions? -----Original Message----- From: Kukla, Alan Sent: Monday, November 01, 2004 10:32 AM To: 'Mike Wicker' Cc: Stambaugh, Sharmon Subject: RE: tyonek leach field Mike, If AOGCC approves of this discharge as an exemption to Alaska Water Quality Standards then DEC will not be your regulatory agency. Ultimately, Thor Cutler of EPA must also agree to the discharge. In answer to your question as to if you can install this connection, DEC has no authority to reply. DEC does however intend to work with Envirotech to resolve this problematic discharge. Note that DEC recognizes that Aurora Gas, as the generator of this wastewater, has some responsibility for the ultimate reciving area of this discharge. Alan Kukla -----Original Message----- From: Mike Wicker [mailto:mwicker@ptialaska.net] Sent: Friday, October 29, 2004 8:59 AM To: Alan Kukla Subject: Fw: tyonek leach field ----- Original Message ----- From: "Mike Wicker" <mwicker@ptialaska.net> To: "Alan Kukla" <alan kukla@environ.state.ak.us> Cc: "Derek Maat" <derekm@hmmenvirotech.com> Sent: Friday, October 29, 2004 7:55 AM Subject: tyonek leach field > Alan, > I just wanted to touch base with you as winter is closing in fast, I > would like to know if it would be ok to install my line from my shop > to the under > ground tank, and tie my leach field into the tank as well before the ground 20f3 1113/20043:55 PM [Fwd: [Fwd: RE: tyonek leach field -- ENVIROTECH]] e e ~ freezes. we will not do any type of discharge in to this system till > we have > your approval. this step will help me before it gets to hard to dig. > > Thank you, > Mike Wicker > John K. Norman <John Normancæadmin.state.us> Commissioner Alaska Oil & Gas Conservation Commission 30f3 1113120043:55 PM Fwd: Request info~e: previous action referenclesterday e Jody, Here is a message trail with regard to an email Steve Davies and I received from Thor Cutler after a phone conversation on 10/21. Tom -------- Original Message -------- Subject: Re: [Fwd: Request info re: previous action referenced yesterday] Date: Mon, 25 Oct 2004 09:33:38 -0800 From: Thomas Maunder <tom maunder@admin.state.ak.us> Organization: State of Alaska To: Rob Mintz <robert mintz@law.state.ak.us> CC: dan seamount@admin.state.ak.us, john norman@admin.state.ak.us, jack hartz@admin.state.ak.us, jim regg@admin.state.ak.us, steve davies@admin.state.ak.us References: <s178f8c2.097@smtpa.law.state.ak.us> I have gathered all the information I am aware that we have with regard produced water disposal drainfield for the CIRI West Fork development. wish to review this information?? Given the 45 day clock that EPA has, objection, I will prepare a transmittal letter and Fed Ex the documents Please comment with any concerns/suggestions.. Tom to the Rob, do you absent any to Thor. Rob Mintz wrote: I am interested in Thor's theory that this is not a Class II well because of its construction. I don't see that distinction in EPA's regulations, but I'd like to know more. »> Thomas Maunder <tom maunder@admin.state.ak.us> 10/22/2004 11:25:26 AM »> All, Here is a message Steve and I received from Thor regarding a call he placed yesterday. Steve and I talked with him in regard to AEO 10 (Envirotech). Thor's questions basically have him where we have been and extending the AE request to a request for a DIO. We stated that the only item we were addressing with the documents he has was the AEO and that we felt the available information met the regulatory requirements and that issuing the exemption was warranted. As you can see from his message, he points out various issues including the small number of samples and the hydraulic connection to the Inlet which he believes links this action to NPDES. During our conversation he also made a statement that "a Class II fluid, if treated might not still remain a Class II fluid". He made mention of some regulation in RCRA, however he was not specific. He also stated that, in his opinion, this installation would be a Class V well and (under current regime) would be regulated by EPA. He further stated that the construction would control the well type, not the fluid that was disposed. We did discuss that historically such a disposal method was authorized in the early 90s for CIRI's West Fork gas well on the peninsula. In response to an earlier request from Sharmon Stambaugh I had copied a series of documents prior to my departure for Erie which I left with Jim. I would propose to copy those documents and send them to Thor. Steve and I believe that this is a topic for the Sr. Staff Meeting if not sooner. Any comments will be appreciated. Tom -------- Original Message -------- Subject: Request info re: previous action referenced yesterday 1 of2 10/26/2004 10:40 AM Fwd: Request info :e: previous action referenclesterday e i Date: From: To: Fri, 22 Oct 2004 08:37:24 -0700 Cutler.Thor@epamail.epa.gov tom maunder@admin.state.ak.us, steve davies@admin.state.ak.us Steve, Tom, Good Morning, Thank you for talking with me about the the Aquifer Exemption No. 10, a shallow unconfined glacial in the vicinity of North Foreland Facility, Tyonek, Alaska. I note a reference to a 45 day timeline for Federal Comment. In our phone conversation, you mentioned an example of a site in the 1990's (West Fork Gas Field, Kenai). Please help me out. Please provide to me at your earliest convenience (Fedex overnight would be appreciated) a copy of the file so that I can understand what you were referring to over the phone yesterday, Oct 21, 2004. As you mentioned yesterday, this is a unique aquifer exemption application. I understand you say the operator, Aurora Energy (Contractor Envirotech) has proposed to AOGCC (1425 program) to use a shallow drainfield (sounds like a shallow Class V drainfield construction, without an ability to perform MIT) that is plannedin the future to be constructed (not yet constructed, right?) in a underground source of drinking water (less than 10,000 TDS) salt water intrusion onshore former Timber camp site (one water sample shows about 3100 TDS at 25 feet below the surface), to dispose treated gas/oilfield generated fluids (fluids that are up from down hole only, commonly injected into a Class II well under 1425 program) to be injected into a shallow unconfined aquifer that is hydrologically in communication with Cook Inlet (saltwater intrusion from the ocean) , a State of Alaska salt water body, which is NPDES permit territory with zero discharge limits. Thank you for your time, and we will be talking again. Thor Cutler 206-553-1673 fax 206-553-0151 cutler.thor @epa.gov 20f2 10/26/200410:40 AM [Fwd: Disposal Injection Order RE AEO 10] . e FYI -------- Original Message -------- Subject: Disposal Injection Order RE AEO 10 Date: Mon, 18 Oct 2004 18:20:00 -0800 From: Ron Rozak <ronrozak@alaska.net> To: Thomas Maunder <tom maunder@admin.state.ak.us> CC: Gerry Allen <gdallen@gci.net>, Derek Maat <derekjmaat.hmm@sympatico.ca>, Mike Wicker <mwicker@ptialaska.net> Tom, I need help. Specifically, what is the next step for Rozak Engineering and Envirotech. Today I received the Commission's letter regarding the subject Aquifer Exemption Order No. 10 and faxed it to Mike Wicker at Envirotech. The letter states that we need to apply for a Disposal Injection Order (DIO) as described in 20AAC25.252. In pages 2-4 of the application for freshwater exemption (dated March 15, 2004), we addressed (in order) the 12 items specified in Chapter 25, Article 3, Section 252(c). Following the hearing on June 10, we provided additional information to clarify several items and Envirotech delivered the letter from CIRI regarding the subsurface ownership. It was my understanding all the post-hearing deliverables were acceptable. Since it looks like we have provided everything listed in Section 252, what else is needed to obtain a DIO? Is there a specific form for the DIO application? I do not understand why another public notice and 30-day comment period is needed to address the same material already included with our exemption application. It was my understanding the AOE would include some conditions, such as obtaining a wastewater discharge permit from ADEC, implementing a groundwater monitoring program (probably part of the WW permit), and periodic reporting requirements. The Commission's letter did not include or mention any conditions except for the 45-day EPA comment period and the DIO. Other than possible EPA comments, will the AOGCC be issuing any conditions? If so, when? Please cc Envirotech with any responses. I will be out of the office (at jobsite in Haines) for the rest of this week. Unless weather and job conditions are really terrible I should be in office on Monday ,Oct 25. I will have a cell phone (252-5640) with me, but the reception at the jobsite is very poor. Our work hours will be 8-6. It would be best to reply by email. Every evening I will call the office for phone messages and email. Ron 1 of 1 11/1/2004 9:27 AM #13 e e FRANK H. MURKOWSKI, GOVERNOR AI,ASIiA. OIL AND GAS CONSERVATION COMMISSION October 15,2004 333 W. 7'" AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 Mr. Ron Rozak, PE Consulting Engineer Rozak Engineering P.O. Box 350 Kenai, Alaska 99611 Re: Aquifer Exemption No. 10 Dear Mr. Rozak: The Alaska Oil and Gas Conservation Commission ("Commission") issued Aquifer Exemption Order No. 10 ("AEO 10") on October 6,2004. On October 12, 2004, the Commission noted a minor error in the text of the order and an error in numbering of pages within the order. The Commission published an Errata Notice that same day correcting these minor errors. Enclosed is a copy of that Errata Notice. ill accordance with the Commission's memorandum of agreement with the U.S. Environmental Protection Agency ("EPA") concerning the Commission's administration of the Alaska Underground illjection Control ("VIC") program, copies of the Commission's decision and the Commission's entire record of this action are being provided to EPA Region 10. According to 40 CFR l44.7(b)(3), this aquifer exemption becomes final upon approval by EPA or if the administrator of EP A Region 10 does not disapprove of the designation within 45 days of receipt of this material. We will notify you of any EP A action or when the 45-day comment period expires without EP A action. It is the Commission's understanding that Envirotech wishes to dispose of produced water from natural gas exploration and production wells in its North Foreland Facility drain field system. This drain field system falls within the Commission's and EP A's definitions of a well. Produced water and treated produced water are Class II fluids, whose underground disposal by well injection is regulated by the Commission under Alaska's EPA-approved Class II UIC program. Therefore, Envirotech's proposed disposal operations within the North Foreland Facility drain field will require Commission authorization under 20 AAC 25.252. As we have previously discussed with you, disposal operations may not begin within the drain field until a Disposal illjection Order ("DIO") is secured from the Commission. Obtaining a DIO requires application by Envirotech, public notice, 30-day public comment period, and possibly a public hearing. The requirements for applying for a DIO are described in 20 AAC 25.252. Envirotech's application for a DIO may be submitted prior to the end of EPA's 45-day action period for AEO 10. If you have any questions, please contact Tom Maunder at 50 or Steve Davies at 793-1224. ~ cc: Sharmon Stambaugh Environmental Specialist IV, DEC . . STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue, Suite 100 Anchorage Alaska 99501 Re: THE REQUEST OF ENVIROTECH LLC for an Aquifer Exemption Order for their North Foreland Facility, Sec. 14, TIIN, RIIW, Seward Meridian, Cook Inlet Basin, Alaska. ) Aquifer Exemption Order No. 10 ) ) Shallow, Unconfined Aquifer at the ) Envirotech LLC North Foreland Facility ) ) October 12, 2004 ERRATA NOTICE The Commission has found the following errors and omissions in its Aquifer Exemption Order No. 10, issued October 6, 2004, which should be corrected as noted. Affected portions are underlined. Finding 4, Applicable Regulations: "Regulation~ 20 AAC 25.440 (a)(l)(B) and (a)(2) provide..." should read "Regulation 20 AAC 25.440 (a)(2) provides. . . . Pagination in header on pages 2 through 4: "Page 2 of Q," "Page 3 ofQ," and "Page 4 of Q" should read "Page 2 of 4," "Page 3 of 4," and "Page 4 of 4," respectively. NOW, THEREFORE, IT IS ORDERED THAT Additional paragraph: "This order shall become effective on the earlier of: 1. approval by the Administrator of Region 10, U.S. Environmental Protection Agency, or 2. Daniel T. Seamount, Jr., Commissioner Alaska Oil and Gas Conservation Commission #12 . ~~~~E (illJ !Æ'~!Æ~~~!Æ . AI,ASIiA OIL AND GAS CONSERVATION COMMISSION FRANK H. MURKOWSKI, GOVERNOR October 12, 2004 333 W. 7'" AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 Certified Mail- Return Receipt Requested 70023150000535210990 Mr. Thor Cutler Ground Water Protection Unit US EP A Region 10 1200 Sixth Avenue, OW-137 Seattle, W A 98101 Re: Aquifer Exemption No. 10, Shallow, Unconfmed Glacial Soil Aquifer in the vicinity of the Envirotech LLC North Foreland Facility, Western Coastline of the Cook Inlet, Alaska Dear Mr. Cutler: Enclosed is a copy of the Alaska Oil and Gas Conservation Commission's decision on the above- referenced aquifer exemption, along with the Commission's entire record of this case, including the application, the public notice, and the public hearing transcript. A summary of the history of this matter is as follows: 1. The application for the aquifer exemption was submitted to the Commission on March 17, 2004. Rozak Engineering provided a copy of the application to you during March of 2004. 2. Notice of opportunity for a public hearing was published in the Anchorage Daily News on April 21, 2004, and a supplemental notice of public hearing was published in the Anchorage Daily News on April 23, 2004. 3. The Commission did not receive any comments, protests, or requests for a public hearing. 4. A public hearing was held on the Commission's own motion on June 10, 2004, and Rozak Engineering presented testimony. 5. In response to Commission requests, Rozak Engineering and Envirotech submitted additional information on June 29, June 30 and August 30, 2004. 6. The Commission issued Aquifer Exemption Order No. 10 on October 6, 2004. 7. On October 12, 2004, minor errors were found in the order, and the Commission published an Errata Notice that same day. I '~ It is our understanding that, under 40 CFR 144.7(b)(3),the exemption will become final if the Region 10 Administrator does not disapprove of the exemption within 45 days. . . .. If you have any questions, please contact Steve D . Attachments UNITED STATES POSTAL SERVICE First-Class Mail Postage & Fees Paid USPS Permit No. G-10 · Sender: Please print your name, address, and ZIP+4 in this box · AK Oil & Gas Conservation Commission 333 W 7TH Ave, Ste 100 Anchorage, AK 99501-3539 ~~¿J /.,/0/ :?/å?~ -", , , ' , ::::'~ /,,1, d,l, !!I!!,II!!!; 'i IL dl" Id H!I., I, 1!'!! ,L;¡ II! lit! ,/ U.S. Postal SarvlceTM CERTIFIED MAILrM RECEIPT ..'. ~.. l'I. , . l' ". _ 4 . . : - # . .~'... _....__. "."....~_,,__._,.__._,,_._._._.J o c- c- o ~;[o].. r;J......~I.:~ ,¡..:. "~.,.~.'.':,,"'~ '~:.:.',I.,~.I u~.. 1.~...(.,~~.I:'I~ I.'.'I'¡ ~ ¡,J\{,., 'A'\f.'1'.'111 E'J " ¡'JI ;¡'JI~.:..:..¡.::., I ~ I - ci£ihT1l~:~ I.IN'" 9Ø1Jrtp ~ I,;;:. rr1 Postage $ ;:i. 40 l~ 1\ í:iI3-SZi:JrJ""-\ U1 Certified Fee ý) y'\ ~ ? -1Ü g¡ Ionn~os:nark 'r.:...'~) ~ (::s::::~:~:;:~ 1. 75 \~ ~::~ K~~ii~ /... J.:!,¡ U1 (Endorsement Required) '\15' /,\ / ~ $ 1''''),'~J;,',u ,"-1-:?;<)" .\1, r;:":'$,()o,,· ru ~;i!d~ffIJeC_-_____m___' ·ëït;,-šiàie:Z,p¡4-L;;;---i//;--....-.m-·.··.-.----9Y/ð-7--- :t-....;¡.J/....I:!t!' I' I I :r""':{"'l"'*"{""II~'W.J't.,,~ Total Postage & Fees 9.l~5 · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on .the front if space permits. ~-'~nt r./~#'A~see I ç. Date 2!- Delivery V tJ,» J'" () '1 D.Adelive~dr~ ~iMt~~?¡ 0 Ves MIiS, .,¡, &;~¡YaVdre~BeldW!~o SENDER: COMPLETE THIS SECTION B. Received by ( Printed Name) 1. Article Addressed to: /If: 71Y/ &J-þr ç!//j?(J d.5 -G'??4- . / ? A A / '7"1-/'lr¿. ¿já/./87 ~. Servi e.:ype . / /) (/ V (,::> rv· ,fred Mall 0 Express Mail fl II' I~ J"/L 0 Registered 0 Return Receipt for Merchandise rt:/l Ie. t</ /1). '. 0 Insured Mail 0 C.O.D. /y /¿1 / 4. Restricted Delivery? (Extra Fee) 0 Yes Ä- 2. Article Number . (Transfer from s~ 7002 3150 0005 3521 1003 PS Form 3811, August 2001 Domestic Return Receipt 102595·02·M·0835 -~ UNITED S'mTES ... POSTiJL SERVICE ***** WELCOME TO ***** 5TH AVENUE POSTAL STORE ANCHORAGE, AK 99501-2351 10/12/04 05:09PM Store USPS Trans 98 Wkstn sys5003 Cashier KH3SMl Cashier:s Name RANDY Stock Unit Id WINRANDY PO Phone Number 800-275-8777 USPS # 0203150535 1. Priority Mai 1 Destination: Weight: Postage Type: Affix. Post.: Total Cost: Base Rate: SERVICES Certified Mail 70023150000535210990 Rtn Recpt (Green Card) Subtotal Total 0.00 98107 1 lb. 9. 90 oz. Affixed -9.45 9.45 5.40 2.30 1. 75 0.00 0.00 Number of Items Sold: We here at the Postal Store appreciate yoU as our customer see you again soon #11 t) Re: Envirotech-North Foreland---DEC Contact - e Our ABO is limited to 1/4 mile around the site--correct? The next step will be for them to apply for an injection order--correct? At that point we can impose conditions as part of our order such as one or more monitoring wells around the area drilled to appropriate depths--correct? John Thomas Maunder wrote: Late yesterday (10/6), I got a call from Sharmon Stambaugh from DEC. She works in their waste water division and the Envirotech facility looks to be her responsibility. Originally the issue was handled by Oran Wooley from Soldotna. As we approached the hearing date, he was transferred to Wasilla. I don't know if DEC has had anyone looking into the operations at that facility. Regardless, Sharmon asked what the status was with regard to our ABO. I told her it was nearing completion. She wondered what their involvement would be once we issued the ABO since the construction is Class V, but the fluids are Class II. She said she has been in contact with Thor Cutler about an "overlay/combination" of Class V and Class II. She indicated that he wasn't sure that would work and he had concerns regarding the whole matter. She did not elaborate on what his concerns might be. She did ask if Thor had called us on the matter and I said no, that Thor doesn't often call us. We did discuss that according to the hearing testimony that if the AB was granted, then Envirotech/Rozak expected to initiate or continue the process with DEC reagarding the "permit" for the facility and installation of any monitoring wells that might be required. Sharmon asked if our order would require such monitoring wells and I indicated that was unlikely, since we were addressing only the AEO and not a disposal action. We may get a request for a meeting with Sharmon and her supervisor on this matter. I told her to send us an email regarding any such request. Tom John K. Norman <John Norman@admin.state.us> Commissioner Alaska Oil & Gas Cmservation Commission 10fl 10110/20043:34 PM Re: Post Hearing Deliverable--Aquifer Exem. North Foreland . Tom, From now on, what does the AOGCC do and what is the approximate timeline for the Commission's response to our exemption application? Ron To: Mike Wicker Cc: Ron Rozak; Jody J Colombie; Steve Davies; John D Hartz Sent: Monday, August 30, 2004 4:06 PM Subject: Re: Post Hearing Deliverable--Aquifer Exemption North Foreland Mike, This message acknowledges receipt of your August 30 fax of the fully executed copy of the "CIRr letter" . At this time, r am not aware of any further item needed to satisfy the post hearing deliverables. Ron or Mike, please call with any questions. Tom Maunder, PE AOGCC Thomas Maunder wrote: Mike, This message acknowledges receipt of your August 26 fax of the CIRr letter regarding the facility at North Foreland. We had talked and r indicated r would get back to you regarding the need for the Commission to have a fully executed version of the document. The document you faxed has not been signed by a representative of Tyonke Native Corporation. The text of the letter reads that the indemnification is binding on Envirotech AND Tyonek Native Corporation. It appears, based on the last paragraph in the document, that until a fully executed copy is returned to CIRr that the agreement isn't complete. We look forward to receiving the fully signed document. Please call with any questions. Tom Maunder, PE AOGCC 1 of! 8/31/2004 9:02 AM , , , Rug 30 04 12:4110 Env.tech LLC 1907'18859 p. 1 T. T[£ ~~ ì~ .: ; ~ .... ~n ...,J'~ ,~lw..~~. " A Subsidiary of Tyonek Native Corporation P.O. Box 8467 Nikiski, AK 99635 46645 Kenai Spur Highway, Mile 19.5 Email mwicker(a).ptialaska.net Website www.hmmenvirotech.com Work 907 776 8766 Fax 9077768859 Cell 907 830 4805 Westside 907 583 2200 Eastside 907 7768795 Facsimile Transmittal Sheet DA TE: ð-3Ö-lJ... TO:~ FROM: ~I COMPANY: AùG-L ~ 07- -a.7l1 . Î 5'1;;;. FAX NUMBER: NUMBER OF PAGES INCLUDING COVER: .:3 PHONE NUMBER: PHONE NUMBER: 907-776-8766 RE: URGENT ~ FOR REVIEW ~ PLEASE COMMENTO PLEASE REPL YO NOTES/COMMENTS: RECE\VED AUG 3 0 2004 Ii' ·l1tOU.Gx~ ('~ I r 'n'm1 - A.~ I?rin¡Mwi:T:re~tm.e.atS.Qij:~~@QiJ;,.Sitt1:(4~~:t1:~'Qjt¡~M4ti~g::A:s~AÞ#~t: Aug 30 04 12:41p AUG-26-04 rnu 01: 38 PH Er,vil"'ötech llC tI~eal Estate lS0777G8S59 FAX NO. 907 2~ao P , 02 1S0717G885 p.c FF\X NO. BQ7 283 5190 1', 02 P.2 A~i OS 04 03:~8p AUG-Oó-04 THU 03:02 PM Et'lVil"ot.ech L.Le CIRI Rpa £5l~te fitCIRJ ...----...-... .-------,... ....--.-.....~...---~- - ^ugust 4, 2004 .... - ----....-- SLlbe C{: fJroþOsed EnvfrQfcCn u.ç W~t~r rre~lmcot and Qli\in fjt!'ð ¡:.,d/Jty at North Forcl.od at ~·YQr)Otk. R,ECEIV't:D AUG 3 0 2004 AJl!Mœ¡ GaCcø.Oi I Ìl.1';Jì ~~ ~;Irt G~ri)~r M~",,"or Repr~sc:ntAUve fn'lirotech, tlC 1'.0. Ho" 933.3 Anchor:\gt>, A" 9~;09-3JJO Deô1rMr. Garbor: P/O.&Q Ç'o\'\sltkr 'his letlcr CIRl's /1on-gpPosÎtíor¡ to EnvirOlcch tlC's aPJJIic::uiu" for.1 MI\- do",..., ~..tew,.... di<cl>;,'8e petmlll,."" lb. AD,C ,.,. ~"" .......... "'. dr.fn ~.I. r.c;1;~ al Non.ll foreland ilt iyonek. CIRJ b;¡ses t"is non-opposition on 11$ /Jnders'¡).ndin~ 'hal; J) Ihl! "cllity i, t..... tod apl" ""t..,,~,y ... "'., I",.., Ceok InI... betw"" ,he "./It\ I....t.nd dock "" d Tyunck C'''k; 2) th. .,,,If,, d"" n.t '."....Iy _. .. a ,...h w.tc< "'..... nl d,'''IdOS ....., "d will ""t .In ,. m ,¡,.. '"'''' b,ca,,", ;1 . t.. hi,loy co......",... "'II/¡ .........."om C"'¡' Inl., " ...... ..,"'""" of driolri"3 ~.'" """"",,,1"'ly ""-Ie; ') tho..., dJ...I..d ,",id, c.....'" of tho 11'"""" W"" I, mo., II". '.00. n>W1 ..'" ~" th.n I..... I>1Wf .IId ts "'" """~,b~ .....octed to 'U!'P1y · publl, w.... '1'>""'1 .nd"J ¡"'-':h Ltc w¡tt 1011.... att applln,",,,, r..Jn..I. 51ðk ðt\d loc:.\ll.:)ws, Tulcs ~T,rl (egulMlol\S¡ il1d 51 En"¡,nlech LLC and it!; P<kCC1t, Tyohek N~live Corpl1fation $h..1f cJer~nd, }(~Id h;)"Tt'es$t .:)J1d defend CIR! a, d~'~ribc.:ò IJelow. Envlrotl:ch, LlC ¡,¡"d its pat~tlr, Tyond<: Nalíve (".(tporACfon ("fl'ldemfl¡""tst/¡ ðnd ,u"'idiOt'" Ihei, ·ß".... cmployoe,. con.."",. "'" "'Ign,. ¡.1ntJy ... """.lIy ....... .11 '_I<y. "'k. "'" ¡¡,blt'~ ... .11 t..jUd.. to ...'..,. '" ...... ,. P.."..ty "''''''''s 1_ the c:on5tr~'c:tíon, h'I<ti'Jlt'''illàC(>, Op~réltio", 01 rc~OV¡¡' of Ih~ "'atet !r(;.}.¡-nent and drain facilftR!s she acn,,, em,·, "''''urlhce .","'.... I..th.... of.. e._ wKh... CaR, ,""'Ult,,. _to. 1M .bI'¡¡...on i, ""<""dlUc",J .nd o\o,,,,u~, "¡,I"'"I '...'. to "'. "".11_ ., ...... 01 "'. "'''''''''' by Ittdon..."",. "'. h """.. ... I"oy .... 'CnI"....., "" "'i.",. """....,.." '8''''' 'a ..y am I.. 'If .....IP" .utT...,.¡ by CliU as . ,,,,,I, of lb. 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'''Y '¡¡'p..,I. ..t..... 'PHI .. ol<ch.rge or 'ny '''_ <"/>OS. I. "¡,,.,.. 'pili ., dlsch.... of ., ...-...-.....-....-. .-.. ~'-". -~..__... 1$1$ "t:o -\ Tttf'-F.j, SUII t_ s~a . I',D. IIIIX "HÞ - IIlIIt:JtCJIlACI:, AI.i\!iICA, ")b'-~~JI, ;'1071 Z7'·1I6,U . I'Jllt (VII?I ¡".n." . OW.I, Sit<, ........<if¡.~ø... '.-",-.. -'--'- -.--...- -..- .---..-.---.... .-...- '--..-...-. . ~_.....-.~-.. --~- "-.., Aug 30 04 12:41p AUG-28-04 THU 0]:38 PM Envirotech LLC ÛI~eal Estate 19077768859 FAX NO. 907 2.190 P. 03 19D77768e5 p.~ F~~ NO. 901 263 S190 P. 03 p.3 Ou," 05 Q4 03: 2Bp . fiOO-OS-04 'fHU 03;03 PM F.nvir-otllcn LLC CIRI Re¡1 E$,.le c.onra.mlJ'ilÙOf) by þô\;tðfdous rn:ucrì~s 3nd iochldl/'\!: C(;RQA and sl;atl:! a:RCLAJ. and envitunrMI)t¡¡ I"¡On'OIYlpl1ðnce IÏI\c/uding IndemnitDIS' Þìlur~ tQ provid~ 1IIIII\formal.ion, mnkc All !íubl'l\i~s"IO\~S, :u,d 1i11tC :111 :!oleps requitecl by du~ ¡)U\"OfÌ1Y under d-.e eraviranment..1 laws or i.\ny olhlH ,,,11'0' c()nc",nÜ,.,g "'II)' sJli\1/ dlscha¡g(!, or cOl\bmin.,¡lon), that may in any manner arise (Jut 0(, in c('\ne~tjon wilh, djrc~\y tH Indirecrly frnm, Or olherwlJ>o incident \0, the Idyl",!, malntcnante. re)::\tr, use, e;(iSlcrtl;:ç or r~Jno'l" of !\J\Y W¡lCr Ile~l\nent ilnd dtAlrUI&~ facni~y, including lhe brr!aking of any Qqu;pI"OI~nl Or \he 1!:lIldnS of I\I'Y $lJbSl~"U! (rOO1 the water 'trcøtme/')t i1nd drain 1~cm'Y or oth~r u:;~ of or contac:l WIL, \he CIRI Subsurf.w~ CSÏrlle, ex¡;c:rJl to Jhe 01CLent tne !ol~ legnl c.~\lSI! ollhe Injury or d.'\m()te j~ ¡!Ie )1~gligenc;o or wiUful misconduct of ORI. Indemnitor' Shan immediatEly aC'c~pt Ih~ tcnqc( by CIRt of nny ~Il'" cl:\lm. c1elmmd, cause of action. !~WSUit, Of Q!hc."f procèeding l)(OfJghl ,,¡;a.inst CtRI. CIRt shall b,. Mn1cd ;as an addi1iQn.\1 insured on allli3bililY poUc;ié5 rOíð!eti 10 ¡ho Plgj~t except worker' I; (:om\}Gf1s.,Üon. Jn~ural\ce policies m¡¡in(Din~d by Envirolt'th Sho1l! 1M: þ'lmary ¡¡nd J1glicit!!å rnalncalnod l7y Ctl~f shall bo \:xçe" I\nd noncol1ulÞulory to (ll,)lfcíes nUÎfltalncd by t:l1viroLcch and shalt include $c~r"bi1lty of ¡ntercsl and CI'Q$$-li:a.bil¡Ry clauses_ I'nWldod the ,bó\le C;OtIcfiti01\5 arc mCl. Clltl c!oÞS not 0J)PO~G ~ne iS5uanœ of a peLn\it "tI¡horì~ina \ho dl7lrl\i\gc rlcld cI¢sc,¡bccl in y~lIl I~ttcr dntœ 'unl!! 17, 7.004, PI~~~ indkiltlt by your siS"iltuf~ bclflW your ;J.)f(¡('f1'ent \0 ¡['IS abollCJ terms and Murn 10 ORI. We wish YØI-' the bf~t in Ú'lis project. 7:!~ \tlco Ptc~de,.\. R~.., E!\t..tc ftECeiVED AUG 3 0 2004 ÞJ.IQA1GaQ;ø.~ ErWlrotilch, u.c: ...--------- ~ --=::...~ ---.... ~~ /~:?;..,- .....~...'!-"" ~:i;!ZJ~ -__ __ ~_.. -1_" ._., .__._. ._..... _..~._ ..._._ _'._., "_._ ._.___._...__....._.__~.._ Post Hearing Deliverable--Aquifer ExemptioWrth Foreland e Mike, This message acknowledges receipt of your August 26 fax of the COO letter regarding the facility at North Foreland. We had talked and I indicated I would get back to you regarding the need for the Commission to have a fully executed version of the document. The document you faxed has not been signed by a representative of Tyonke Native Corporation. The text of the letter reads that the indemnification is binding on Envirotech AND Tyonek Native Corporation. It appears, based on the last paragraph in the document, that until a fully executed copy is returned to COO that the agreement isn't complete. We look forward to receiving the fully signed document. Please call with any questions. Tom Maunder, PE AOGCC 1 of! 8/27/20043:39 PM Post-Hearing Deliverables - Aquifer ExemPt.~r Envirotech's Nor... . Mike, We have received your request to keep the hearing record open for an additional 30 days. Closing of the record had been set for Monday, August 2. I have spoken with Commissioner Norman and he agrees that it is appropriate to grant your request. On that basis, the record in this matter will remain open until 4:30 pm September 1,2004. Please contact me with any questions. Tom Maunder, PE AOGCC Mike Wicker wrote: July 30, 2004, John K. Norman Commissioner State of Alaska Alaska Oil And Gas Conservation Commission 333 West Seventh Avenue, Suite 100 Anchorage, Alaska 99501 Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Dear Mr. Norman, I am writing to request that the record regarding the Envirotech Aquifer Exemption Application remain open for an additional 30 days. We have been working with Cook Inlet Region Inc. (CIRI), the owner of the subsurface at North Foreland, to obtain permission to operate the treatment system. The person responsible for real estate at CIRI, Mr. Kirk McGee, has indicated that the company's permission for the operation of the proposed Envirotech facility is forthcoming but that fmal sign off is required from several officials in the company. Unfortunately, the approval process is working at a slower pace than what was hoped. lof2 7/30/20043:40 PM Post-Hearing Delíverables - Aquifer ExemPwr Envirotech's Nor... . Envirotech has been assured that the required approval will be granted following a meeting of the COO board which is scheduled to take place on Thursday, August 5, 2004. We have requested a 30 day extension from July 30 to accommodate any other unforeseen delays in the CIRI approval process that might require the record remaining open past the 5th of August. Please do not hesitate to call us if you have any questions or comments. Sincerely, Envirotech, LLC. Mike Wicker Operations Manager cc. Thomas Maunder Ron Rozak Mike, I will be asking the CIRI Board for approval to deed the top 500 feet of our subsurface around your facility at Tyonek. This will be on the agenda at the Aug 5th BOD meeting. I will call you immediately afterwards. I am recommending approval. Kirk 20f2 7/30120043:40 PM Rug 26 04 02:28p Envirotech LLC . 19077768859 p. 1 . A Subsidiary of Tyonek Native Corporation P.O. Box 8467 Nikiski, AK 99635 46645 Kenai Spur Highway, Mile 19.5 Email ~wicker(a}])tialaska.net Web site www.hmmenvirotech.com Work 907 776 8766 Fax 907 776 8859 Cell. 907 830 4805~~\~'~1<:~~~} Westslde 907 583 22~~""~'i Eastside 907 776 8795 R~f~:~(,:§ Facsimile Transmittal Sheet DATE: 8-¿;¿{ô-6<-f ·trIII~.t ~ TO: ~:>'^--- ~;...'-'-~..<~ROM: rv,::::L.~ l~~R..... COMPANY: rR~~r FAX NUMBER: &~-':r54:L NUMBER OF PAGES INCLUDING COVER: t-/ PHONE NUMBER: PHONE NUMBER: 907-776-8766 RE: URGENT 0 FOR REVIEW 0 PLEASE COMMENTO PLEASE REPL YR NOTES/COMMENTS: - lo¡,.v-..... pl-è-A..f\i5" C """'-'- ~£' A, 9130'-"-180.5" t......."'"'ð...... ~q<~ ¡le-C "'n·\;!::,~ --rH ~...L\.L. _( l'~' :- f"v......-::s_.I.G . :QrinlM:wt¡T:r~wAt~¡~m~Q~·t~it~;.t:1.~'Q.p·. jé)~ "",\'=7 \'> r¿~ '-.) \ m\crek > ~~~Cs ~ C-\\L~ \\ \ ~ - II \........ (~ O"'~~ O~"-Q:..t<,\'\.\ ~ \~S()(.. ~~<:, ~~~~~\.)(t~\SJJ· ~~ \~4\\'1 ~\J.\.Ç\c..~V'\;-\~ Sh:>ù \ð ~ Q<;.\c.- ~~ \oc{k:r ~N'? ~ ~(~ ~~( "'~....... o'""'~\~ \ Aug 26 04 02:28p AUG-26-04 THU 01:55 PM Envirotech LLC .Real Eslale 19077768859 FAX NO, 907 ~190 p.2 p, 01 ~CIRI FAX Cover Sheet To: j)¡u).u_ (AlLUvV._ Fax #: -J.ð7 - 77lP '" 8Áf--7 f\Et.. '" "\Æt) From: ¡Vu ~ t/ ,'. f'"' ~~ .~·_~&~t_" "" .. \'':'\t~ Date: ?(. 2-'"~" . () t/ .---- Pagcs~ 3 Comments: ~'- ~. "'- Tho information conrained in this f~cslm¡le tr¡¡nsmiUal is ¡ntr:nded only {or the addres~'(:e or the addre$sec's autfwriZr!:d agent. The message /n':¡y GOnt<1ÌH ,n{ormiJtiO/1 chat i., privilé'ged, confidential, or olllerwi.H~ excmpt {rom disclosure. If Un! ((:iJ.dçr of lIw inform~líon is not the ilJtended f('cipienr, or recipient's agent, you are hereby nor,ff;cd char .iny dissominill/on, distlibution or copying of this in(ormariM i5 strinly prohibítcd. If you have received lhi» infornJcHÎtJ/J in ~rr()r, please ¡!Olify rhu sender m¡mC'di¡¡Cely by tdcpho/JIJ and ret(¡m lhe original informalio¡) /(} rno senc.l~r, by U.S. mail. at the iJddress be¡ow NOTE: If there are any prohlems with this tr.ansmi~sinn, ple<lse call (907) 274-8638. 2525 "C" STREET, SUITE .500· P.O. BOX 93330. ANCHORAGE, AI.ASKA ?~509-3330 (907) 2711.8638 . FAX (907) 263-5190 . Web Sire: ..,¡¡ww.c'ri.com Rug 26 04 02:28p AUG-26-04 THU 01:55 PM Envirotech LLC . Rea I Estate 19077768859 FAX NO. 907 ~190 p.3 P. 02 - Ru~ 05 04 03:2Hp Enviro~ech LLC nUG-05-04 THU 03:02 PH CIRI R~~I Eslate 190?776DIJS9 FPt:< NO. 907 263 6190 p.~ p, 02 tJttCIRI .....__._...._~.---'-, -----"- AL~SU"14, 2004 ,Ò':.,__/--._~:··,:f('\;!r;~;:·{,:;". 1 ~~, . ¡,._., " , "~,"'~!J'_ 13M' G3rber Mcmb~'r 1~l;"rrescnt<ltive £nvirorcch, lLC P,O, HQX 9333 Anc:l,of;lgc, Ale 9ÐS09·33:iO '~;:'ì., i:_"Þn;f).,~ Subjecl: (troposed EnvirQlcçft LLC Waler Tre"lmcnt and Dmin field factHty at North Foreland J\ 'ryonak. O~;)r Mr, C;¡rbcr: PI~iI~ com(dl}r 'his lettcr ClIlI'~ f)on·oppo~i\ion 10 Env¡rotec:h I.lC's apI)líC:ó1tiun for ,J non- dome~tic waç\ew.1tcr di5chMge penni' from the ADEC for <I w~!er treatment and draín field f~ctH!y al Nonh foreland "t Tyooe!<. CIRI bases ,h¡i non-appositiOr1 01'1 ils IJnder>t<U1din8 rhat 1) the f.1Cility ¡.. lo,Jt~d :\pproxjm.:\tl.'ly 40(1 feet from Coo;c. Inlct, h~~ween the North r:orc¡¡ncf dock and Tyol'lc!c Creek; 2) (hc! aquifer docs not curlcf\~ly serve OS.l fresh w~tcr SOtJfc:e of drinking w.).(er ~nd wíl1l1CJI cf4) $0 in ~hc future bcc¡,u5e it Is 101) highly cQnVllT1jnated wilh ~.hwitter from Cook Inlet \0 I'".lke reCovery 0# drínftir'\¡': willer cconomic.11}y pr"crjc:¡ble¡ 3) the t()I~1 djss(.Ived solids co,,1cnt of rhe grotl"û waler is mort: than 3,000 "'1'/1 ~I\J less th:lf) 10,QOO m,yl <md is not rcasOI'lõ1bly c)(pc:r.:ted to sUJp1y ¡¡ public w;¡tc-r system; .and 4} Enviroleçh LLC lNill (oHow a[/ applicable federal. S!<Jtc i.Ind loc~1 laws, rulcs '\rId reßul"llons; and 5) Envìrotcch llC and its p~rcnr. TY()f1i!/c N"tjv~ Corporation shall defend, hold hJo1'1Ics!, :mcl defend ORI as c!escribed below. Envjrolccn, LtC and ìts p:u"nr, Ty(nck Native Corporation 'lIh~cJemni(or5") and SLJLsidi~(ièç, lhl!Ír agenls, employees, contractors :\nó assign~. joil'\t1y and swerally élssume all rès("IomiblUly, ri~';, <tlld li"biJity [or :III Injuries to pcrSOl1S or clðmage to property resultjn.q {rom the construction, mililltenanC(!, op~rAIir:m, or (~nI0"ill of lh~ water In:atlTltl)t <.IOU drain f¡¡cìJj¡C'j site .1cro~. eml's 5ubsurfit(c c:lille ..od for thc usc of or COnldice wilh the ORI submrfar::e est;¡tc, This obligAtion ÎS tmC:Qnditiol'..d Md òilbsorUlC, without rC~lIrd ~o th~ nc&ligcf1ce or degree of cilr~ e)(crci~d by IndctI'mitors, their agents, crHployees, conlr¡¡Ceors .1nd assigns, Inckmnitors agreo to p<lY CIJU for ;¡II J,:"""ges ~u(ferr:d hy ClRI <IS a resull of th.e exercis<: by Indemnitors of the risht.s gr"11tcu In rhis leucr agreerrlel1t, or for v¡o!.tion to lh~ terms of Ihìs fetter a¡:;reement. The obtig.1lion of 1nciemnrlrm to }><ly darn:Jgcs eXLends to o>cr¡¡tions within and outside tl1e bou"d;triéS o( the CIRI m"~lIffJce Cstòla. Indt>rnnjtors, their ~g(!I'!S, ernplCJYlo!es, c:onlr~lC)tS òJnd a~$¡gns H¡:ree 10 d(!(el,d, indcn1f1ily, ô1/'1d hoJd h3rmlcss ORI. its i1gCI1IS, employc~s, "I"I<J ¡1SSigns from and against any i\l\d ;;IU dem.u\l..ls, ClIuses ò' âlc::tÎ(m (WhNhcr in thl! nalLlre (.f:ln .1((;01"1 fnr cJ.",,~~cs. indemnilY, c;ontribIHlon, go'o't.!m1\1~nt co~t rCC()\lcry 01 othcrwi~f.'), finc5, judgments. suì'~, dJims, ;¡ctJcms, prQ(t!('díngs. los!K1s, CO¡'U (including rcasonJblc Jtloln('y~' f~1:'S and c:osl~), expcl1SeS, cÞ;\r~c~, forfcltures, li!!ns, liabfliliM, settlements, ~~ni\llic$, violations. ,)r bw and damag~ of ,my kind or nature Wh;¡tsf;lever, li\dLlrling, bu~ no! limited 10 tho5e Jlleging personal ¡njuIY, wrongful death. I)ui~~ncc poropcny d:\lnago. clwirOI"lIl1C'nt;¡1 conr.1l"1lin;¡t'ir¡n (il\c:Iuding, but not limited to, ôlny di5pOSJI, rclc.m~. SI)ilf or ùi$<;hM&~ or öIr1Y thrC\l(CncJ di~posJ.J. rdc"i:;e, spilt or discharge or or ....--. ·,......-__.".e________.,o "'.._-.-, .__ '...__._....._._. _.__....._..... HH "ê:" ~"TIlr.r.T, SU!Jt: )/1(1. P,I), HJX HHO· ^NClIOMcr. ^L^~I(A ?'IO~..\\Jn 19<17. 17~·M.~" . "M( 11~') 17'."\~· OW,h ~iw "'...~ ,,,;,,a,,, _._~;".'l"'._."..__________..,. *,. ,~........~.______.... . -,..---. "..___ H"'''' ----......._......-- FAX NO, 19077768859 907 e 5190 p.4 Rug 26 04 02:28p AUG-26-04 THU 01:55 PM Envirotech LLC . Real Estate p, 03 , r Aug 05 04 03:2Bp Envirctech LLC AUG~05-04 mu 03:03 I'll elRJ R!!al £!;lale 190?TJ68859 FA~ NO. 9D7 263 5190 )0.3 P. 03 c.ClntaminmiM hI' h~:alJðous In.1lcr;¡¡ls ~nd including CŒCLA ¡¡nd ~(aIC (:r.RCLA), ðnd erwi rOf'!(ìl(¡l1t,1 I nùt1cc¡'1)pllan(c (incFtJding "demn¡¡ors' f:\iIufc tl) provitl!: all fnforma.Lipn, mak~ air slIbm!ss1ons. MHJ lake .311 $!Cpi rcqvired \.Jy the ~ult1or¡IY uncJcr the envirònmcntJI laws Of any OthCf I¡¡w col1camìn¡; ''IIIy ¡¡pill, (/jsch.,cgí', or contarl\i"~tio", th¡)t Miy in ;¡ny m,)nner Jrise out of, Ìlt Cùrtl1t;>çtìon wiLh, dircclfy 01 indirectly (roO'l, Of olherwìsQ Í/\ctœnt to, ¡he IJyil1g, mJint~n1nce rep"lr, us!;", t:¡(ISLcnCe or rcrnovJI Qf MY Willcr tlt)oiltl'ent an~ dr",,/&~ (aeílíIY, ¡ncluding lhe bro;:¡king of any cqLJipl11CM Or ill(¡ IC.1ldng of ;lilY ~ul>st"ncc (re>m Ih~ waler treatment ,'\d drll¡n f,1cilily or othèr us~ ()( or COI11.'1ct wil.h tho CIRI Sllbsurr,,,,~ c>t¡¡te, eXCé(lt to the cxtent Lhe 5011! leg") C""~C of ¡he injury or d~m,¡¡g~ is l/1C 11egIigenca r.n wHlful misconduct of ClR!. Indemnj{ors shall IItlmcdi<llely "'(;Cpt toe tr:ndr:r by CIIU r;f ..oy such claim, dern;¡nd, C.1IJS8 of a('ion, ],)w5uit, 01' 01/)(;( proceeding brought <I¡P.iI1H CII~I. C'~J sl1<111 be ).)(ncd 3!: \In <tcidi'íon,, íl\5urerl Of'> iJJ/ fi~biljlY policies r~bterl [0 !f1o prOiiK.1 except worker'5 comp<>nsJtJoJ1. Insllr..nce pontic. mJitHi1incd b)' rovitoleel) shall be prlm;¡¡ry and policies mainrained hy CII~I shall be CJltC1SS c1I1d noncol1ltihutory L'O policies m~jnt,'íncd by l!n\l;rolcch 3nd ~¡"ù1l include sevcr.1b¡lil)' of interCSI ~nc cro!;:!-liabjl¡ly clauses. 1'toyid~d ,ho "bove conditions are mel, ClRI docs not oppose the issuance of a permit .'T,llhorizinß Lf,c d,ai,,;\¡:c field clcsctihcr/ in your fetter dõllc:d lone 7.2, 2004. r'~3se indica te by YOUt sigllatur£' Lc/ow your ¡¡grCl:'n~ent to ¡he aòoYl: terms anù return Lo Cf~r. We wish you th" best in thi~ pmjed, S;Jq~ Kt:e~ Vice PrcsicJcnf.,. Real l~sta(c i ~.i:(~t:j VCr) C"" LG'~ [);~ fn\litOteçh. uc: Tyon<:k N3tive Corpor;1tlon: ~"~~ -~ , '--~, -:-....-::c---=::.... _:~ (V\..-.:r l~ ~;I..c.~C2- D{>~il...'A.-i:.~c..,,¡,J.~ ~^",-\~í2._. ----_. '_" _" ..___._. I ..__~_._ .....___.. . .._.. "___''''. .~_... ...._.... ..__ . ....__...... ...__..._ I. .__. Ju1 30 04 01:55p Envirotech LLC - 19077768859 - p. 1 L1~I~ C ¡' ." ~' \ " t' ::,~ A .~ .'\"~ A Subsidiary of Tyonek Native Corporation P.O. Box 8467 Nikiski, AK 99635 46645 Kenai Spur Highway, Mile 19,5 Email mwiclœr(Ø¿ptialas.<a.net Website www.hmmcnvirotech.c_om Work 907 776 8766 Fax 907 776 8859 Cell 907 830 4805 Westside 907 583 2200 Eastside 907 7768795 M....· l...........·-' "P"". ". ".''''.''''". ·D"'·· f~ hr;.:' ~ ~ ·V'· '{,L:\Jt:1 ' t: ['1 >,,1 ·\~Ofj&GiGGa~.~··· Facsimile Transmittal Sheet ~··~'l·:\t:w~ DATE: 7 - 30·0..1 TO: 0IVY'"'t M?-t ,-vv-"'''"'' FROM: fl7J{J? (¡ )"-,,, !fA COMPANY: ,\:b.-1.Cè &-/- aÞ~Qf{ct - A 0 (; (. FAX NUMBER: 9 (.1 7-.::l. 7 &. - -; s tJ ~ NUMBER OF PAGES INCLUDING COVER: .3 PHONE NUMBER: PHONE NUMBER: 907-776-8766 RE: URGENT 0 FOR REVIEW ~ PLEASE COMMENTO PLEASE REPL YO NOTES/COMMENTS: Px:iU;røM¡Tr~1~tS.QU':[t~rµ~~Q~S.~tf¡{;;'I~vp:,'W~!{)iJ·~ì'm4¡Jþgt\g~Aþ~t?ffl.~nt¡ Envirotech LLC 19077768859 p.2 Ju 1 30 04 01: 55p ~ 'I;¡';q' IA v fI - A Subsidiary of Tyonek Native Corporation P.O. Box 8467 Nikiski, AK 99635 46645 Kenai Spur Highway, Mile 19.5 Email mwickcn:â!lltialask.t.nct Website www.hmmcmirotech.com Work 907 776 8766 Fax 907 776 8859 CeIJ 907 830 4805 Westside 907 583 2200 July 30, 2004, f{EC;EiVEIJ John K. Nonnan Commissioner State of Alaska Alaska Oil And Gas Conservation Commission 333 West Seventh Avenue, Suite 100 Anchorage, Alaska 99501 "_Oil & Ga; GI:.;)¡, QÇ;mr~~~: Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Dear Mr. Nonnan, I am writing to request that the record regarding the Envirotech Aquifer Exemption Application remain open for an additional 30 days. We have been working with Cook Inlet Region Inc. (COO), the owner of the subsurface at North Foreland, to obtain permission to operate the treatment system. The person responsible for real estate at COO, Mr. Kirk McGee, has indicated that the company's permission for the operation of the proposed Envirotech facility is orthcoming but that final sign off is required from several officials in the company. Unfortunately, the approval process is working at a slower pace than what was hoped. Envirotech has been assured that the required approval will be granted following a meeting of the CIR! board which is scheduled to take place on Thursday, August 5,2004. We have requested a 30 day extension from July 30 to accommodate any other unforeseen del':ls in the COO approval process that might require the record remaining open past the 5 of August. Please do not hesitate to call us if you have any questions or comments. Drilling Mud Treatnent Soil Remediation Site Cleanup Jnceration Used Oil ffand1ing Asbestos Abatement Jul 30 04 01:55p Envirotech LLC . 19077768859 e p.3 Envirotech LLC Sincerely, Envirotech, LLC. .---~~ ---- ~ /' //?~-- ~ Mike Wicker Operations Manager p'i <': ""\ C ~.,) CC. Thomas Maunder Ron Rozak ~J' I"":." ' ¡' ,. _.~ Ü. \~ \Æ~", ÍAêW~~, 2 Re: ~ost-He~ing Deliverables - Aquifer Ex_on for Envirotech's... . Mike, et al: We have received your latest message requesting to keep the record opbn with regard to the aquifer exemptión application for North Foreland. Commissioner Norman agrees and the record on this matter will remain open until close of business on Monday August 2, 2004. Please contact me with regard to this and any other issues on the exemption application. Mike or Ron, please confirm by return message that you have received this. Tom Maunder, PE AOGCC Mike Wicker wrote: Tom, I received a call from Lisa Rigier with CIRllate Friday afternoon and they are trying to get the letter finished up, but due to some people that will not be back in the office for a week they asked if we could get a two week extension. Lisa feels they can have this all done by then.That would bring us to august 1st. should this pose a problem please let me know and I will pass it on. Thank you, Mike Wicker To: Mike Wicker Cc: Ron Rozak; Gerry Allen; Derek Maat ; Jody J Colombie Sent: Friday, July 16, 2004 2:45 PM Subject: Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Mike, I have received your email requesting that the record remain open with regard to the aquifer exemption application for North Foreland. Commissioner Norman agrees and the record on this matter will remain open until close of business on July 23, 2004. Please contact me with regard to this and any other issues on the exemption application. Tom Maunder, PE AOGCC Mike Wicker wrote: Tom, I spoke with CIRI on Thursday and went over everything with them and we were anticipating the letter today but have not received it yet. if we could please keep the record open till Friday of next week that would sure help. I appreciate your patience lof4 7/20/2004 2:31 PM Re: ~ost-Hearing Deliverables - Aquifer E.on for Envirotech's... . on this. Thank you, Mike Wicker To: Maunder Cc: Gerry Allen; Derek Maat ; Mike Wicker Sent: Wednesday, June 30, 2004 5:50 PM Subject: Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Tom, I talked to Mike Wicker at Envirotech and he agreed we should keep the record open. He was told the permission letter would be no problem, but he does not have it and does not know when it will be delivered. Therefore, on behalf of Envirotech LLC, we request the record be kept open until July 16, 2004. Ron To: Ron Rozak Sent: Wednesday, June 30,200411:15 AM Subject: Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Ron, Based on discussion with Commissioner Norman, you should probably request that the record be kept open. I think we need to have a complete record to make a decision and ownership is a key issue. Do you have any idea of when COO might deliver their letter/documents to Envirotech/Tyonek?? It is probably unlikely that anything would happen until next week. Please let me know. Tom Ron Rozak wrote: Tom, IF Envirotech cannot supply CIRl's authorization letter by tomorrow, I guess the record needs to remain open until you get the letter, unless the aquifer exemption permit could be conditioned on you receiving the permission letter. The boring log was faxed (not electronic version) to me, and not a good copy, but I will fax it to you. Ron ...... .·.··""=o"'="''''====''*''~=.~'''''''"·,,'~.,='''''==_'''==''=='''''=''',,"""""'=:_''''='''''====_ ................................""',=.===~.===,== To: Ron Rozak Sent: Wednesday, June 30, 2004 7:26 AM Subject: Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Thanks Ron. Your response implies that you will need the record to remain open. Is 20f4 7/20/2004 2:31 PM Re: ~ost-He~ring Deliverables - Aquifer E.ion for Envirotech's... . that correct?? Also, in your letter it is mentioned that a boring log is attached. I presume that is only coming with the hard copies as there was no electronic copy attached to the message. Please let me know regarding these questions. Tom Maunder, PE AOGCC Ron Rozak wrote: Tom, Thank you for the acknowledgement. The original was mailed today. We have not received the CIRI permission letter. According to Derek Maat, CIRl's legal department is drafting an indemnification form for Envirotech to sign before CIRI will issue the letter of permission. I am copying this em ail to Mike and Derek so one of them can answer your question about when the letter should be available. This may similar to those Aggie jokes I hear occasionally, "How may lawyers does it take to draft a form?" I will have my legal department get back to you on that? Ron To: Ron Rozak Sent: Tuesday, June 29, 2004 1 :59 PM Subject: Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Ron, This acknowledges receipt of your submittal. One item needs further clarification. It is not clear if you/Envirotech have received a letter from COO or if you are still waiting on such letter. Would you please clarify?? If you have not received the a letter, do you have an idea when you might get one?? Will you need the record to remain open longer?? Thanks, Tom Maunder, PE AOGCC Ron Rozak wrote: Tom, Our letter with deliverables requested by the Commission is attached. The signed and stamped original is being mailed today. This is alii can do with the information available at this time. I hope it sufficiently answers the questions. As always, I appreciate your candid comments. Ron .='''=. ....mu.................,..._,",.==,==""==.=="".~_ .. ............,...,."'...,"~.===,... .. .. . . . _.... n. .... n. ==..,....."'~..~.~ --.- .............................,..................... To: Ron Cc: Gerry Allen; Derek Maat ; Mike Wicker; Jodv J Colombie 30f4 7/20/2004 2:31 PM Re: ~ost-He~ring Deliverables - Aquifer E.ion for Envirotech's... . Sent: Friday, June 18, 2004 11 :57 AM Subject: Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Ron, I just sent you a fax with regard to your clarification on "confining layer". Regarding your request to extend the date to submit the deliverables, Commissioner Norman has advised me that extending the date to July 1 is acceptable. Please feel free to contact me with any further questions. Tom Maunder, PE AOGCC Ron Rozak wrote: Tom, I believe Envirotech has the letter addressing the ownership of the subsurface rights, but we are waiting for a well log from Aurora (in Houston, TX) that would help answer some of the Commission's questions. However, I will be out of the office most of next week and unable to submit the deliverables by Thurday, June 24. Therefore, we would to extend the date to July 1. Let me know if this is a problem. Ron PS - Did my June 16 email accurately state the Commission's question about the confining layer? 40f4 7/20/20042:31 PM Re: Post-Hearing Deliverables - Aquifer Exe.on for Envirotech's... .. , . Ron, This note acknowledges receipt of your message requesting that the record on this matter remain open until July 16. I have been advised that this is acceptable. Please also be informed that we have received the original copy of your "deliverables" letter. Please contact me with any questions or comments. Tom Maunder, PE AOGCC Ron Rozak wrote: Tom, I talked to Mike Wicker at Envirotech and he agreed we should keep the record open. He was told the permission letter would be no problem, but he does not have it and does not know when it will be delivered. Therefore, on behalf of Envirotech LLC, we request the record be kept open until July 16, 2004. Ron ""''''='''''''''''''''''..-hmm,m.===='',,, .. ................ ..... . ...... ,_,.. _._........==,.,=="=======""==,,,,==,,,,==,..... """"""'=="'=="'="""""""==="-'==="'''''''='''''''''''='''''''''''''> To: Ron Rozak Sent: Wednesday, June 30,200411 :15 AM Subject: Re: Post-Hearing Oeliverables - Aquifer Exemption for Envirotech's North Foreland Facility Ron, Based on discussion with Commissioner Norman, you should probably request that the record be kept open. I think we need to have a complete record to make a decision and ownership is a key issue. Do you have any idea of when CIRI might deliver their letter/documents to EnvirotechlTyonek?? It is probably unlikely that anything would happen until next week. Please let me know. Tom Ron Rozak wrote: Tom, IF Envirotech cannot supply CIRI's authorization letter by tomorrow, I guess the record needs to remain open until you get the letter, unless the aquifer exemption permit could be conditioned on you receiving the permission letter. The boring log was faxed (not electronic version) to me, and not a good copy, but I will fax it to you. Ron ...........................="===....=.=",="',,,""""',..,,,,,,.,,,"""""""""''''''=.=='''''''''==''===''''''''''='''''','''''''=''=''.=-'.''''==''="===,=""",=,,,,=,,=,==,,===~.="===""==''''==='='==''=''.==,,== 1 of3 7/6120048:44 AM Re: post-Heari~g Deliverables - Aquifer Ex_on for Envirotech's... . To: Ron Rozak Sent: Wednesday, June 30, 2004 7:26 AM Subject: Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Thanks Ron. Your response implies that you will need the record to remain open. Is that correct?? Also, in your letter it is mentioned that a boring log is attached. I presume that is only coming with the hard copies as there was no electronic copy attached to the message. Please let me know regarding these questions. Tom Maunder, PE AOGCC Ron Rozak wrote: Tom, Thank you for the acknowledgement. The original was mailed today. We have not received the CIRI permission letter. According to Derek Maat, CIRl's legal department is drafting an indemnification form for Envirotech to sign before CIRI will issue the letter of permission. I am copying this email to Mike and Derek so one of them can answer your question about when the letter should be available. This may similar to those Aggie jokes I hear occasionally, "How may lawyers does it take to draft a form?" I will have my legal department get back to you on that? Ron To: Ron Rozak Sent: Tuesday, June 29, 2004 1 :59 PM Subject: Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Ron, This acknowledges receipt of your submittal. One item needs further clarification. It is not clear ifyou/Envirotech have received a letter from COO or if you are still waiting on such letter. Would you please clarify?? If you have not received the a letter, do you have an idea when you might get one?? Will you need the record to remain open longer?? Thanks, Tom Maunder, PE AOGCC Ron Rozak wrote: Tom, Our letter with deliverables requested by the Commission is attached. The signed and stamped original is being mailed today. This is alii can do with the information available at this time. I hope it sufficiently answers the questions. As always, I appreciate your candid comments. Ron 20f3 7/6120048:44 AM Re: post-Heari~g Deliverables - Aquifer Ex_on for Envirotech's... . To: Ron Rozak Cc: Gerry Allen; Derek Maat; Mike Wicker; Jody J Colombie Sent: Friday, June 18, 2004 11 :57 AM Subject: Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Ron, I just sent you a fax with regard to your clarification on "confining layer". Regarding your request to extend the date to submit the deliverables, Commissioner Norman has advised me that extending the date to July 1 is acceptable. Please feel free to contact me with any further questions. Tom Maunder, PE AOGCC Ron Rozak wrote: Tom, I believe Envirotech has the letter addressing the ownership of the subsurface rights, but we are waiting for a well log from Aurora (in Houston, TX) that would help answer some of the Commission's questions. However, I will be out of the office most of next week and unable to submit the deliverables by Thurday, June 24. Therefore, we would to extend the date to July 1. Let me know if this is a problem. Ron PS - Did my June 16 email accurately state the Commission's question about the confining layer? 30f3 7/6/20048:44 AM [Fwd: Re: Post-H~aring Deliverables - AqUWXemption for Envir... . Enclosed are Mr. Rozak's post hearing deliverables with regard to the Envirotech hearing of a few weeks back. He indicates that he has sent signed copies in the mail. It is not clear if a letter from CIRI, the sub-surface owner, has been obtained. I will clarify this point. Tom -------- Original Message -------- Subject:Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Date:Tue, 29 Jun 2004 11 :21 :01 -0800 From:Ron Rozak <ronrozak(G}alaska.net> To:Thomas Maunder <tom maunder(G}admin.state.ak.us> References :<00530 1 c45 566$1 f3 f8c20$0200a8cO@HP7955> <40D34917.8040004(G}admin.state.ak.us> Tom, Our letter with deliverables requested by the Commission is attached. The signed and stamped original is being mailed today. This is alii can do with the information available at this time. I hope it sufficiently answers the questions. As always, I appreciate your candid comments. Ron To: Ron Rozak Cc: Gerry Allen; Derek Maat ; Mike Wicker; Jody J Colombie Sent: Friday, June 18, 2004 11 :57 AM Subject: Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Ron, I just sent you a fax with regard to your clarification on "confining layer". Regarding your request to extend the date to submit the deliverables, Commissioner Norman has advised me that extending the date to July 1 is acceptable. Please feel free to contact me with any further questions. Tom Maunder, PE AOGCC Ron Rozak wrote: I Tom, 10f2 6/29/20042:35 PM [Fwd: Re: Post-H~aring Deliverables - AqUitixemption for Envir... . I believe Envirotech has the letter addressing the ownership of the subsurface rights, but we are waiting for a well log from Aurora (in Houston, TX) that would help answer some of the Commission's questions. However, I will be out of the office most of next week and unable to submit the deliverables by Thurday, June 24. Therefore, we would to extend the date to July 1. Let me know if this is a problem. Ron PS - Did my June 16 email accurately state the Commission's question about the confining layer? to Hearing Questions, 6-28-04 Content-Type: applicationlmsword Content-Encoding: base64 20f2 6/29/20042:35 PM [Fwd: FW: Envirotech Aquifer Hearing] . . Subject: [Fwd: FW: Envirotech Aquifer Hearing] <tom _ maunder@admin.state.ak.us> 7 :43 -0800 Jody, Here is another email that ties in with the most recent one from Ron Rozak. I have a hard copy with attachments that I am bringing to you. Tom Subject: Date: From: To: <David -------- Original Message -------- FW: Envirotech Aquifer Hearing Thu, 03 Jun 2004 15:57:20 -0800 Woolley, Oran <Oran Woolley@dec.state.ak.us> Stambaugh, Sharmon <Sharmon Stambaugh@dec.state.ak.us>, Johnson, David Johnson@dec.state.ak.us>, Wingerter, Tim <Tim Wingerter@dec.state.ak.us> I am forwarding an invite to you Sharmon, that I received from AOGCC, to attend a hearing on this project. This will affect ADEC in a profound way. I attached an e-mail summary I sent you last April on this project. This is a funny situation for me. When this gets approved, Rozak will send us plans for the injection well for us to approve. Since I do some plan reviews, I guess it makes sense for me to do it as I am familiar with the facility. However, the permit app will go to you Sharmon. You will have to work with Tom Maunder at AOGCC to put a permit in place for it. It is kind of a convoluted process. This thing will be precedent setting for us. Seems like it makes sense to keep an eye on it and figure out what is in our best interest. Any questions, give me a call. Oran -----Original Message----- From: Thomas Maunder [mailto:tom maunder@admin.state.ak.us] Sent: Thursday, June 03, 2004 3:33 PM To: Oran L Woolley Subject: Envirotech Aquifer Hearing Oran, Just wanted to drop you a note with regard to the upcoming hearing on Envirotech's (Rozak) application for an aquifer exemption on the West Side. A hearing on this application is set for Thursday, June 10 beginning at 9 in our offices at 333 W. 7th Ave. (behind Nordstrom). I was wondering if you or any of your associates might be coming?? This has been an interesting issue as you well know. Holding a hearing for an aquifer exemption is fairly normal for the Commission and the intent is to build a sound record for the decision. You and/or your colleagues are welcome to attend. Please give me a call with any questions. Regard, Tom Maunder, PE AOGCC lof3 6/21/20041:29 PM Re: Post-Hearing Deliverables - Aquifer Exe. for Envirotech's... . Tom, Thank you for the quick response. FYI, I just received a call from Sharmon Stambaugh at the Industrial WW Division and we discussed the project and what type of permit would be needed. She was not very familiar with the project, only what she had discussed with Oran Woolley by phone, but said she would be the supervisor for the review and thought it sounded like we would need to submit plans for review per site specific criteria in 18AAC70 and apply for an individual permit for injection similar to one ADEC issued for the GTL plant in Nikiski. She would have Oran send all of his files and review them before saying anything conclusive, thought it would be best for Envirotech and I to meet with her and go over the Envirotech treatment process, onsite drainfield design, aquifer exemption permit, and site conditions, proposed MW locations, etc. We will let you know of meeting. Of course, none of this happens if we do not get exemption permit. Ron To: Ron Rozak Cc: Gerry Allen; Derek Maat; Mike Wicker; Jody J Colombie Sent: Friday, June 18, 2004 11 :57 AM Subject: Re: Post-Hearing Deliverables - Aquifer Exemption for Envirotech's North Foreland Facility Ron, Ijust sent you a fax. with regard to your clarification on "confining layer". Regarding your request to extend the date to submit the deliverables, Commissioner Norman has advised me that extending the date to July 1 is acceptable. Please feel free to contact me with any further questions. Tom Maunder, PE AOGCC Ron Rozak wrote: Tom, I believe Envirotech has the letter addressing the ownership of the subsurface rights, but we are waiting for a well log from Aurora (in Houston, TX) that would help answer some of the Commission's questions. However, I will be out of the office most of next week and unable to submit the deliverables by Thurday, June 24. Therefore, we would to extend the date to July 1. Let me know if this is a problem. Ron PS - Did my June 16 email accurately state the Commission's question about the confining layer? 1 of 1 6/21/20048:14 AM FW: Envirotech Aquifer Hearing . Subject: FW: Envirotech Aquifer Hearing From: "Woolley, Oran" <Oran_ Woolley@dec.state.ak.us> Date: Thu, 03 Jun 2004 15:57:20 -0800 To: "Stambaugh, Sharmon" <Sharmon_Stambaugh@dec.state.ak.us>, "Johnson, David" <David_Johnson@dec.state.ak.us>, "Wingerter, Tim" <Tim_ Wingerter@dec.state.ak.us> - I am forwarding an invite to you Sharmon, that I received from AOGCC, to attend a hearing on this project. This will affect ADEC in a profound way. I attached an e-mail summary I sent you last April on this project. This is a funny situation for me. When this gets approved, Rozak will send us plans for the injection well for us to approve. Since I do some plan reviews, I guess it makes sense for me to do it as I am familiar with the facility. However, the permit app will go to you Sharmon. You will have to work with Tom Maunder at AOGCC to put a permit in place for it. It is kind of a convoluted process. This thing will be precedent setting for us. Seems like it makes sense to keep an eye on it and figure out what is in our best interest. Any questions, give me a call. Oran -----Original Message----- From: Thomas Maunder [mailto:tom maunder@admin.state.ak.us] Sent: Thursday, June 03, 2004 3:33 PM To: Oran L Woolley Subject: Envirotech Aquifer Hearing Oran, Just wanted to drop you a note with regard to the upcoming hearing on Envirotech's (Rozak) application for an aquifer exemption on the West Side. A hearing on this application is set for Thursday, June 10 beginning at 9 in our offices at 333 W. 7th Ave. (behind Nordstrom). I was wondering if you or any of your associates might be coming?? This has been an intèresting issue as you well know. Holding a hearing for an aquifer exemption is fairly normal for the Commission and the intent is to build a sound record for the decision. You and/or your colleagues are welcome to attend. Please give me a call with any questions. Regard, Tom Maunder, PE AOGCC -.-.-................................................................................................................... Content-Description: Envirotech Tyonek II . ForwardedMessage.eml ' Content-Type: message/rfc822 -- .--....-.-.-..-......................... ..... ""-" --- ----- ............................................................ ............ 1 of 1 6/21/20049:08 AM Envirotech Tyonek . . Subject: Envirotech Tyonek From: "Woolley, Oran" <Oran_ Woolley@dec.state.ak.us> Date: Fri, 9 Apr 2004 15:24:05 -0800 To: "Johnson, David" <David_Johnson@dec.state.ak.us>, "Wingerter, Tim" <Tim _ Wingerter@dec.state.ak.us>, "Keiser, Gretchen" <Gretchen _ Keiser@dec.state.ak.us>, "Stambaugh, Sharmon" <Sharmon_Stambaugh@dec.state.ak.us>, "Williams, Beverley" <Beverley _ williams@dec.state.ak.us>, "Forgue, Scott" <Scott_Forgue@dec.state.ak.us>, "Kukla, Alan" <Alan _ Kukla@dec.state.ak.us> For those of you that may not know, Envirotech is a subsidiary of Tyonek Native Corp, and they advertise themselves as a, "Hazardous Waste Abatement" company that does remediation, spill cleanup and (incidentally) wastewater treatment. The Tyonek facility has been servicing the gas fields near Tyonek for a year or two now. They have been accepting drill muds, produced water and solid waste mainly from a company named Aurora Energy. Aurora Energy operates the Tyonek gas field and has a contract with Envirotech to send them all the produced water from Aurora's gas well(s) for disposal. Envirotech began accepting and disposing of the produced water without an engineered plan approval or permit. They attempted to gain engineered plan approval but were unable to do so in a timely fashion. They were also operating an incinerator without the proper permits. The Department entered into a COBC with Envirotech, which was a joint effort between the divisions of AWQ (air compliance) and EH (wastewater disposal) . The COBC was signed by Kristin Ryan and Tom Chapple. Under the COBC, Envirotech is currently disposing of the produced water by a vaporization method utilizing the incinerator. This is a temporary disposal method and Envirotech has been searching for alternate methods of treatment and disposal that they can get approved and permitted. Envirotech applied for an NPDES permit for discharge of the water, after treatment, to Cook Inlet. EPA denied the application, citing their policy of zero discharge of produced water to the Inlet. Envirotech is aware that even after treatment, the produced water will not be close to meeting the water quality standards, mainly for salt and TDS. However, the groundwater aquifer that they would be discharging to if they disposed of the produced water in a Cl V UIC (which was their original intent) is under the influence of tidal action from Cook Inlet, and therefore brackish and not potable. Last month, on March 15th, Envirotech, through their engineer, Ron Rozak, submitted a request for an aquifer exemption to A.O.G.C.C., citing 20 AAC 25.440 of the Oil and Gas regulations (see attachment below). A.O.G.C.C. has reviewed the submittal and has found it to be consistent with the requirements of the regulation. They are preparing to go to public notice with the aquifer exemption request. Pending the results of the public notice, A.O.G.C.C. is planning to grant the aquifer exemption. This would make the aquifer eligible for disposal of produced water under A.O.G.C.C. regulations. A.O.G.C.C. contacted me yesterday and said that if/when the exemption is granted, that they would like ADEC to do the plan review and the Cl V permitting since A.O.G.C.C. does not have expertise or regulatory authority over the Cl V type construction. However, since this wastewater is a Cl II fluid regulated by A.O.G.C.C. they would like to do what they called an "overlay" permit on our Cl V permit. So what we have is a UIC that is not a straight forward Cl II UIC or a Cl V UIC. It is really a combo of both and will require cooperation between A.O.G.C.C. and ADEC to regulate. Assuming that Envirotech and A.O.G.C.C. finalize the exemption within the next 4-6 weeks, we will have to address how we will handle an engineered plan submittal and a wastewater discharge permit application to an aquifer that that has been exempted from the typical regulatory scheme by A.O.G.C.C. approval of an exemption. To my knowledge, ADEC has not run into this 10f2 6/21/20049:07 AM Envirotech Tyonek situation before. I be~ A.O.G.C.C. and EPA have appr~aquifer exemptions in the State before, however none that would affect ADEC in this way. The engineered plans and permit application will be for a produced water treatment system that they have been operating under the COBC for some time now, which will be connected to a new bed type soil absorption system, approximately 600 feet from the Inlet, that will discharge between 240 barrels per day (bpd) and 1,200 bpd maximum. The wastewater will be saline with high TDS and some metals, such as barium. It would seem the groundwater would need to be monitored to insure that the discharge did not make the groundwater quality worse than it is, however, I do not see how 18 AAC 70 or 72 even addresses this issue. The Antidegradation Policy regs in chapter 70 do not seem to apply, and I do not know how our regs work in conjunction with the chapter 20 A.O.G.C.C. regs. So those are the issues we will probably have to address soon. Let me know what you think. Oran «20 AAC 25.doc» Oran Woolley@dec.state.ak.us 43335 K. Beach Road, #11 Soldotna, AK 99669 (907) 262-5210 ext. 227 Fax - (907) 262-2294 iEnvirotech Tyonek.eml 20f2 6/21/20049:07 AM . . 20 AAC 25.440 FRESHWATER AQUIFER EXEMPTION. (a) Upon receipt of a letter of application, and in accordance with (b) of this section, the commission will, in its discretion, issue an order designating a freshwater aquifer or portion of it as an exempt freshwater aquifer, if the freshwater aquifer meets the following criteria: (1) it does not currently serve as a source of drinking water, and it cannot now and will not in the future serve as a source of drinking water because (A) it is hydrocarbon-producing or can be demonstrated by the applicant to contain hydrocarbons that, considering their quantity and location, are expected to be commercially producible; (B) it is situated at a depth or location that makes recovery of water for drinking water purposes economically or technologically impractical; or (C) it is so contaminated that recovery of water for drinking water purposes IS economically or technologically impractical; or (2) the total dissolved solids content of the ground water is more than 3,000 and less than 10,000 mg/l, and it is not reasonably expected to supply a public water system. (b) To apply for exemption of a freshwater aquifer, an operator shall submit to the commission a letter of application that includes sufficient data to justify the proposal, including data to substantiate that the criteria in (a) of this section are met. The commission will provide 15 days legal notice and the opportunity for a public hearing on the matter in accordance with 20 AAC 25.540. (c) Freshwater aquifers within the state that, as of June 19, 1986, are designated as exempt aquifers by the United States Environmental Protection Agency under 40 C.F.R. 147.102 are accepted as exempt aquifers by the commission. (d) A commission order designating a freshwater aquifer or a portion of it as an exempt freshwater aquifer is not effective with respect to underground disposal or storage operations subject to 20 AAC 25.252 or injection operations subject to 20 AAC 25.402 until the United States Environmental Protection Agency has been provided the opportunity to review the order under 40 C.F.R. 144.7(b)(3) and has (1) approved the order, if it was issued under (a)(I) of this section; or (2) has allowed the applicable time period within which to disapprove the order to expire without acting on it, if the order was issued under (a)(2) of this section. History - Eff. 4/2/86, Register 97; am 11/7/99, Register 152 Authority - AS 31.05.030 #10 Rug 30 04 12:41p AUG-26-04 THU 01:38 PH Envirotech LLC Ce<ea l Eslale EI"I\Jtrot.Ðcn L.LC C\Rl Re~1 Esl~~e 19077768859 FAX NO. 907 2.190 P 02 1907176885 p.~ FRX NO. 9Q7 2B3 Sl9Q P, 02 p.2 Auë os 04 03:28p AUG-QD-04 THU 03:02 PM ~tCIRI _1._-.-·...-·,-·- ....__..... ...- ---...-- ^\lgU$t 4, 2004 B;u\ Gllfbcr Mcmbor ~E!prëscnUld\Je Erl'lìroccch, LLC P.O. HOK 9)33 ^"choragl'. AK '.)9509-3330 SLlbec¡: (>rOþOlied Erwlrotcch Ll'Ç W~tf:r Tre~lmcn\ and Drãin l'it!lð ¡;"dllly at Norln For~land.:ll WQnl"k. _~'-..~" /oa'.!:'::.-·· r:.;;~· ,"~;""_,,,,\._ "",:.- r> . -1\(}~ De;¡r Mr. Garber: Plöa1Q t'onslclor this Ictlcr CIRI's roon·cppo~i\ion to Enviroled1 lLC's ap!)\i¡;ó\tiun f(1r 3 non· rlonlL'!scic w~&lew;ner disdtñrge )¢trl'lìt from Lha ADEC for a weller tre:umcnl and dr.dn (¡aid fa.cililY al Non.h fDreland at iyonelc. ClRt b"se.s thís non-opposition on IlS I,Ind8rSI"'l'Idìn~ that; 1) lhQ f"dliLy i5 lot"2Itecl npploximM~Y 400 "'et flom Cnok Inlcl, bdwc~n the North foreiI"d dock ~.,cl Tycnclc C1eek; 2} !h,! aG\lÏfer doc~ oot currently $efve as a ftl!sh WOller source of drlnkinß W3lef nnd will flot do so in Lhl! futulc bccðu~e it is tQO highty con1...mln¡Htd .....Ilh alMfilter from Cook Inl~t \0 mate recQv~ty of drinleif'lg w<\ter eCOI\t>micillly p'ò1ctici)ble; 3) Iha tQlat dissolved s~id5 con\enlof th~ srOlmd w:lller ì~ mor~ th~1\ 3.000 mr/t ô\nJ 1~5S th:1n 10.000 Tnp)1 "I'd is "ot re<JSlJn:\bly c;xpec\ed to ¡¡¡rply iI p\.lbllc W~f~r sys~etT1¡ òill1d 4) Et\Yirotllch Ltc wiB foHow all applic;&blc '(:d~rill. slate j11\c! loc:.\ laws, rules arId reBLlIMlons¡ and 5) Env¡,nlech I.LC and if!> palcol, Tyonek N:Jlive Carp(,rðtion snail derend, huld h;m'f\less, :¡nd delend CII~I ii' described Þelow. Envirou:r:h, LLC >!od its p4)wnr, Tyondc Native C.orporAtlon ("lndernnil.Ors'l) and su[)sidì:trie~ lhal, a~GI\lJ, emplDyees, cont,~ctOr! and ~si¡;nS. ÎDirrt1v ¡md 51JI¡ørally a"un'¡e "II rcsponsibHilY, ris\¡, ~nd li<1birily for 311 I"juries to pOfSClI'U or damage \0 plop~rly resulting (roo¡ ,he r:ota¡tr~lctìon, MiJjl"I~'''ilnc'-', op(!talion, or r~mO'l¡1 or thœ wate.' Ir(;~tl1\ent and dra¡~ fllCill\lcs site iu;ms.. Ctl~I's Sr¡bslJrfðce esl;ü~ .nrJ for Lht: U~ of or c:ònt3cr will\ ,ho CIRl subsurface ~st.'(<1, Th¡s obligolricn is lInconciÎtjon:tI ilncl absolulC, without r~lrd to \h~ tlCgligertce or cfe.gree o( CIIIC c¡o.ofcls~d by Indemnitor., their ~Eel'\ts, Qm¡)Qyees, COI\Irac\D!'S ¡¡nú auigns. Indemnilors "srQC to p~y ORI for ;\11 dð''r'Il1ges $o((t:rcd by CIR.I :I~ ò le$ulc or du~ e~erc1sr: by Indert\nitor5 Qf the rlßh~ gIMLet.! In this letler agreemo\t, 0( for violation U) lhe tellns of this. letter .:\srœement. Th~ Qbligiltion of Ind~rMitcm to pay ddtnitges eXlCl\d$ to OI)Oril~¡on' w¡~hin and ollt$ldc the bound.uics or the CIRl <:lIhröL1TfJ.ce cstal~. rndemnitor~. their 1Ig(!l\ts, en11)luyee.s, contractors :md ~"llSns Clgrec 10 doft:nd, índ~l\mify, and huld harmless CtR!, i\$ Ò\SQMS, emploYI2C$, ~n~ ¡usisns from nnd :!g.inst any .,nd ~n dem,mtls, causeS ()f action (whl'."lhcr ¡nthe nanlle tlf :In :led"n for d,1'fi~gOJ, indcmnilY, t:onu1bulon, gOý(HM'CI\~ (em (ac()\t~ry 01 OIhcrwÎs~), fines, judgments. suits, c1¡)Îms. M.:tinn5, ~ror;l!C!rliI18S, l¡)s~5, costs. (including 1~sono.De .m.Qrnc)l'~ leE's ant! cons), c)cpCI'Sl!s¡ charges, rOl'feltLtrc:~, 1i~ns, lIn.bltitlC!$, 5ettl~mcn~, p~n.1lje$, ,,¡o!;¡tionr. of bw Md dafl1i!gt!s of ,my kínri or ~tUI~ whatsoever, lì\dlHfjn~ b\} nðl Limlœd to 11m,,, illlcgin¡; p~15cnlll inÎLSIY, wrol1gM dUJlfh, nuÚi¡¡nce I>rupcny d~m¡~(), ~rwirOOlI1~nt.a1 c;ont~"\¡n,,\i()n (i\(:luding, but nOE limired to, ~ny disposal. rdcò\\;8. 5plfl or dí,ch1rge or <In\, \hr~~tcncJ ÓI~pOSC1I, fC:\c41Se. spill or di'char~ of or ...........,---... ...,~--........._-_.. ._______._.....__ I --....-.. ~............._-.......---.,... Jn~"c .!oYnr.f.T. SVII t. S~~ . 1'.0. !III( 'UJ~ . I'oNum1tAC&, I\L^!i1(A "~tJ.·)~"1 ;<¡IP 17'·Aua . 1'^K ,Un7) ¡'p.n~' . 'IV,I, Site: 1Io.""...d,I.<øon ..--.,-". -,-,,-_._,._-,,-,-~,--,_.._._..__..- ---.,.-.,>.-... .----......- Aug 30 04 12:41p AUG-28-04 THU 0]:38 PM Envirot@ch LLC CI.ea I Eslah 19077768859 FAX NO. 907 2' 90 p, 03 190777S695 p.~ FAX NO. 907 263 6190 P. 03 p.3 nu, 05 04 03:2ep , (tUG-05-04 THU 03;03 PM r.r'\\l ~ r"'otøcn LLC CIR! Re~1 Estale conmn'th,aüoo hV hi\itardous 'n~I<:,ì.,s :Inti iod\l(ling CtRClA and SIi11C CL:RCLA,. and enl(i'of\1'1~'tò\1 nonC:O\'I1pl1ðncø ¡including Indemniton' bllur~ tQ provid~ all tl\formlll.ion, mGkc AU S(Jbl'l\ì~~iol'S, ~l1d l¡)l~c 311 ~Ieps rcq...it15cl by eke ¡suthQ(Ì1y under d,e enviNnmenl.11 laws or any t)1¡'1.I! 'aw (C)nc",rning <'oilY spill, dJschilrgr.. or cOl\t:!min.\lion), that may in any m;¡oner arise V\Jt Or, in cánnec:tioll with, dircclly ~r Indirccdy (rnm. or ,,¡herwlsc ¡",(dent to, the idVI",. maintenance, rct)3.tr, IJse, (1)(iSlc"c:C: or ICInO"'"I of ;\ny wa\Cr IU!lIlInent and dtAI"~&ê bcllity, including Lhe br¡~akjn!& of .my QCu;prru~nl Or \he Ic.kina of IU\Y ~lJbstM\Ct! ('001 1ho water treatment and drj\ìo f~cmty Of oth~r U~~ 01 or contact w¡Ln ~he CIRI Sub\l,Hf..\œ ~st;lte. exCCfI{ to !he C1CLent tne sote legnJ C3USI! of the Injury or di\më1ße j.) tlte '~ßlígen(o or willM misconduCt of aft!. fodemnilur5 $"'(\11 imrncdiau¡ly IIC'Ct'lt !he tlmr/CI l)y ClRI of Dny ~Il'" dl\1m. de¡n;.m£., còu~e of IIclion. I..VlSUa, or Qlhc:r proceeding bfOlJgh¡ ¡\¡;ainst C(f~1. (JR! sh..tI bt' Mn1cd ;1£ ó\Þ additiQNI irn¡ured on all li:lbililY potici~5 r~I13len (0 tho ploj~(l ~(Cepl worker'. COn1\}Ofls",IÎl)n. Il\&ural\œ roliclcs rni)in(¡1if\~d by E.nvirolcch sh:\1\ be primary ;loci pCllki(!fo malnralnQd hy clI~r shall be:! t:·ucss IInd ooncotluibulory to r'C)Hc:íes nuintnlncc:! by I:nvrro\,cc[, ~nd $hall indLJdc sCV\lral)i1tly of 1nterc5\ and cl'Qss-lìabiJicy clauses. I'nWi(tod .he ,bove c;ol'\ditíon5 arc mc'. ORI èoc=s not QJ)PO~G ¡Me isw;¡nœ of <1 pernht Atllhoriz:ífl6 Iho ¡kafl1ngc field cl¢sc(lb~(t in yùllr I~rtt!r dated 'un!!! U, 2004. PII#.;t$~ indicate by your ~ÎS"¡¡t&.lfC b~l('w your :Ll:;røt'lnent ~ .he abo\l~ terms and rt!turr\ 10 CUtl. We wish YO~I tM best in this prc\;ect. ?!!/Ú^-- VIce! Pr(!sldefl\' R,,;Io! E~tJ,l~ Envlrolflcn, u.c: ....--~ ~__ ~~~_ 7""_,~ :;I:U;!;¿'~ -_ __ 4..... "._" ..... .__, _.... ,..._ _......~ _.._,.. ,,_. ._.. ,,_._ .__" '__._ ...._.. '-",. _.... ...._. .___. #9 e e ROZAK ENGINEERING Civil, Construction & Environmental Consulting P.O. Box 350 Kenai, Alaska 99611 (907) 283-5640 Fax (907) 283-0747 June 29, 2004 John Norman, Commissioner Alaska Oil & Gas Conservation Commission 333 W 7th Avenue #100 Anchorage, Alaska 99501-3539 Re: Freshwater Exemption for Underground Disposal of Treated Oil Field Wastewater Envirotech Facility at North Foreland, Cook Inlet, Alaska Dear Mr. Norman: On behalf of Envirotech LLC, a subsidiary of Tyonek Native Corporation, we are submitting this letter in response to the questions raised by AOGCC at the hearing on June 10, 2004. Based on our notes and on the pages of the transcript that Tom Maunder provided to us, we have restated the questions, which are followed by our responses. 1. Where are the boundaries of the aquifer under consideration for the freshwater exemption, particularly the boundary for 3000 mg/l total dissolved solids (TDS)? We do not know the boundaries of the surface aquifer encompassing this area, however, according to credible references and our experience, we do know enough to give a sense of what is happening at this site. As stated in a U.S. Geological Survey paper, normally freshwater moves seaward continuously at a rate related to the head above mean sea level in the freshwater aquifer. The result of this movement is that, in an unconfined system [like the aquifer at the subject facility], freshwater discharges to the sea through the saturated zone from the high-tide line for some distance offshore.l Walton states that, under natural conditions a hydraulic gradient exists toward the sea that causes a discharge of fresh water to the sea and that there is a body of salt water, usually in the shape of a wedge, underneath fresh water [at the seaward interface with the aquifer]. This fresh-salt water interface is typically assumed to be abrupt, however, it is a transitional zone subject to dispersion? Freeze and Cherry wrote that, assuming simple hydrostatic conditions in a homogeneous, unconfined coastal aquifer, there tends to be a mixing of salt and fresh water in the zone of diffusion and that the size of the zone is controlled by the dispersive characteristics of the geologic strata.3 1 U.S. Geological Survey, Water-Supply Paper 2254, Study and Interpretation of the Chemical Characteristics of Natural Water, Third Edition: 1989. 2 Walton, William C., Principles of Groundwater Engineering. (Chelsea, MI: Lewis Publishers, Inc., 1991) 3 Freeze, R.A. and J.A. Cherry. Groundwater. (Englewood Cliffs, NJ: Prentice-Hall, Inc., 1979) e e Application for Freshwater Aquifer Exemption Envirotech Facility, North Foreland The analytical data obtained from the non-potable well at the site indicate the boundary that exceeds 3,000 mg/l in TDS extends further inland than the non-potable well. The non- potable well is located approximately 50 to 100 feet further inland, and up-gradient, of the drainfield. The monitoring wells that we propose to install at this site will be used to confirm that the direction of groundwater flow, which is assumed toward Cook Inlet, is correct. Sampling and analytical testing of the proposed monitoring wells will be conducted to ensure that the effluent from the drainfield does not impact water that is not initially above the 3,000 mg/llevel for TDS. The subsurface information available at the site is not sufficient to determine the depth and lithology of the lower confining layer (aquitard). This information will be obtained when the proposed monitoring wells are drilled at the site. The lithology for each borehole will be recorded. Based on the depth of water in the non-potable well at the site, approximately 300 feet from the drainfield, and on a conversation with Bob Hughes, President of Hughes Drilling Co., who drilled a significant number of wells at Shirleyville (Granite Point), it is expected that a dense silt confining layer will be encountered between 30 and 50 ft below ground surface. We received logs of two wells that Aurora Gas had drilled in Shirleyville. Unfortunately, the log of a gas well was not useful because it did not have lithology information for the first 200 feet below the surface. The log of a water well (attached), drilled for Aurora (Power) by Denali Drilling, is incomplete and the lithology is not very detailed. The location of the Shirleyville water well is similar to the location of the well and drainfield at the North Foreland in that it is several hundred feet from the Cook Inlet beach and it is flanked by high bluffs. The well log shows sand and gravel (boulders) to a depth of 40 ft, silty sand from 40 ft to 76 ft, with gravel, sand, boulders, and water from 76 to 146 ft (bottom of hole). We suspect that the layer of silty sand, located between 40 ft and 76 ft, is the confining layer for the surface groundwater aquifer [probably contaminated by salt water], and that they drilled through the confining layer to access the underlying aquifer. 2. How can we be sure that the monitoring wells will be correctly located so that the effluent from the drainfield enters those monitoring wells? According to a U.S. EP A publication, contaminants in groundwater will move primarily in a horizontal direction that is determined by the hydraulic gradient. The contaminants will decrease in concentration because of such processes as dispersion, filtration, . . . time rate release of contaminants, and distance of travel. 4 According to Martin, the first task in the design of a ground-water quality monitoring system is the selection of the target monitoring zones and placement of the well screens in the aquifer at locations and depths that would have the highest likelihood of detecting contamination from the drainfield. The target zone usually lies in the saturated geologic unit in which the groundwater flow rates are the highest because it possesses the highest 4 U.S. Environmental Protection Agency, "Protection of Public Water Supplies from Ground-Water Contamination": U.S. EPA Center for Environmental Research Information, Cincinnati, OR: 1985. 2 e e Application for Freshwater Aquifer Exemption Envirotech Facility, North Foreland hydraulic conductivity of those geologic materials adjacent to or underlying the facility of interest. The movement of water through aquifer/confining unit systems is controlled by the vertical and horizontal conductivities, the thickness of the aquifers and confining beds, and hydraulic gradients. Because of the relatively large head loss that occurs as water moves across confining beds, the most vigorous circulation of groundwater normally occurs through the shallowest aquifers. Movement generally becomes slower as depth increases. Groundwater monitoring in complex alluvial deposits often presents problems for identification of target monitoring zones. Generally, if all soil borings installed during the site investigation contacted the definable unit [i.e. confining bed] at equivalent elevations, it is likely that the geologic stratum is continuous.5 To minimize the possibility that drainfield effluent would pass beneath the wells, the wells will be drilled to the confining layer underlying the upper aquifer. The engineering plans we submit to ADEC for review to obtain a discharge permit will include the locations and design of the monitoring wells. We anticipate the screened interval of the wells will be in the zone where the first saturated hydraulic unit is encountered. According to Martin, this should be where effluent from the drainfield moves through this aquifer. As indicated earlier, the monitoring wells will also be surveyed to confirm that the direction of groundwater flow in the unconfined groundwater aquifer is indeed toward Cook Inlet. 3. Please clarify subsurface ownership of the site. The subsurface of the site is owned by Cook Inlet Region Inc. (CIRI). We have requested a formal letter from CIRI granting their permission for the proposed drainfield and they have indicated that they will forward a letter to us. Once we receive their letter we will forward a copy to you. We hope the additional information sufficiently addresses the Commission's concerns. After installing the monitoring wells, we will be able to provide better information about the aquifer and the flow of the effluent. Please let us know if you have any further questions or comments. Sincerely, I 1<&;-,.- ;,QoooÐ&OVQO~ " ~ s'" IfIi o' r/'.¿ .''' tf '" f49:œ Ø'~~ö~6oo~a Oð~0000ØÐ ~ (I.'; ';j e~_'¡;'_-J-,::'OCHJÐOØOOOOo(JQoo(}e 0 )gOJÜ (:;? 'I ~\ CE 56.49 ' 1.f8 cÚ Ronald T. Rozak, PE ~I~"'\" Ronald T Rozak f#if C 1 . E· 'I>.'~ "0 "CO ~~&-"7 onsu tmg ngmeero, ~'9.t.o<>G"ø<>o""o<>""oo :\- ~£;r' , ~ \~ROFESS\():~$'? cc: Mike Wicker, Derek Maat;~~~'tech LLC Sharmon Stambaugh, ADEC Division of Water 5 Sara, Martin N., "Ground-Water Monitoring System Design," Practical Handbook of Ground-Water Monitoring, David M. Nielsen, editor. (Chelsea, MI: Lewis Publishers, Inc., 1991). 3 )un 24 04 07:50a En1llrtech LLC 29 'B3 01:43PM " Denali Dnlhng .~ -- - ..." .. ,.. 19077_859 p.2 P.Z,r2 r)~!"") ~t:t~l$btIlV S'd":~ ~"t':'f".)f..¡¿C! .Aì......k.. ~~¡j7 ';IJI !l01 St'!è',L:.t\i:' ¡:'~jI ~U7 S'Ó;.! .;'-), j t. ",..tt l).:(\.r,d..øal.hi¡"~ I\~I t-'emIH NwmDer _ _. Date Of Issueá-5' z.9..s~ Parcel Idel1tificstion Number_-_._ D.~t Started ~-C::, .·05Ditte Completed ..:i·:..LJ~·~ Is wl"1I 'oc;at~d al approved perrnillo¡;a1Ion" eYes :; NO Legal Desc.rJpliOn ~l'¡"z'2. ~ U¡:I {~ I Bore-hole Oata: Soil Type & Thickness & Waler Strahi I "r AIJ"t> ~.JI"t'_L l tb,,( ~.Lx:.J S.:w~ .~~ì:> ~%f.. ~ $JWi:> (l~f&d .00 ...,~ TE.It_ ~~ ~A.c£f ~:c I 7:y b,4....,¡., A,.j~ '"'->"'iti1?,. ~//JIIl~ SAN ~ ~'~Fi,,~ ~,bF~') 1"---_ Bloc!l I Lol Deplh FUJII, "0 'It; , D ~o 76 ( 7~ 'dD &;:' 8~/ '6'3' ( /1/0 Property Owner Name & Address: /lv.R.O~Ä fOo....)EK Method Of Drilling: rv-"air ~ota;Y o cable tool Casing Type: W2I11 Thicl<ness_inctle3 ;)ia~rer~inche$ deplt1_fee! Liner Type: Diameter_inches. deplh_feel Cuing Stickup Above Ground: feel Static Water Level (from ground level); feel F'umpiog Level:_feel 2Iner_hrs. pumpil19_ppm Recovery Rat~: Qpm MethDd Of Tuting: Well Intake Opening Type: o ScreenS(]; Stan e.. Pl!rforatiOl'1S Shlr1 71' Q Open E.nd öJ Open Hole feel Slopped feet f~t Stoppeà 71./ I feel /iJ~¡ . ~ ":GrõütTypc:".:oï~ (I.~?~ Volume Depth: from h' ferel to. ?_~.. feel Pump 'ntake Depth: feet Pump S;n "p Brand Name W." O;sinf,c1ed Upon Completionr 0 Yes C No MetAod Of Dìsinlec:tíon; Camments: dD ~ 'Well DrilterName ~ Lo..li- Company ðç.4}/"í.. IpzJ{,-.AJ&ry Mailing Address ~;4() ~~8~ e.4. City AzdI .~tate . ~£ . Zip 975ðý Attention: The well c1ñ\ler shall provide a welt log to the property owner within 30 days of completion and the property owner or the well driller shall provide a weH log to the Depl Df Health & Human S~rvite6 wi1hin 60 days ot completion. .._~ 2'd SS8SS28S0S ~UI WWH Wd8~:~ ~002 ~2 unr #8 Today's Hearing e . Ron, Thanks to you and your colleagues for coming to the hearing today. After the hearing was adjourned, the Commission staff met to review our notes regarding the hearing and action items resulting. On one item, we wanted to assure that our mutual understandings were similar. That item concerned an understanding of how far inland or upland the brackish water aquifer extends. You have provided a water analysis from the non-potable well that gives a TDS value at that location. What is not clear is how that TDS and/or salinity profile changes as one would go inland or up gradient. The Commission's authority on an Aquifer Exemption does not apply to waters with less than 3000 ppm TDS and it is not presently clear where that TDS "boundary" might be in relation to the drain field and the non-potable water well. It is requested that this item be added to your list of deliverables. Please call me with any questions. Tom Maunder, PE AOGCC 1 of 1 6110/20043:03 PM #7 · · · e . 1 ALASKA OIL AND GAS CONSERVATION COMMISSION 2 PUBLIC HEARING 3 4 In Re: 5 Envirotechts application for approval of aquifer exemption order related to 6 the North Foreland FacilitYt Cook Inlet the approximate location within Section 7 14t Township 11 Northt Range 11 Westt Seward Meridian. 8 9 TRANSCRIPT OF PROCEEDINGS 10 11 Anchoraget Alaska June lOt 2004 9:05 otclock a.m. 12 13 14 COMMISSIONERS: 15 JOHN NORMANt Chairperson DAN SEAMOUNT 16 17 18 19 20 * * * * 21 22 23 JUN "1 f '7nO-4 .It '} _.) 24 25 METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 e . · 1 TABLE OF CONTENTS 2 3 OPENING REMARKS BY CHAIRPERSON NORMAN Page 3 4 TESTIMONY RONALD T. ROZAK Page 5 5 END OF PROCEEDINGS Page 41 6 7 8 * * * 9 10 11 12 13 · 14 15 16 17 18 19 20 21 22 23 24 25 · METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 . . . e e 3 1 PRO C E E DIN G S 2 (On record) 3 I'll call this meeting to order. For CHAIR NORMAN: 4 the record this is on the morning of Thursday, June 10th, and 5 it is approximately 9:05 a.m. This hearing is being conducted 6 at the offices of the Alaska Oil and Gas Conservation 7 Commission, 333 West Seventh Avenue, Anchorage, Alaska. 8 Present is myself, John Norman, Chairman of the Alaska Oil and 9 Gas Conservation Commission. On my left, Commissioner Dan 10 Seamount. A quorum is present and the meeting is legally 11 convened. Also here today is Assistant Attorney General Rob 12 Mintz, who provides legal advise to the Commission, and 13 additionally we have with us Teresa Mielke, a court reporter. 14 A transcript of these proceedings will be prepared and in the 15 event that anyone in the future wishes to have a copy it can 16 be made available. 17 The purpose of the hearing is to consider an 18 application from Rozak Engineering on behalf of Environmental 19 [sic] Tech, LLC, to approve an aquifer exemption order related 20 to the North Foreland Facility, Cook Inlet, the approximate 21 location within Section 14, Township 11 North -- yeah, 22 Township 11 North, Range 11 West, Seward Meridian. 23 Notice of the hearing is duly reflected and has been 24 published in the Anchorage Daily News on April 21 and 25 supplemented on April 23rd. We do not have any record in the METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 . . . e e 4 1 file of any formal objections being received. We are 2 proceeding today in accordance with the provisions of the 3 Alaska Administrative Code, specifically 28 AC 25.540 and 4 these are the regulations governing public hearings. 5 If today, in considering this, there is testimony, 6 greater weight would be given to sworn testimony than non- 7 sworn testimony, although we would not require that a witness 8 in this proceeding be sworn. If someone wishes to express a 9 professional opinion, such as an engineering opinion, then we 10 will ask you to first state your qualifications. 11 We'll hear from the applicant and then if there are 12 any others in the audience that wish to ask questions, our 13 normal procedure is to request that you submit questions to 14 the Commission and then we will present the questions. We 15 also will do our best to try to cover anything that any 16 members of the public wish to have addressed at this hearing 17 but we will not provide for cross-examination, that's not the 18 setting in which this hearing is to proceed. 19 I'll now ask the applicant to proceed and if you would 20 state, for the record, when you talk, remembering that we are 21 making a record here, and so it's important to state who is 22 speaking. Additionally if you -- if you are making reference 23 to a map or plat or diagram, it's important to remember 24 that the record can't see that and so we'll need to identify 25 that in some way to have it made part of the record, METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 5 1 if that's your wish. 2 So, Mr. Rozak, do you wish to proceed? 3 MR. ROZAK: My name is Ron Rozak. I'm a registered, 4 professional engineer in the State of Alaska. My specialty 5 being civil and environmental. My offices are in Kenai, 6 Alaska. My last name is R-o-z-a-k. 7 CHAIR NORMAN: Thank you, sir. Please proceed. 8 MR. ROZAK: One point I would like to make is that the 9 application was made on behalf of Envirotech, a limited 10 liability corporation, not Environmental Tech..... 11 CHAIR NORMAN: I'm sorry, I may have -- if I misstated 12 that, I apologize, it may have been in my reading of it. 13 MR. ROZAK: And the application for the fresh water 14 exemption, dated March 15, 2004, addresses as well as I could 15 determine, the requirements of regulation 20 AAC 25.252(c), 16 and it was my understanding that the staff and perhaps the 17 Commissioners had some questions because a lot of the -- 18 this -- this was not a conventional discharge in the sense of 19 a drilled well, 5000 feet deep or something. It was a 20 shallower discharge disposal, more in keeping with the 21 concerns and issues that the Department of Environmental 22 Conservation would typically address. 23 As a result of that, Tom Monder (ph) sent me sixteen 24 questions bye-mail that I assume summarizes the primary 25 questions that the Alaska Oil and Gas Commission probably METRO COURT REPORTING 745 West Founh Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 6 1 had -- Conservation Commission had and if it was appropriate I 2 would try to address those in the order presented to me unless 3 the Commissioners prefer to proceed in some other fashion. 4 CHAIR NORMAN: No, that's just fine. Go ahead and 5 proceed please. 6 COMMISSIONER SEAMOUNT: May I say something? 7 MR. ROZAK: Yes. 8 COMMISSIONER SEAMOUNT: I believe those set of 9 questions, the first five were related to the aquifer 10 exemption, which is what this hearing is about. 11 MR. ROZAK: Okay. 12 COMMISSIONER SEAMOUNT: The rest of the questions I 13 think do not necessarily have to be addressed at this hearing. 14 They would have to be addressed or in some other setting but 15 if -- if you feel like you'd like to address them in this 16 hearing, you know, you're more than welcome to. We'd like to 17 hear what the answers are. But, I believe up through five are 18 just are the ones that are appropriate to this hearing. 19 MR. ROZAK: Okay. The first question was, did Rozak 20 Engineering provide copies of the application for aquifer 21 exemption to EPA Region 10 and to the Alaska Department of 22 Environmental Conservation? 23 And yes, we personally delivered a copy to the ADEC 24 Kenai office, to Orren Wooley (ph) the environmental engineer, 25 who at that time was administratively overseeing this METRO COURT REPORTING 745 West Fourlh Avenue, Sui1e 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 7 1 application. And we sent a copy, at the same time, we mailed 2 a copy to this office, AOGCC, to the EPA Region 10, certified 3 mail, return -- a receipt was received. 4 CHAIR NORMAN: And when was that copy delivered to Mr. 5 Wooley? 6 MR. ROZAK: That would have been the date, let's see, 7 either March 15th or March 16th. I don't remember if it was 8 the date of -- I have a date stamped, received copy when I 9 delivered it, where the DEC office date stamped it and I 10 brought that back to the office. 11 The second question was, did either of those agencies 12 provide comments or voice objections to this project? 13 We did not receive comments from either of the 14 agencies, however, on, let's see, I think it was April or, 15 yeah, April 2nd of 2004, Mr. Wooley at the DEC Kenai area 16 office told me that a geologist from AOGCC had called him and 17 asked a number of questions, mostly about the drain field 18 aspect of the system. And Orren thought he had appropriately 19 answered the questions; he -- we didn't go into a lot of 20 detail of exactly what the questions were, but I would 21 suspect, or at least conveyed to me, was they were more of the 22 nature of -- of, you know, one staff professional to another 23 about concerns that one department might have that another 24 department may not know about type of thing. Also, and Orren 25 did not indicate to me, that any of the questions weren't METRO COURT REPORTING 745 West Fourlh Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 . . . e e 8 1 answered or unsatisfactorily answered. 2 What were Envirotech's responses, was the second part 3 of that question two, and basically Envirotech and myself, 4 Rozak Engineering, have jointly worked on this. They 5 approached me with the need for assistance to put together 6 this application, provided me with the information they had on 7 hand, partially from an earlier application for a drain field 8 in this layered area. Information about the treatment 9 process, whereby the treated -- produced waters are treated, 10 and then I started assembling the application, using the 11 regulations and the criteria and stuff to make sure everything 12 was put in the right order, and whenever I had questions, I 13 would address them to Mike Wicker, the President of 14 Envirotech..... 15 MR. WICKER: Op -- op -- Operations Manager. 16 MR. ROZAK: The Operations Manager, yes. Or 17 occasionally..... 18 MR. WICKER: Or Derek Mott. 19 MR. ROZAK: Derek Mott, right bye-mail. He would be 20 the Environmental Manager..... 21 MR. WICKER: Yeah, he's our Environmental Engineer for 22 Envirotech. 23 MR. ROZAK: So, the answer to that is when we asked 24 what were Envirotech's responses, is they were really 25 incorporated as we went along and the application submitted to METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 9 1 you was sent to them for final review before I signed it and 2 submitted it and delivered it. And I neither Envirotech nor 3 myself I have received any comments or objections from either 4 the EPA or DEC. 5 COMMISSIONER SEAMOUNT: What does EPA and DEC -- I 6 meanl do they -- do they want to be involved in this or do 7 they -- is there some formal permitting you/re going to go 8 through with either of those two agencies? 9 MR. ROZAK: 1/11 answer the easier part of the 10 question first. With DECI Orren Wooley being the primary 11 point of contact with DECI it was recognized early on I guess 12 that this sitel because of the saltwater intrusionl while it 13 might be a good candidate for the disposal process we/re 14 submittingl wouldn/t readily fall under the conventional non- 15 domestic waste water process. Because the groundwater there 16 at this point doesn/t meet drinking water standards and yet 17 the discharge we/re proposing is very common to the 18 characteristics of the groundwater I mainly it being a 19 saltwater intruded environment. 20 SOl he recommended I after some discussion between 21 Orren Wooley and the EPA Region 10 staff person in Seattlel I 22 don/t remember..... 23 MR. ALLEN: Thor Cutler (ph)? 24 MR. ROZAK: Thor Cutler. There was some discussion 25 about who had jurisdiction and what sort of fell out of this METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 10 1 was the State DEC would take the lead and in recognizing 2 Alaska Oil and Gas Conservation Commission really also had 3 jurisdiction¡ we proceeded with guidance from Orren Wooley in 4 the direction to pursue the aquifer exemption. If that was 5 approved¡ then it would fall back within DEC¡s jurisdiction to 6 permit the requirements for the monitoring or whatever 7 drinking water standards or other standards would be 8 applicable¡ where the measurement of those say points of 9 compliance would bel and the other conditions that would be 10 more common. EPA¡ I understood¡ would comment through -- 11 directly to AOGCC or DEC as either of those -- either the 12 aquifer exemption was forwarded or the non-domestic waste 13 water discharge permit was pursued. Does that answer your 14 question? COMMISSIONER SEAMOUNT: Yeah¡ I think so. 15 MR. ROZAK: It is not a clear..... 16 COMMISSIONER SEAMOUNT: DEC wants to be involved¡ the 17 EPA wants to kind of stand off a bit and -- and make comments¡ 18 is that your..... 19 MR. ROZAK: I think that¡s my understanding. 20 COMMISSIONER SEAMOUNT: Okay. And -- and DEC wants us 21 to certify that -- that this is that this could be an 22 exempt aquifer or is an exempt¡ if we approved it? 23 MR. ROZAK: Yeah¡ DEC was looking to your commission 24 to make the determination as to whether it was appropriate to 25 exempt the aquifer¡ then they would put¡ what they thought METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 . . . e e 11 1 were the comfortable conditions or restrictions or whatever on 2 the use or monitoring of. 3 COMMISSIONER SEAMOUNT: This is such a hybrid, that's 4 why we asked you to come in today. It's -- it's somewhat 5 confusing to us. 6 MR. ROZAK: Well, my wife tells me that the more I 7 talk, the more confusing I get, so I'll try to keep my answers 8 short then. 9 COMMISSIONER SEAMOUNT: I think all wives say that. 10 Okay, yeah, thank you. 11 MR. ROZAK: Then the third question was, did 12 Envirotech receive a NPDES permit from EPA? If not granted, 13 what were the reasons for denial? 14 And EPA or Envirotech did apply for and was denied an 15 NPDES permit from the EPA and it was related to a discharge 16 off the dock, located adjacent to this property. And it was 17 determined to -- it was denied because they felt that the 18 effluent didn't meet the guidelines that would apply to such a 19 facility. Basically, this is a shore facility, not a platform, and that was the basis for the denial. There was no discussion or they did not entertain any additional input as 20 21 22 to dispersion or modeling or anything else to deal with how 23 the discharge from the dock might have dispersed or met the 24 other conditions that would have been appropriate for a 25 platform. METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 12 1 CHAIR NORMAN: Could we -- on that point, was the 2 quality of the treated effluent the same as what you would 3 expect after passing through this treatment facility and then 4 if so it would have been the same except you were looking to 5 go directly from the dock and discharge into Cook Inlet, is 6 that..... 7 MR. ROZAK: Yes, the effluent would have gone through 8 Envirotech's treatment process. 9 MR. WICKER: That's correct. MR. ROZAK: And then pumped directly out to the end of the dock and discharged under conditions of tide levels and 10 11 12 direction of tides and other, you know, things. But the 13 effluent quality would have been the same. 14 MR. WICKER: That's correct, that's correct. 15 COMMISSIONER SEAMOUNT: Would it be the same as what 16 would go off a platform, is that what you're saying or? 17 MR. ROZAK: No, I would- -- I don't know -- I think 18 the treatment that Envirotech is doing is -- would treat the 19 water to a much cleaner standard than what is probably coming 20 off the platform, but I can't say that for sure. 21 COMMISSIONER SEAMOUNT: But did you say that if it was 22 on a platform it would be allowed and since it's coming from 23 onshore it was not allowed? 24 MR. ROZAK: It was denied because it wasn't on a 25 platform. METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 13 1 COMMISSIONER SEAMOUNT: Okay. 2 MR. ROZAK: I'm assuming that if they would have 3 entertained the application, there may have been questions, 4 and I'm not -- based on the quality of the effluent, I would 5 assume it would be approved. 6 COMMISSIONER SEAMOUNT: Okay, could we backup..... 7 MR. ROZAK: Yep. 8 COMMISSIONER SEAMOUNT: Just -- I had a question. I 9 think you have the same list of questions that I have, does it 10 look like this? 11 MR. ROZAK: Yes. 12 COMMISSIONER SEAMOUNT: Okay, it's got a paragraph on 13 top. 14 MR. ROZAK: Oh, yes. COMMISSIONER SEAMOUNT: Okay. Do you agree with the 15 16 statement in the first sentence in the second paragraph that 17 the proposed drain field system will impact an unconfined 18 shell of aquifer that is directly connected to waters of Cook 19 Inlet. Do you agree with that statement? 20 MR. ROZAK: Yes. I guess the discussion with DEC will 21 get into the degree of impact. That's where the waters will 22 be received. 23 COMMISSIONER SEAMOUNT: Are they directly connected to 24 waters of Cook Inlet? I..... 25 MR. ROZAK: And I assume they are. METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 14 1 COMMISSIONER SEAMOUNT: Okay, I -- I believe you said 2 that in your application or you eluded to that. 3 MR. ROZAK: Well, I assume they are because it 4 appears, based on observations in the field and the topography 5 of the site, my general knowledge of the way groundwater flows 6 in terrain like this, that the waters will flow from the 7 mainland or the upland toward the beach and our facility is 8 near the beach, so waters coming from the upland would pass 9 under our facility, which would include the drain field and 10 migrate toward Cook Inlet. That is the assumption I'm making 11 and that would be substantiated by monitoring wells, be placed 12 -- be surveyed, and things like that. 13 COMMISSIONER SEAMOUNT: Okay. 14 CHAIR NORMAN: I'd like to ask a follow-up question on 15 that point. To your knowledge is -- at this location is this 16 tide -- is this aquifer tidally influenced at all? In other 17 words, does it go back the other way at times of extreme high 18 tide? 19 MR. ROZAK: I -- I have -- I doubt very much that the 20 groundwater at the site, which is about 600 feet from the high 21 tide mark, will be significantly affected by tides. As an 22 example, I've done work on the Homer Spit, out at the end of 23 the Homer Spit. And I'm not sure that it's 600 feet from one 24 side to the other, let's just assume it is. And there's a 25 bulk plant out there, pretty much in the middle, and we did METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 15 1 monitoring for a month on 15 minute intervals, automatic data 2 recording, and there was a movement of a foot or a foot and a 3 half elevation difference when the tides varied from over 20 4 feet plus to three or four feet minus, so you had 25 to 30 feet of tide differential and only a foot or foot and a half of ground - - water level variation at the site. 5 6 7 And the Kasilof and Kenai River, I've done some 8 monitoring well work where just 15 or 20 feet inland from a 9 high tide or the high river mark, you'll notice very small 10 differences compared to what is occurring in the river itself. 11 Again, maybe on an order of one to 10, and it's not a linear 12 change either. As you go twice let's say you go from 10 13 feet to 50 feet away from say the beach, it becomes much 14 dampened. Now, that's affected by your soil types too. We do 15 have a coarse material in this area, sand and gravel versus 16 silts and clays and things like that. But usually on the 17 beach you still have a certain amount of finds that settle out 18 there, not necessarily on the surface, but below the surface. 19 So, I would expect very, very little influence from the Cook 20 Inlet, as far as the groundwater level at the site, that would 21 be influenced more by the infiltration, some snow melt, 22 rainfall, the amount of water that's held in the muskegs and 23 lakes and things up there that seep down toward the -- the 24 site. 25 COMMISSIONER SEAMOUNT: Would you think that the Cook METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · 8 9 10 11 12 13 · 14 15 16 17 18 19 20 21 22 23 24 25 · e e 16 1 Inlet muds offshore would act as a confining layer? I mean, 2 it almost sounds like that's what you're describing right now? 3 MR. ROZAK: Okay. Would the Cook Inlet muds offshore 4 act as a confining layer? I think, to whatever extent they 5 are now, they would continue to do that because even though it 6 sounds like we're putting a lot of water into the ground, when 7 you look at the volume of water and the groundwater table, or the ability, we would have to spread the -- lets say discharge out through multiple drain fields for example, separated by several hundred yards perhaps, or things like that. We wouldn't be increasing the amount of water moving toward the inlet so much that it would, lets say, cause a bathtub affect, or I don't think where there may be a -- a mounding affect, where it would try to find a way through that confining area, it's under gravity not under pressure. But I -- I don't know. Yes, in the rivers, you get the silt, the glacial silts and such that build up on the banks, they do provide a confinement to onshore waters migrating towards the river sometimes, so the waters tend to follow coarser sands and gravels that are at more depth, and they may come up under a river rather than through the sides or banks. Does that answer that question? COMMISSIONER SEAMOUNT: Yes, thank you. MR. ROZAK: I apologize for over-looking the first paragraph. Were there any other questions associated with that first paragraph -- second paragraph? METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 17 1 COMMISSIONER SEAMOUNT: I was just concerned that 2 since this will go into the record that if you disagreed with 3 that statement, that you had the opportunity to comment on it. 4 MR. ROZAK: Lets see, then the fourth question was, 5 how was the depth of the current water table determined in the 6 project area? 7 Mike Wicker was involved in digging a fairly deep 8 trench to a depth of about 20 feet below the ground surface to 9 bury a electrical service. Depth of the ditching was to 10 approximately 20 feet. Water -- which is about where the 11 water was encountered at that time and I can ask Mike to 12 comment on the time of year of when that occurred. So, that 13 was one estimate for the basis of the depth groundwater. 14 Another would be, is on occasion, there -- Mike Wicker has 15 also pulled a pump from a well at this site, which is not used 16 for drinking water, and the piping and pump, you know, it's 17 about estimated to be about 20 -- the well's estimated to 18 be 25 to 30 feet deep, and the pump at about the 25 foot level as I recall. Mike, any comments on that? MR. WICKER: That's where a pump sits for a non- 19 20 21 potable well and when we were trenching that's where we did 22 hit our groundwater, was approximately 20 feet down. 23 MR. ROZAK: And that would be north of the proposed 24 drain field site. The southern termination of that trench 25 would have been approximately 3- -- 300 feet north of the METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 18 1 drain field. I would note that during the different times of 2 the year, and from one year to another, that depth of 3 groundwater will vary several feet, I don't know exactly. 4 The fifth question, if the exemption -- aquifer 5 exemption is granted as requested, what other permits are 6 required to allow this project to operate? 7 Again, I -- and I just talked to Orren Wooley from the 8 Kenai DEC office yesterday on this, I'd forwarded the question 9 to him bye-mail several days before that, and while he is not 10 at this moment, or no longer at this moment I guess directly 11 overseeing the -- this project, due to realignment of staff 12 and projects within the department, he indicated that, one he 13 referred me to Sherman Stanbaugh (ph) with the office here in 14 Anchorage, with the Industrial Discharge Section of the 15 Anchorage office of DEC. But he thought that or indicated 16 that his approach would have been that this would be a 17 combination permit, as he defined it, a classified structure, 18 receiving Class 2 fluids and that the application, yes, there 19 would be a need for a permit, and the application for that 20 permit would include items such as the proposed target levels 21 for the contaminants concerned, the two primary ones in this 22 case being the chlorides and the total dissolved solids. 23 Engineered plans, as part of that, which would be the plans 24 showing the lay-out of monitoring wells and I showed three in 25 my application. In the last several years DEC is frequently METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 19 1 requiring four, well, if that's what -- three or four, 2 whatever's acceptable. The purpose of those would be to use 3 the elevations in those monitoring wells to determine or 4 estimate the direction of groundwater flow and to determine 5 which was the upgradient direction, the importance of that 6 being to ensure that the wells are located, such that samples 7 collected from the wells, would reflect the -- any change in 8 the concentrations of your contaminants concerned. 9 CHAIR NORMAN: Could I ask a follow-up question on 10 that? 11 MR. ROZAK: Yeah. 12 CHAIR NORMAN: On the monitoring of the wells. In the 13 diagram I'm looking at one of them is inland from the drain 14 field tankage, one of them is toward the line -- seaward and 15 the other looks like it's between the area in Tyonek Creek? 16 MR. ROZAK: Yes. 17 CHAIR NORMAN: And so my question would be that if 18 this was approved and went forward and at some point you 19 confirmed there was a significant flow from the drain field 20 into this seaward monitoring -- as picked up in the seaward 21 monitoring well, and the well or -- and/or the well at 22 Tyonek Creek, indicating that we were getting this fluid 23 migrating into Tyonek Creek or into Cook Inlet, what action 24 would be contemplated here? 25 MR. ROZAK: Well, first of all, let me clarify that METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 20 1 the monitoring well locations would be such that if we, 2 through our sampling efforts, determined there was an increase 3 in the contaminants concerned, the well locations would be 4 such that we could take action before the contaminant levels 5 reach the creek. And DEC's primary concern would, I would 6 imagine being the fresh creeks or supposedly fresh water for 7 drink- -- potential drinking water sources. The actions to be 8 taken, there are several. One is to reduce the flow of the 9 effluent into the drain field system. Another could be to 10 and if that -- and if the (indiscernible) or the input was 11 such that it could be reduced, we would do that. 12 The other would be in consultation with DEC, and 13 normally this would occur as part of our permit process, weld 14 identify some of these potential options so we didn't have to 15 wait until a situation occurred before we tried to address it. 16 But one would be to increase the size of the drain 17 field. Put an alternate drain field or several other drain 18 fields in where, on a daily or weekly basis, the discharge 19 would go from -- alternate between the three, spreading it 20 out. Now, another would be -- it's possible during certain 21 times of the year, the gradient, the slope of the groundwater 22 might be flatter than at other times of the year. And perhaps 23 this condition occurs during a low ground water condition 24 inland, prior to say July or something like that, and maybe 25 during those times of year the discharge would have to be METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 . . . e e 21 1 reduced. 2 But, one of the questions I hear is the concern of the 3 higher concentrations reaching the creek. I would assume that 4 one or at least two of these wells would be on the side of the 5 -- the creek side of the site. And the way I've shown them 6 here, one is between the drain field and the -- call it the 7 discharge of the creek into the Cook Inlet. The other is on 8 the inland side, or upland -- toward the upland side where the 9 source of water would be coming. A fourth well, not shown on 10 here, may be located somewhere within the drain field area 11 because sometimes, especially in the last several years, they 12 want to know what the peak concentrations are. Did I answer 13 both questions? 14 CHAIR NORMAN: Did you say peat or peak? 15 MR. ROZAK: Peak. 16 CHAIR NORMAN: Peak, yeah. 17 MR. ROZAK: The -- the maximum. The highest 18 concentration. 19 COMMISSIONER SEAMOUNT: When you have a fresh water 20 stream flowing over an area of -- of brackish water that's 21 underground, is there an underground supply of drinking wa- 22 of fresh water under that stream? 23 MR. ROZAK: Say that question again please? 24 COMMISSIONER SEAMOUNT: Can you look at -- underneath 25 the stream that's flowing over the brackish Cook Inlet waters, METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 22 1 there -- there underground, is there a zone of freshwater 2 under the stream? 3 MR. ROZAK: I couldn't answer that question. In some 4 condi- -- situations, possibly. 5 COMMISSIONER SEAMOUNT: I'm not a hydrologist but it 6 seems to me that the fresh water is going to weigh have 7 lower density than the brackish water and it would tend to 8 float on top. 9 MR. ROZAK: We're down near the lower limits of the 10 stream. I know that during the winter, on the Kenai River, 11 you'll get some segregation between the salt water and the 12 fresh water, within the tidal influence area of the stream or 13 the river and the -- out in Cook Inlet. But, I don't think 14 the -- In a stream this size, there would be a discernable 15 difference. 16 COMMISSIONER SEAMOUNT: In the underlying brackish 17 water, is that what you're saying? 18 MR. ROZAK: Well, see -- I don't know exactly how far 19 inland the saline intruded water extends. Obviously it 20 extends as far as the sampling location on the creek but how 21 much further, I -- I would expect that the grading of the 22 creek might be the determining factor in that. 23 COMMISSIONER SEAMOUNT: Okay, thank you. 24 MR. ROZAK: Other components of the permit would deal 25 with the program for the sampling, the intervals of sampling, METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 23 1 the analytical requirements, and again, what we were just 2 talking about, identifying the point of compliance, if you 3 will, for location for the monitoring wells and the triggering 4 mechanism under which we would reduce flow or take other 5 actions. That answers or completes the I guess the questions 6 or the answers that I had for those five questions. Are there 7 any other questions? 8 CHAIR NORMAN: Mr. Seamount? 9 COMMISSIONER SEAMOUNT: I have no other questions. 10 Were you intending to go through the other questions or did 11 you want to hold off on those? 12 MR. ROZAK: If the Commission desires, I'll try to do 13 that and be real brief. 14 CHAIR NORMAN: I have a couple of questions and they 15 might touch on this. I think Commissioner Seamount has 16 properly focused us all on the aquifer exemption, application 17 and disposal, but one question is, who owns the sub-surface 18 estate, is that also Tyonek Native Corporation? 19 MR. WICKER: I believe that that is Tyonek and Cook 20 Inlet Regency [sic] both. 21 CHAIR NORMAN: And Cook Inlet region do you think? 22 MR. WICKER: I believe so, yes. I can't say for sure 23 exactly which ones own sub-surface exclusively. That would be 24 something I would have to research and get..... 25 CHAIR NORMAN: Could you find that out for us and, of METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 24 1 course, if it is, turns out that Cook Inlet Region owns this, then we would want to be sure that, in addition to our public notice, that there was actual notice given to Cook Inlet 2 3 4 Region, Inc. The sooner that you could check that out and get 5 back to us we would appreciate it. An e-mail would suffice if 6 that's easier for you or a fax. We'll need something in 7 writing confirming ownership of that. 8 MR. WICKER: That's not a problem. Great. 9 CHAIR NORMAN: A second question, I -- I know it's 10 considered but -- has been considered and rejected, but why 11 why would you not simply drill a conventional underground 12 injection well here? Is it -- is expense -- the cost, the 13 major consideration? 14 MR. WICKER: Yes, sir. 15 CHAIR NORMAN: Okay. And is there, on orders of 16 magnitude, is this significantly more efficient or how, on 17 orders of magnitude. I mean, if cost is the consideration, 18 what we'd normally be looking at is -- is a conventional 19 injection well and that's why we would like to know why you've 20 chosen to proceed this way? 21 MR. WICKER: Well, we've chose to proceed this way, 22 one, due to cost of an injection well, and two, due to the 23 fluctuating volumes, I mean, a lot of the times there won't be 24 the high volumes that we have listed here. This is more of a 25 maximum that we are looking at on the high end. If everything METRO COURT REPORTING 745 West Fourth Avenue, Suiie 425 Anchorage, Alaska 99501 (907) 276-3876 · 7 8 9 10 11 12 · 13 14 15 16 17 18 19 20 21 22 23 24 25 · e e 25 1 came together with all the different drillers and all the 2 different wells and that's an engineered calculation of what 3 the maximum figures that we would be look -- looking at, but 4 realistically they're much lower than that, the cost in 5 general for the little bit that we are looking at, it just 6 doesn't justify a deep injection well. CHAIR NORMAN: Good, okay, I understand. MR. ROZAK: I think also we probably wouldn't be considering this if you weren't treating the water to remove the petroleum hydrocarbons and the rest of it. That treatment process enabled us to look at this option. MR. WICKER: That's correct as well. CHAIR NORMAN: Mr. Rozak, if you did want to address any of the remaining questions, six through 18, you can do so, or if you'd rather defer that, that's fine with us too so. MR. ROZAK: May I suggest that if there are staff people present that would like me to address all or anyone of those questions, that might be appropriate. CHAIR NORMAN: I think what we might do to economize on your time, we do know that it's a bit of an inconvenience for you to come here today and we appreciate it, I think what the Chair would like to do is take about a 10 minute recess now. We'll try to collect all our questions so that they don't come at you piecemeal, and then we'll come back on the record. So, we'll go off the record at approximately 9:41 METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · - e 26 1 a.m. 2 (Off record) 3 (On record) 4 CHAIR NORMAN: We're back on record. The time is 5 approximately 10:20 a.m. First, we took a little longer but I 6 think it will save time in the long-run 'cause we were able to 7 distill down some of the questions that we have. We do have a 8 -- let's see I have probably three or four questions, that 9 we'd like you to address and if right now you need to get 10 additional information, we'll, of course, leave the record 11 open and you can supplement it and we'll discuss that when we 12 finish. But, the first one is, the thickness of the affected 13 zone, into which you are placing this leach field, what is 14 that? We're trying to look for the bottom of this; where is 15 the bottom of this affected zone into which you will be 16 introducing this effluent? 17 MR. ROZAK: This is Ron Rozak. I would esti- -- it 18 will vary but generally I'd say what would occur, because of 19 the dispersion dilution, there's a way the effluent is 20 discharged through a gravity means, that it would be pretty 21 much from the surface of the groundwater to possibly the -- 22 the underlying impermeable layer. And I'm not sure if it's 30 23 feet, 40 feet or whatever, it would be close -- it would be 24 more in the upper portions of that because the water probably 25 moves only a foot a day or something like that, so near the METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 27 1 site, it would be closer to the surface. Further from the 2 site it would tend to lower concentrations probably from the 3 surface to that un- confining layer beneath the unconfined 4 aquifer. Does that answer that question? 5 CHAIR NORMAN: Yes, somewhat. If this is discharged 6 and begins to though, do we know geologically whether - - at what point do you hit an impermeable layer where the fluid, instead of continuing to cone out and discharge, will flow 7 8 9 toward Cook Inlet, if it if it's d? 10 I would I would say that there gets to MR. ROZAK: 11 be a point, and I don't know if it's 100 feet or 100 yards, 12 but not too far from the source, because of dispersion, where 13 you would really have a hard time telling the difference 14 between what might be considered the in situ or ambient water 15 out there, and the water that was mixed with the effluent, 16 there is no hydraulic head in the specific gravities and other 17 things associated with what we're doing. The -- it's very, 18 very -- for instance, the dissolved solids, they if they 19 easily separate out, they would have separated out, so the 20 chemistry of the water going into the groundwater is similar, 21 so similar that I don't think there's going to be a layer such 22 as putting cream in coffee where you can see the light brown, 23 dark brown, I don't think you're going to see that. 24 Sure, and I understand that. And CHAIR NORMAN: 25 you're referring to how this is going to behave when it goes METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · 5 6 7 8 9 10 11 12 · 13 14 15 16 17 18 19 20 21 22 23 24 25 · e e 28 1 in dilution or compatibility but to consider an aquifer 2 exemption, the first question we ask is, what is the aquifer. 3 And what exactly is the aquifer that we are exempting? What 4 are the bounds on the. . . . . MR. ROZAK: Oh, I see. Well, there are no -- we don't have any wells or logs of wells out there to show us where the gravels say go to silts, clays, or confining layers. And frankly, it wasn't my intent to put monitoring wells deep enough to find that, because normally you don't want to penetrate a confining layer. We can answer that question, I've done this before, where one of the wells is, you know, drilled or augured to a depth where you start picking up say a confining layer. I -- I -- I looked -- I searched the records, the state records and others for soils information, wells, logs of wells in the area. I talked with people from several agencies and unfortunately there really wasn't much available. The drinking water, for instance, in Tyonek comes from a lake. This well on-site is not that deep and only went into gravels, 25 to 30 feet is the depth of the well. I would, I guess I I could try to answer that in -- I don't think I can answer right now a. . . . . CHAIR NORMAN: Yes, certainly. MR. ROZAK: And part of that I know comes from the Oil and Gas perspective or definition of confining layers, and I had some discussion with this I think with Tom Monder that METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 . . . e e 29 1 this is the unconfined surface, shallow aquifer and whatever 2 is confining it, we won't penetrate. And that's not a direct 3 way of answering it but it's -- because of the gravity, nature 4 of the water, similarity of what's there, my experience in all 5 these years, and I've done some dye tests and done monitoring, 6 from monitor wells around sewer systems for hydrocarbons and 7 other contaminants from underground storage tanks and sites 8 like that. Some of the things, for instance, you can get a 9 gradient of water, the direction -- a particle might move in 10 the water, isn't always horizontal, may be on an incline. In 11 this instance, I don't know where that underlying area or 12 strata would be. If it has to be identified, I could discuss 13 with your staff what might be an appropriate way to do that. 14 Maybe that's the best way to answer that. 15 CHAIR NORMAN: All right, sure, and I can understand 16 right now that you may not be prepared to do that. To help 17 frame your thinking, in my mind, the AOGCC is somewhat like 18 air traffic controllers and we're supposed to know throughout 19 the state, generally where these injection areas, aquifers are 20 exempted, and if a citizen wants to put in a well, we've got 21 to have some id- -- at some point in the future, 10 years from 22 now, and they're going to put in a well at some point, we've 23 got to have some idea of whether something is being injected 24 there and we've got to be able to keep track of all this. And 25 so for my own benefit, and I believe Commissioner Seamount's, METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 30 1 we need to have a better understanding of exactly what this 2 aquifer consists of, that's being injected to because as 3 you've correctly perceived, we are used to thinking in terms 4 of confining layers, that you will inject at this point and 5 it's impossible for it to go below this point because we have 6 two impermeable barriers. 7 In this instance, we're talking about an aquifer but 8 we don't know where exactly it goes. I think we can make some 9 assumptions, just based perhaps on common sense and the 10 topography and what we know about the way water might behave 11 and the pressures, but we're still, I think, without enough 12 foundation to be able to act with confidence here. 13 MR. ROZAK: What -- you're talking about a vertical 14 confinement, I guess part of DEC's concern was for the 15 horizontal dispersion or plume, call it, and that question 16 would be answered directly or indirectly -- or based on the 17 results of samples from the monitoring wells, you can make 18 some prediction of is the plume inside those wells or just 19 slightly outside so you could draw on a map an approximate 20 perimeter for horizontal that's a plume or dispersion. 21 Vertically, that I'd be willing to discuss. It sounds like it 22 probably would be more of an AOGCC concern than a DEC concern. 23 CHAIR NORMAN: Yes. Yeah, and of course, that's what 24 we are is AOGCC so that is our -- we are trying to focus on 25 the things that are properly within our area and other things METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 31 1 are DEC's concern. Within the drain field -- well, my 2 question is, how deep is this drain field at it's deepest 3 point the way it's configured? 4 MR. ROZAK: I'll refer to the figures in the 5 application. 6 CHAIR NORMAN: It indicates it's approximately 15 feet 7 above the groundwater table, as I'm reading it here. 8 MR. ROZAK: That's correct. On Figure 6 -- and might 9 I stand and make..... 10 CHAIR NORMAN: Please. 11 MR. ROZAK: Okay. I'm referring to Figure 6, details, 12 produced water, disposal system, and the middle figure, the 13 middle -- the profile, in the middle of that figure, shows at 14 the left side, the discharge line into a 22,000 gallon tank. 15 The top of that tank is approximately four to five feet below 16 the ground surface. The discharge -- that's the inlet, the 17 discharge is approximately the same depth which would go 18 horizontally into a drain field and drain fields are designed 19 to be as horizontal as possible to allow for the water to 20 uniformally throughout the entire length and width of the 21 drain field. So the drain -- the perforated pipe in the drain 22 field is again about five feet below the surface and the 23 approximately five to six feet underneath that was excavated, 24 it varied -- and replaced with three inch minus beach rock, 25 termed drain rock on this. The soils beneath that, which METRO COURT REPORTING 745 West Fourlh Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 32 1 would be about 10 to 12 feet below ground surface would be 2 native soils, based on our excavations at the site, are a 3 fairly course sand and gravel, so the depth to the well water table, identified as GWT, with the triangle on this profile, listed at about 20 feet below ground, would be in the 4 5 6 neighborhood of probably eight feet below the bottom of the 7 drain-on. And again, the water table could fluctuate several 8 feet. The DEC regulations for sewer systems requires a 9 minimum of four feet separation. And that's if you're 10 discharging a water that would need to be treated, going 11 through the drain field or infiltration system. They call it 12 soil absorbent system. 13 The drain rock serves -- in this purpose serves sort 14 of as a reservoir, the voids in the rock, when the water comes 15 out of the tank, it fills up that and then that slows the 16 discharge, allows it to spread out, throughout the drain field 17 area, migrating downward, and coarser materials migrates more 18 directly; with the finer materials, it'll spread out a little 19 more. Does that answer that question? 20 CHAIR NORMAN: Yes, it does, and again, for the 21 record, Mr. Rozak's been referencing a plat generally and 22 we've been reviewing within the plat attached as Figure 6 to 23 the application. Mr. Seamount, any more questions? 24 COMMISSIONER SEAMOUNT: You probably have it in the 25 record but is -- one of your monitoring wells going to be METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 . . . e e 33 1 inland of the drain field? 2 MR. ROZAK: Will one of the monitoring wells be inland 3 from the drain field? 4 COMMISSIONER SEAMOUNT: Uh-hum (affirmative). I 5 assume, again, yeah, okay, my question's answered just by 6 looking at Figure 4. Okay. 7 MR. ROZAK: I have a larger picture of that if that 8 would help -- or color picture of it. 9 COMMISSIONER SEAMOUNT: Will you be constructing a 10 lift log as you drill these monitoring wells? 11 MR. ROZAK: will we what? 12 COMMISSIONER SEAMOUNT: Will will you be 13 constructing a lithology log and..... 14 MR. ROZAK: Yeah, typ- -- typically, even in the DEC 15 regulations, there's a requirement to create a well log and a 16 profile of the well casing so to speak or the drilled depth 17 location of the casing, any perforated or well units. If 18 there is any sealing at the surface, and the soils through 19 which the well is drilled under the unified -- the USG unified 20 soil classification system, the observed depth of ground 21 water, diameter of well, a specified amount of information 22 that -- that's the gist of it. And I frequently take samples, 23 soil samples, at two to five foot intervals. Now these -- 24 that would be if it was a drill like hollow-stem drill auger. 25 In this case, the equipment at the site we probably -- at METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 . . . e e 34 1 least part of the excavation would be with a backhoe, that's 2 to be determined. So it would be visual in the course of the 3 excavation which gives you a fair idea if there's any strata 4 you're going through as well. 5 COMMISSIONER SEAMOUNT: And one final question, how 6 deep will the monitoring wells be? 7 MR. ROZAK: Typically, we try to put in about a 10 8 foot screened interval about two-thirds below the absorbed 9 water table, which would be about seven -- six, seven feet, 10 and about the remaining third above. 11 COMMISSIONER SEAMOUNT: Okay. I have no further 12 questions. 13 CHAIR NORMAN: Now, let me see if I can follow this. 14 The drain field sits above the water table about 15 feet, is 15 that right? 16 MR. ROZAK: The drain pipe would be about 15 feet 17 above the..... 18 CHAIR NORMAN: Groundwater table. 19 . . . . . groundwater table that we've MR. ROZAK: 20 identified. 21 CHAIR NORMAN: And the monitoring -- so, at that 22 point, to encounter the groundwater table, you need to go down 23 15 feet, is another way of saying it? 24 MR. ROZAK: Yes. 25 CHAIR NORMAN: It's 15 feet below the surface? METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 35 1 MR. ROZAK: Yes. 2 CHAIR NORMAN: Okay. And then in answer to Sea- -- 3 Commissioner Seamount's question, your monitoring well would 4 be how deep? 5 MR. ROZAK: The monitoring wells would be, let's just 6 say if the water table is at 20 feet, the bottom of the well 7 would be 26 to 27 feet. And just for clarification, on Figure 8 6, I've shown a monitor tube, MT. That is typically installed 9 in the drain field or at the perimeters or end of the 10 drainpipe, drain field area, not to groundwater, but to the 11 bottom of the drain rock, and it's a visual location, usually 12 they're a four inch diameter, to see if water -- it's an early 13 warning of a failure of a drain field. So, if you start 14 seeing water appear in those, that's an indication that 15 groundwater is raised or something is causing a clogging or 16 such in the system. The monitoring wells are the ones we'd be 17 placing several hundred feet away from the drain field. They 18 are the ones that would go six, seven feet below the 19 groundwater to a depth of say 26, 27 feet, to be determined at 20 the site at the time of drilling. 21 The purpose is, you want the well to go far enough 22 below the groundwater so that if you take a sample, with a 23 typical three foot or one meter length bailer (ph), it's 24 gathering -- there's enough water in the well to take a 25 sample. METRO COURT REPORTING 745 West Founh Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 36 1 CHAIR NORMAN: In your professional experience as an 2 engineer, if you have the effluent from the drain field pluming or coning out, is this six to seven feet into the water table sufficient to intercept it if it was coning out 3 4 5 differently? If I had a board I could show you the question I 6 have in my mind, I don't know if I'm asking it correctly. 7 I understand. Normally, yes, the -- under MR. ROZAK: 8 rare circumstances, and you'd need a hydrologist maybe to 9 better explain that but there are conditions where a gradient 10 of water flow at a site is fairly steep. Say, instead of 20 11 feet in a 1,000 or 20 feet in a mile, sometimes there can be 12 conditions at a site that cause it to be much steeper than 13 that. And there might be those conditions that would -- where 14 if you're sampling in six, seven feet below the within that 15 six, seven feet below the surface of the water, it -- there 16 may be concentrations going beneath. I -- I will -- I'll talk 17 to either someone within DEC or a hydrologist friend. I -- I 18 guess as we look at the site, and try to get a picture of the 19 surface -- where the groundwater surface is, and when you put 20 the monitoring wells in, you're able to get a better idea if 21 you survey all of those to a common bench elevation, of what 22 the surface gradient is. That won't completely answer the 23 question you're asking but it goes in someways towards 24 answering that. The other is sometimes by taking temperature 25 readings and conductivity and some other parameters in wells, METRO COURT REPORTING 745 West Fourlh Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 37 1 it gives you some idea of what sort of mixing or separation or 2 zones there are within a well, and Gerry, you might be able to 3 answer that question a little better. 4 MR. ALLEN: Well, I -- this is Gerry Allen. I do -- I 5 do monitoring for a number of the discharge lagoons on the 6 septic side of the Peninsula but I've never actually -- on 7 those systems I've never noticed any -- any variation from 8 those sample sites, as far as a temperature differential. So 9 really, I -- I haven't run across that. 10 MR. ROZAK: Let me just say that I can't an- -- I 11 can't say no.. ... 12 MR. ALLEN: Yeah. 13 MR. ROZAK: .... . there couldn't be a situation. 14 Normally on the wells I've worked and within the top six or 15 seven feet is where -- and frequently -- frequently it's 16 closer to the surface, where the higher concentrations tend to 17 be. If we had -- if we were dealing with settleable solids 18 rather than dissolved solids, or chlorides that are pretty 19 much uniformly mixed, there may be -- there may be a higher 20 chance of high concentrations deeper than near the surface. 21 DEC will probably be interested in that also. Because that's 22 part of the sampling program I'd mentioned that you identify 23 the locations of wells, depth of wells, where you take the 24 samples, what you analyze for, the method by which you collect 25 the samples. METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 . . . e e 38 1 CHAIR NORMAN: Okay, I thank you. I can appreciate 2 that answer and as you supplement your testimony, we'll try to do a wrap-up here, the things that are on our mind, but that will be a fairly important point. If the Commission 1S able 3 4 5 to approve this aquifer exemption, these monitoring wells, the 6 knowledge that they'll be there would give a level of safety 7 margin if you will, telling us these are the alarm bells that 8 would go off. And if there's a possibility that the effluent 9 would undercut those so that it wouldn't be picked up in those 10 monitoring wells, then they create a false sense of what's 11 happening, how this is behaving. So we'd want to know that 12 those monitoring wells would be deep enough to intercept this 13 effluent and tell us how it's behaving. 14 Commissioner Seamount, do you have any other 15 questions. 16 COMMISSIONER SEAMOUNT: No, I have no other questions. 17 CHAIR NORMAN: Okay. To -- I think to wrap-up, we had 18 mentioned needing some clarification on sub-surface ownership. 19 MR. WICKER: If I could interject something? 20 CHAIR NORMAN: Yes. 21 MR. WICKER: This is Mike with Envirotech. I got a 22 hold of my engineer that got back with our corporate office. 23 The sub-surface is actually owned by CIRI. The above surface 24 is owned by Tyonek. They're drafting up a letter now, which I 25 will forward to you as soon as I receive it, that says that METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 39 1 they are in full agreement with what we are doing here at this 2 time. 3 CHAIR NORMAN: And this would be a letter from Cook 4 Inlet Regional? 5 MR. WICKER: Yes, sir. 6 CHAIR NORMAN: Okay, good, that will help take -- 7 check that off on our list. And then the other major area 8 that we had discussed is the extent to which you could shed 9 further light on this receiving zone and also the depth of 10 monitoring wells, and provide an opinion on whether those, 11 given what is anticipated in your professional opinion, will 12 be sufficient to tell us whenever the effluent enters those 13 monitoring wells. At this point I would -- I'd first like to 14 ask if there's anyone else present in the hearing room that 15 would like to ask any questions or offer any statements? 16 Okay. Hearing none, then I would like to ask the applicant, 17 is there anything else, at this point, you would like to say? 18 We'd anticipate leaving the record open for whatever time you 19 tell me you might need to address this final point. 20 MR. ROZAK: I guess -- this is Ron Rozak. The area 21 I'll be dealing with would be responding to your question 22 about the confining layer and the concerns for monitoring 23 wells to adequately -- the samples collected from the wells, 24 adequately represent the conditions in -- at the groundwater 25 at that point. I would guess it would probably be, well, I'd METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · · · e e 40 1 like to say a week, but with the other things I know I'm 2 committed to, probably two weeks. For me to contact another 3 hydrologist associate, maybe discuss this with DEC. We have 4 made some inquiries of everyone we can think of as to 5 knowledge of the water and soils in this area, and there's not 6 much, nothing we've found, that's documented. So, the answer 7 gets to be really -- and maybe what we're willing -- what we 8 would propose to do, and that's why I need to talk to DEC, and 9 they may have some requirements that will answer the question. 10 CHAIR NORMAN: Yes, I can appreciate that. Then 11 Commission Seamount, if you are in agreement, then we'll leave 12 the record open for -- until close of business on Friday, June 13 25th, which will be two weeks from tomorrow, and you may 14 submit anything additionally that you chose to do so. I think 15 you've got an idea of the points that we're interested in but 16 you may submit anything else during that period. 17 I have a question also. Who would be the MR. ROZAK: 18 staff person I could contact in the interim to clarify if I 19 have information to. . . . . 20 CHAIR NORMAN: You may contact Mr. Monder, that I 21 believe has been your contact. And, for the record, if anyone 22 else in attendance at the hearing or having knowledge of this 23 wishes to submit anything else, we will also leave the record 24 open for anyone else, including the sub-surface owner, Cook 25 Inlet Region, Inc., or owners of any of the adjacent property METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 . . . e e 41 1 also until close of business on the 25th. At the time of 2 close of business on the 25thl we will consider we have 3 everything that is to be submitted and then the Commission 4 will proceed to make a decision on this as promptly as we can. 5 I do thank you all for your attendance today and I know that 6 it is an effort to come here and do this and I compliment you 7 for all the detail in this and our questions are really 8 prompted by the fact that this is a slightly different type of 9 dis- -- or aquifer exemption that we normally act on and we 10 also want to be sure that what we do will stand the test of 11 time in the future. 12 All right I if there/s nothing more from any of the 13 parties or Commissioner Seamount I then we will -- is there 14 anything more Mr. Rozak you wish to say? 15 MR. ROZAK: No. 16 CHAIR NORMAN: Okay. Then we will adjourn at 10:45 17 a.m. 18 (Off record 10:45 a.m.) 19 * * * END OF PROCEEDINGS * * * 20 21 22 23 24 25 METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 · 7 8 9 10 11 12 13 · 14 15 16 17 18 19 20 21 22 23 24 25 · e . 42 1 C E R T I FIe ATE 2 SUPERIOR COURT ) ) ss. ) 3 STATE OF ALASKA 4 5 I, Jerri Young, Notary Public in and for the State of Alaska, do hereby certify: 6 THAT the annexed and foregoing pages numbered 2 through 41 contain a full, true and correct transcript of the Public Hearing before the Alaska Oil and Gas Conservation Commission, taken by Teresa Mielke and transcribed by me: THAT the Transcript has been prepared at the request of the Alaska Oil and Gas Conservation Commission, 333 West Seventh Avenue, Anchorage, Alaska. DATED at Anchorage, Alaska this 13th day of June, 2004. SIGNED AND CERTIFIED TO BY: 11/03/07 METRO COURT REPORTING 745 West Fourth Avenue, Suite 425 Anchorage, Alaska 99501 (907) 276-3876 #6 . . STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION NAME - AFFILIATION (PLEASE PRINT) ("r\ :::r. I.l-.£ t Å'") ':l c... ~ D ~.a..-.. f?"O'ë a l<.. Cd''' I' ï ~II ~V\ ~/ln M'I' Ie-v ~.~ ~~~~~. . ~~G:: \)C>...~ 't<t. So \HearinL Sign-In AQUIFER EXEMPTION NORTH FORELAND June 10, 2004 9:00 am ADDRESS/PHONE NUMBER Y. n ~~ B--Ib 7-- AI:z..r ~s~ - p ~ ~;;<. "3 ~v k~Y\ ð.; /A-¡¿ 2?<K S iA s. ì e..c....V'\ ø... l", +< e. II'. a...~ 11l '6 p~-\ \ð\'\l1 U~J Ç~{\e-¡?:L ~~CC - 71?-{¿¿~ TESTIFY (Yes or No) o/lb - ~ '7-0~' ')eJS ïe' ~ no Nb Wo No #5 e - Application for Aquifer Exemption Envirotech's North Foreland Facility Questions In their application dated March 15, 2004, Envirotech seeks a freshwater aquifer exemption that will be used in connection with a non-domestic wastewater treatment plant and disposal drain field constructed at their North Foreland facility during 2002. The proposed drain field system will impact an unconfined, shallow aquifer that is directly connected to the waters of the Cook Inlet. Although the construction of the drain field and the produced water treatment process are described at length, based on the current application, the only issue the Commission can address is the freshwater exemption sought for their North Foreland facility. Questions Concerning the Aquifer Exemption Application: 1. Did Rozak Engineering provide copies of the application for Aquifer exemption to EP A Region 10 and to the Alaska Department of Environmental Conservation? 2. Did either of those agencies provide comments or voice objections to this project? If so, what were those comments or objections? What were Envirotech's responses? 3. Did Envirotech receive an NPDES permit from EPA? Ifnot granted, what were the reasons for denial? 4. How was the depth to the current water table determined in the project area? 5. If the AEO is granted, as requested, what other permits are required to allow this project to operate? Questions Regarding Disposal Injection (no formal application received yet): 6. Were any soil borings made to determine the type and lateral variability of the soil, either beneath the drain field or within the project impact area? 7. Has type of fluid been disposed in the drain field to date? If so, describe the fluid(s), its source, any laboratory analytical results, and describe the volume disposed. Are there any manifests for the disposed fluids? 8. Although the soils have been described as "highly permeable sands and gravels, what evidence do you have that the expected average of 240 BWPD and maximum daily rate of 1200 BWPD can be adequately handled? e e a. Have you conducted a percolation test or any other type of test to determine the hydraulic properties ofthe soils beneath the project area to confirm your anticipated disposal capacity for the drain field? b. Do you know of any such tests conducted in similar settings in the Cook Inlet Basin? 9. What radius of waste plume would develop around the drain field assuming the waste stayed in place? 10. What evidence do you have that waste disposed in the drain field will be confined, and will not migrate to, the surface, freshwater, or the Cook Inlet? 11. Do you know of any analogous large-scale drain field systems that have been successfully operated in the Cook Inlet Basin, or in Alaska? 12. Explain the ADEC lOX drinking water standards referenced in the application. 13. How often will laboratory analysis be conducted on the influent and effluent samples to ensure effectiveness of the treatment process does not diminish over time? 14. What contaminant levels will signify system problems and the need for alternative operations? 15. Concerning the three proposed monitoring wells: when will they be installed and sampled? Will cores or samples be taken and logged during drilling ofthese monitoring wells to provide soils information? 16. What recurring sampling and analysis program is being proposed for the monitoring wells? 17. What is the expected life span of the drain field and treatment facility? 18. What are Envirotech's contingency plans in case of plugging ofthe drain field by disposed solids? (500 bbls per day for 10 years = 1.8 million barrels, which also equals 6800 bbls of disposed TDS) #4 STATE OF ALASKA ADVERTISING ORDER a NOTICE TO PUBLISHER _ INVOI~T BE IN TRIPLICATE SHOWING ADVERTISING ORDER N~TFIED AFFIDAV" OF PUBLICATION (PART2 OF THIS FORM) WITH ATTACHEù C,ÜPY OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE ADVERTISING ORDER NO. AO-02414032 F AOGCC R 333 W 7th Ave, Ste 100 o Anchorage, AK 99501 M AGENCY CONTACT Jodv Colombie PHONE DATE OF A.O. April 20, 2004 PCN (907) 793 -1 ~? 1 DATES ADVERTISEMENT REQUIRED: T Peninsula Clarion o Kenai AK April 23, 2004 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Type of Advertisement X Legal D Display STOF0330 Advertisement to be published was e-mailed D Classified DOther (Specify) SEE ATTACHED REF TYPE VEN 2 ARD 3 4 NUMBER AOGCC, 333 W. 7th Ave., Suite 100 Anchorage, AK 99501 AMOUNT DATE I I TOTAL OF I PAGE 1 OF ALL PAGES$ 2 PAGES COMMENTS 02910 FIN AMOUNT SY CC PGM LC ACCT FY NMR DI5T LlQ 04 02140100 73540 2 3 .:QUISlnONED .Y(~j)...7 G & (owl / ¡ \ DIVISION APPROVAL: 02-902 (Rev. 3/94) Publisher/Original Copies: Department Fiscal, Department, Receiving AO.FRM · It Supplemental Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Aquifer Exemption Order North Foreland, Cook Inlet Alaska Approximately 1.75 miles SW ofTyonek, Alaska Approximate Location: 61°02' 33.5"N, 151°09' 50.6"W Sec 14, TllN, RllW, SM This is a SUPPLEMENTAL NOTICE adding to the NOTICE OF PUBLIC HEARING published April 21, 2004, concerning the application of Rozak Engineering on behalf of Envirotech, LLC, for the above-referenced Aquifer Exemption Order. This supplemental notice is being issued because the AOGCC has changed the date for the tentative public hearing and has extended the period for receiving written comments on the application. Except as provided in this supplemental notice, the contents in the AOGCC's notice of April 21, 2004, are incorporated by reference. The Commission has tentatively set a public hearing on this application for June 10,2004, at 9:00 am at the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. A person may request that the tentative hearing be held by filing a written request with the Commission no later than 4:30 pm on May 10,2004. If a request for hearing is not timely filed, the Commission may consider the issuance of an order without a hearing. To learn if the Commission will hold the public hearing, please call 793-1221. In addition, a person may submit written comments regarding this application to the Alaska Oil and Gas Conservation Commission at 333 West ih Avenue, Suite 100, Anchorage, Alaska 99501. Written comments must be received no later than 4:30 pm on May 24, 2004, except that if the Commission decides to hold a public hearing, written comments must be received no later than 9:00 am on June 10, 2004. If you are a person with a disabi . to comment or to attend the blic before June 1,2004. may need a special modification in order lease contact Jody Colombie at 793-1221 Published Date April 23, 2004 ADN AO# 02414031 C1arion AO # 02414032 . e e .. RECE'VED I~PH '¿ ~OtI&Ga&~'~ .~IÓ~ UNITED STATES OF AMERICA, STATE OF ALASKA PUBLISHER'S AFFIDAVIT } ss: Denise Reece being first duly r------...------....-.., I S\lpplem.... ~ .~ PuIIIIc Hearing . I I STATe,F ALAS", . I AlaSka Oil and Gas Conservation '.' I Commission '1 I Rè: Aquifer Exemption Order . I North Foreland. Cook Inlet Alaska . Approximately 1.75 miles SW of 1ÿonek. ' 1 I Alaska . I Approximate Loeatlon:. 61° 02' 33.5" N. . I 151°09'50.6"W I See 14, TH\¡, . I R11W, SM ,I · This is a SUPPLEMENTAL NOTICE adding ~. · the NOTICE OF PUBLIC HEARING published' I April 21,2004,concerningthe a~icatiOn ofl · Rozak Engineering on behalf of Emnrotech. LLC. ,I I for the above-referenced Aquifer Exemption.. Order. . This supplemental notice is being issued I · ~ the AOGCC has changEldthe date for the .', · ..... public hearing and has extend.. .. · period for receiving written commen1$ on .., · ~lIIion. Except as provided in this ........ .11'I8ntIII notice, the contents in the AQGCC·S..... of ApfI21, 2004, lire incorporated by refer.... I I The Commission hás tentatively set a ......'. · hewing on this application for June 10, ~ . · e:oo 11m at the Alaska Oil and G$S ~ , · ComrniIBion at 333West7th Avenue, Suite _. I Anc:hortIge, Alaska 99501. A person may ......... that.... tentative hearing beheld by filing a _. I requeet with the Commission no later than 4., · pm on May 10. 2004. · If . l1!Quest for hearing is not timely filec:i. _, I CommIesionmay COI')Sicler the issuançe .of__ I orWr without a hearing. To learn if the I · Commiesion will hold the public hearing, pi..... call 793-1221. .. · In addition, a person may submltwrittEln.com- ments regarding this application to the Alaska Oil I and Gas Conservation Commissión at 333 w.t.' 7th Avenue, Suite 100, AnOOOI'ag8, Alaska 99501.1 Written coml)'lents must be received no later thao 1 4:30 pm on May 24, 2004,ex~pt ~.. if the I Commission decides to hold a public heanng. writ-, I ten comments must .I)e received no later than 9:00 · am on June 10, 2004... , 1 · If you are a person with a disability who may I I need a special modification in order to commeot 1 or to, attend the public hearing, please contact. I · Jody Colombie at 793-1221 before June 1, 2004. . :~= K. NonMn I I PUBLISH: 4ID," . _fl__ I L_____~____~____~ sworn, on oath deposes and says: That I am and was at all times here in this affidavit mentions, Supervisor of Legals of the Peninsula Clarion, a news- paper of general circulation and published at Kenai, Alaska, that the Aquifer Exemption Order/Supplemental Notice AO-02414032 a printed copy of which is hereto annexed was published in said paper one each and every day for one successive and consecutive day in the issues on the following dates: , April 23, 2004 X ¡jle/1/';'1~ /PU:ØÆ'L.- SUBSCRIBED AND SWORN to me before ¡J);Ø;0~ 2004 NOTARY PUBLIC in favor for the State of Alaska. My Commission expires 17-Nov-07 Ollal. HAR"OP NOTARY PUBLIC StIt, of AlaSl<a My CømMII,tiOn ExsIires Nov. 17, 2007 RE: Supp1mental Notice - . Hi Jody: Following is the confirmation information on your legal notice. Please let me know if you have any questions or need additional information. Account Number: STOF 0330 Legal Ad Number: 134290 Publication Date(s): April 23, 2004 Your Reference or PO#: 02414031 Cost of Legal Notice: $178.12 Additional Charges Web link: E-Mail Link: Bolding: Total Cost to Place Legal Notice: $178.12 Ad Will Appear on the web, www.adn.com: XXXX Ad Will Not Appear on the web, www.adn.com: Thank You, Kim Kirby Anchorage Daily News Legal Classified Representative E-Mail: legalads@adn.com Phone: (907) 257-4296 Fax: (907) 279-8170 ---------- From: Jody Colombie Sent: Tuesday, April 20, 2004 5:04 PM To: legalads Subject: Supplmental Notice «File: Ad Order form.doc»«File: Amended AEO Envirotech.doc» Please publish the attached Notice on 4/23/04. Jody 1 of 1 4/20/20045:41 PM STATE OF ALASKA ADVERTISING ORDER . NOTICE TO PUBLISHER _ INVOIC ST BE IN TRIPLICATE SHOWING ADVERTISING ORDER N.RTIFIED AFFIDA T OF PUBLICATION (PART 2 OF TliIS FORM) WITH ATTACHED COpy OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE ADVERTISING ORDER NO. AO-02414032 F AGENCY CONTACT DATE OF A.O. AOGCC 333 West 7th Avenue, Suite 100 o Anchorage, AK 99501 M 907-793-1221 R Jody Colombie April ?O, ?004 PHONE PCN (907) 793 -12? 1 DATES ADVERTISEMENT REQUIRED: T o Peninsula Clarion April 23, 2004 Kenai AK THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: United states of America AFFIDAVIT OF PUBLICATION REMINDER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. A CERTIFIED COpy OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMITTED WITH THE INVOICE. ATTACH PROOF OF PUBLICATION HERE. division. Before me, the undersigned, a notary public this day personally appeared who, being first duly sworn, according to law, says that helshe is the of Published at in said division and state of and that the advertisement, of which the annexed is a true copy, was published in said publication on the day of 2004, and thereafter for _ consecutive days, the last publication appearing on the _ day of . 2004, and that the rate charged thereon is not in excess of the rate charged private individuals. Subscribed and sworn to before me This _ day of 2004, Notary public for state of My commission expires 02-901 (Rev. 3/94) Page 2 AO.FRM PUBLISHER STATE OF ALASKA ADVERTISING ORDER _ NOTICE TO PUBLISHER . INVOI9!ST BE IN TRIPLICATE SHOWING ADVERTISING ORDER N RTIFIED AFFIDAVII OF PUBLICATION (PART2 OF THIS FORM) WITH ATTACHE COpy OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE ADVERTISING ORDER NO. AO-02414031 F AOGCC R 333 W 7th Ave, Ste 100 o Anchorage, AK 99501 M AGENCY CONTACT DATE OF A.O. Jody Colombie PHONE April 20, 2004 PCN (907) 793 -1)71 DATES ADVERTISEMENT REQUIRED: ¿ Anchorage Daily News POBox 149001 Anchorage, AK 99514 April 23, 2004 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Type of Advertisement X Legal o Display STOF0330 Advertisement to be published was e-mailed o Classified DOther (Specify) SEE ATTACHED REF TYPE VEN 2 ARD 3 4 NUMBER AOGCC, 333 W. 7th Ave., Suite 100 Anchorage, AK 99501 AMOUNT DATE I I TOTAL OF I PAGE 1 OF ALL PAGES$ 2 PAGES COMMENTS 02910 FIN AMOUNT SY CC PGM LC ACCT FY NMR DIST LID 04 02140100 73540 2 3 (' 4 /\ ' REQUISITIONED(~~~lkb~ i / DIVISION APPROVAL: 02-902 (Rev. 3/94) Publisher/Original Copies: Department Fiscal, Department, Receiving AO.FRM e e Supplemental Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Aquifer Exemption Order North Foreland, Cook Inlet Alaska Approximately 1.75 miles SW of Tyonek, Alaska Approximate Location: 61°02' 33.5"N, 151°09' 50.6"W Sec 14, TllN, RllW, SM This is a SUPPLEMENTAL NOTICE adding to the NOTICE OF PUBLIC HEARING published April 21, 2004, concerning the application of Rozak Engineering on behalf of Envirotech, LLC, for the above-referenced Aquifer Exemption Order. This supplemental notice is being issued because the AOGCC has changed the date for the tentative public hearing and has extended the period for receiving written comments on the application. Except as provided in this supplemental notice, the contents in the AOGCC's notice of April 21, 2004, are incorporated by reference. The Commission has tentatively set a public hearing on this application for June 10,2004, at 9:00 am at the Alaska Oil and Gas Conservation Commission at 333 West ih Avenue, Suite 100, Anchorage, Alaska 99501. A person may request that the tentative hearing be held by filing a written request with the Commission no later than 4:30 pm on May 10, 2004. If a request for hearing is not timely filed, the Commission may consider the issuance of an order without a hearing. To learn if the Commission will hold the public hearing, please call 793-1221. In addition, a person may submit written comments regarding this application to the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. Written comments must be received no later than 4:30 pm on May 24, 2004, except that if the Commission decides to hold a public hearing, written comments must be received no later than 9:00 am on June 10, 2004. If you are a person with a disabi . to comment or to attend the blic before June 1, 2004. may need a special modification in order lease contact Jody Colombie at 793-1221 Published Date April 23, 2004 ADN AO# 02414031 Clarion AO # 02414032 «chOrage Daily News Affidavit of Publication 1001 Northway Drive, Anchorage, AK 99508 e PRICE OTHER OTHER OTHER OTHER OTHER ~ AD# DAT~ PO ACCOUNT PER DAY CHARGES CHARGES #2 CHARGES #3 CHARGES #4 CHARGES #5 TOTAL 134290 04/23/2004 02414031 STOF0330 $178.12 $178.12 $0.00 $0.00 $0.00 $0.00 $0.00 $178.12 STATE OF ALASKA THIRD JUDICIAL DISTRICT Teresita Peralta, being first duly sworn on oath deposes and says that she is an advertising representative of the Anchorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the aforesaid place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental fonn) of said newspaper on the above dates and that such newspaper was regularly distributed to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Signed ~M«/J~ Subscribed and sworn to me before this date: hOrMi ~ 7, MCr¡ r Notary Public in and for the State of Alaska. Third DiV, ision. Anchorage, Alaska ., j MY COM MISS ION EX, PIRES/Z. OCt. ,'JYd ';UJ7 )~ '7J1Î 'U' .\!I(((({(/.r . j \\\ 1\>"1'1': , \\ 10."" ,........ - \ . ., " "<r. '."" " . I Mil J .' ~\:' , '''',t¥, ';'<~,e::::- VVfV/~ ..."". '. .' ',,- " ~'.,¡?''''''OTi~'!f,.~.:r- , ~ ..+~. _'!I.!)~'fr· r-."'"...... ~ ; ........' ..- '- . il'.. ... '- . ,..p .1'(:»1 ~C : ,;::: -:;. 'l.:i4I_' ' ~..... :=.,:¡.) ..l~ ........ 'f:.."t:Gl'~ -~ ~J:>'" ~~ . \t~ -- .oC..- rv. .. '\.¥' . . .!\.':'\ ' -.:::- ., -..or., . ":\ :.:;..., ~v. . '. . . ',.Ò,.. \\ :.I./'tt! Explr<;~:.:\ ))\ :1,/ j J lllJJ ¡) \ Supplemental Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Aquifer Exemption Order North Foreland, Cook Inlet Alaska APproximately 1.75 miles SW of Tyanek, Alaska Approximate Location: 61· 02' 33.5" N, 151009' 50.6" W Sec 14, Tl1N. Rl1W, SM This is a SUPPLEMENTAL NOTICE Qdd\ng to the NOTICE OF PUBLIC HEARING published April 21 2004 concerning the application of Rozak Enginee'ring ~n behalf. of Envirote~h, LLC, for t~e above-referenced AquIfer ExemptIon Order. ThIs supplemental notice is being issued becayse the AOGCC has changed the date for the.tentQtlve P~b- lic hearing and hQS extended the p!,no~ for recelv,' ing written comments on the appllcat"on. Except QS provided In this supplemental notIce, the con· tents In the AOGCC's notice, of April 21, 2004. are incorporated bY reference. The Commission has tentativelY set a public hearing on this application for June 10, 200;4, at 9:00- am at the AlaskQ Oil and Gas Con~ervahon Com- mission at 333West 7th Avenue, SUIte 100, Anchor- age, Alaska 99501. A persc¡n m~y request that the tentative hearing be held !>y f~ia'", 9a written re- quest with the CommissiolT"ÐOl\!ifér,than 4:30 pm on May 10, 2004. If a request for hearing is not timely filed, the Commission maycon~der the I.ssuance of ~n .or· der without a heQriniJ'. To learn If the CommIssion will hold the public hearing, please call 793-1221. In addition, a person m.QY ~ubmit written com.· ments regarding this pppilcatlon to the Alaska 011 and Gas Conservation Commission at 333 West 7!h Avenue Suite 100. Anchorage, Alaska 9950L Wnt- ten co~ments must be received no later tha.... 4:30 pm on May 24, 2004, except that. if the C.ommlss1on decides to hold a public hearong, wrotten com· ments must be received no later than 9:00 am on June 10, 2004. If you are a person with a disability wha may need a special modification in order to comment or to attend the pUblic hearing, please contact Jody Colombie at 793·1221 before June 1, 2004. John K. Norman Chair AO# 02414032 Publish: April 23. 2004 STATE OF ALASKA ADVERTISING ORDER .. NOTICE TO PUBLISHER a INVOI~ST BE IN TRIPLICATE SHOWING ADVERTISING ORDER N.RTIFIED AFFIDi'\vI f OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED CuPY OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE ADVERTISING ORDER NO. AO-02414031 F AGENCY CONTACT DATE OF A.O. AOGCC R 333 West 7th Avenue, Suite 100 o Anchorage,AJ( 99501 M 907-793-1221 Jody Colombie April 20, ?004 PHONE PCN (907) 793 -12? 1 DATES ADVERTISEMENT REQUIRED: T o Anchorage Daily News POBox 149001 Anchorage, AJ( 99514 April 23, 2004 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: United states of America AFFIDAVIT OF PUBLICATION REMINDER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. A CERTIFIED COpy OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMITTED WITH THE INVOICE. ATTACH PROOF OF PUBLICATION HERE. division. Before me, the undersigned, a notary public this day personally appeared who, being first duly sworn, according to law, says that he/she is the of Published at in said division and state of and that the advertisement, of which the annexed is a true copy, was published in said publication on the day of 2004, and thereafter for _ consecutive days, the last publication appearing on the _ day of , 2004, and that the rate charged thereon is not in excess of the rate charged private individuals. Subscribed and sworn to before me This _ day of 2004, Notary public for state of My commission expires 02-901 (Rev. 3/94) Page 2 AO.FRM PUBLISHER Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 Kelly Valadez Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Kay Munger Munger Oil Information Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage, AK 99502 Ciri Land Department PO Box 93330 Anchorage, AK 99503 David Cusato 600 West 76th Ave., #508 Anchorage, AK 99518 James Gibbs PO Box 1597 Soldotna, AK 99669 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 e Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Schlumberger Drilling and Measurements 3940 Arctic Blvd., Ste 300 Anchorage, AK 99503 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Jack Hakkila PO Box 190083 Anchorage, AK 99519 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 SOldotna, AK 99669-2139 Cliff Burglin PO Box 70131 Fairbanks, AK 99707 North Slope Borough PO Box 69 Barrow, AK 99723 e David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 John Levorsen 200 North 3rd Street, #1202 Boise,ID 83702 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, WA 98119-3960 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 Darwin Waldsmith PO Box 39309 Ninilchick, AK 99639 Penny Vadla 399 West Riverview Avenue Soldotna, AK 99669-7714 Bernie Karl K&K Recycling Inc. PO Box 58055 Fairbanks, AK 99711 / ) a ¿ / é" c:/-h:; épé/I'Cl·-k yo ¿¡ /z¡)J i Supplemental Notice e e Clarion Ad Order form.docl Content-Type: applicationlmsword Content-Encoding: base64 AEO _ Envirotech.doc Content-Type: applicationlmsword Content-Encoding: base64 1 of 1 4/20/20045:10 PM Supplemental Notice e e Amended AEO _ Envirotech.doc Content-Type: applicationlmsword Content-Encoding: base64 lof2 4/20/20045:10 PM Supplemental Notice e . Please replace the Notice that I e-mailed on 4/16/04 with the attached Supplement. Thank you. Jody Content-Type: applicationlmsword Amended AEO Envirotech.doc Content-Encoding: base64 1 of 1 4/20/20045:10 PM RE: Notice . e Hi Jody: Following is the confirmation information on your legal notice. Please let me know if you have any questions or need additional information. I did not receive the AO for this legal notice. Account Number: STOF 0330 Legal Ad Number: 134188 Publication Date(s): April 22, 2004 Your Reference or PO#: 02414030 Cost of Legal Notice: $183.96 Additional Charges Web link: E-Mail Link: Bolding: Total Cost to Place Legal Notice: $183.96 Ad Will Appear on the web, www.adn.com: XXXX Ad Will Not Appear on the web, www.adn.com: Thank You, Kim Kirby Anchorage Daily News Legal Classified Representative E-Mail: 1ega1ads@adn.com Phone: (907) 257-4296 Fax: (907) 279-8170 ---------- From: Jody Colombie Sent: Tuesday, April 20, 20044:33 PM To: legal ads Subject: Notice «File: BOPE supplement notice.doc» Please publish on 4/22/04. Thank you. 1 of 1 4/20/20045:10 PM #3 STATE OF ALASKA ADVERTISING ORDER . NOTICE TO PUBLISHER . INVOIC" ,II ST BE IN TRIPLICATE SHOWING ADVERTISING ORDER N TIFIED AFFIDAVIT OF PUBLICATION (PART2 OF THIS FORM) WITH ATTACHED COPY OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE ADVERTISING ORDER NO. AO-02414028 F AOGCC R 333 W 7th Ave, Ste 100 o Anchorage, AK 99501 M AGENCY CONTACT Jodv Colombie PHONE DATE OF A.O. April 16, 2004 PCN (907) 793 -1 ?21 DATES ADVERTISEMENT REQUIRED: T Clarion Peninsula o Kenai, Alaska April 21, 2004 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Type of Advertisement X Legal D Display STOF0330 Advertisement to be published was e-mailed D Classified DOther (Specify) SEE ATTACHED REF TYPE VEN 2 ARD 3 4 NUMBER AOGCC, 333 W. 7th Ave., Suite 100 Anchorage, AK 99501 AMOUNT DATE I TOTAL OF I PAGE 1 OF ALL PAGES$ 2 PAGES COMMENTS 02910 FIN AMOUNT sy CC PGM LC ACCT FY NMR DIST LID 04 02140100 2 3 R:QUISITIO(r,ŒD..·.'.;;y.};.\/.. '} .:~ /.... i/l '- /~^-t,J4~ r:5IALk~ , / \..,/ ~">" 02-902 (Rev. 3/94) Publisher/Original Copies: Department Fiscal, Department, Receiving AO.FRM . . Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Aquifer Exemption Order North Foreland, Cook Inlet Alaska Approximately 1.75 miles SW ofTyonek, Alaska Approximate Location: 61002' 33.5" N, 151009' 50.6" W Sec 14, TllN, RllW, SM Rozak Engineering on behalf of Envirotech, LLC (a subsidiary of Tyonek Native Corporation) by letter dated March 15, 2004 has requested the Commission issue an Aquifer Exemption Order pursuant to 20 AAC 25.440. The requested order would exempt from consideration as freshwater, the unconfined saline groundwater beginning at the ground surface around a waste water disposal drainfield installed at the Envirotech Facility at the site. This exemption will allow Envirotech to pursue a permit for subsurface disposal of treated wastes. The Commission has tentatively set a public hearing on this application for May 25,2004 at 9:00 am at the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. A person may request that the tentative hearing be held by filing a written request with the Commission no later than 4:30 pm on May 6, 2004. If a request for hearing is not timely filed, the Commission may consider the issuance of an order without a hearing. To learn if the Commission will hold the public hearing, please call 793-1221. In addition, a person may submit written comments regarding this application to the Alaska Oil and Gas Conservation Commission at 333 West ih Avenue, Suite 100, Anchorage, Alaska 99501. Written comments must be received no later than 4:30 pm on May 22, 2004, except that if the Commission decides to hold a public hearing, written comments must be received no later than 9:00 am on May 25, 2004. If you are a person with a di to comment or to attend the publ' before May 10, 2004. lity who may need a special modification in order ng, please contact Jody Colombie at 793-1221 111 A ) o~~ Published Date: April 21, 2004 ADN AO# 02414027 Clarion AD # 02414028 . ( PUBLISHER'S AFFIDAVIT UNITED STATES OF AMERICA, } STATE OF ALASKA ss: ftMI&Ct III'/¡ 2 8 t:1V'ED AJ_L.. tI I:' r' f.ß 0 4 ~Oit&~·· ,( l: ~.::Q--' J L.. . t.Cr¡i·l-\,'fíHf¡¡""" "'!t;,~ ..".....1 consecutive day following dates:. April 21, 2004 in the issues on the r-'-_:" - -- -..,,~.....-..--..---_.., . ....... of NIle ....119 . I· . 1TAT8.0f~·. I · Alaska on and Ga's COMervation . · Commission . · Re: Aquifer Exemption Order I I North Foreland, Cook Inlet Alaska . I · Approximately 1.75 miles-SW ofTyonek, . · Alaska I . Approximate .Location: 610 02' 33.5" N, · 151D09'.50.6"W · Sec 14,T11N.R11W, SM I Rozak Engineering on behalf of Envirotech, I LLC (a subsidiary ofTyonek Native CorpOration) I by letter dated March 15, 2004 has requestecl·1 the Commission issue an Aquifer Exernt*n . Order pursuant to 20 AAC 25.440. The request- . ed order would exempt· from consideration . I freshwater, the unconfihedsallne grouncIwaW I. beginning at the ground surface around a .... . water. disposaldrainfield Installed · at the I I EnvirotechFacilityat the site. This exernpllan I I will allow Envi.rotech to pursue a permit for tub- I IlUrlace disposal of treated wastes.. I I The· Commissio~ has tentatively set a puÞlØl . Maring on this application for May 25, 2004 .. I 9:00 am at the Alaska Oil and Gas ConserVJlOn Commission at 333 West 7th Avenue, Suite 100. I Anchorage, Alaska 99501.. A person may I request that the tentative hearing be held br" I ing . Written reqIJest with the Commission, no I later than 4:30 pm on May 6, 2004. '. ". request for hearing Is not timely filed, the. CommIssion may consider the issuance .of an Ot"der WitholJt a hearing. To learn if the I Commission will hold the pUblic hearing, please I call 793·1221. I In adclltion, a person may submit written com- . ments regarding this application to the Alaska I Oil and. Gas Conservation CommiSsion at 3331 West 7th Avenue. suite 100, Anchorage, Alaska I 99501. Written comments must be received no I later than 4:30 pm o,n May 22, 2004, except that If the Commission decides to hold a pIJbliC hear- I ing, written comments must be received no later I than 9:00 am on May 25, 20$)4. I If you are a person with a disability who may' need a special modification in order to comment I or to attend the pubii~ hearing, please contact I I Jody Colombie at 793-1221 before May 10, I . 2004. I I John K.Nor.m.n Chair I I PU~: 4111,1104 *'/2074 I L_______________~ Denise Reece being first duly sworn, on oath deposes and says: That I am and was at all times here in this affidavit mentions, Supervisor of Legals of the Peninsula Clarion, a news- paper of general circulation and published at Kenai, Alaska, that the Aquifer Exemption Order AO-02414028 a printed copy of which is hereto annexed was published in said paper one each and every day for one successive and x ~11 . , -il.L<./1, / ./'U./ IP...¿/ t"'.L~ Sm- BS RI.BEDA.ND SWORN to me before thl r, LL~~ ~ April , 2004 i V/-iUljJJJtJt¡p NOTARY PUBLIC in favor for the State of Alaska. My Commission expires 17-Nov-07 DEBBIE HARROP NOTARY PUBLIC State Of Alask. My CØIm1Iiøion Expires Nov. 17.2007 STATE OF ALASKA ADVERTISING ORDER . . NOTICE TO PUBLISHER . INVOI, ST BE IN TRIPLICATE SHOWING ADVERTISING ORDER RTIFIED AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE ADVERTISING ORDER NO. AO-02414028 F AGENCY CONTACT DATE OF A.O. AOGCC R 333 West 7th Avenue, Suite 100 o Anchorage, AK 99501 M 907-793-1221 Jody Colombie PApril 16, ?004 PHONE CN (907) 793 -1 ??1 DATES ADVERTISEMENT REQUIRED: T o Clarion Peninsula Kenai, Alaska April 21, 2004 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: United states of America AFFIDAVIT OF PUBLICATION REMINDER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. A CERTIFIED COPY OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMITTED WITH THE INVOICE. ATTACH PROOF OF PUBLICATION HERE. division. Before me, the undersigned, a notary public this day personally appeared who, being first duly sworn, according to law, says that helshe is the of Published at in said division and state of and that the advertisement, of which the annexed is a true copy, was published in said publication on the day of 2004, and thereafter for _ consecutive days, the last publication appearing on the _ day of . 2004, and that the rate charged thereon is not in excess of the rate charged private individuals. Subscribed and sworn to before me This _ day of 2004, Notary public for state of My commission expires 02-901 (Rev. 3/94) Page 2 AO.FRM PUBLISHER STATE OF ALASKA ADVERTISING ORDER . NOTICE TO PUBLISHER . INVOI ST BE IN TRIPLICATE SHOWING ADVERTISING ORDER N RTIFIED AFFIDAVIT OF PUBLICATION (PART2 OF THIS FORM) WITH ATTACHED COpy OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE ADVERTISING ORDER NO. AO-02414027 F AOGCC R 333 W 7th Ave, Ste 100 o Anchorage, AK 99501 M AGENCY CONTACT Jodv Colombie PHONE DATE OF A.O. April 16, 2004 PCN (907) 793 -12?1 DATES ADVERTISEMENT REQUIRED: ~ Anchorage Daily News POBox 149001 Anchorage, AK 99514 April 21, 2004 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: Type of Advertisement X Legal D Display STOF0330 Advertisement to be published was e-mailed D Classified DOther (Specify) SEE ATTACHED REF TYPE 1 VEN 2 ARD 3 4 FIN AMOUNT NUMBER AOGCC, 333 W. 7th Ave., Suite 100 Anchorage, AK. 99501 AMOUNT DATE I I TOTAL OF I PAGE 1 OF ALL PAGES$ 2 PAGES COMMENTS 02910 SY CC PGM LC ACCT FY NMR DIST LID 04 02140100 2 3 4 REQUISITIOrD B\ \", ~'·--'·^·"""·~·"·í ¡ ¡ , , \ \. ..\~. i ¿ ~. ~ì /" / ..-' . _}' """",r'" 02-902 (Rev. 3/94) Publisher/Original Copies: Department Fiscal, Department, Receiving AO.FRM . . Notice of Public Hearing STATE OF ALASKA Alaska Oil and Gas Conservation Commission Re: Aquifer Exemption Order North Foreland, Cook Inlet Alaska Approximately 1.75 miles SW of Tyonek, Alaska Approximate Location: 61°02' 33.5"N, 151°09' 50.6"W Sec 14, T11N, R11 W, SM Rozak Engineering on behalf of Envirotech, LLC (a subsidiary of Tyonek Native Corporation) by letter dated March 15, 2004 has requested the Commission issue an Aquifer Exemption Order pursuant to 20 AAC 25.440. The requested order would exempt from consideration as freshwater, the unconfined saline groundwater beginning at the ground surface around a waste water disposal drainfield installed at the Envirotech Facility at the site. This exemption will allow Envirotech to pursue a permit for subsurface disposal of treated wastes. The Commission has tentatively set a public hearing on this application for May 25,2004 at 9:00 am at the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. A person may request that the tentative hearing be held by filing a written request with the Commission no later than 4:30 pm on May 6, 2004. If a request for hearing is not timely filed, the Commission may consider the issuance of an order without a hearing. To learn if the Commission will hold the public hearing, please call 793-1221. In addition, a person may submit written comments regarding this application to the Alaska Oil and Gas Conservation Commission at 333 West 7th Avenue, Suite 100, Anchorage, Alaska 99501. Written comments must be received no later than 4:30 pm on May 22, 2004, except that if the Commission decides to hold a public hearing, written comments must be received no later than 9:00 am on May 25, 2004. If you are a person with a di to comment or to attend the publ" before May 10, 2004. lity who may need a special modification in order ng, please contact Jody Colombie at 793-1221 'j~ A ) o~~ Published Date: April 2],2004 ADN AO# 02414027 Clarion AO # 02414028 RE: Legal Notice e . Hi Jody: Following is the confirmation information on your legal notice. Please let me know if you have any questions or need additional information. Account Number: STOF 0330 Legal Ad Number: 130875 Publication Date(s): April 21, 2004 Your Reference or PO#: 02414027 Cost of Legal Notice: $175.20 Additional Charges Web link: E-Mail Link: Bolding: Total Cost to Place Legal Notice: $175.20 Ad Will Appear on the web, www.adn.com: XXXX Ad Will Not Appear on the web, www.adn.com: Thank You, Kim Kirby Anchorage Daily News Legal Classified Representative E-Mail: legalads@adn.com Phone: (907) 257-4296 Fax: (907) 279-8170 ---------- From: Jody Colombie Sent: Friday, April 16, 2004 11 :11 AM To: legalads Subject: Legal Notice «File: Ad Order form.doc»«File: AEO Envirotech.doc» Please publish on 4/21/04 -lody 10fl 4/16/20043:05 PM 4InchOrage Daily News Affidavit of Publication 1001 Northway Drive, Anchorage, AK 99508 . PRICE OTHER OTHER OTHER OTHER OTHER GRAND AD# DATE PO ACCOUNT PER DAY CHARGES CHARGES #2 CHARGES #3 CHARGES #4 CHARGES #5 TOTAL 130875 04/21/2004 02414027 STOF0330 $175.20 $175.20 $0.00 $0.00 $0.00 $0.00 $0.00 $175.20 STATE OF ALASKA THIRD JUDICIAL DISTRICT Teresita Peralta, being first duly sworn on oath deposes and says that she is an advertising representative of the Anchorage Daily News, a daily newspaper. That said newspaper has been approved by the Third Judicial Court, Anchorage, Alaska, and it now and has been published in the English language continually as a daily newspaper in Anchorage, Alaska, and it is now and during all said time was printed in an office maintained at the aforesaid place of publication of said newspaper. That the annexed is a copy of an advertisement as it was published in regular issues (and not in supplemental form) of said newspaper on the above dates and that such newspaper was regularly distributed to its subscribers during all of said period. That the full amount of the fee charged for the foregoing publication is not in excess of the rate charged private individuals. Signed YffMç¡/ft0 Subscribed and sworn to me before this date: ¡Jf~ti ;if. :Jt01j Notary Public in and for the State of Alaska. Third Division. A. nChOrage,. Alaska ,,) j¿y .OMMlSSI..~N .EXP.IRES.~ /1' ~w 1 ..' W~/ /JÆ....~( .\I.l((((.d.ffr..r cA 11 c . \\\ \.."l Ji,., I(/., I"rr. - . - ", :!f..~ , ' . .- , , ~<~ .-;... ~~.,' .........,.J..-;.. ! l· ~~" O· 1:A.Ry. -;. I -..;-...~. - ...... w... '.,ø':""> .._ ........ IIdlh ' ... ,._ . _ ::: : bH. ~f'.'$;\..\'v . 1::;:::: .... . ruP ~. ~'"' S ~.:. dI~ .."'..../: ~.~ ~:r.' ~.':'\ ~ ~' .17iar "'. ,',.lY-:\, ~ . .' ...._~. .~\'\ .............. EJ.v.";". . \ \' :lIJJÚJJ))))\ Notice of Public Hearing ~TATE OF ALASKA . Alaska Oil and Gas Conservation Commission Re:Aquifer Exemption Order North Foreland, Cook In"!! Alaska ApProximatelY 1.75 mlles SW of Tyanek, Alaska Approximate Location : 61002' 33.5"N, 1510 09' 50.6" WSec 14, TllN, RlIW, SM Rozak Engineering on beh~lf of Envirotech, LLC (a subsidiary of Tyanek Native Corporation) by letter doted March 15, 2004 has requested the Cammissiqn issue an Aquifer Exemption Order pursuant to 20 AAC 25.440. The requested order would exempt fromC?nsideration os freshwater, the unconfined saline groundwater beginning at .the ground surface around 0 waste water~ispasal drainffeld installed at the Envirotech Facility at the site. This exemption will allow Envirotech to ~~~~:.a permit for subsurface disposal of treated The Commission has tentativelyset.a p'ublic ~~~r~hDe" lr¿;~:~:fC;:~dnci~~ ~g~s~v~~~na~~~ mission at 333 West 7th .Avenue, Suite 100, Anchor- age, Alaska 99501. A person may request that the tentative hearing be held bY filing 0 writtèn reo quest with the Commission nl) later than 4:30 pm on May 6, 2004. If 0 request for hearing is not timelY filed, the Commission may consider the issuance of on or· der without 0 hearing. Tl)learn if the Commission will hold the public hearing, plèo$e call 793-1221. In addition., a person may submit written com' mentsregarding this application to the Alaska Oil and Gas Conservation Commission at 333 We!l't 7th f;,~e~~:;;~~~tt~ ~~stb~h~;~iï~e:l~g~~t:~~ån~~~õ pm on May 22, 2004, except that if the Commission decides to hold 0 publichearhìg, wrllten co.m" ments must be received no iater than 9:00 om on May 25, 2004. If yoU ore 0 person with 0 disability who may need 0 special modification in order to comment or to attend the public hearing, piease contact Jody Colombie at 793·1221 before· May 10, ~004. John K. Norman Choir AO# 02414027 Publish: April 21. 2004 STATE OF ALASKA ADVERTISING ORDER . NOTICE TO PUBLISHER . INVOI ST BE IN TRIPLICATE SHOWING ADVERTISING ORDER N RTIFIED AFFIDAVIT OF PUBLICATION (PART 2 OF THIS FORM) WITH ATTACHED COPY OF ADVERTISEMENT MUST BE SUBMITTED WITH INVOICE ADVERTISING ORDER NO. AO-02414027 F AGENCY CONTACT DATE OF A.O. AOGCC 333 West 7th Avenue, Suite 100 o Anchorage,AJ( 99501 M 907-793-1221 R Jody Colombie April 16, ?004 PHONE PCN (907) 793 -1 nl DATES ADVERTISEMENT REQUIRED: T o Anchorage Daily News POBox 149001 Anchorage, AJ( 99514 April 21, 2004 THE MATERIAL BETWEEN THE DOUBLE LINES MUST BE PRINTED IN ITS ENTIRETY ON THE DATES SHOWN. SPECIAL INSTRUCTIONS: United states of America AFFIDAVIT OF PUBLICATION REMINDER State of ss INVOICE MUST BE IN TRIPLICATE AND MUST REFERENCE THE ADVERTISING ORDER NUMBER. A CERTIFIED COpy OF THIS AFFIDAVIT OF PUBLICATION MUST BE SUBMITTED WITH THE INVOICE. ATTACH PROOF OF PUBLICATION HERE. division. Before me, the undersigned, a notary public this day personally appeared who, being first duly swom, according to law, says that he/she is the of Published at in said division and state of and that the advertisement, of which the annexed is a true copy, was published in said publication on the day of 2004, and thereafter for _ consecutive days, the last publication appearing on the _ day of , 2004, and that the rate charged thereon is not in excess of the rate charged private individuals. Subscribed and swom to before me This _ day of 2004, Notary public for state of My commission expires 02-901 (Rev. 3/94) Page 2 AO.FRM PUBLISHER Citgo Petroleum Corporation PO Box 3758 Tulsa, OK 74136 Kelly Valadez Tesoro Refining and Marketing Co. Supply & Distribution 300 Concord Plaza Drive San Antonio, TX 78216 Jerry Hodgden Hodgden Oil Company 408 18th Street Golden, CO 80401-2433 Kay Munger Munger Oil Information Service, Inc PO Box 45738 Los Angeles, CA 90045-0738 Mark Wedman Halliburton 6900 Arctic Blvd. Anchorage; AK 99502 Ciri Land Department PO Box 93330 Anchorage, AK 99503 David Cusato 600 West 76th Ave., #508 Anchorage, AK 99518 James Gibbs PO Box 1597 Soldotna, AK 99669 Richard Wagner PO Box 60868 Fairbanks, AK 99706 Williams Thomas Arctic Slope Regional Corporation Land Department PO Box 129 Barrow, AK 99723 . Mary Jones XTO Energy, Inc. Cartography 810 Houston Street, Ste 2000 Ft. Worth, TX 76102-6298 . Robert Gravely 7681 South Kit Carson Drive Littleton, CO 80122 Richard Neahring NRG Associates President PO Box 1655 Colorado Springs, CO 80901 Samuel Van Vactor Economic Insight Inc. 3004 SW First Ave. Portland, OR 97201 Schlumberger Drilling and Measurements 3940 Arctic Blvd., Ste 300 Anchorage, AK 99503 Jill Schneider US Geological Survey 4200 University Dr. Anchorage, AK 99508 Jack Hakkila PO Box 190083 Anchorage, AK 99519 Kenai National Wildlife Refuge Refuge Manager PO Box 2139 Soldotna, AK 99669-2139 Cliff Burglin PO Box 70131 Fairbanks, AK 99707 North Slope Borough PO Box 69 Barrow, AK 99723 David McCaleb IHS Energy Group GEPS 5333 Westheimer, Ste 100 Houston, TX 77056 George Vaught, Jr. PO Box 13557 Denver, CO 80201-3557 John Levorsen 200 North 3rd Street, #1202 Boise, ID 83702 Michael Parks Marple's Business Newsletter 117 West Mercer St, Ste 200 Seattle, W A 98119-3960 Baker Oil Tools 4730 Business Park Blvd., #44 Anchorage, AK 99503 Gordon Severson 3201 Westmar Cr. Anchorage, AK 99508-4336 Darwin Waldsmith PO Box 39309 Ninilchick, AK 99639 Penny Vadla 399 West Riverview Avenue Soldotna, AK 99669-7714 Bernie Karl K&K Recycling Inc. PO Box 58055 Fairbanks, AK 99711 Ill/'ll/eel ¿jJ¡¿'ßLj AEO Notice . . Content-Type: applicationlmsword iAEO Envirotech.doc Content-Encoding: base64 1 of! 4/16/200411:09 AM AEO Notice . . Please publish()Il....J.iJ:l~.....Joci¥ f I m¡ I . .1 Content-Type: applicationlmsword i[ !AEO EnVlroteCh.dOC¡ i i - . Content-Encoding: base64 i 1--...........______........"....____________..."."'....______....."'.,......---..,...."....--..------.----...1.....----------............________..............--..----------""""',...-------..---.................-------------.----...............----------------................--- l 1 of 1 4/16/2004 11 :09 AM Legal Notice . . Please publish on Content-Type: applicationlmsword Order form. doc i Content-Encoding: base64 'j Content-Type: applicationlmsword AEO Envirotech.doc Content-Encoding: base64 I of 1 4/16/200411:11 AM Legal Notice . . Content-Type: application/msword Ad Order form Clarion. doc Content-Encoding: base64 AEO Content-Type: application/msword Content-Encoding: base64 1 of 1 4/16/200411:12 AM #2 [Fwd: FW: Envirotech Aquifer Hearing] . e 20f3 6/21/2004 1 :29 PM [Fwd: FW: Env!rotech Aquifer Hearing] e e exemptions in the State before, however none that would affect ADEC in this way. The engineered plans and permit application will be for a produced water treatment system that they have been operating under the COBC for some time now, which will be connected to a new bed type soil absorption system, approximately 600 feet from the Inlet, that will discharge between 240 barrels per day {bpd} and 1,200 bpd maximum. The wastewater will be saline with high TDS and some metals, such as barium. It would seem the groundwater would need to be monitored to insure that the discharge did not make the groundwater quality worse than it is, however, I do not see how 18 AAC 70 or 72 even addresses this issue. The Antidegradation Policy regs in chapter 70 do not seem to apply, and I do not know how our regs work in conjunction with the chapter 20 A.O.G.C.C. regs. So those are the issues we will probably have to address soon. Let me know what you think. Oran «20 AAC 25.doc» Oran Woolley@dec.state.ak.us 43335 K. Beach Road, #11 Soldotna, AK 99669 (907) 262-5210 ext. 227 Fax - {907} 262-2294 Content-Type: message/rfc822 (null).eml Content-Encoding: 7bit 20 AAC Content-Type: applicationlmsword Content-Encoding: base64 30f3 6/21/2004 1 :29 PM #1 . . r- ROZAK ENGINEERING Civil, Construction & Environmental Consulting P.O. Box 350 Kenai, Alaska 99611 (907) 283-5640 Fax (907) 283-0747 March 15, 2004 John Norman, Commissioner Alaska Oil & Gas Conservation Commission 333 W ih Avenue #100 Anchorage, Alaska 99501-3539 Re: Freshwater Exemption for Underground Disposal of Treated Oil Field Wastewater Envirotech Facility at North Foreland, Cook Inlet, Alaska Dear Mr. Norman: On behalf of Envirotech LLC, a subsidiary of Tyonek Native Corporation, we are submitting this application for a freshwater exemption in accordance with Regulation 20 AAC 25.440. Copies of this application are being submitted to the Alaska Department of Environmental Conservation (ADEC) and the US Environmental Protection Agency (EP A). The exemption is for discharge of treated "produced" water into the groundwater aquifer at Envirotech's North Foreland facility. The facility is located approximately 600 feet from Cook Inlet, between the North Foreland dock and Tyonek Creek. The aquifer meets the following criteria specified in Section 440(a) of the regulation: (1) It does not currently serve as a fresh water source of drinking water, and it will not in the future serve as a source of drinking water, because it is so highly contaminated with saltwater from Cook Inlet that recovery of water for drinking water purposes is economically impractical; and (2) The total dissolved solids content of the groundwater is more than 3,000 mg/l and less than 10,000 mg/l, and it is not reasonably expected to supply a public water system. The produced water is from natural gas exploration and production wells in the area. Envirotech proposes to use a novel drainfield system rather than the normal method of drilling a Class II underground injection control (UIC) well for disposal of production water. The process proposed by Envirotech will use a water treatment plant and a drainfield disposal system. Anticipating the issuance of a nondomestic wastewater discharge permit from the ADEC, in 2002 Envirotech engineered and constructed the treatment plant and drainfield. ADEC notified Envirotech that a UIC permit or aquifer exemption would be required to discharge the water via the drainfield. The treatment process includes settling tanks, mechanical filters, and an electrical coagulation unit to remove petroleum hydrocarbon compounds and particulates down to I-micron diameter. Treated water will be discharged into a 22,000-gallon underground tank, allowed to flow by gravity into a subsurface drainfield (consisting of perforated pipes laid horizontally in a gravel bed), and then allowed to percolate by gravity through the gravel bed and underlying native soils to the groundwater (approximately 10 feet below the drain pipe). Initial treatment and disposal capacity is projected to be 240 barrels per day (bpd), with maximum capacity of 1,200 bpd. . . Application for Freshwater Aquifer Exemption Envirotech, North Foreland In support of this application for freshwater exemption, we are including the following information required by Regulation 20 AAC 25.252(c) with applications for underground disposal of oil field wastes. 1) The Envirotech facility, the proposed drainfield system, and all wells within one-quarter mile of the drainfield system are marked on the topographic maps and low-angle aerial photographs, Figures 1- 4. Only one well is within one-half mile ofthe drainfield. The well is at the Envirotech facility, approximately 300 feet from the drainfield. GPS coordinates of the proposed disposal site are: 61° 02' 33.5"N, 151°09' 50.6"W 2) Tyonek Native Corporation is the only surface owner and their subsidiary, Envirotech LLC, is the only operator within a one-quarter mile radius of the proposed disposal site. 3) Affidavits (attached) show that the operators and surface owners within a one-quarter mile radius of the disposal site have received a copy of this application for disposal. 4) Wastewater will be discharged approximately five feet below ground surface and will percolate by gravity through approximately six feet of3-inch minus drain rock and nine feet of native gravelly-sand into the atmospheric (unconfined) groundwater aquifer. The groundwater table is approximately 20 feet below ground surface and the direction of groundwater flow is towards Cook Inlet. Soils at the site are alluvial terraces classified as Nancy-Kashwitna complex (Soil Survey of Yentna Area, Alaska, USDA Natural Resources Conservation Service). These unconsolidated glacial soils were deposited over a thick sequence of coal bearing rocks of Tertiary Age, that rest on Mesozoic rocks (Generalized Geology, Cook Inlet Subregion, Figure 53b, Alaska Regional Profiles, Southeast Region, 1974). 5) A well log is not available for the only well within one-quarter mile of the drainfield. The nearest community, Tyonek, located 1 ~ miles northeast of the subject site, obtains its drinking water from an inland lake. There are no available records of the onsite well's construction or witnesses of its installation. Envirotech personnel, who pulled the submersible pump several times using a front-end loader, estimate the well is 25 to 30 feet deep. It appears likely that the previous site operator, a Japanese timber company, installed the well before approximately 1985. The site was abandoned for 10-15 years until Envirotech started operations at the facility in 2001. 6) This item does not apply; the proposed disposal method will not use conventional wells. 7) The oil field waste to be disposed at this facility will be water from wells generated through the exploration and production of natural gas and, possibly, crude oil. The untreated water was sampled and sent to an analytical laboratory for testing of the following parameters: residual and diesel range organic compounds, 8 volatile organic compounds, magnesium, calcium, lead, 13 inorganic contaminants, and 14 secondary contaminants. Analytical results showed eight parameters exceeded the maximum contaminant levels (MCL) established for drinking water. Five parameters exceeded the ADEC "10x" standards: barium, chloride, potassium, sodium, and TDS. 2 · '. Application for Freshwater Aquifer Exemption Envirotech, North Foreland As summarized above and more completely addressed in the attached narrative and drawings titled "Description of Envirotech Water Treatment Process - Tyonek", the produced water will be treated before being discharged into the groundwater aquifer. Initial treatment capacity is projected at 240 barrels per day (bpd), with maximum capacity of 1,200 bpd. Samples of the treated water were analyzed for the same parameters as the raw water (above). Analysis results show the treated water meets the ADEC "lOx" drinking water standards except for four secondary contaminant parameters: chloride = 6080 mg/l; potassium = 1300 mg/l; sodium = 2780 mg/l; and TDS = 10,900 mg/l. The treated water is compatible with the water in the proposed groundwater aquifer in that both waters have elevated concentrations for parameters common to saltwater. Concentrations of chloride and TDS in Cook Inlet water are more than five times the groundwater at the site and approximately twice the treated water. 8) The treated wastewater will enter and flow through the groundwater aquifer under the influence of gravity; the wastewater will not be "injected" by pressure. 9) The proposed discharge method will not use high pressures, chemicals, or techniques that would initiate or propagate fractures through any confining zones. The discharge point (drainfield) will be approximately 15 feet above the groundwater table. The filtered and treated discharge water will readily percolate under the influence of gravity to the groundwater table and disperse toward Cook Inlet through the coarse-grained, highly permeable, sands and gravels present at this site. The chemical and physical composition of the wastewater indicates there is little potential for retardation or mounding to occur. Dispersivity is difficult to measure in the field or determine in the laboratory. We will monitor the gradient and concentrations of chloride and TDS in groundwater around the drainfield by installing three monitoring wells (Figure 4). The groundwater table will be surveyed and water samples will be collected at each monitoring well before the initial discharge from the system and quarterly while the system is operated. Discharge volume, rate, or frequency will be reduced to prevent the flow of water, or increased contaminant concentrations in the water, toward Tyonek Creek (away from Cook Inlet). 10) Relevant quality parameters of the water at the site have been determined by analysis of samples collected by Envirotech. The samples were analyzed by North Creek Analytical, for Total Dissolved Solids (TDS) by EPA Method 160.1 and for Chloride by EPA Method 300.0. The samples were collected at three locations (Figure 4): Cook Inlet, the cased well at the site (groundwater aquifer), and Tyonek Creek. The analytical results (attached) in mg/l are summarized below: Cook Inlet #1 TDS = 17,000 Chloride = 9740 Well at Lower Shop TDS = 3300 Chloride = 1710 Tyonek Creek TDS = 1500 Chloride = 868 11) There are no freshwater exemptions in accordance with 20 AAC 25.440. 3 . . Application for Freshwater Aquifer Exemption Envirotech, North Foreland 12) Wells within one-quarter mile radius of the site have not penetrated below the unconfined groundwater aquifer, therefore, this item does not apply. The well at the site draws its water from the unconfined groundwater aquifer; the water is non-potable and unsuitable for use as drinking water. A sample collected from the well and Cook Inlet indicates that saltwater intrusion from Cook Inlet has contaminated the source of the well water. Envirotech has executed a compliance order with ADEC. One ofthe conditions states "by March 31, 2004, in the event Envirotech has not received a NP DES permit from EP A, Envirotech shall submit engineered plans to ADEC for approval of the non-domestic wastewater treatment works along with a new wastewater permit application for disposal of treated non-domestic wastewater to the lands or waters of the State." EPA denied Envirotech's NPDES application to discharge the treated wastewater into Cook Inlet from a nearby dock. Envirotech has invested considerable effort into developing the water treatment technology and disposal system at this facility. Their treatment process effectively removes the hydrocarbons, metals, and most secondary contaminants found in oil field wastewater. The only contaminants not treated by the process are common, already present, in the saltwater-intruded groundwater at the site. The drainfield may be an uncommon method for disposing oil field wastewater, but it is an effective and appropriate method for this facility. In accordance with Section 440 (a), we request that the commission designate the groundwater aquifer as an exempt freshwater aquifer for disposing of the treated production water described herein. The proposed disposal system will not be modified without prior approval by the commission. .~,";,,'\ "';;b~ Of A (J'b q 00"....000000 4~ llf\¡ p~" 00" ~'r:; Ç11 f? 0°" 0l¡ ""f7' I)~ ~ * i'A9TU 0').1i? .:11,..1£' ,. ~ ~ ~ ~iO ,,."', r';;/ ".'~.:Ø... ~,'t~.Ø;.".. "GoMOOOOO oo~"""8°A. Q.~.. .~ . ..~ 1-4. ~. ',f ~..:: ~ß...ø"o"oooo<>OQO"O~O.ð";;'; .~ .-' '\ r'E "649 0 Q;: c.q ,~>,'-(\'~ '.w.,-.' è"l..t.J£t2 " ç:¡., '0. Ronald T. Rozak ,,0 ~ '~-o.,~ f..,~ () <:P a f¢.' .,>.:J nco. ,Qoo <-~'41f' /ct:¿) ~I(!!;)Ç!il{)C¡0:'.;;J, ~\.o ¥,(,:c;;~~ b:/lfOFESS\\J~ ~~. '~" -~~-,,~\ 't~~_'I;'Þ..~~i:~~~)"~ Prepared by, Ronald T. Rozak, PE Consulting Engineer cc: Mike Wicker, Derek Maat; Envirotech LLC xc: Oran Woolley, Engineer Associate ADEC Wastewater Program 43335 K-Beach Road, Suite 11 Soldotna, AK 99669 Thor Cutler, Environmental Engineer Region 10, US EP A 1200 6th Avenue Seattle, WA 98101 4 . . Application for Freshwater Aquifer Exemption Envirotech, North Foreland Attachments Figure 1 - Location and Vicinity Map Figure 2 - Topographic Map and Color Aerial Photograph Figure 3 - Low angle Color Aerial Photographs Figure 4 - Low angle B& W Aerial Photograph (enlarged) Figure 5 - Site Plan of Produced Water Disposal System Figure 6 - Details of Produced Water Disposal System Item 7 - Description of Envirotech Water Treatment Process - Tyonek Item 8 - Affidavits for Acknowledged Receipt of Application Item 9 - Analytical Results of Raw Produced Water Item 10 - Analytical Results of Treated Produced Water Item 11 - Analytical Results of Raw Water from Inlet, Groundwater & Tyonek Creek 5 AACTlC OC&N '- 8IEf<lNG S64 ü <;:! r- From Source is Base 81, Alaska Atlas Et 1992 1" = 2 Miles Approx. Scale 1 Low-angle photographs from airplane taken by Derek Maat, 9/24/03 Produced water disposal site is marked with "X" 3 ENVIROTECH FACILITY A T NORTH FORELAND, ALASKA Aerial photograph of NW view taken 09/24/03 by Derek Maat Figure 4 -\ o -z. <i", ),.,0 u q, ~,-- 'J71ó iP-o 'Ïii1! O<?O -z.'"" (f) -::¡ (I'\ .z. ~ .... !lJ> 1" = 40 ft Approx Scale l r ¡ , I ~ : DRAINFIELD 1 I I , c!> ~ èJ ttj) '~26'-30' -/ . I- I tJ / / #/ (ý" R/ ,?:~ 0°/ Q' o .s/ ~ 1-..;:)/ '<~ / It / - - . r-CAMLOCK FITTINGS ~ FOR TRUCK LOADING -1:f- ENVIROTECH SHOP EMPTY GREEN BUILDING ,~ :> SITE PLAN - PRODUCED WA TER DISPOSAL SYSTEM Envirotech Facility, North Foreland, Alaska Revised by R. T. Rozak 3-11-04 f- AlG CAMLOCK FITTING o 22K TANK " " b <r? '" ~ APPARENT GW FLOW > 1 600' (APPROX) TO COOK INLET HIGH TIDE Figure 5 . . 40' 20'- I· 11.5' 0 ~ @ TANK c:: UJ o « UJ :r: PERF PIPE MONITOR TUBES (MT) -e.- 10' -e' .- 10' ----0 -1- 32' ----- ~ o ----- o :J o (f) PLAN VIEW ----- DRAINFIELD L= =~f:~~;:GEL(_ MT GROUND/SURFACE 22,000 GAL TANK Ì' 5' ~ :e:N:OC: ;;;;-: ;; , ~ -+ o N PROFILE ( NATIVE GRAVEL ~ \JGWf ~ / 26' -30' / ~ 6' ~ DRAINFIELD X-SECTION NOT TO SCALE 1 " = 20 ft Approx Scale DETAILS - PRODUCED WA TER DISPOSAL SYSTEM Envirotech Facility, North Foreland, Alaska Revised by R. T. Rozak 3-11-04 Figure 6 . . Envirotech LLC Description of Water Treatment Process 1.0 SUMMARY The Envirotech LLC (Envirotech) water treatment system located near Tyonek, Alaska, treats "produced water" generated through the exploration for and production of natural gas and, possibly, crude oil. Currently, the treated water evaporates to the atmosphere. The facility operates under the authorization of a Compliance Order by Consent issued by the Alaska Department of Environmental Conservation (ADEC). Produced water comes out of the underground reservoir with oil, or gas, as they are produced. Extensive sampling and analytical results that fully characterize the influent water from the gas well are available. The results show relatively low concentrations of metals characteristic of produced water from gas wells in the area as well as low concentrations of hydrocarbon-based compounds. The system design can be expanded to accommodate an average flow of produced water of 30,000 gal/day and a maximum flow of 50,000 gal/day. These flow rates are estimated on the high side in order to allow for the treatment of produced water generated by wells that are projected to be drilled or brought on line in the future. 2.0 DESCRIPTION OF CURRENT TREATMENT PROCESS Figure 1 (attached) depicts the layout of the treatment components. Figure 2 (attached) diagrams the flow of water through the treatment process. A. 21,000 Gallon Settling Tank Produced water will be pumped from vacuum trucks into the top of a 21,000 gallon settling tank via a 4" diameter flex hose. This tank is the primary settling tank. Sludge that accumulates in this tank falls under the E&P exemption, according to the document entitled "Exemption of Oil and Gas Exploration and Production Wastes from Federal Hazardous Waste Regulations", as constituents are removed from the produced water before it is injected or otherwise disposed. If required to accommodate increased treatment flow rates, another settling tank would be added in parallel. The retention time in the settling tank will be approximately six (6) hours during full- scale treatment. Sludge will slowly accumulate in the 21 ,OOO-gallon tank. The sludge will be properly contained and stored on site until Envirotech transports it to an approved treatment or disposal facility. B. Pack of Four Filter Towers The water will be pumped from the 21,000 gallon settling tank through a series of four filter towers, configured in series (coded 1-N, Figure 2). The first two filter towers consist of 10- micron paper filter towers, each containing 14 filters, designed to remove particulate. The second two filter towers each contain seven 5-micron charcoal filters designed to remove hydrocarbons. Description ofEnvirotech Water Treatment Process - Tyonek 1 Item 7 p.1 of5 . . Envirotech LLC Each filter tower is fitted with a pressure gauge. The filters will be replaced when the pressure at the filter reaches 75 PSI. The spent filters will be stored on site in drums and upon completion of analytical testing will be incinerated at the Envirotech permitted facility in Nikiski, if they pass the criteria for incineration. If analytical results indicate that the filters contain contaminants that cannot be incinerated, they will be disposed of at a landfill permitted to accept the waste. c. Electrocoagulation Following the series of four filters the water will be passed through an electrical coagulation unit (coded 2-I, Figure 2). Electrocoagulation is the process of destabilizing suspended, emulsified or dissolved contaminants in an aqueous medium by introducing an electrical current into the medium. The electrical current provides the electromotive force to drive the chemical reactions. When reactions are driven or forced, the elements or compounds will approach the most stable state. Generally, this state of stability produces a solid that is either less colloidal or less emulsified (or soluble) than the compound at equilibrium values. As this occurs, the contaminants form hydrophobic entities that precipitate and can easily be removed by a number of secondary separation techniques. D. 10,500 Gallon Settling Tanks After passing through the electrical coagulation unit, the water will be pumped into the top of one of two 1O,500-gallon settling tanks (coded I-V, Figure 2). Solids generated by the electrical coagulation unit will settle out in these tanks. The residence time in these tanks will be approximately six (6) hours. As one of the 10,500-gallon tanks is filled, clear water from which the solids have settled will be pumped to the other; this process will alternate between tanks as one becomes full and the other is emptied. E. Sludge Handling The sludge in the 21,000 gal tank and the two 10,500 gallon tanks will be accumulated, removed, and treated with a nontoxic chemical with the trade name DM-49. It is expected the rate of sludge production from the settling tanks will be in the range of 500 gallons per day of wet sludge. DM-49 chemically fixes any metals in the solid matrix and prevents toxic leachate. This chemical has been approved by the ADEC (Permit No.0223-BA004) for use in chemically fixing metals in drilling waste. The chemical uses water in the reaction and, therefore, also acts as a dewatering agent. Additional drying of sludge to attain a minimum of 10% solids will be carried out, as needed, using a heat assisted drier. Pending satisfactory analytical results, the treated sludge will be sampled, analyzed, and disposed at a permitted landfill. F. Paper Filtration Following the 10,500-gallon sedimentation tanks, the water will be drawn through a series of three I-micron filter towers (coded 1-N, Figure 2). Two sets ofthree filter towers will be located in parallel to allow for filter cleaning of one set while the other set remains on line. Additional sets of filter towers will be brought on line as treatment flows increase. The filters will be replaced when the pressure at the filter reaches 75 PSI and will be tested and disposed of in the same fashion as described earlier for the pack of 4 filter towers. Description ofEnvirotech Water Treatment Process - Tyonek 2 Item 7 p.2 of 5 . . Envirotech LLC G. Granular Activated Carbon and Sand Filtration Depending on the quality of the effluent, Envirotech may include two additional granular activated carbon (GAC) filters and a silica sand filter (coded l-R, Figure 2) at the end of the treatment train. If installed, the capacity of the GAC filters will be based on the water quality of the effluent of the previous paper filters. Based on capacity calculations, the first GAC filter will be taken off line when it reaches capacity, the second GAC filter will be moved up the line to takes its place and a fresh GAC filter will take the place of the second GAC filter. Attachments Figure 1 - Water Treatment Layout at Tyonek Facility Figure 2 - Water Flow Diagram Description ofEnvirotech Water Treatment Process - Tyonek 3 Item 7 p.3 of 5 . . En virotech LLC Mo.rch 8. 2004 not to scale drown by d;n Figure Water Treatment Layout Tyonek Facilily Package Treatment Plont (includes two 3/4 top pumps) !- I- I 1 J 10.500 gal Storage Tonk , o ....' 00 00] c::JCJt ~tJ) -- 21.000 gal Settling Tonk (spore for use when primory settling tonk undergoes maintenance) Storage 1 inch dia industl rubber hose rated ot 250 - 500 __ PSI(t)!>,\ { ~t~c:triCo.l r ~Oo.gl)lo.tjOn .. Unit Skid containing 4 fitter towers and 1/2 Hp ~pump 00 800 500 Col Diesel AST 21,000 gal Settling 10nk ~ J inch dio flex hose for looding tonk \!- I ~ to drain field \N ~ 3 -....¡ ~ ~ o -., <.n 1-N Zl,OOO gat settling tonk 1-U 10 "It_ nUtR 10 "Ie_ n~ ftlt 5 NlCA(III nLTtt CHNlCD.o&. - . P~oduced water FrOM gas p~ool\.ction WE'll (0. verage ra te 30,000 gal/doy) I spent Filters to be saMpled and OllspoSE?cI of in o.pp~opriQte Manner according to thl? analytical resul1:s \ 2-' ELECtt.C"!. CI!AG\A." f 101; ~IT 10,500 go.\ settling tonk ctorifil!'d 11II0. tl?r pl"ll'lpE.>d FroM top of wo. ter coll"ll'ln (0. verage ro. te 29.700 gat/day) - þ .. P1H' 10,500 go.l settling tonk . 1-U p -iJ 1-U ~ E 1·N 1-R 1-N 1·N ~ h h --£r I Nle. I HIe. I NIC. FIUtt r[L 1[' FILTER PI.W ,.. --- trl?ated water pUMped . to Clischorge point in Drein nE'lcI ... 1-N (Qp~U <Cpt..,..." II»t_n ~ ~ h J NIt. I HIe. I IIIC. rll.I£R rtL '(II rruclI to --- ãf 3 ""'I ~ (¡ o ..... (¡ - ¡1 sludge reMoved perìodicoUy for'" dewe. terìng one! disposal to landfill (average rete 300 galle!I).Y) dried sludgE' wilt be. sal'lpleol, cheMically 1:rE'C ted jf required ana dispost'd of in an I).pproprio te landfill Envirotech LLC not to. scole drown by djrn Mo.rch 10. 2004 Figure ~ Water Flow Diagram . . A Subsidiary of Tyonek Native Corporation P.O. Box 8467 Nikiski, AK 99635 46645 Kenai Spur Highway, Mile 19.5 Emai/ mwicker(ti}ptialaska.net Website www.hmmenvirotech.com Work 907 776 8766 Fax 907 776 8859 Cell 907 830 4805 Westside 907 583 2200 Eastside 907 7768795 March 12, 2004 Re: Permit Application Tyonek Native Corporation is aware and received the permit application for Produced Water Disposal. Tyonek Native Corporation is the surface owner of the property. Envirotech LLC is the operator of the said property. Sincerely, "",,____ ...""..-:::::::"....".."...._~;-~ //?'7~'- ~ ) Mike Wicker Operations Manager THIS IS TO CERTIFY that on this 12th day of March. 2004. Before me, the undersigned, a Notary Public in and for the State of Alaska, duly commissioned and sworn as such, personally appeared Mike Wicker ofEnvirotech LLC, to me known to be the individual(s) described in and who executed the foregoing instrument of writing and he acknowledged to me that he signed and sealed the same freely and voluntarily for the uses and purposes therein mentioned. WITNESS MY HAND AND SEAL the day and year above in this certificate written. ~ 'i¥d-'-7.ð /}v'h ~fi:J Notary Public in and fo?"Alaska My commission expires: 01-13-07 ST OFFICIAL SEAL ATE OF ALASKA STACY ANN FAGAN . NOTARY PUBLIC My Comm. Exp.: 1-';.3 -Oì Item 8 . . Table 2: Complete Analytical Results For Influent and Effluent Samples (Jan.15 and Feb. 12, 03) 15..Jan-Ð3 15-Jan-Ð3 12-Feb-Ð3 12-Feb-Ð3 ~ Effluent I!:ItIs!mIt Effluent (mglL) (mg/L) (mglL) (mg/L) PARAMETERS RRO 4.53 1.09U 12.3 1.00U DRO 1.35 0.808 1.66 0.62 ...,Magnesium 183 174 NA NA Calcium 322 304 NA NA Metals By ICP/MS Lead 0.396 0.400U 0.0354 0.000705 Waters Department Foaming Agents 0.500U 0.500U NA NA Inorganic Contaminants Antimony 0.00456 0.00123 0.001 U 0.001 U ......Arsenic 0.0145 0.0165 0.00303 0.002U Barium . 6.94 6.12 9.88 3.58 ......Beryllium O.OOO4U 0.0004U O.OOO4U O.OOO4U /Cadmium 0.000507 0.000128 0.0001U 0.0001 U ""'Chromium O.OO4U 0.0228 O.OO4U O.OO4U Cyanide 0.0050U 0.006 0.0050U O.OO50U ~ercury by Cold Vapor 0.0002U 0.0002U 0.OO02U 0.0002U Nickel _ 0.0992 0.0193 0.0179 0.0178 /Nitrate-N 1.OOU 1.00U 1.00U 1.00U ,.Æitrite-N 1.00U 1.ooU 1.00U 1.00U ...selenium . 0.0466 0.0516 0.0257 0.0121 Thaßium .:. 0.0003U 0.0003U 0.00193' 0.8ooU' Secondary Contaminants Chloride 6560 6610 5830 3720 /Color (PCU) 50 50 NA NA ';þcop)er 1.75 0.0261 0.0677 0.0218 Fluoride . 1.OOU 1.OOU 1.OOU 1.OOU ,Iron 45.9 5.34 31.5 0.945 Langlier Index @ 140 OF 1.15 1.557 NA NA Langlier Index @ 40 of 0.07 0.0477 NA NA /Manganese' 0.919 0.895 0.926 1.25 Odor (TON) 8 4 NA NA ...pH 6.95 7.1 7.4 7.4 Sodium 2880 2820 3030 1960 /Sulfate . 2.50U 2.50U 2.50U 68.S' Total Dissolved Solids 10500 10700 10300 7190 Zinc 1.89 0.297 89.1 1.16 Volatile GC/MS 1,2,4 Trimethylbenzene 0.0027 0.0072 NA 0.00050U 1,3,5 Trimethylbenzene 0.00076 0.0016 NA 0.00050U /'Benzene 0.00051 0.0005U 0.00041 O.00050U Æthyfbenzene 0.0085 0.0042 O.OOtu 0.00050U ~aphthalene 0.0037 0.0036 0.0609 O.Ooo50U O-Xylene 0.0022 0.0051 NA 0.00050U P & M Xyfene 0.0032 0.008 NA 0.00050U Toluene 0.0055 0.0033 0.00106 0.OOO50U Total Xylenes , 0.0055 0.0059 0.002U O.OO1OU All other Parameters Analyzed using Volatile Gas Chromatography/Mass Spec. did not exceed method detection limits "U' indicates non detect below stated concentration NA indicates not analyzed Item 9 Table 1: Electrical Coa Test Results 6/713 and Raw EC followed Water 10 J( DW Produced EC-1 EC by MCls MCls Water Filtration (mg/l) PARAMETERS Contaminants 0.006 0.06 nd(O.OO6) nd(0.OO3) nd(0.003) nd(0.003) Arsenic 0.05 0.5 0.0175 0.00422 0.00214 0.0126 Barium 2 20 11.5 10.4 0.154 0.004 0.04 nd(O.001 ) nd(O.OO1) Cadmium 0.005 0.05 nd(0.002) nd(O.OO1) nd(O.001 ) nd(O.001 ) Chromium 0.1 1 0.163 0.1 nd(0.OO1} 0.00224 Nickel 0.1 1 0.05 0.0138 0.00509 0.0168 Selenium 0.05 0.5 0.0137 0.00946 0.00114 0.0142 Thallium 0.002 0.02 nd(0.002} nd(O.OO1) nd(O.OO1} nd(O.OO1} Contaminants Chloride 250 2500 Copper 1 10 0.148 0.182 0.00415 0.00175 Iron 0.3 3 nd(O. 0.05 0.5 0.121 Potassium 3 30 Sodium 250 2500 Sulfate 250 2500 nd(2.00} 79.6 Zinc 5 50 1.88 0.13 0.122 nd(O.OO1} 22.2 1.63 0.0665 nd(0.05} Total Dissolved Solids 500 5000 pH, 5.5-8.5 indicates exeedance of 10 x drinking water MCLs ·'9y@- Seattle 11720lh Creek Pkwy N, Suire 400. Bothe! WA ge!I11-8244 4254 fax 425.420.9211) Spokane East ntgomery, Suite B. Spokane, \'IA 99206-477£ 509.924. 00 fax 509,924,9290 . Portland 9405 SW Nimbus Avenue, Seaverton, OR 97008-7132 5039069200 fax 503,906.9210 Bend 20332 Empire Avenue, Suite F-1, Send, OR 97701-5711 5413839310 fax 5413827588 Anchorage 2000 W, International Airport Road, SU!Í€ A10, Anchorage, AK 99502-1119 907563.9200 fax 907.563.9210 18 December 2003 Mike Wicker Envirotech, LLC P.O. Box 8467 Nikiski, AK 99635 RE: Water West Side Enclosed are the results of analyses for samples received by the laboratory on 12/09/03 12:35. If you have any questions concerning this report, please feel free to contact me. Sincerely, ~þL~ i Jeff Gerdes Project Manager North Creek Analytical, Inc. Environmental Laboratory Network Item 11 p. 1 of 4 · ~ www.nn.l.b....m Envirotech, LLC P.O. Box 8467 Nikiski, AK 99635 I Sample ID Inlet #1 Well Lower Shop Creek seatIJ.!e 1172.. Creek PJIwy N, Sui!!: 41). U. Bot!\el. WA 9i!\11·8244 425, fax 425.420.921íJ . Spokane East ntgomery, Suite B. Spokane, WA 992íJ6-4776 509.9249200 !ax 509.924.9290 Portland 9405 SW Nimbus Avenue, Beaverton, OR 97008·7132 503.90;i9200 !ax 503.906.9210 Bend 20332 Empire Avenue, Suite F·1. Bend, OR 97701·5711 541383.9310 lax 541.3821588 Anchorage 2000 W. intematíona! Airport Road, Suite A10, Anchorage. AK 99502·1î19 907.563.9200 !ax 907.563.92HJ Project: Water West Side Project Number: Not Provided Project Manager: Mike Wicker Reported: 12/18/0313:26 ANALYTICAL REPORT FOR SAMPLES North Creek Analytical - Bothell CJ!-~ "~ Jeff Gerdes, Project Manager Laboratory ID Matrix B3L0330-0l Water B3L0330-02 Water B3L0330-03 Water Date Sampled Date Received 12108/03 12:00 12/09/03 12:35 12/08/03 12:00 12109/03 12:35 12/08/03 12:00 12/09/03 12:35 The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. North Creek Analytical, Inc. Environmental Laboratory Network Page 1 of7 Item 11 p.2 of 4 ..~ _w. ocolobs. com r. Sea tile 11721) Icreek PIIwy. N..SU.iIe 4íJO, Bo!!1e~, WA, 9!!01í,8244 4254 fax 425.420.92tí) S¡JO!¡¡¡~e East 1 ntgomery. Suite 8, Spokane. WA 99206-4776 509,924." fax 509924,9290 Portland 9405 SW Nimbus Avenue, 8eavertoo, OR 97008,7132 503906,9200 fax 503.906,9210 Bend 20332 Empire Avenue, Suite F,1, Bend, OR 97701,5711 541383(J31O fax 54i.382.7588 Anchorage 2000 W International Airport Road, Suite MO, Am;horage. AK 99502,1119 907.563,9200 fax 907,563,9210 Envirotech, LLC P.O. Box 8467 Nikiski, AK 99635 Project: Water West Side Project Number: Not Provided Project Manager: Mike Wicker Conventional Chemistry Parameters by APHAlEP A Methods North Creek Analytical- Bothell Reported: 12118/03 13:26 Reporting AnaIyte Result Limit Units Dilution Batch Inlet #1 (B3L0330-01) Water Sampled: 12/08/03 12:00 Received: 12/09/03 12:35 Total Dissolved Solids 17000 10 mgll 1 3LlI048 Well Lower Shop (B3L0330-02) Water Sampled: 12/08/03 12:00 Received: 12109/03 12:35 Total Dissolved Solids 3300 10 mgll 1 3LlI048 Creek (B3L0330-03) Water Sampled: 12/08/0312:00 Received: 12/09/0312:35 Total Dissolved Solids 1500 10 mgll 1 Prepared Analyzed Method Notes 12111103 12115/03 EPA 160.1 121II/03 12/15/03 EPA 160,1 3LlI048 I2III/03 12115/03 EPA 160.1 North Creek Analytical - Bothell \41- ~ '1 The results in this report apply to the samples analyzed in accordance with the cham of custody document. This analytical report must be reproduced in its entirety. Jeff Gerdes, Project Manager North Creek Analytical, Inc. Environmental Laboratory Network Page 2 of7 Item 11 p.3 of 4 T. sealt!~. 11720lcreek P kwy N. Suite 400, Bo!he!!, WA 911011-8244 425.4 fax 425A20.921íJ SX!~"'lie East 1 nlgomery, Suite B. Spokane. WA 99206-477~ 509.924. 0 fax 509.924.9290 Portland 9405 SW Nimbus Avenue, Beaverlon, OR 97008-7132 503.90£.9200 fax 503.906.9210 Bend 20332 Empire Avenue, Suite F·I. Bend, OR 97701·5711 541383.9310 fax 541.382.7588 Anchorage 2000 W. international Airport Road. Suite A10, Anchorage, AK 99502-1119 907.563.9200 fax 907.563.9210 Envirotech, LLC P.O. Box 8467 Nikiski, AK 99635 Project Water West Side Project Number: Not Provided Project Manager: Mike Wicker Anions by EP A Method 300.0 North Creek Analytical- BotheD Reported: 12118/03 13:26 Analyte Inlet #1 (B3L0330-01) Water Chloride Reporting Result Limit Units Dilution Batch Prepared Analyzed Method NOres Sampled: 12/08/03 12:00 Received: 12/09/03 12:35 9740 2000 mgll 5000 3Ll5001 12112/03 12112/03 EPA 300.0 Well Lower Shop (B3L0330-02) Water Sampled: 12/08/03 12:00 Received: 12/09/03 12:35 Chloride 1710 400 mgll 1000 3Ll 200 I 12111I03 12/11/03 Creek (B3L0330-03) Water Sampled: 12/08/03 12:00 Received: 12/09/03 12:35 Chloride 868 200 mgll 500 3Ll2001 12111/03 12111/03 EPA 300.0 EPA 300.0 North Creek Analytical - Bothell Cf-Ý:- ~ The results in this report apply to the samples analyzed in accordance with the chain of custody documenL This analytical report must be reproduced in its entirety. Jeff Gerdes, Project Manager North Creek Analytical, Inc. Environmental Laboratory Network Page 3 of7 Item 11 pA of4