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Home My WebLink AboutO 046 e e Image Project Order File Cover Page XHVZE This page identifies those items that were not scanned during the initial production scanning phase. They are available in the original file, may be scanned during a special rescan activity or are viewable by direct inspection of the file. o 0 Lf.(O Order File Identifier Organizing (done) o Two-sided 111111111111111111I o Rescan Needed 1111111111111111111 RESCAN ~color Items: D Greyscale Items: DIGITAL DATA D Diskettes, No. D Other, No/Type: OVERSIZED (Scannable) o Maps: D Other Items Scannable by a Large Scanner D Poor Quality Originals: D Other: OVERSIZED (Non-Scannable) D Logs of various kinds: NOTES: Date J-léJD / Q 7 I I Date~/d-ð1 07 o Other:: BY: ~ 151 n1~p Project Proofing BY: ~ 11111111111 11111111 151 lliP ~J Scanning Preparation BY: Date: = TOTAL PAGES (Count does not include cover sheet) 151 Production Scanning Stage 1 Page Count from Scanned File: Íç:>.J- (Count does include cover ~et) Page Count Matches Number in Scanning Preparation: l/ÝES BY: ~ Date:~\:J-óJ 07 Stage 1 If NO in stage 1, page(s) discrepancies were found: YES 11111111111I1111111 NO 151 V\~/ P NO BY: Maria Date: 151 11I11111111I1111111 Scanning is complete at this point unless rescanning is required. ReScanned 111111111111111111I BY: Maria Date: /5/ Comments about this file: Quality Checked 11111111I1111111111 10/6/2005 Orders File Cover Page. doc . . Other 46 Redoubt Dl Enforcement Action I. November 19,2004 Forest Oilltr for Authorization to Inject 2. December 15, 2004 Forest Oil report ofmisinjection 3. January 4, 2005 Forest Oil's Notification of Improper Class II Injection Redoubt Unit #Dl 4. January 12, 2006 AOGCC Notice of proposed enforcement action 5. January 25, 2006 Forest Oil's response 6. January 26,2006 Scheduling Letter 7. February 23,2006 Sign In Sheet for Informal Review 8. March 2, 2006 E-mail re: Itemized Injection Costs 9. March 3, 2006 Forest Oil Additional Information request from the AOGCC 10. June 15,2006 Forest Oil's updated response to Proposed Enforcement Action II. February 15,2007 Forest Oil's response to Proposed Decision and Order No. 46 12. March 22, 2007 Forest Oil 2nd Progress Review 13. April 13, 2007 Forest Oil3rd Progress Review 14. May 16, 2007 Forest Oil 4th Progress Review 15. June 5, 2007 Forest Oil 5th Progress Review 16. July 13,2007 Forest Oil 6th Progress Review 17. July 20, 2007 US EP A Final Approval to inject into UIC Class I West MacArthur Unit #4D Well and Redoubt #Dl 18. August 21, 2007 Closeout to Forest Oil 19. August 27,2007 Forest Oil's Waste Management Plan . . STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue, Suite 100 Anchorage Alaska 99501-3539 Re: Improper Class II Injection in Redoubt ) Unit Well Dl; Forest Oil Corporation ) ) AOGCC Order No. 46 February 16,2007 DECISION AND ORDER The Alaska Oil and Gas Conservation Commission ("Commission") issued a Notice of Proposed Enforcement Action (''Notice'') under 20 AAC 25.535(b) on January 12,2006 stating that it considered that Forest Oil Corporation ("Forest") may have engaged in improper waste injection at Redoubt Unit Well Dl. The Commission proposed specific corrective actions and a $39,000 civil penalty under AS 31.05.150(a). A Proposed Decision and Order was sent to Forest on January 29, 2007 following informal review and extensive consideration of factors that might impact the enforcement decision. The Proposed Decision and Order was substantially the same as in the notice of proposed enforcement, except for the elimination of the civil penalty. Forest did not file a written request for hearing within the time allowed by 20 AAC 25.535(d) and, therefore, the Commission now issues this Decision and Order. A. Summary of Proposed Enforcement Action In its Notice, the Commission identified an apparent violation by Forest, specifically Rule 2 of Disposal Injection Order 22. The violation consisted of Forest's failure to comply with fluid restrictions imposed on Underground Injection Control ("UIC") Class II waste disposal wells by allowing the injection of domestic wastewater generated at the Osprey Platform for 39 days.! The Commission proposed to order the following corrective actions be completed by Forest: 1 October 23, 2004 through November 30, 2004. AOGCC Order #46 Page 2 of6 . . February 16,2007 1. Within 90 days, Forest shall be required to provide the Commission with underground injection guidelines that ensure the operator's compliance with regulatory requirements and implementation of best management practices for disposal and enhanced recovery injection actions taken at all Forest-operated facilities within Alaska; 2. Upon approval of the guidelines by the Commission, Forest shall be required to implement the injection guidelines; 3. Forest shall be required to train all field personnel engaged in injection activities with the new best practices guidelines, and shall provide the Commission with written confirmation that all personnel have received this training; 4. Forest shall be required to provide written progress reviews detailing corrective actions completed, and updating the status and timing for the completion of unfinished corrective actions. The report shall be due on or before the 15th of each month following the effective date of the enforcement order, and until all corrective actions have been completed. In addition, the Commission proposed payment by Forest of a civil penalty under AS 31.05. 150(a) in the amount of $39,000 ($1,000 per day for each day domestic wastewater was improperly injected into Redoubt Unit Well Dl). B. Misiniection of Domestic Wastewater Rille 2 of Disposal Injection Order 22 provides: This authorization is limited to Class II waste fluids as follows: produced water, drilling, completion and workover fluids, rig wash, drilling mud slurries, NORM scale, tank bottoms, and other fluids brought to the surface in connection with oil and gas development activity on the Osprey platform. AOGCC Order #46 Page 3 of6 . . February 16,2007 Three administrative approvals under DIO 22 further define the fluids eligible for injection into RU Well D1.2 None of the approvals authorized the injection of domestic wastewater (i.e., effluent from sink and shower drains on Redoubt Unit Osprey platform). C. Violation In its letter dated January 25, 2006 Forest agreed that domestic wastewater was "inappropriately injected into a Class II disposal injection well (Redoubt Unit Well Dl)." An informal review was held at Forest's request on February 23, 2006 to discuss the Notice and to give Forest the opportunity to provide additional information it believes has not been considered in the Commission's findings. Forest also accepted full responsibility for the delay in notifying the Commission of the improper injection. Following informal review, Forest provided the Commission with letters dated March 3,2006 and June 15,2006 outlining proactive responses to the proposed corrective actions. D. Mitigating Circumstances Forest stated in its January 25, 2006 letter that the civil penalty amount was excessive, ''understanding that proposed penalty of $39,000 was based on the maximum daily fine allowable." Forest's understanding is incorrect. The proposed civil penalty was calculated on $1,000 per day instead of the maximum $5,000 per day allowed by AS 31.05.150(a). Mitigating factors applied to the proposed civil penalty amount included (1) Forest's good faith effort to reconfigure domestic wastewater disposal systems to ensure compliance with Commission regulation and orders, and; (2) the lack of injury to the public as demonstrated by the good mechanical integrity ofRU Well Dl; and, (3) the confinement to the intended injection zone of all fluids injected into RU Well Dl, as most recently confIrmed by the Commission as part of administrative action DIO 22.004. 2 DIO 22.001 authorizes injection of storm water collected on Osprey platform; DIO 22.002 authorizes injection of a mixed stream of treated sanitary effluent and produced water; DIO 22.004 authorizes the commingling of appropriate Class II oilfield wastes ftom West McArthur River Unit Production Facility, Kustatan Production Facility, and various planned exploration drilling activities on the West side of Cook Inlet for the purpose of disposal injection into RU Well D 1. AOGCC Order #46 Page 4 of6 . . February 16,2007 Additional mitigating circumstances were presented to the Commission during the informal review. Despite the delay, Forest did take the initiative to report the error when it realized unauthorized fluids were being injected into Well D1. Forest states that the error is attributable to confusion about the fluids eligible for injection, in part due to past practice of overboard discharge of a commingled sanitary effluent and domestic wastewater streams authorized under a National Pollutant Discharge Elimination System permit. Injection occurred at a time when Forest was working toward conversion of the Redoubt Unit Osprey platform to a zero surface discharge facility. Mitigating circumstances presented by Forest during the informal review also included the fact that the fluids have been demonstrated as non-hazardous by comprehensive testing. Additionally, an aquifer exemption has been granted for all freshwater sources beneath the Redoubt Unit below 3,650 feet true vertical depth subsea. That information coupled with the confirmed mechanical integrity of the well and confinement of injected fluids mitigates the concerns about harm to the surface and subsurface environments. Forest points out that the cost of injecting wastewater exceeds the cost of overboard disposal; at no time did Forest realize a benefit from the injection of domestic wastewater since overboard disposal is authorized for this waste stream under the EPA's National Pollutant Discharge Elimination System permit. One final mitigating factor of note is the implementation of corrective actions taken by Forest when it was realized that domestic wastewater was being improperly disposed into Redoubt Unit Well Dl. The following proactive efforts have been completed by Forest according to their correspondence dated June 15,2006: 1. Compliance Matrix - comprehensive review of all injection orders and regulations outlining fluids authorized for injection and wells that have specific approvals, reporting, and monitoring requirements; AOGCC Order #46 Page 5 of6 . . February 16,2007 2. Training - completed training of all employees and contract personnel working for Forest in waste management, including both Resource Conservation and Recover Act and UIC requirements; refresher training will be completed annually; 3. UIC Class I Well- completed the conversion of Redoubt Unit Well Dl to UIC Class I (EPA UIC Permit AK-1I007-A), effective October 12, 2006; this conversion eliminates confusion about the segregation of fluids eligible for Class II injection; 4. Zero Surface Discharge Facility - as of July 15, 2005, completed implementation of zero surface discharge for all eftluent streams on Redoubt Unit Osprey platform except the recycled Cook Inlet water used for testing the fire water pumps. E. Findings and Conclusions For the reasons stated above, the Commission fmds that Forest violated rules governing the proper fluids for disposal injection, namely that domestic wastewater was improperly injected into UIC Class II disposal well Dl within the Redoubt Unit. Mitigating circumstances outlined above are relevant and should be considered in the Commission's fmal decision about the need for proposed enforcement actions. After careful consideration of all the relevant facts and the arguments presented by Forest at the February 23, 2006 informal review conference and in its associated written submissions, the Commission fmds that it is appropriate to exercise the Commission's discretion not to assess a civil penalty in this case. NOW THEREFORE IT IS ORDERED THAT: Forest shall comply with the following corrective actions: 1. Within 90 days from the effective date of this order, Forest shall provide the Commission with underground injection guidelines that ensure the operator's compliance with regulatory requirements and implementation of best management practices for disposal and enhanced recovery injection actions taken at all Forest-operated facilities within Alaska; AOGCC Order #46 Page 6 of6 . . February 16,2007 2. Upon approval of the guidelines by the Commission, Forest shall implement the injection guidelines; 3. Forest shall provide the Commission with written confirmation that all personnel involved in injection operations and decisions have received the training consistent with the new best practices guidelines. Done at Anchorage, Alaska this 16th day of February, 2007. rrumsslon a y P. oerster, Commissioner Alaska il and Gas Conservation Commission U.S. Postal Servicerr" ·CERTIFIED MAIL,., RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) m ..[] m IT" m LO I"- LO ,...:¡ I:J I:J I:J I:J ..[] ,...:¡ ,...:¡ LO I:J I:J I"- -, ANQ,¡! f=9t£ I A L USE Postage $ $0.63 0535 Certifled Fee $2.40 Return Receipt Fee $1.85 (Endorsement Required) Restricted Delivery Fee $0.00 (Endorsement Required) Total Postage & Fees $ $4.88 nt 0 ÞS Form 3800. June 2002 See Reverse for Instructions . . .~~"-~"',"',~"Y~""'r~" ...,...._~ .. UNITED STATES POSTAL SERVICE \1\1\\ First-Class Mail Postage & Fees Paid USPS Permit No. G-10 I · Sender: Please print your name, address, and ZIP+4 in this box · þ ñj' '" ~ t\) o =: "1"1 m aJ State of Alaska Alaska Oil and Gas Conservation Commission 333 West 7th Ave., Suite 100 Anchorage, Alaska 99501 Q.O ;ÞG"J ~ OJ :;:r'" o C? .... 0 "" ::I co t-'I (U . i l..:') 1:.>., ;u m () rn --- "'. <"~. ""' = = __J ~. ,. !(! Nß~ 0 rLØJJtf, f%J.,ifØlÞII11I ""IIIIIJI,,,,II/J'II~J,ß'I,I( 4: SENDER: COMPLETE THIS SECTION COMPLETE THIS SECT/ON ON DEL/VERY · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so th~f we can return the card to you. I . Attaç/tthls card to the back of the mailpiece, I ,or ðri the front if space permits. ) 1. Article Addressed to: I. ~b EltilL ~ H-SE ~.vt- rolU1 f at CoJtp , "310 K <J,~ Sk. '100 A,,~, Åk. "Jt1!;ð/. TJ, ~_~/ 3. .Service Type o Certified Mall 0 Express Mall o Registered 0 Retum Receipt for Merchandise o Insured Mail ,0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 7005 1160 0001 5753 ~363 2. Article Number !' (Transfer from servIce labeO PS Form 3811, February 2004 Domestic Retum Receipt ~_.. 1 02595-02·M-1 840 ¡ . . STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue, Suite 100 Anchorage Alaska 99501-3539 Re: Improper Class II Injection in Redoubt ) Unit Well Dl; Forest Oil Corporation ) ) AOGCC Order No. 46 January 29, 2007 PROPOSED DECISION AND ORDER Followin2 Informal Review On January 12,2006 the Alaska Oil and Gas Conservation Commission issued an initial Notice of Proposed Enforcement Action ("Notice") under 20 AAC 25.535(b), finding that Forest Oil Corporation ("Forest") appears to have engaged in improper waste injection at Redoubt Unit Well D1. The Notice proposed requiring Forest to perform specific corrective actions designed to bring waste disposal at Redoubt Unit into compliance with Commission rules. Forest responded to the Notice in writing on January 25, 2006 stating that it agreed with the Commission's findings of improper disposal of domestic wastewater, and requested the Commission consider mitigating circumstances in the proposed enforcement actions. A. Summary of Proposed Enforcement Action In its Notice, the Commission identified an apparent violation by Forest, specifically Rule 2 of Disposal Injection Order 22. The violation consisted of Forest's failure to comply with fluid restrictions imposed on Underground Injection Control ("UIC") Class II waste disposal wells by allowing the injection of domestic wastewater generated at the Osprey Platform for 39 daysl. The Commission proposed to order the following corrective actions be completed by Forest: 1 October 23, 2004 through November 30, 2004 AOGCC Order #46 Page 2 of6 . . January 29, 2007 1. Within 90 days, Forest shall be required to provide the Commission with underground injection guidelines that ensure the operator's compliance with regulatory requirements and implementation of best management practices for disposal and enhanced recovery injection actions taken at all Forest-operated facilities within Alaska; 2. Upon approval of the guidelines by the Commission, Forest shall be required to implement the injection guidelines; 3. Forest shall be required to train all field personnel engaged in injection activities with the new best practices guidelines, and shall provide the Commission with written confirmation that all personnel have received this training; 4. Forest shall be required to provide written progress reviews detailing corrective actions completed, and updating the status and timing for the completion of unfinished corrective actions. The report shall be due on or before the 15th of each month following the effective date of the enforcement order, and until all corrective actions have been completed. In addition, the Commission proposed payment by Forest of a civil penalty under AS 31.05.150(a) in the amount of $39,000 ($1,000 per day for each day domestic wastewater was improperly injected into Redoubt Unit Well Dl). B. Misiniection of Domestic Wastewater Rule 2 of Disposal Injection Order 22 provides: This authorization is limited to Class II waste fluids as follows: produced water, drilling, completion and workover fluids, rig wash, drilling mud slurries, NORM scale, tank bottoms, and other fluids brought to the surface in connection with oil and gas development activity on the Osprey platform. , AOGCC Order #46 Page 3 of6 . . January 29, 2007 Three administrative approvals under DIO 22 further defme the fluids eligible for injection into RU Well D1.2 None of the approvals authorized the injection of domestic wastewater (i.e., effluent from sink and shower drains on Redoubt Unit Osprey platform). C. Violation In its letter dated January 25, 2006 Forest agreed that domestic wastewater was "inappropriately injected into a Class II disposal injection well (Redoubt Unit Well Dl). An informal review was held at Forest's request on February 23,2006 to discuss the Notice and to give Forest the opportunity to provide additional information it believes has not been considered in the Commission's findings. Forest also accepted full responsibility for the delay in notifying the Commission of the improper injection. Following informal review, Forest provided the Commission with letters dated March 3,2006 and June 15,2006 outlining proactive responses to the proposed corrective actions. D. Mitigating Circumstances Forest stated in its January 25, 2006 letter that the civil penalty amount was excessive, ''understanding that proposed penalty of $39,000 was based on the maximum daily fme allowable." Forest's understanding is incorrect. The proposed civil penalty was calculated on $1,000 per day instead of the maximum $5,000 per day allowed by AS 31.05.150(a). Mitigating factors applied to the proposed civil penalty amount included (1) Forest's good faith effort to reconfigure domestic wastewater disposal systems to ensure compliance with Commission regulation and orders, and; (2) the lack of injury to the public as demonstrated by the good mechanical integrity ofRU Well Dl; and, (3) the confinement to the intended injection zone of 2 DIO 22.001 authorizes injection of storm water collected on Osprey platform; DIO 22.002 authorizes injection of a mixed stream of treated sanitary effluent and produced water; DIO 22.004 authorizes the commingling of appropriate Class II oilfield wastes ITom West McArthur River Unit Production Facility, Kustatan Production Facility, and various planned exploration drilling activities on the West side of Cook Inlet for the purpose of disposal injection into RU Well Dl. AOGCC Order #46 Page 4 of6 . . January 29, 2007 all fluids injected into RU Well Dl, as most recently confIrmed by the Commission as part of administrative action DIO 22.004. Additional mitigating circumstances were presented to the Commission during the informal review. Despite the delay, Forest did take the initiative to report the error when it realized unauthorized fluids were being injected into Well D1. Forest states that the error is attributable to confusion about the fluids eligible for injection, in part due to past practice of overboard discharge of a commingled sanitary effluent and domestic wastewater streams authorized under a National Pollutant Discharge Elimination System permit. Injection occurred at a time when Forest was working toward conversion of the Redoubt Unit Osprey platform to a zero surface discharge facility. Mitigating circumstances presented by Forest during the informal review also included the fact that the fluids have been demonstrated as non-hazardous by comprehensive testing. Additionally, an aquifer exemption has been granted for all freshwater sources beneath the Redoubt Unit below 3,650 feet true vertical depth subsea. That information coupled with the confirmed mechanical integrity of the well and confinement of injected fluids mitigates the concerns about harm to the surface and subsurface environments. Forest points out that the cost of injecting waste wastewater exceeds the cost of overboard disposal; at no time did Forest realize a benefit from the injection of domestic wastewater since overboard disposal is authorized for this waste stream under the EP A's National Pollutant Discharge Elimination System permit. One final mitigating factor of note is the implementation of corrective actions taken by Forest when it was realized that domestic wastewater was being improperly disposed into Redoubt Unit Well Dl. The following proactive efforts have been completed by Forest according to their correspondence dated June 15,2006: AOGCC Order #46 Page 5 of6 . . January 29, 2007 1. Compliance Matrix - comprehensive review of all injection orders and regulations outlining fluids authorized for injection and wells that have specific approvals, reporting, and monitoring requirements; 2. Training - completed training of all employees and contract personnel working for Forest in waste management, including both Resource Conservation and Recover Act and UIC requirements; refresher training will be completed annually; 3. UIC Class I Well- completed the conversion of Redoubt Unit Well Dl to UIC Class I (EPA UIC Permit AK-1I007-A), effective October 12, 2006; this conversion eliminates confusion about the segregation of fluids eligible for Class II injection; 4. Zero Surface Discharge Facility - as of July 15, 2005, completed implementation of zero surface discharge for all effluent streams on Redoubt Unit Osprey platform except the recycled Cook Inlet water used for testing the fire water pumps. E. Findings and Conclusions For the reasons stated above, the Commission finds that Forest violated rules governing the proper fluids for disposal injection, namely that domestic wastewater was improperly injected into UIC Class II disposal well Dl within the Redoubt Unit. Mitigating circumstances outlined above are relevant and should be considered in the Commission's fmal decision about the need for proposed enforcement actions. After careful consideration of all the relevant facts and the arguments presented by Forest at the February 23,2006 informal review conference and in its associated written submissions, the Commission finds that it is appropriate to exercise the Commission's discretion not to assess a civil penalty in this case. NOW THEREFORE IT IS ORDERED THAT: Forest shall comply with the following corrective actions: 1. Within 90 days from the effective date of this order, Forest shall provide the Commission with underground injection guidelines that ensure the operator's compliance with regulatory requirements and implementation of best management practices for disposal AOGCC Order #46 Page 6 of6 . . January 29, 2007 and enhanced recovery injection actions taken at all Forest~operated facilities within Alaska; 2. Upon approval of the guidelines by the Commission, Forest shall implement the injection guidelines; 3. Forest shall provide the Commission with written confirmation that all personnel involved in injection operations and decisions have received the training consistent with the new best practices guidelines. This Proposed Decision and Order shall become fmal and effective on the 11 th day after the date of issuance shown below, unless within 10 days from the date of issuance Forest files a written request for a hearing under 20 AAC 25.535(c). If Forest timely files a written request for a hearing this Decision and Order shall be of no effect. Done at Anchorage, Alaska this 29th day of January, 20 . oerster, Commissioner il and Gas Conservation Commission U.S. Postal ServiceTM CERTIFIED MAIL" RECEIPT (Domestic Mail Only; No Insurance Coverage Provided f'- Et) fT1 IT' fT1 Lf' f'- Lf' . ;. ~ ~ff9f'<C I A l USE Postage $ $0 .63 ñ t:J Certlfled Fee t:J c:J Return Receipt Fee (Endorsement Requfrød) c:J Restricted Deßvery Fee ..lJ (Endorsement ReqUIred) ñ ñ Total Postage & Fees $ Lf' c:J c:J f'- $2.40. $1.85 $0.00 $4.B8 · 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 mailplece, or on the front ,if space permits. . 1. Article Addressed to: '. /viR. Á.£ON~eJ) GUWL-é"¡ ¡;eG5í 0/1.. f.OI!.P. ~IIJ K ~ ~Ee7; Sa (IE 700 ~NC.fOC.A£1~" fHt- qq5Ð I 2. Article Number (rrans(er from setvlce label) PS Form 3811, February 2004 D. Is detlveIY addreSS different Item 17 If YES. enter delivery address below: 3. Service Type "'Certified Màil 0 Express Man o Registered 0 Retum Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 7005 1160 0001 5753 9387 Domestic Return Receipt 102595.Q2·M"1540 . . STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue, Suite 100 Anchorage Alaska 99501 Re: Improper Class n Injection in Redoubt ) Unit Well Dl; Forest Oil Corporation ) ) AOGCC Order No. 46 January 29,2007 Recusal from Decision Daniel T. Seamount, Jr., Commissioner hereby recuses himself from the above entitled case. January 29. 2007 Date ~19 . . Regg, James B (DOA) From: Sent: To: Subject: Bob Elder [RGElder@forestoiI.COm]<\Ì/jLl'r13IZS;1(07 Thursday, August 23,200712:10 PM \<-...e'..£It-' \ Regg, James B (DOA) Waste Management Plan Attachments: FST AKWstMnPln.doc FSTAKWstMnPln.do c (3 MB) Jim- Thanks for your call and input on our Waste Management Plan. I've corrected the editorial issues you pointed out, fixed (and improved) the waste manifest, and made some other improvements based on additional review and feedback from the field. Please let me know if you have other suggestions. I intend to rollout some final training on it next week. Thanks again for the assistance. Bob . . Page 1 of 51 FOREST OIL WASTE MANAGEMENT PLAN Alaska Operations 8/27/07 8/21 . . Page 2 of 51 Table of Contents Section Scope....................................................................................... .... Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. Regulatory. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . General Waste Management Guidelines. . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . ... Waste Minimization. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. Labeling........... ................ ... ........................ ..... .... ............ ...... Storage and Segregation of Solid Waste............................................ Transportation of Solid Wastes............... ............... ......... ...... ..... .... Summary Guidelines............... ........... . ....................................... Available Recycle/Reuse/Waste Disposal/Storage Facilities... . . . . . . . . . . . . . . . . . . . . . .. Identification of Waste Streams and...................................................... Environmental Standard Operating Procedures......... ........ ........ ........ ... ...... Training and Awareness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... Compliance Personnel. . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... . . Inspections and Audits...... ............. .................... ....... ..... ................... Pa2;e 3 3 4 4 4 5 5 6 6 7 8 9 10 10 10 APPENDICES Appendix I. Forest Oil Waste Manifest.. .. .. .. .. .. .. .. .. .. ..... .. .. .. .. .. . .. .. .. .. .. ... 12 Appendix II. Waste Analysis Plan for CLASS I wells......... ... .................... 13 Appendix III. List of Approved Class I Waste Streams......... ....................... 41 Appendix IV. DIC Compliance ..Matrix................................................. 44 Appendix V. Waste Analysis Plan for Osprey EOR...... ......... .................... 45 8/21 2 . . Page 3 of 51 Forest Oil Waste Management Plan Alaska I. Scope. This Plan encompasses all waste management and associated activities conducted by Forest Oil Corporation (FST) in Alaska. It addresses the management of all solid wastes (under the RCRA definition of "solid waste" even liquid and gaseous wastes are considered solid waste) and the management of wastes injected into Class I and Class II underground injection control (UIC) wells. The plan does not address the management of emissions that are managed under air quality permits, or liquid discharges that are managed under federal (NPDES) permits or State wastewater discharge permits. II. Introduction. The Plan outlines the policies, procedures, guidelines, standard operating procedures and other system used for appropriately managing wastes generated during exploration and production. Management of wastes extends to all facets of waste handling including generation, storage, transportation, recycling and disposal. Forest Oil follows waste management procedures that are designed to assure compliance with Federal and state regulations and solid waste disposal and underground injection permits. To accomplish this objective, the Plan incorporates procedures to: · encourage the minimization of wastes and recycling of materials wherever possible, · reduce the possibility of uncontrolled releases of wastes to the environment and exposure of personnel to potential hazards associated with wastes, · eliminate unnecessary expense and liability associated with waste generation, storage, transportation and disposal, · ensure that wastes are stored, transported and disposed of properly. This Plan is composed of the following elements: · Regulatory · General Waste Management Guidelines o Waste minimization o Labeling o Storage and segregation of solid wastes o Transportation of solid wastes o Summary Guidelines · Recycle/Reuse/Waste Disposal/Storage Facilities · Identification of Waste Streams and Disposal Options · Standard Operating Procedures · Training and awareness · Compliance personnel · Inspections and audits m1 3 . . Page 4 of 51 III. Regulatory. Waste management at Forest's Alaska operated properties is impacted by several government agencies, including those at the federal, State and local levels. Examples include: · Federal o Pollution Prevention Act of 1990 o Resource Conservation and Recovery Act (RCRA) of 1976 o Hazardous and Solid Waste Amendments of 1984 o Safe Drinking Water Act (Underground Injection Control (UIC)) of 1974 o Area and Facility Permits · State o Solid Waste Management Regulations o Drinking Water Regulations o Underground Injection Control Regulations o Area and Facility Permits · Local o Kenai Peninsula Borough (Landfill) o Matanuska Susitna Borough (Landfill) o Municipality of Anchorage (Landfill and wastewater) o Area and Facility Permits IV. General Waste Management Guidelines. The following guidelines are designed to be general practices only for handing wastes and recyclable materials. They do not replace detailed procedures in place for individual and specific waste streams and recyclable materials. For detailed information on how to manage specific materials refer to Standard Operating Procedures and other plans and compliance tools found in the appendices to this document. In any and all cases, call Environmental for guidance if questions or confusion occur. Waste Minimization Declare nothing a waste until it has been determined that the material must be discarded. The following waste minimization procedures should be employed to reduce the amount of waste generated: · Prevention. Planning assures that only the amount of substances that are needed for ajob are on-site thus reducing the amount of waste generated. All chemicals and other materials, to the extent possible, must be entirely used for their intended purpose. Do not discard unused chemicals without notifying the Environmental Department. · Product Substitution. Wherever possible, materials with lower toxicities should be substituted for others that would pose greater heath, safety and environmental risks. Avoid substances that would become hazardous wastes when discarded if other products are available. 8/21 4 . . Page 5 of 51 · Recycle and Beneficial Reuse. Wherever possible substances that would otherwise become wastes should be recycled or used beneficially. Labelin2:/Manifestin2: · Labeling o All containers for wastes and recyclables must be labeled with the appropriate label type, the name of the waste, the date it was first generated or placed in the container o Universal wastes must be labeled with the name of the contents (lamps, batteries, etc.) and the area where they are stored must be identified with a sign saying "Universal Waste Storage Area". o Containers of used oil must be labeled as "Used Oil". Do not deviate from these actual words. o Any hazardous waste container must be labeled "Hazardous Waste". Do not deviate from these actual words. o Dumpsters must be labeled with the actual contents. · Manifesting o All fluid wastes that are recycled or disposed of at Forest Oil operated facilities must be manifested from the point of generation to the site of disposition with the "Forest Oil Waste Manifest-Alaska Operations" (Appendix I). o All wastes being shipped off-site must be accompanied by an appropriate manifest. Ensure that the shipper has and uses appropriate manifests. Stora2:e and Se2:re2:ation of Solid Wastes · Storage. FST's operations and contractors use the following types of waste storage facilities: o Temporary storage area for muds and cuttings (permitted) o Universal Waste Accumulation Areas (UAAs) o Dumpsters (KPB) · Metal · Oily Waste · Kitchen Waste · Trash · Segregation. The above storage areas should be clearly marked and all FST and contractor personnel are instructed not to mix wastes, either between storage areas or between containers within each storage area. Personnel are also instructed not to mix wastes in transportation vehicles unless they are destined for disposal at the same facility. m1 5 . . Page 6 of 51 Transportation of Solid Wastes . Transportation Companies. FST contracts with transportation companies that are familiar with and experienced in hauling Alaska waste loads. . Alaska Waste Manifest. The Forest Oil Manifest must be used for all waste fluids destined for disposal/recycle/beneficial reuse at facilities operated by Forest Oil. Summary Guidelines for Waste Mana2:ement In general, the following guidelines should be followed when handling recyclables and waste: · Minimize the volume of waste whenever possible. This can be accomplished by insuring that all existing chemicals are completely used and that containers are completely empty (call Environmental for the definition of "empty") before being sent to waste disposal facilities. If possible, return all unused chemicals to the vendor for credit. · Recycle materials where possible. Many lubricants and other hydrocarbons (as long as they would NOT otherwise be classified as hazardous waste) may be recycled into the production streams. · Never mix wastes unless authorized by Environmental. Wastes which may otherwise be recycled or disposed of as non-hazardous wastes are much more expensive to dispose of when mixed with hazardous wastes. · Wastes should be stored on pallets, within secondary containment, away from surface waters, and protected from accidental damage. Designated areas for all wastes at each facility should be identified and constructed as appropriate and with signs identifying what they are. · Keep labels on containers in good condition and with as much information on the contents as possible. Re-Iabel if they show signs of deterioration. · Seal or cap all containers tightly. Drums must have tightly fitting lids. · Transfer wastes from containers that are leaking or that show signs of deterioration into intact ones as soon as possible. · Never use "short-cuts" to expedite waste removal. If any questions arise, consult with Environmental immediately. · Manifests are required for all off-site shipments of waste and all wastes trucked to on-site Class I injection, or recycle (including EOR): o When a waste is generated, immediately label the container and complete the manifest as fully and as accurately as possible. o Never deposit a waste at any facility without the approval ofthe foreman or lead operator at that facility and making sure that he/she signs the manifest upon receipt. o Never accept wastes without either initiating a manifest or completing the necessary information on a manifest already in existence. 8/21 6 . . Page 7 of 51 V. Available Recycle/Reuse/Waste Disposal/Storage Facilities · Federal o Pollution Prevention Act of 1990 o Resource Conservation and Recovery Act (RCRA) of 1976 o Hazardous and Solid Waste Amendments of 1984 o Safe Drinking Water Act (Underground Injection Control (UIC)) of 1974 o Area and Facility Permits 8/21 Responsible Agency · Facilities Forest operated facilities in Alaska Temporary oily waste storage- WMRU Incinerator- WMRU Class I Disposal wells (Converted from Class II in 2007) (See App. II and III for required W AP and list of approved waste streams) WMRU 4D RUD#l Class II Disposal wells (Converted to Class I in 2007) (See App. IV for DIC compliance matrix of approved waste streams) WMRU 4D RUD#l Class II EOR wells AOGCC (See App IV and V for DIC compliance matrix of approved EPR fluids and required W AP for RD #6) WMRU #2A RU#6 Universal waste storage areas-WMRU, KPF, Osprey In-State facilities Wastewater treatment, oily waste incineration, and landfill facilities owned and operated by Alaska Boroughs Wastewater treatment. Municipalities Recycle, non haz waste disposal. Emerald! AIM/Raven (Private) Out-of-State Disposal (Private) FST has contracts in place with certified hazardous waste shippers and out-of-state deposal facilities. ADEC EPA EPA 'I AOGCC EPA · KPB, MSB Anchorage · EPA, ADEC EPA, ADEC 7 . . Page 8 of 51 Identification of Waste Streams and Disposal Options Table 1 contains a list of potential waste streams which could be generated at Forest Oil- operated facilities and recommended management/disposal options. Table 1. Waste Management Options Forest Oil, Alaska Operations List of Wastes Management Options acids None. Call HSE if occurs. aerosol cans Use entire contents. Puncture in designated puncture drum. Recycle in metal dumpster. aluminum Soft trash dumpster. Ash, incinerator Soft trash dumpster but only after testing for HAZWA characteristics (Metals)-Call Environmental to arrange caustics None. Call HSE if occurs. construction waste By project or metal/wood/soft trash dumpsters. contaminated soil chemical Call HSE. Lined mud boxes. Segregate by material. To Emerald or grind and inject if NOT HAZARDOUS. gasoline Call HSE. Segregate in lined mud box. Treat as Hazardous Waste. To Emerald/AIM/Raven. glycol Lined mud boxes. May commingle with oil contaminated soil. To Emerald or grind and inject. Includes diesel, lube, and crude, hydraulic. Lined mud boxes. oil Segregate by material. To Emerald/AIM/Raven or grind and inject. e&p waste Class lor Class II injection. e-waste Send to Total Reclaim for recycle. filters Incinerator. glass Soft trash dumpster. glycol EG Do not use for freeze protection. Class I injection or to Emerald/AIM/Raven. Call Emerald/AIM/Raven to verify. TEG Do not use for freeze protection. Class I injection or to Emerald/AIM/Raven. Call Emerald/AIM/Raven to verify. Call Environmental. IF ALL CHEMICALS ARE ENTIRELY Hazardous Waste (HAZWA) USED AND USED PROPERLY HAZWA SHOULD NOT OCCUR hydrotest water Discharge to surface only after applying for permit (call Environmental) or Class I injection kitchen wastes Incinerator. metal Metal dumpsters (rented)-goes to KPB landfill or other approved disposal/recycle facility paint Use all. paint cans Use all and to metal dumpster. plastics Incinerator or soft trash dumpster. 8/21 8 . . Page 9 of 51 List of Wastes Management Options rags/sorbents chemical Call HSE ASAP to determine if Hazardous Waste and disposal options. gasoline Send out as Hazardous Waste-Benzene. oilld iesel/crude/I u bel hydraulic Incinerate. soft trash Incinerator or soft trash dumpsters and to KPB landfill if incinerator not workinç¡. Use all. Keep out of sumps. Get rid of all chlorohydrocarbons solvents (e.g. Brakeclean, Lectraclean with 1,1,1, TCE, etc.). Review MSDSs. spilled chemical Call HSE ASAP to determine if Hazardous Waste and disposal ootions. universal waste batteries All (lead acid, nilcad, lithium, alkaline) to universal waste area in totes. Send to KPB landfill for recvcle. Hg switches None. light bulbs Everything but incandescent to universal waste area unbroken. Send to Total Reclaim. used oil Includes diesel, lube, crude, hydraulic. Recycle- test for haloaens Chlor-detect Kit. used PPE Incinerator. used/unused chemicals Use all. Don't leave anvthina unused. Otherwise call HSE. welding rods Metal dumpsters (rented)-aoes to KPB landfill. wood waste Burn permit or wood dumpsters and to KPB landfill. Quantity of HAZWA Icalendar month-must be kept under 100 kg/mo (220 Ibs/mo) Environmental Standard Operating Procedures (SOPs) and Plans The following plans and SOPs are available to ensure that wastes are appropriately managed: · THIS PLAN · Wildlife Deterrence Plan · W AP for Class I Wells · UIC Matrix · Used Oil Management (SOP) · Used Aerosol Can Management (SOP) · Universal Waste Management (SOP) · Incinerator Use (SOP) · Vac Truck Use (SOP) Personnel must familiarize themselves with these procedures prior to handling any materials addressed in the SOPs. 8/21 9 . . Page 10 of 51 Training/Awareness · Training. All FST and contract personnel responsible for waste management decisions in Alaska are required to attend annual waste management training. · Safety Meetings. Regular safety meetings are conducted for all FST operations. Environmental subjects, including proper waste management, are included at those meetings. Compliance Personnel · Production Manager. In the event that waste management option/procedures are unclear, always ask the Production Manager for advice. · Health. Safety. Environment Manager. The HSE manager in Anchorage is available at all times to help with decisions on waste management issues that cannot be solved by the Production Manager. Inspections/Audits · Environmental Inspections. FST HSE personnel routinely inspect all facilities to identify and resolve potential waste management issue with field personnel. · Audits. Periodic EHS audits are conducted ofFST's operations by qualified personnel from the Corporate Office. 8/21 10 . . Page 11 of 51 APPENDICES 8/21 11 . . Page 12 of 51 Appendix 1. Forest Oil Waste Manifest or Ul s ecyc e , or estme or ass or fiI ectIOn 1. GENERATOR INFORMATION Field! I Owner I Date Asset Company Contact Rig! (Print Name) Location Time ? AM ? PM Phone! Cost Code! Activity Code! Pager Source! Wen No. AFE! Approver ID 2. GENERATING ACTIVITY OR PROCESS 3. VOLUME ? Bbls (Estimate) ? Gal ? Cuvd 4. DESCRIPTION (Composition must e~uall00% - use whole numbers) Crude Oil % Glvcol % Fresh Water! Eouiument Wash Water % Produced Water % Acid % Seawater! Brine! KCI % Drilling Mud % Line Pigging Material % Chemicals % Cuttings % Diesel! Water Gel % Sump Fluid % Cement! Contaminate % Scale! Corrosion Inhibitor % Snow % Diesel % Boiler Blowdown % Soil! Sand % Methanol % Used Oil % Domestic Wastewater (Describe) % OTHER _% ~% Description Description - % _% Description Description 5. REUSE / RECYCLE: Will the material be reused/recycled in an approved manner? ? YES Select method at right and go to PART 8 ? Water RecyclelEOR ? NO Go to PART 6 ? Hydrocarbon Recycle ? Other Beneficial Reuse (Describe) 6. WASTE CLASSIFICATION: Was the waste brought to the surface from downhole or used during direct production operations? ? YES Go to PART 7 if Class I facility will be used ? NO Go to PART 7 or contact Environmental 7. CLASS 1 DISPOSAL: Is the waste either non-exempt and non-hazardous (TESTING MAY BE REQUIRED TO DETERMINE- CALL ENVIRONMENTAL), or exempt from regulation as a hazardous waste (40 CFR 261.4)? ? YES Indicate classification at right and Go to PAR T 9 ? RCRA Exempt ? Non-Exempt and Non-Hazardous ? NO--HAZARDOUS WASTE-Not approved for on-site disposal- contact Environmental, Go to PART II 8. DESTINATION: EOR or RECYLEDIREUSED FLUIDS (TESTING MAY BE RERQUIRED-CALL ENVIRONMENTAL) RUD #6 0 Other: WMRU # 2A 0 Go To PART 10 9. DESTINATION FOR CLASS I FLUIDS RUD #D1 0 WMRU#4D 0 Go To PART 10 10. TEST DATA (IF REQUIRED) BY RECEIVING FACILITY Flash point Degrees F Organic Chlorides (ppm) % Solids Testing Not Required_ pH Units % Hvdrocarbons % Water Go To PART 11 11. GENERATOR Name Signature LocationIFacility: (Print) Certificate: This consignment, to the best of my knowledge and belief, is accurately described Date above and I have applied the provisions of the Waste Analysis Plan! Guide in making decisions concerning the reuse or disposal of this material. 12. TRANSPORTER Name Signature Company (Print) Vehicle Type (Truck, Boat, Helicopter, etc.) Date 13. RECEIVER Name Signature Offloaded at: (Print) Volume Received: Date Bbl Gal Cuyd ? ? ? Forest Oil Class IlRecyclelEOR Manifest-AK Operations F FI'd Rid D d fì CI I EOR I . 8/21 12 . . Page 13 of 51 Appendix II. Waste Analysis Plan for CLASS I wells Waste Analysis Plan Class I Disposal Wells Forest Oil Corporation Cook Inlet Alaska CONTENTS 1.0 Purpose/Scope .............................................................. ......... ............................................................14 1.1 Description of Facilities ...........................................................................................................14 1.2 Description of Cook Inlet Wastes ............................................................................................14 2 .0 De fini ti 0 ns ............................................................................ ............. .................... ........... .............. ....15 3.0 Gen eral Requirements ..................................................... ................ .... .................................. ...........15 3.1 Contents ofW AP .....................................................................................................................15 3.2 Criteria for Underground Injection...........................................................................................16 4.0 Key Respo nsibili ties ................................ ........... ..... ..........................................................................16 5.0 Proced ures ........................... ............................... ....... ......... ...............................................................1 7 5.1 Waste Classification.................................................................................................................17 5.2 Analysis of RCRA-Exempt Wastes .........................................................................................18 5.3 Analysis of Non-Exempt Wastes .............................................................................................19 5.4 Mixed Wastes. ................... ...... ......... ........ .................... ................. ........ ......... ....................... ...20 5.5 Sampling Methods..... ................... ....... ................................ ......... .................... ...................... .20 5.6 Sampling Frequency...................... ................ ........... ............ ......................... ........... ...... ..........21 5.7 Record Keeping and Documentation .......................................................................................21 5.8 Quality Assurance and Quality Contro1...................................................................................22 6.0 Key Documen ts/T ools/Ref erences ...................................................................................................11 "Vaste .Analysis Plan - Revision Log ...........................................................................................................24 Exhibit 1 Waste Disposal Flow Schematic (WMRU)......... ......... ......... .................... ..............13 Exhibit 2 Waste Disposal Flow Schematic (Redoubt Platform)...............................................14 Exhibit 3 Wastes Identified in Permit Application ................................................................................27 Exhibit 4 Cook Inl et Waste Streams ....................... ..... ...........................................................................2 7 Exhibit 5 Cook Inlet Class I Waste Sources ...........................................................................................32 Exhibit 6 Analytical Requirements for Non-Exempt Waste Streams ..................................................33 Exhibit 7 Analyti cal Methods ....................................... ........................................... ................................34 Exhibit 8 Hazardous Waste Characteristics....... ........................ ........... .................................................3 5 Exhibit 9 Reactivity Checklist .................................... ............... ............... ...............................................3 6 Exhibit 10 Hazardous Waste Toxicity Characteristics ............................................................................3 7 Exhibit 11 Waste Manifest Form ..............................................................................................................38 8/21 13 '1;,.. . . Page 14 of 51 1.0 Purpose/Scope This Waste Analysis Plan (W AP) outlines procedures for classifying, sampling, and analyzing wastes prior to disposal in the Forest Class I injection wells located in the Cook Inlet. Forest has prepared this W AP to fulfill the requirements of Section ----- of Underground Injection Control (UIe) Permit AKm------. 1.1 Description of Facility The two Class I disposal wells are located on the following oil production facilities: . West McArthur River Unit (WMRU) onshore production and processing pad. . Redoubt Platform, offshore West Foreland land fall. Wastes are injected into the Tyonek Formation at a subsea depth of approximately 5200 feet at WMRU and at approximately 8200 feet at Redoubt. Exhibits 1 and 2 are simplified waste flow diagrams for these Cook Inlet facilities. A complete description of the disposal process is contained in Forest's UIC Permit Application of July 2006. 1.2 Description of Wastes 1.2.1 Waste Volume and Composition Several million barrels of waste could be injected in each Class I well over an anticipated 7-10 year life. Exhibit 3 lists the wastes that were described by Forest in the UIC permit application. About 98 percent of the total volume projected to be disposed of will be produced water or domestic wastewater as indicated below. One percent could be drilling related waste and 0.002 percent industrial non-hazardous waste. Waste Stream Composition (Proiected) Component Produced water Camp wastewaters and storm water Well workovers and flowbacks Miscellaneous production wastes Drilling mud/slurry and flush (potential) Industrial non-hazardous wastes (Class I) Åpprox. % of Total 97 1 0.5 0.5 1 0.002 1.2.2 Waste Streams Primary oil and gas operations in general generate similar types of wastes. These can be grouped into broad categories, or "waste streams", that are reasonably consistent over time. Exhibit 4 lists typical waste streams on the North Slope of Alaska that analytical data have been collected on for several years to support injection of these streams at Class I facilities on the North Slope; which includes facilities at Northstar, Pad 3, Badami, and Alpine. These streams are applicable to the similar Cook Inlet facilities. 1.2.3 Cook Inlet Waste Sources Exhibit 5 lists the primary sources of Class I wastes at the Forest facilities in Alaska. Wastes enter the Class I disposal streams by two routes. 1) Hardlined from Production Facility. Most major fluids are hard-lined to the disposal wells from the production and drilling facilities and include the following sources. 8/21 14 . . Page 15 of 51 . Produced water for disposal. . Treated sanitary wastewater, domestic waste, and deck drainage from the platform wastewater treatment plant. The WMRU plant may not be hard piped as it is planned to be an intermittent standby alternative. 2) Batch Injection at Wellhead. "Batch wastes" are generated by intermittent processes that are not permanently connected to the injection well. These wastes are either injected directly at the well through temporary hookups or into feed tanks through temporary hookups. 1.2.4 Waste Ownership Forest assumes ownership of all wastes generated on the Redoubt platform and at the several onshore pads on the West Forelands operated by Forest staff or by contractors under Forest's supervision. Wastes generated outside of the Forest production, processing, or exploration facilities, or wastes generated by non-Forest activities, are considered Non-Unit or Third Party wastes. On a case-by-case basis, Forest will evaluate Non-Unit or Third Party wastes for injection at the injection site. As directed by the Forest Environmental Manager, the Non-Unit or Third Party generator must provide information needed to characterize the waste. 2.0 Definitions Class I: Class I disposal wells inject wastes below the deepest underground source of drinking water (USDW). They are subdivided into industrial and municipal categories based on their ownership, and into hazardous and non-hazardous based on the nature of the injected waste. The Forest wells are industrial, non-hazardous Class I wells. There are no USDWs in the disposal and confining zones and the overlying aquifers àre generally exempted as a source for public water supply because of the high salinity. mc: Underground Injection Control. A program authorized by the Safe Drinking Water Act to protect USDWs by regulating the disposal of waste fluids through underground injection wells. Regulations are published in Title 40 of the Code of Federal Regulations, primarily in Parts 144 through 146. 3.0 General Requirements The Environmental Protection Agency (EP A) regulates the construction and operation of the Forest Class I disposal wells through Underground Injection Control (DIC) Permit AK--------. (The Alaska Department of Environmental Conservation (ADEC) is also involved through a General Wastewater Disposal Permit 2005DB0001 generated through provisions of Alaska statutes 46.03). These permits are posted at each facility and are also available electronically. 3.1 Contents of the WAP Section ----- of the EP A permit requires a plan for obtaining "detailed chemical and physical analysis of representative samples of the injected wastes which includes the following: 1) The parameters for which the waste will be analyzed and the rationale for the selection of these parameters; 2) The test methods that will be used to test for these parameters; and 3) The sampling method that will be used to obtain a representative sample of the waste to be analyzed." Waste streams that are hard-piped continuously fÌom the production facilities to the wellhead require "such sampling and testing as may be necessary to provide a description of the nature and composition of all 8/21 15 . . Page 16 of 51 injected fluids, and to support any statements that the waste is exempt from regulation as hazardous waste as defmed by 50 CFR 261.4". 3.2 Criteria for Underground Injection Wastes must meet the following criteria for underground injection. 1) The waste is included in the Forest Class I permit application (see W AP Exhibit 3). Note that this list includes broad categories that encompass virtually all waste streams anticipated. Any waste that is not on this list requires approval from a Forest Environmental Manager or Advisor. 2) The waste is classified as non-hazardous or exempt from hazardous waste management regulations under the Resource Conservation and Recovery Act (RCRA). (See W AP Section 2). 3) The waste meets the injection facility's safety and operational criteria. 4) Disposal is properly documented (see W AP Section 5). 4.0 Key Responsibilities Forest Oil Health, Safety and Environment Manager, or Designee · Supervises the collection of samples and coordinates analysis as specified in Section 5 of the WAP. · Makes hazardous waste determinations using laboratory data and/or generator knowledge. In making these determinations, consults with the Environmental Manager and/or a UIC Class UC1ass II Regulatory Classifications Technical Authority (TA) as needed. · Periodically reviews manifests and waste analysis records. · Maintains waste analysis records as specified in Section 5 of the W AP. · Submits W AP initially to EP A and makes subsequent revisions available to EP A. · Reviews W AP and related documents for technical accuracy. · Coordinates updates to W AP and related documents · Obtains ADEC General Disposal Permit 2005DB0001 as required by State of Alaska regulation. · Provides regulatory guidance relating to waste classification and management options. · Provides regulatory guidance related to waste classification and management options. 8/21 16 . . Page 17 of 51 5.0 Procedures Wastes are evaluated for injection in the Class I disposal wells according to the following procedures. 5.1 Waste Classification Wastes injected in the Class I wells must be classified as non-hazardous or exempt from regulation as hazardous waste under the Resource Conservation and Recovery Act (RCRA), Subtitle C. A hazardous waste determination must be made before wastes are introduced into the disposal system if it is not an exempt waste. Hazardous waste determinations are made primarily by the Environmental Specialist and/or Environmental Compliance Manager. 5.1.1 Hazardous Wastes A waste is considered hazardous under RCRA if it is listed in 40 CFR(I) 261, Subpart D, or if it displays any of the characteristics described in 40 CFR 261, Subpart C. Hazardous waste characteristics, outlined in Exhibit 8, include ignitabi1ity, corrosivity, reactivity, and toxicity. Toxicity is measured by the Toxicity Characteristic Leaching Procedure (TCLP). Thresholds for regulation due to toxicity are summarized in Exhibit 9. 5.1.2 Decharacterized Hazardous Wastes Decharacterized hazardous waste may be approved for direct iniection at the wellhead if it no longer displays a hazardous characteristic at the point of injection. Examples of hazardous wastes that could potentially be de characterized include: · Turbine wash water (cadmium, flash point) · Glycol (selenium, other contaminants) · Acids, bases (corrosive) 5.1.3 RCRA-Exempt Wastes Some broad categories of wastes are excluded from strict management under RCRA. In most cases, the exemption is based on the process that generates the waste, not on its actual composition or properties. Exempt wastes must still be managed properly, but they are not subject to RCRA's full storage, documentation, transportation, and disposal restrictions. Important exemptions applicable to Cook Inlet include: . RCRA Exploration and Production (E&P) Exemption The RCRA E&P exemption applies to certain wastes associated with oil and gas exploration and production. Exhibit 4 lists examples of Cook Inlet wastes covered by the RCRA E&P exemption, and numerous non-exempt wastes. Additional guidance may be found in the references cited in Section 6. . Empty Container Exemption Residues remaining in containers are not regulated as hazardous waste if the container is empty as defined by 40 CFR 261.7(b): 1) All wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container, e.g., pouring, pumping, and aspirating; and 2) No more than 2.5 centimeters (one inch) of residue remain on the bottom of the container or inner liner; or (I) Code of Federal Regulations 8/21 17 . . Page 18 of 51 1. No more than 3 percent by weight of the total capacity of the container remains in the container or inner liner if the container is less than or equal to 110 gallons in size; or 11. No more than 0.3 percent by weight of the total capacity of the container remains in the container or inner liner if the container is greater than 110 gallons in size. NOTE: The waste is exempt when it remains in an empty container, but when it is removed from the empty container by rinsing, EP A considers it to be a new waste (no longer exempt). A hazardous waste determination must be made to determine whether or not the removed rinsate is hazardous. If the container has held an acutely hazardous waste, it is considered empty if the container has been triple-rinsed with an effective solvent, or the inner liner (if present) has been removed. The initial rinsates and/or inner liner must be managed as hazardous waste. 5.1.4 Non-Exempt Wastes Exhibit 5 lists several Cook Inlet wastes that are not RCRA-exempt. The exemption does not apply to products that have not actually been used for their intended purpose in exploration or production. Wastes are generally not RCRA E&P exempt if they have not been brought to the surface during oil and gas operations or have not come into direct contact with the production stream. Wastes generated by the wastewater treatment plants and other support operations, such as facility and vehicle/boat maintenance, are typically RCRA non-exempt. 5.1.5 Non-Exempt Sales Pipeline Wastes Wastes recovered from DOT regulated Cook Inlet crude oil and gas transportation pipelines must be evaluated as non-exempt wastes since the RCRA E&P exemption includes only production process facilities and associated offshore and on shore gathering lines. For the oil stream going to Cook Inlet Pipeline, the exemption ends at the point of custody transfer which is the Cook Inlet LA TC meter. For the gas sales line going to Marathon, the exemption ends at the point of custody transfer at meter # 6106. The Redoubt platform fuel gas line is supplied by gas routed directly ftom the onshore processing equipment; therefore, liquids, gas, and residues in this line are exempt. 5.1.6 Consequences of Mixing Wastes Mixture rules are complicated, and should be used with caution. For guidance, consult the references provided in Section 6 and the regulations cited below. Three conservative mixture rules are: 1) Hazardous waste + non-hazardous waste = hazardous waste (40 CFR 261.3( a)(2) 2) Non-hazardous/non-exempt waste + exempt waste = exempt waste (U.S. EPA, 1995) 3) Hazardous waste + exempt waste = hazardous waste (40 CFR 261.3(a)(2)(iii) Wastes must be classified before they are commingled with other materials in sumps, pits, or containers. 5.2 Analysis of RCRA-Exempt Wastes RCRA exempt waste streams (Exhibit 4) are approved for injection without prior sampling and ana1vsis, providing the activity is clearly identified as generating exempt wastes. The same material, generated by a non-exempt process, may be regulated as hazardous waste. All processes and facilities are subject to audit by the HSE staff to verify that waste-generating activities are accurately described as RCRA-exempt. (Note that wastes generated from the transportation of crude oil and gas are not RCRA-exempt ). Exempt wastes may actually have properties that make them dangerous to handle. Therefore, they must meet all applicable safety, compatibility, and operational restrictions at the injection well. 8/21 18 . . Page 19 of 51 5.3 Analysis of Non-Exempt Wastes Non-exempt wastes must undergo a hazardous waste determination before they enter the disposal system. 5.3.1 Characterization Without Analysis Sampling is not always necessary to characterize a waste. . Commercial Chemical Products Commercial chemical products can sometimes be adequately characterized by generator knowledge in accordance with 40 CFR 262.11(c)(2). Generator knowledge may be based on a Materials Safety Data Sheet (MSDS) or other applicable data. Before sending the material to the injection well, the generator should provide a copy of the MSDS (or other data) to the Environmental Specialist for review. «(Does Forest maintain a computerized MSDS database for products used in Cook Inlet») I. MSDSs can also be obtained from the product manufacturer, or the contractor providing the material. If the MSDS for a product clearly indicates that it is not RCRA hazardous when discarded, and it has not been mixed with any unknown material, the waste will generally be approved for injection without further analysis. Generator knowledge is also sufficient to characterize seawater or fresh water that has not been mixed with anything else. . Existing Analytical Data Wastes submitted under an approved, "current" waste stream (see following section) do not have to be analyzed on a 10ad-by-10ad basis. At the discretion of the Environmental Specialist, analytical data from other locations may be used to characterize a common, recurring waste stream. 5.3.2 Characterization by Analysis Sampling and laboratory analysis are required for any non-exempt waste that either (a) does not fit into a current, established waste stream, or (b) cannot be characterized by generator knowledge to the satisfaction of the Environmental Specialist, in consultation with the Environmental Manager. Non-exempt waste streams must be sampled and analyzed as indicated on Exhibit 6. Non-exempt wastes will be evaluated as follows. 1) Initial characterization. A representative sample of the waste will be collected by the Environmental Specialist or a professional person under the Specialists supervision, and it will be sent to a commercia11aboratory for full hazardous waste characterization. Analytical parameters are listed on Exhibit 6. Methods, sample containers, and holding times are summarized on Exhibit 7. Results will be compared to the hazardous waste characteristic limits in Exhibits 8 and 9. See Exhibit 9 for special instructions on the characteristic of reactivity. . More than one sample may be necessary to characterize the waste stream, particularly if there are several different sources. Waste streams should be re-samp1ed if the waste- generating process changes over time. . Waste streams that were analyzed before the Class I wells were commissioned do not have to be re-tested if there is reasonable assurance that: a) The sample (as collected) is representative of the current process. Database is currently accessible on the Forest Intranet Site.???????? 8/21 19 . . Page 20 of 51 b) The sampling procedures and analytical methods were consistent with those described in this W AP . . Once initial profiling is complete, testing requirements can be reduced for subsequent loads of the same waste. As long as the waste stream remains consistent, testing will consist of periodic fmgerprint analysis as indicated on Exhibit 6. 2) Fin!!:erprintin!!:. "Fingerprinting" involves testing a sample for a few indicator parameters to confirm that the waste stream remains non-hazardous over time. Fingerprinting focuses on the most likely hazardous characteristics, based on generator knowledge and previous analytical results. Fingerprint parameters and acceptable ranges are indicated on Exhibit 6. Some fingerprint tests can be done on-site using field test kits. . Any waste that "fails" a fingerprint test should be sampled and sent to a laboratory for complete characterization. 3) Spot-checks. Any waste load is subject to spot-checks at the discretion of the Environmental Specialist. Spot-checks may consist of selected fingerprint parameters (such as pH or flash point), or full analysis. 5.4 Mixed Wastes Mixtures of exempt and non-exempt wastes should not be sampled or analyzed. Many exempt wastes have characteristics that would actually "fail" RCRA analysis, and their presence in the mixture would produce meaningless and misleading results. Mixing wastes of different classifications is generally discouraged unless the non-exempt waste has been adequately characterized before mixing. 5.5 Sampling Methods Samples for waste characterization or fingerprinting will be collected or supervised by the Environmental Specialist, commercial laboratory personnel, or other qualified individuals. In most cases, these will be grab samples taken directly from the waste container. Wastes from different sources should a1wavs be segregated until sample results are received. 5.5.1 Containers Exhibit 7 shows the minimum sample volumes and container types required for various analyses. Pre- cleaned containers should be obtained from the analytical lab or a reputable supplier of laboratory goods. Disposable containers should not be re-used. 5.5.2 Representative Samples and Composites For initial characterization, waste stream samples from different locations should not be combined for testing unless the waste-generating processes are virtually identical. Each source should be analyzed separately to establish a "track record". This is especially true for waste streams such as sump fluids, facility wash waters, and lubrication oils and glycols, which may come from several different locations. For fingerprint analysis of established waste streams, composite samples from several sources are acceptable, providing all wastes are derived from the same process. Waste should be visually examined, if possible, before sampling. If it appears homogeneous, a composite sample may be taken. If the waste appears stratified or contains more than one phase (sludge plus liquid, for instance), each layer or phase should be sampled and analyzed separately. The approximate volume of each phase should be estimated. Different phases may be combined into a single composite if (1) the phases cannot or will not be separated for disposal and (2) samples from each phase are combined in 8/21 20 . . Page 21 of 51 proportion to their estimated volume in the container. (Note that if one phase proves hazardous and the other does not, the entire container must be handled as a hazardous waste.) If a composite sample shows any RCRA hazardous waste characteristics, individual containers must be analyzed to isolate the source of hazardous waste. If there are measurable levels of toxic components (Exhibit 10) in the composite, the TCLP concentration must be multiplied by the number of samples in the composite. If this level exceeds RCRA limits (Exhibit 10), the individual containers must be evaluated to isolate the hazardous material; otherwise, the entire batch is a hazardous waste. 5.5.3 Sampling Tools Various sampling tools are available. For fluids in drums or relatively shallow sumps, a coliwasa or "drum thief' may be most effective. For larger containers, such as boat tanks, tiger tanks, etc., fluid may be pumped or siphoned through clean tubing into a sample container. It may be necessary to improvise equipment for a particular situation. Sludges or solids may be sampled with clean hand tools or coring devices (such as clean PVC tubing). 5.5.4 Analytical Methods Analytical parameters are listed on Exhibit 6. Methods, sample containers, and holding times are summarized on Exhibit 7. 5.6 Sampling Frequency 5.6.1 Exempt Waste Streams Exempt waste streams are not sampled. However, the Environmental Specialist in consultation with the Environmental Manager will conduct periodic process reviews to ensure that wastes have been properly characterized as RCRA-exempt. 5.6.2 Non-Exempt Waste Streams After the initial characterization, waste streams will be fmgerprinted semi-annually. The Environmental Supervisor may approve reduced sampling frequency for established waste streams that have been consistently non-hazardous over time. If a waste stream has not been generated during a semi-annual period, no fingerprint is required until the next semi-annual period in which the waste is actually generated. Generator knowledge and/or manufacturer's data may be substituted for laboratory analysis as appropriate. 5.7 Record Keeping and Documentation According to Forest UIC PefITÙt Section ------, Forest must keep records concerning the nature and composition of all injected fluids until three years after the well is plugged and abandoned. Manifests and analytical records should be kept on-site at the appropriate Cook Inlet facility for at least three years; then they may be forwarded to the central compliance files in Anchorage. 5.7.1 Manifests A Manifest (Exhibit 11) is required of all batch loads injected directly at the wellhead. The designated receiver is responsible for keeping the signed copy of the manifest and for filing as directed by the Environmental Specialist. The manifests will be periodically reviewed by the Environmental Department and may be required for EP A quarterly reports, audits, or other purposes. 5.7.2 Analytical Data Records of analytical data must include: 1) The date, exact place, and time of sampling or measurements 2) The name(s) of the individua1(s) who performed the sampling or measurements 8/21 21 . . Page 22 of 51 3) The date(s) analyses were performed 4) The name(s) of the individua1(s) who performed the analyses 5) The analytical techniques or methods used; and 6) The results of such analyses 5.8 Quality Assurance and Quality Control The following Quality Assurance/Quality Control (QA/Qc) requirements are consistent with EPA's Guidelines for Quality Assurance Project Plans (see Section 6 ofW AP for complete citation). 5.8.1 Field QAlQC Sample Handling and Custody Procedures Sampling procedures are outlined in Section 5.5. For each analytical method, the appropriate containers, preservation methods, and holding times are outlined in Exhibit 7. Before collecting or sending any samples, field personnel should always contact the receiving laboratory to confirm procedures and to make the necessary logistical arrangements. The laboratory will indicate whether trip blanks are required. Each container will be labeled with the sample number, date and time sampled, sampler's initials, and required analyses. A Chain-of-Custody form will accompany each sample, and will be verified and signed by each person handling the sample until its final disposition. Quality Control Samples QA/QC for any analyses performed on site will include, at a minimum: · Equipment calibration according to manufacturer's instructions · Periodic duplicate testing to verify consistency The Environmental Specialist should keep a file of calibration records and any duplicate testing performed on-site. Training An appropriate level of training will be provided for all personnel involved with waste generation, transportation, and disposal. «(What about personnel at other facilities such as the east side warehousing and docks ???») Training records will be maintained by the Training Department and/or by the contract employee's company. 5.8.2 Laboratory QAlQC Commercial laboratories are expected to maintain QA/QC plans, which will be provided to Forest upon request. Laboratories may be asked to provide the following QA/QC documentation along with sample results. · Method blank · Surrogate recovery (if applicable) · Matrix spike and matrix spike duplicate results (if applicable) · Duplicate results 8/21 22 . . Page 23 of 51 Laboratory reports will be reviewed by the Environmental Specialist with assistance, as required, by the HSE staff in Anchorage. Each report will be reviewed for: · Correct sample number and location · Correct analytical parameters · Values within acceptable ranges · Any reported QA/QC discrepancies · Forest may, at any time, conduct audits of contract laboratories as well as internal audits of field procedures. 6.0 Key DocumentslT ools/References ASTM Standards Online. http://www.astm.org/ u.s. Environmental Protection Agency (EPA). July 6, 1988. Regulatory Determination ofOi! and Gas and Geothermal Exploration, Development, and Production Waste. Federal Register Vol. 53 No. 129. u.s. EPA. October 2002. Exemption ofOi! and Gas Exploration and Production Wastes from Federal Hazardous Waste Regulations. EPA Publication EPA530-K-01-004. «( This is an update to EPA's "1995 Brown Book on Guidance to the oil Industry" ») http://www.epa.gov/epaoswer/other/oil/oil-gas.pdf u.s. EP A. December 2002. Guidance for Quality Assurance Project Plans (EP A QA/G5). EP A Publication EP A/240/R-02/009. http:/íwww.epa.gov/quaIity/qs-docs/g5-final.pdf u.s. EP A: Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. EP A Publication SW 846. http://www.epa.gov/epaoswer/hazwaste/test/main.htm 8/21 23 . . Page 24 of 51 WAP Revision Log - Changes to the Document 1. 2. 3. 8/21 24 Class I Disposal Wells Waste Analysis Plan Page 25 of 51 Exhibit 1 Waste Disposal Flow Schematic GAS OIL sALES ...J II ...1 ~* 5, .., 1 , CHEMICAL INJECTIDN <NOTE) . SALES GAS DIL PRCIDU.!ŒD ....ATER DlSP!:ISAL I I J I 1 f sTClRAGE TANKS , ---------------------------~ TRUCK OFf LOAlJINl; INJ PUMP . TRUCI< (]f'F LOADING INTtRMITTtNT SHUT IN STAND lIY .tIIIIEII. I. NlJRHAU. Y NIl i'UJ.... Print Date: 8/29/2007 Class I Disposal Wells Waste Analysis Plan CHEMICAL INJECTIDN SUBMERSIJILE PUMP DlL/VATER EMULSlm \/ELL WRKDVERS Exhibit 2 Waste Disposal Flow Schematic SE'iER PLANT ElTLUEMT SDLIDS IIISPOSAL PUMP iMiØ·· I I I I I I: ~I I I INTERMITTENT GAS I I I I I I I I HIGH PRESSURE PRIJIUCED VATER Ffllf NPlJES IIISCHARGE NC Þ4 NC . NPDES III$CHARGE (STAND BY) Page 26 of 51 . . .wIES. 1. NCRNALL Y NC FLD\{ KUSTATAN PReCESSING FACILITY Print Date: 8/29/2007 . . Exhibit 3 Cook Inlet Wastes Identified on Permit Application The following wastes were identified on the Forest VIC application as examples that constitute the majority of wastes that will be injected in the Class I wells. Waste General Description Acid Used widely as cleaning fluid in well work and chemical processes. Low pH. Usually exempt but may be considered hazardous if not from downhole. Boiler blowdown Fresh water used in boilers, typically to make steam for drilling rigs. It is collected water when the boiler is taken ~t of service. Caustic fluid A wide range of high-pH materials normally generated by cleaning operations, as off- specification chemical compounds, or as the result of chemical combinations. Cement and cement Variations of standard Portland cements, consisting of limestone, clay, and other rinsate additives (accelerators, retarders, fluid loss additives). Rinsate comes from cleaning tanks, pumps, and associated equipment. Clean-up fluids Predominantly water which has been contaminated in the process of washing down (washwaters) an area, engine, etc. Condensate Effluent from the normal process separation of oil, water, and gas. Collected from drain sumps, blow case discharge, and knockout pots. Crude oil Generated as waste from a well workover or from spills. A blend of many types of hydrocarbons with some impurities. May be contaminated with water. Diesel Diesel wastes may be generated as contaminated fuel, solvent, workover fluid, or freeze protection fluid. May be contaminated with small amounts of chemicals or water. Usually exempt but considered hazardous if not from downhole operations. Domestic waste Originally potable water; comes from the kitchen, showers, lavatories, laundry, water toilets, and any camp floor drains. See further comments below. Drilling muds, oil- Used for cooling and for the flushing of cuttings during well drilling. Typically a based. mixture of a hydrocarbon fluid (usually mineral oil or diesel), clay or asphalt, some Well flowbacks water, and dissolved chemicals, which enhance certain properties of the mud. The odor is characterized by the hydrocarbon fluid. Primarily from flowbacks on new wells and workovers. Drilling muds, water- Used for cooling, lubricating the drill bit, and flushing cuttings to the surface. based. Consists of water, clay (usually bentonite), and additives such as barium compounds Well flowbacks that enhance certain properties. Primarily from flowbacks on new wells and workovers. Glycol An alcohol that is widely used in circulating fluid systems to prevent freezing. May be contaminated with water, hydrocarbons, or solids. Also used for dehydration of natural gas. . . Waste General Description Laboratory waste Various chemicals, products, and contaminants that are non-hazardous Line Pigging Materials that have built up on the walls of crude oil pipelines and produced water or Material seawater pipelines. Normally pushed through the pipelines to the production onshore facilities and deposited in facility vessels, from which it is later removed as vessel sludge/sand. Occasionally pigging waste will be removed directly from pipelines. Can include crude, produced or seawater, biomass, paraffin, formation solids, calcium scale, and iron sulfide. Minor amounts of solids. Lubricating oils and Produced as wastes from engines and power transmission systems. Contain small hydraulic fluids amounts of metal and chemical additives to enhance their properties. Methanol Light alcohol used widely as a freeze prevention fluid. May be used in combination with other materials, such as glycol. Primarily from well flowbacks. Usually exempt but considered hazardous if not from downhole operations. Only exempt methanol will be injected for injection. Miscellaneous Includes seawater, rain, snowmelt, and fresh water which is not considered clean-up wastes fluid. May contain small amounts of contaminants. Natural gas liquids Petroleum products (propane, butane, etc.) which are disposed of as wastes when (NGLs) they become contaminated with water, solids or some other hydrocarbon. Ignitable. Produced water Brine produced from the oil reservpir during the oil recovery process, separated from the oil and gas during on board testing and sampling. Production Broad category that includes chemicals used in production or transportation of crude chemicals to achieve certain desirable effects. Examples include corrosion inhibitors, emulsion breakers, foam suppressants, and proprietary compounds used in drilling fluids, muds, and cleaning products. Only exempt or non-hazardous production chemicals will be accepted for injection. Radioactive tracer Fluid containing a low-level, short half-life radioactive substance used downhole for periodic mechanical integrity tests. This process is not considered disposal- it is part of the well operation. Solvents A wide range of products that may be contaminated with grease, solids, and/or water. All solvents must be carefully evaluated for disposal options - only those classified as non-hazardous will be accepted for disposal. Source water Cook Inlet seawater. Potentially used for making drilling mud and left over from EOR operations. Used as toilet flush water and for flushing disposal wells. Stimulation fluids Chemical compounds which are injected into producing or injection zones to enhance the productivity or injectivity of a well. May contain various chemicals to enhance its properties. Primarily from well flowbacks. Transformer oil Used as a non-conducting medium in electrical power transformers. Discarded when the equipment is abandoned. Vessel sludge/sand Fine solid particles from the oil producing formation, biomass, pipe scale. Can accumulate in test separators, tanks, production facility vessels, and heat exchangers. These solids are periodically removed and frequently hauled off; however, can be associated with crude oil, fresh or seawater, and production chemicals or solvents. Wastewater Opaque fluid with very low solids. The platform plant typically discharges with a treatment plant BOD of about 6 Mg/liter and a total suspended solids ranging from 2-30 Mg/liter, effluent average of 4 Mg/liter. . . Waste General Description Waste water Semi-solid residue from treating camp domestic wastewater. Not currently planned treatment plant for Class I disposal. sludge Workover fluids Wastes from the maintenance of a hydrocarbon production well. Predominantly water; may contain small amounts of chemicals, crude oil and minor solids. Also present during well flowbacks. Storm Water Rain collected in catchment basins and selected platform sumps. NORM Natural occurring radioactive material. A scale that deposits inside production lines and vessels. It has very low radioactivity and has been judged safe for handling. It is a Class II exempt waste. . . Exhibit 4 Cook Inlet Waste Streams Exempt Typical Main Constituents Potentially Hazardous Properties Wastes Exempt Sources or Constituents Exploration & Production (E&P) 1 · Primary drilling and production operations · Drilling rigs, well cellars, production lines & vessels Hydrocarbons, formation solids, returned drilling mud Note that exempt wastes may actually have hazardous properties or constituents, but they are not regulated as hazardous waste. Non-Exempt Typical Main Constituents Potentially Hazardous Properties Wastes Non-Exempt 3 Sources or Constituents Boiler blowdown · Rig or production facility boilers Water Typically non-hazardous; remote possibility of heavy metals Commercial product · Products left over, spilled, outdated, off- Varies Varies - check for listed wastes, specification, or no longer usable solvents, heavy metals. Cement · Drilling mud and additives that have not been rinsates, acids and caustics must be circulated downhole non-hazardous for pH (spot check · Gel, barite, calcium carbonate, polymers and neutralize as needed). Non- · Fresh or seawater rinsate with product residual exempt methanol or diesel not approved for disposal. Contained snowl · Outdoor containment around fuel and chemical Water, possible traces of Typically non-hazardous ponded water storage tanks hydrocarbon or chemicals if there · Depressions on or between skids, etc. have been spills Facility wash water · Internal or external washdown of skids, Water, possible traces of Typically non-hazardous; possibly modules hydrocarbon, chemicals, detergent benzene or flash point (from · Equipment cleaning (using non-hazardous hydrocarbons) detergents or degreasers) Glycol 1 heat · Vehicles, boats, & equipment (antifreeze) Glycol (MEG, DEG, TEG, Typically non-hazardous; remote exchange media propylene) possibility of heavy metals at specifically identified locations Hydrotest fluid · Pressure test of new or non-exempt process Water, glycol, possible product Typically non-hazardous unless (water or glycol lines, vessels residual in existing lines, traces of methanol or diesel are used only) · Non-exempt methanol or diesel must be chlorine or other biocide recovered for re-use, not disposal Photo processing · Spent developer solution from x-ray equipment Water Typically non-hazardous; silver fluid (corrosion tests, medical), after passing through removed and recovered silver recovery unit Sanitaryl domestic · Camp wastewater treatment plant(s) and site Water, soap residuals, human Typically non-hazardous wastewater enviro-vacs waste Spill clean-up · Fluids recovered from cleanup of non-exempt Water, snow, soil, with Depends on product spilled - spills hydrocarbon or chemical products benzene (diesel or gasoline spills), · Contaminated soil or snow flash point, listed constituents Sump fluids · Snowmelt and external dirt from equipment, Water, grit, possible traces of Typically non-hazardous as long as collected in floor drains hydrocarbon. sumps are properly managed. · Floor washings Process control is critical - · Incidental equipment leaks & spills hazardous wastes should never be dumped or drained to floor sumps. Tank cleaning 1 · Drum rinsinglcrushing Water, possible traces of Typically non-hazardous, subject to drum rinsate · Wash bay sumps hydrocarbons, chemical residues, fingerprint - flash point, pH, benzene, · Residues removed from RCRA-empty glycol, unused drilling products organic chlorides as necessary containers 2 Turbine wash water · Routine cleaning of turbine fins Water, detergent, sometimes Possible flash point (if methanol methanol used), cadmium or other metals Used oil · Motor oil Hydrocarbon Typically non-hazardous; possible · Transmission fluid flash point or organic chlorides from · Hydraulic oils solvent or fuel contamination. Usually recycled - not discarded. Other · Any waste not covered by another waste Varies Varies stream L Wastes ITom DOT-regulated pipelines are not RCRA E&P exempt. (See Section 5.1.5). · . 2. Residues removed from RCRA empty containers must be evaluated as non-exempt waste. They were previously considered RCRA exempt ((???». 3. Note that similar wastes may be RCRA exempt, depending on waste-generating process. . . Exhibit 5 Cook Inlet Class I Waste Sources Wastewater Treatment Plant Effluent (WWTP) Domestic Wastewater Production Facility Drilling and Wells Non-Exempt · Sanitary Wastewater (Toilets) Non-Exempt · Camp drains, showers, kitchen, etc. Normally an NPDES discharge RCRA Exempt (E&P) · Crude oil, gas, and produced water from separation process · Process fluids from integral facility piping and associated sumps RCRA Exempt (E&P) Returned muds, returned stimulation & workover fluids NO NO NO NO 2) Direct Injection at Wellhead Platform Structure Non-Exempt YES · Non-exempt spill cleanup WMRU Pad · Contained snow/ponded water · Stormwater Drilling and Wells Non-Exempt YES · Non-exempt products (unused, leftover, not returned from downhole) · Rig boiler blowdown Other Examples Non-Exempt YES · Decharacterized hazardous waste · Glycol/heat exchange media · Hydrotest fluids · Non-hazardous photo processing fluid · Source water «????».....??? · Sump fluids (Shop, top deck, etc) · Turbine wash water . . Exhibit 6 Analytical Requirements for Non-Exempt Waste Streams Parameter Initial Testing Fingerprine Acceptable Range (See Exhibit 6 for Methods) Requirement Appearance X Descriptive only - no pass/fail criteria pH X X 2<pH<12.5 Flash point X X >60°C (>140°F) Reactivity X Nonreactive TCLP Metals X See Exhibit 8 TCLP Volatiles X See Exhibit 8 TCLP Semi-Volatiles X See Exhibit 8 Benzene, Total or TCLp4 X < 0.5 (mg/I) Total Organic Chlorides5 X :::;1000 (ppm) Fingerprint semi-annually if waste is generated during that 6-month period. Environmental Advisor may approve reduced fingerprint frequency for established waste streams. Any solid sampJe that exceeds 10 mglL total benzene (20 times the TCLP limit of 0.5 mglL) must be re-analyzed by TCLP method. Required only for used oil that will be injected or recycled. . . Exhibit 7 Analytical Methods6 Analysis and Method7 Recommended Acceptable Range Alternative methods NOT permitted for Container Preservative Holding Time for Non-Hazardous parameters with asterisk (*) Material Ignitability (flash point) 250 ml glass, Chill to 4°C 7 Days Flash point> 140°F 1010A* (Pensky-Martens closed cup) Teflon-lined cap (60°C) 1020A* (Setaflash closed cup) Corrosivity (pH) 250ml None As soon as 2 < pH< 12.5 9040C* (Electronic meter8) polyethylene/glass possible9 90450* (Soil and waste pH) Reactivity Nonreactive Generator knowledge (See Exhibit 7B) Toxicity Characteristics Leaching See below See below See below See Exhibit 8 Procedure (TCLP) Extraction 1311* TCLP Metals Arsenic ......... 7060A/7061A. 1 ea. 1 L amber Acidify with 180 days except See Exhibit 8 Barium .......... 7080A/7081 glass, Teflon-lined HN03 to pH<2 mercury (28 days) Cadmium ...... 7130/7131A cap Lead.............. 7420/7421 Mercury.........7470A/7471A Selenium.......7740/7741A Silver............. 7760A/7761 Chromium .....7190/7191 TCLP Volatile Organics 40 ml VOA vials, Chill to 4°C 14 days See Exhibit 8 8260B or equivalent no headspace Benzene <0.5 mg/L Benzene onl/o: 8021 b, 8260B TCLP Semi-volatile Organics 1 ea. 1 L amber Chill to 4°C Extract w/in 7 days, See Exhibit 8 8270C glass, analyze w/in 40 Teflon-lined cap days of extraction Organic Chlorides 500 ml glass, Acidify with 28 days :5;1000 ppm EPA 8021B Teflon-lined cap HzSO 4 to pH<2 Chlor-in-oil test or equivalent 12 100 ml glass, Chill to 4°C Teflon cap Appearance (color, homogeneity, etc.) Clear container As soon as possible Visual observation against clear or white backQround NOTE: Contact laboratory for specific instructions. For routine fingerprints, the following containers are usually sufficient: · 1 ea. 500 ml glass wlTeflon-lined cap (pH, flash point, appearance) · (Additional 500 ml glass wlTeflon-lined cap if organic chlorides are analyzed) · 2 ea. 40 ml VOA vials (benzene) 10 Methods shown are promulgated as of the date of this document. All methods from SW-846 unless otherwise indicated. On July 14,2005, EPA promulgated the Methods Innovation Rule GQ..fR ;JA;;.;J~), h\tp.:l.Ó~}y'}y',.~P.,\.,gºY!'2ªQ~W,.r!hi!?}yª~te!te.§\!.mi.Lh.¡m), which deletes the requirement to use SW-846 test methods ITom the RCRA regulations, except for 27 method-defined parameters. Method-defined parameters in this table are indicated by the "*,, symbol. Note that pH indicator paper is NOT an approved method for RCRA determinations of corrosivity. In the fieJd, pH should be measured as soon as possible after the sample is collected. For samples analyzed by a commercial laboratory, the holding time is 24 hours following collection. Total benzene is appropriate for liquids that do not require TCLP extraction, and as a screening method for solids. Total benzene provides worst-case concentration. Any non-liquid sample that exceeds 0.5 mg/L total benzene must be re-analyzed by TCLP. Used as an indicator oflisted chlorinated solvent. The analytical method measures aromatic and halogenated volatiles by gas chromatography. Halogens are presumed to be chlorides. Field screening kit with appropriate sensitivity may be used. 11 12 . . Exhibit 8 Hazardous Waste Characteristics Ignitability Alcohol content of greater than 24 percent, or Flash point less than 140 degrees Fahrenheit (60 degrees Centigrade) Corrosivity pH less than or equal to 2 or greater than or equal to 12.5, or Corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.250 inch) per year at a test temperature of 55°C (130°F) Reactivity Normally unstable and readily undergoes violent change without detonating Reacts violently with water Forms potentially explosive mixtures with water When mixed with water, generates toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment Is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5 can generate toxic gases; Is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement Is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure; or Is a forbidden explosive as defined in 49 CFR 163.51, a Class A explosive as defined in 49 CFR 163.53, or a Class B explosive as defined in 49 CFR 163.88. Toxicity Contains any of the contaminants listed on Exhibit 2 above the indicated concentration . . Exhibit 9 Reactivity Checklist Initial Waste Characterization for Underground Injection in Class I well For the initial hazardous waste determination, a waste stream must be evaluated for the characteristic of reactivity. A waste is a reactive hazardous waste if it exhibits one or more of eight properties described below (40 CFR Section 261.23). EP A's Methods Innovation Rule! (6/14/05) withdraws various reactivity test methods from SW-846. Instead, "generators and other persons can use other appropriate methods or process knowledge in determining whether a particular waste is hazardous due to its reactivity". The checklist is to be completed by the waste generator and submitted to the ACS Environmental Specialist for review. A copy ofthis checklist should be filed with the analytical data for the waste stream. Description of Waste Source Generator (Print) Generator (Sign and Date) To the best of your knowledge, do any of the following criteria apply to this waste stream? YES NO 1. Normally unstable and readily undergoes violent change without detonating 2. Reacts violently with water 3. Forms potentially explosive mixtures with water 4. When mixed with water, generates toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment 5. Is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5 can aenerate toxic aases 6. Is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement (example: pressurized aerosol cans) 7. Is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure 8. Is a forbidden explosive as defined in 49 CFR 163.51, a Class A explosive as defined in 49 CFR 163.53, or a Class B explosive as defined in 49 CFR 163.88. . . Exhibit 10 Hazardous Waste Toxicity Characteristics As determined by Toxicity Characteristics Leaching Procedure (TCLP) Source: 40 CFR 261.24 Maximum Maximum Contaminant concentration Contaminant concentration (mg/L) (mg/L) TCLP Metals TCLP Semi-Volatiles Arsenic 5.0 o-Cresol 200.0* Barium 100.0 m, p-Cresol 200.0* Cadmium 1.0 m, p-Cresol 200.0* Chromium 5.0 Cresol (total) 200.0* Lead 5.0 2,4-Dinitrotoluene 0.13** Mercury 0.2 Hexachlorobenzene 0.13** Selenium 1.0 Hexachlorobutadiene 0.5 Silver 5.0 Hexachloroethane 3.0 Nitrobenzene 2.0 TCLP Volatiles Pentachlorophenol 100.0 Benzene 0.5 Pyridine 5.0** Carbon tetrachloride 0.5 2,4,5- Trichlorophenol 400.0 Chlorobenzene 100.0 2,4,6- Trichlorophenol 2.0 Chloroform 6.0 1,4-Dichlorobenzene 7.5 TCLP Pesticides/Herbicides*** 1,2-Dichloroethane 0.5 Chlordane 0.03 1,1-Dichloroethylene 0.7 2,4-0 10.0 Methyl ethyl ketone 200.0 Endrin 0.02 Tetrachloroethylene 0.7 Heptachlor 0.008 Trichloroethylene 0.5 Lindane 0.4 Vinyl chloride* 0.2 Methoxychlor 10.0 Toxaphene 0.5 2,4,5-TP (Silvex) 1.0 * If 0-, m-, and p-cresol concentrations cannot be differentiated, the total cresol concentration is used. Method quantitation limit is higher than regulatory limit. Use quantitation limit as maximum allowable level. Pesticides and herbicides are not used or expected to be present at Cook Inlet. No testing is required. ** *** . . Exhibit 11 Waste Manifest Form . . Forest Oil Class IJRecycle/EOR Manifest-AK Operations For Fluids Recycled, or Destined for Class I or EOR Injection 1. GENERATOR INFORMATION Field 1 I Owner I Date Asset Company Contact Rig 1 (Print Name) Location Time DAM D Phonel Cost Code I Activity Code I Pager Source 1 Well No. AFE 1 Approver ID 2. GENERATING ACTIVITY OR PROCESS 3. VOLUME (Estimate) 4. DESCRIPTION (Composition must equal 100% - use whole numbers) Crude Oil % Glycol % Fresh Water 1 Equipment Wash Water Produced Water % Acid % Seawater 1 Brine 1 KCI Drilling Mud % Line Pigging Material % Chemicals Cuttings % Diesel 1 Water Gel % Sump Fluid Cement 1 Contaminate % Scale 1 Corrosion Inhibitor % Snow Diesel % Boiler Blowdown % Soil 1 Sand Methanol % Used Oil % Domestic Wastewater (Describe) OTHER % % - Description Description % % - Description Description 5. REUSE / RECYCLE: Will the material be reused/recycled in an approved manner? D YES Select method at right and go to PART 8 D Water RecyclelEOR D NO GotoPART6 D Hydrocarbon Recycle D Other Beneficial Reuse (Describe) 6. WASTE CLASSIFICATION: Was the waste brought to the surface from downhole or used during direct production. D YES Go to PART 7 if Class I facility will be used D NO Go to PART 7 or contact Environmental 7. CLASS 1 DISPOSAL: Is the waste either non-exempt and non-hazardous (TESTING MAY BE REQillRED TO DET CALL ENVIRONMENTAL), or exempt from regulation as a hazardous waste (40 CFR 261.4)? D YES Indicate classification at right and Go to PART 9 D RCRA Exempt D Non-Exempt and No D NO----HAZARDOUS WASTE-Not approved for on-site disposal- contact Environmental, Go to PART 11 8. DESTINATION: EOR or RECYLED/REUSED FLUIDS (TESTING MAY BE RERQUlRED-CALL ENVIRONMEN RUD #6 D Other: WMRU # 2A D Go To PART 10 9. DESTINATION FOR CLASS I FLUIDS RUD #D1 D WMRU#4D D Go To PART 10 10. TEST DATA (IF REQillRED) BY RECEIVING FACILITY Flash point Degrees F Organic Chlorides (ppm) % Solids Testing Not Requ pH Units % Hydrocarbons % Water Go To PART Ij 11. GENERATOR Name Signature Location/Facility: (Print) Certificate: This consignment, to the best of my knowledge and belief, is accurately described Date above and I have applied the provisions of the Waste Analysis Plan/ Guide in making decisions concerning the reuse or disposal of this material. 12. TRANSPORTER Name Signature Company (Print) Vehicle Type (Truck, Boat, Helicopter, etc.) Date 13. RECEIVER Name Signature Offloaded at: (Print) Volume Received: Date Bbl Gal Cuyd n n Ii . . Forest MANIFEST INSTRUCTIONS This form is valid ONLY if it is signed by "certified" Generators, Transporters, and Receivers who have completed the Certification Training Program. Parts 1 through 10 are completed by the GENERATOR PART 1 GENERATOR INFORMATION: Fill in all sections legibly. PART 2 GENERATING ACTIYITY OR PROCESS: Clearly describe the activity or process that generated the material. PART 3 VOLUME: Estimate the quantity in barrels, gallons, or cubic yards. PART 4 DESCRIPTION: Estimate the percentage of all components, and be sure numbers add up to 100%. Use "trace" when percentage is significantly less than I %. (These percentages are only estimates, and should not be used in calculations to detennine RCRA compliance.) Do not use "Other" without providing a complete description. PART 5 REUSE/RECYCLE: Check with the HSE staff on recycle options if your particular activity is new. Environmental staff will review on a case-by-case basis. PART 6 CLASS II: Waste must be specifically listed for Class II disposal as shown in ...... ??.... Note Class II waste may also be sent to a Class I disposal facility providing it meets the facility's operating requirements. PART 7 CLASS I: Waste must be listed as RCRA-exempt or non-hazardous in ....??..... If not, it must be specifically approved by the HSE staff on the basis of testing or other information. You must check either RCRA-Exempt or Non-Exempt, Non-Hazardous in Part 7. PART 8 DESTINATION: Check the appropriate box or write the name of the facility where this load will be managed. Be sure to check ......... ??..... for site-specific restrictions and requirements. PART 9 SCREENING OR TEST DATA: Check with the facility in advance to find out if any special testing or screening is required. Provide results, or attach supporting data (lab results, MSDS, etc.) as instructed. PART 10 GENERATOR CERTIFICATION: Generators must read, sign, and date this section. PART 11 TRANSPORTER SECTION: By completing and signing this section, the Transporter certifies that he/she has picked up only the material described by the Generator and delivered it only to the designated facility. PART 12 RECEIVER SECTION: The Receiver must review the manifest for completeness, and verify that the Generator and Transporter are currently certified. Contact the Generator if there are any questions or discrepancies. Indicate the actual location where the material is offloaded, and the volume received. By signing this section, the Receiver acknowledges that the material, as described by the Generator, meets the criteria for acceptance at the facility. COMMENTS SECTION: To be used as required by Generator, Transporter, andlor Receiver. Cross-reference other manifest numbers here for "mixed loads". . . Appendix III. List of Approved Class I Waste Streams Waste General Description Acid Used widely as cleaning fluid in well work and chemical processes. Low pH. Usually exempt but may be considered hazardous if not from downhole. Boiler blowdown Fresh water used in boilers, typically to make steam for drilling rigs. It is collected water when the boiler is taken out of service. Caustic fluid A wide range of high-pH materials normally generated by cleaning operations, as off- specification chemical compounds, or as the result of chemical combinations. Cement and cement Variations of standard Portland cements, consisting of limestone, clay, and other rinsate additives (accelerators, retarders, fluid loss additives). Rinsate comes from cleaning tanks, pumps, and associated equipment. Clean-up fluids Predominantly water which has been contaminated in the process of washing down (washwaters) an area, engine, etc. Condensate Effluent from the normal process separation of oil, water, and gas. Collected from drain sumps, blow case discharge, and knockout pots. Crude oil Generated as waste from a well workover or from spills. A blend of many types of hydrocarbons with some impurities. May be contaminated with water. Diesel Diesel wastes may be generated as contaminated fuel, solvent, workover fluid, or freeze protection fluid. May be contaminated with small amounts of chemicals or water. Usually exempt but considered hazardous if not from downhole operations. Domestic waste Originally potable water; comes from the kitchen, showers, lavatories, laundry, water toilets, and any camp floor drains. See further comments below. Drilling muds, oil- Used for cooling and for the flushing of cuttings during well drilling. Typically a based. mixture of a hydrocarbon fluid (usually mineral oil or diesel), clay or asphalt, some Well flowbacks water, and dissolved chemicals, which enhance certain properties of the mud. The odor is characterized by the hydrocarbon fluid. Primarily from flowbacks on new wells and workovers. Drilling muds, water- Used for cooling, lubricating the drill bit, and flushing cuttings to the surface. based. Consists of water, clay (usually bentonite), and additives such as barium compounds Well flowbacks that enhance certain properties. Primarily from flowbacks on new wells and workovers. Glycol An alcohol that is widely used in circulating fluid systems to prevent freezing. May be contaminated with water, hydrocarbons, or solids. Also used for dehydration of natural gas. Laboratory waste Various chemicals, products, and contaminants that are non-hazardous Line Pigging Materials that have built up on the walls of crude oil pipelines and produced water or Material seawater pipelines. Normally pushed through the pipelines to the production onshore facilities and deposited in facility vessels, from which it is later removed as vessel sludge/sand. Occasionally pigging waste will be removed directly from pipelines. Can include crude, produced or seawater, biomass, paraffin, formation solids, calcium scale, and iron sulfide. Minor amounts of solids. Lubricating oils and Produced as wastes from engines and power transmission systems. Contain small hydraulic fluids amounts of metal and chemical additives to enhance their properties. . . Waste General Description Methanol Light alcohol used widely as a freeze prevention fluid. May be used in combination with other materials, such as glycol. Primarily from well flowbacks. Usually exempt but considered hazardous if not from downhole operations. Only exempt methanol will be injected for injection. Miscellaneous Includes seawater, rain, snowmelt, and fresh water which is not considered clean-up wastes fluid. May contain small amounts of contaminants. Natural gas liquids Petroleum products (propane, butane, etc.) which are disposed of as wastes when (NGLs) they become contaminated with water, solids or some other hydrocarbon. Ignitable. Produced water Brine produced from the oil reservoir during the oil recovery process, separated from the oil and gas during onboard testing and sampling. Production Broad category that includes chemicals used in production or transportation of crude chemicals to achieve certain desirable effects. Examples include corrosion inhibitors, emulsion breakers, foam suppressants, and proprietary compounds used in drilling fluids, muds, and cleaning products. Only exempt or non-hazardous production chemicals will be accepted for injection. Radioactive tracer Fluid containing a low-level, short half-life radioactive substance used downhole for periodic mechanical integrity tests. This process is not considered disposal - it is part of the well operation. Solvents A wide range of products that may be contaminated with grease, solids, and/or water. All solvents must be carefully evaluated for disposal options - only those classified as non-hazardous will be accepted for disposal. Source water Cook Inlet seawater. Potentially used for making drilling mud and left over from EOR operations. Used as toilet flush water and for flushing disposal wells. Stimulation fluids Chemical compounds which are injected into producing or injection zones to enhance the productivity or injectivity of a well. May contain various chemicals to enhance its properties. Primarily from well flowbacks. Transformer oil Used as a non-conducting medium in electrical power transformers. Discarded when the equipment is abandoned. Vessel sludge/sand Fine solid particles from the oil producing formation, biomass, pipe scale. Can accumulate in test separators, tanks, production facility vessels, and heat exchangers. These solids are periodically removed and frequently hauled off; however, can be associated with crude oil, fresh or seawater, and production chemicals or solvents. Wastewater Opaque fluid with very low solids. The platform plant typically discharges with a treatment plant BOD of about 6 Mg/liter and a total suspended solids ranging from 2-30 Mg/liter, effluent average of 4 Mg/liter. Waste water Semi-solid residue from treating camp domestic wastewater. Not currently planned treatment plant for Class I disposal. It sludge Workover fluids Wastes from the maintenance of a hydrocarbon production well. Predominantly water; may contain small amounts of chemicals, crude oil and minor solids. Also present during well flowbacks. Storm Water Rain collected in catchment basins and selected platform sumps. NORM Natural occurring radioactive material. A scale that deposits inside production lines and vessels. It has very low radioactivity and has been judged safe for handling. It is a Class II exempt waste. . . Appendix IV. UIC Compliance Matrix The following waste streams are approved for injection at the designated Class I and Class II wells Class II Wells Well Fluid RU #D1* WMRU 4D* RU #6 EOR" WMRU 2A EOR Class II Fluids Related to Osprey OK OK Only produced water Only produced water Class II Fluids from Any Facilily NO OK NO NO Class II Fluids from WMRU OK OK Only produced water Only produced water Class II Fluids from KPF OK OK NO Only produced water Class II Fluids from Exploration Well OK OK NO NO Sanitary waste from Osprey OK NO OK NO Gray Water from Osprey NO NO OK NO Deck Drainage from Osprey OK NO OK OK Produced Water from Redoubt OK OK OK OK Produced Water from WMRU OK OK OK OK Produced Water from West Forelan¡ OK OK OK OK 2° Containment Water-KPF NO Only if contaminated with OK OK Class II ?' Containment Water-WMRU NO Only if contaminated with OK OK Class II * These wells have been converted to Class I Wells (see below). Permitted injection wastestreams have been expanded to include those in the following tabl ** Must adhere to the EOR WAP found in Appendix V Class I Wells Fluid RU #D1*** WMRU 4D*** Any Exempt Fluid OK OK Non-hazardous Wastes listed in Exhibit 3 of the WAP (see Appenix OK OK II) . . Appendix V. Waste Analysis Plan for Osprey EOR Analysis Plan "Other" Injection Fluids RU#6 EOR Forest Oil-Osprey Platform 1/30/06 Purpose Forest Oil Corporation (Forest Oil) is permitted to inject produced water from the Hemlock Formation into well RU #6 for enhanced oil recovery (EOR) according to Enhanced Recovery Injection Order (ERO) No. 2, issued on August 26,2004. Subsequent to the issuance ofERO No.2, Forest Oil was issued administrative approvals ERO 2.001 and ERO 2.001A, which allow the use of "other" fluids for EOR operations in RU #6. As a condition for subsequent approvals, Forest Oil "must continue to collect and analyze representative samples of the mixed fluid stream at the Redoubt Unit injection manifold to demonstrate its non-hazardous characteristics and its continued suitability for EOR injection". This sampling plan was developed to satisfy that condition in ERO 2.001 and ERO 2.001A. Fluids ReQuirin2 Testin2 The "other" fluids permitted by ERO 2.001 and ERO 2.001A are: 1. treated sanitary waste from the Osprey 2. gray water from the Osprey 3. produced water from WMRU 4. storm water ITom secondary containment areas at KPF 5. storm water from secondary containment areas at WMRU 6. storm water from secondary containment areas on the Osprey Platform (deck drain fluids) ERO 2.001 and ERO 2.001A require analysis of the "mixed fluid stream". The wording is confusing because the largest volume of water being injected for EOR is Redoubt produced water. Produced water is exempt from RCRA hazardous waste regulations and not subject to RCRA testing. Likewise, produced water from WMRU is exempt ITom RCRA testing. In an e-mail on August 24, 2005, Mr. Jim Regg of AOGCC clarified that the intent ofERO 2.001 and ERO 2.001A was for Forest Oil to test only fluids that are not exempt from RCRA hazardous waste regulations. Accordingly, the only fluids that will be analyzed to satisfy the testing requirement ofERO 2.001 and ERO 2.001A are the following: · treated sanitary waste from the Osprey · gray water ITom the Osprey · storm water from secondary containment areas at KPF · storm water from secondary containment areas at WMRU · storm water from secondary containment areas on the Osprey Platform (deck drain fluids) . . Samplin2 Point (Osprev) Samples should be taken at a point at which as many of the streams as possible are commingled, exclusive of produced water. This would most likely be the manifold pump in the marine sanitatíon device room on the Osprey for 1) treated sanitary waste, 2) gray water and 3) storm water from secondary containment areas (deck drain fluids) on the Osprey. Storm water from secondary containment areas at KPF and WMRU will have to be sampled separately if, and when, necessary. General Approach: Analysis of the above fluíds will consist of testing for hazardous waste characteristics, using knowledge of the fluids, and fingerprint analyses. Testingfor Hazardous Waste Characteristics Initially, the above fluids will be analyzed for a full set of hazardous waste characteristics except for reactivity and herbicides/pesticides. Knowledge of the fluids indicates that it is extremely unlikely that either of these is present but the initial analyses will consist of the following: Characteristic Analysis Method Sample Location of Container Analysis Corrosivity pH pH meter NA Field Ignitabílity Flash Point SW1010 1 x40z Lab glass As SW 13111SW 6010 Ba SW 13111SW 6010 Cd SW13111SW601O 1 x 500 m1 Toxicity (TCLP) Cr SW13111SW601O HDPE, Lab Metals Pb SW13111SW601O unpreserved Se SW13111SW601O Ag SW13111SW601O Hg SW13111SW7470A Characteristic Analysis Method Sample Location of Container Analvsis 1,1- Dichloroethy1ene 1,2- Dichloroethane 1,4-Dichlorobenzene Methy1ethy1 ketone 3x40 m1 Toxicity (TCLP) Benzene septa vial, Volatiles Carbon tetrachloride SW1311/SW8260B unpreserved, Lab Chorobenzene no Chloroform headspace Tetrachloroethylene Trichloroethylene Vinyl chloride . . Characteristic Analysis Method Sample Location of Container Analvsis o-Creso1 Pyridine m-Creso1 u-Creso1 Total Cresol Toxicity (TCLP) Hexachloroethane 2 x 1 liter Nitrobenzene SW13111SW8270C amber glass, Lab Semivo1ati1es Hexach1orobutadiene unpreserved 2,4,6- Trich10rouhenol 2,4,5- Trich1orophenol 2,4- Dinitrotoluene Hexach10robenzene Pentachlorophenol Samples will be collected from the mixed fluids prior to injection at the manifold and commingling with produced water. After the initial analyses for hazardous waste characteristics, additional analyses for hazardous waste characteristics will be conducted only if knowledge of the source or constituents of the fluids becomes questionable or if fingerprint analyses (see below) indicate that the characteristics of the fluids have changed from those exhibited during initial testing. Knowledge of the Fluids Forest Oil will document the source of each of the fluids used for EaR. If the known source and constituents of the fluids changes or become questionable, hazardous waste testing for characteristics will be performed according to the suspected source ofthe alteration. Initially, as mentioned above, and in the future, unless knowledge of the fluids indicates otherwise, reactivity and herbicides/pesticides will not be analyzed. Fingerprint Analyses At the same time that the initial analysis for hazardous waste characteristics is conducted, the samples will be analyzed for fingerprint characteristics. The intent is to correlate the results of the analyses for hazardous waste characteristics with simpler and less expensive fingerprint characterization. Fingerprint analyses will then be conducted routinely in the future unless fingerprint characteristics of the combined fluid streams change. Changes in fingerprint characteristics, if they occur, will be treated as a presumptive change from the initial hazardous waste characteristics and as a possibility that the fluid may have become hazardous. In that case, a full analysis of the initial hazardous waste characterization would be conducted again to confirm that hazardous waste criteria had not been exceeded. . . Fingerprint analyses will consist of the following: Characteristic Analysis Method Sample Location of Container Analvsis Corrosivity pH pH meter NA Field Color Appearance Solids/Liquid Visual NA Field Phases/Homogeneity Sheen Gasoline Range 3 x 40 m1 AK10 septa vial, (including benzene) HCL 2 x 1liter Diesel Range AK102 amber Organics glass, HCL Lab 1 x 500 m1 Total Organic Chlorides glass, (Total Halogens as SW9020 preserved c Chloride) H2S04, 28 day holding Samplin2 FreQuenCV · Hazardous Waste Characteristics Full testing for hazardous waste characteristics will be done once initially, each time that fingerprint analyses demonstrate the characteristic of the fluid stream may have changed significantly, and each time a previously untested fluid stream is injected. · Fingerprint Analyses Fingerprint analyses will be done initially and then each quarter for the first year, each time that the characteristics of the fluid stream may have changed significantly, and each time a previously untested fluid stream is injected. After the first year, if no significant changes in the fluid stream are detected, fingerprint analyses will be performed semiannually at which time they will consist only of corrosivity and appearance. Replicate Samples and Volumes · Hazardous Waste Characteristics See tables above. · Fingerprint Analyses See tables above. Sample Containers · Hazardous Waste Characteristics See tables above. · Fingerprint Analyses See tables above. . . Holdin2 Times. · Hazardous Waste Characteristics Samples must be received by the laboratory within 2 days of collection. . Fingerprint Analyses Samples must be received by the laboratory within 2 days of collection. Shippin2 · Glass sample jars should be wrapped in bubblewrap, placed in a cooler with plenty of ice and a temperature blank, and shipped to Northern Test Laboratories with afully executed chain-ofcustody form. (Instructions for filling out COCs will be included with the bottle kit) Results · Results must be sent to the Forest Oil HSE Manager in Anchorage as soon as possible: HSE Manager Forest Oil Corporation 310 K Street Anchorage, AK 99501 . Hazardous Waste Characteristics The following limits on hazardous waste characteristics must not be exceeded: Characteristic Analysis Limit (in mg/L unless otherwise indicated) Corrosivitv pH >2.0 <12.5 units Ignitability Flash Point <140°F As 5.0 Ba 100.0 Cd 1.0 Toxicity (TCLP) Metals Cr 5.0 Pb 5.0 Se 1.0 Ag 5.0 Hg 0.2 1,1-Dich10roethv1ene 0.7 1,2-DicWoroethane 0.5 1,4-DicWorobenzene 7.5 Methy1ethyl ketone 200.0 Toxicity (TCLP) Volatile Benzene 0.5 Carbon tetrachloride 0.5 Organics Chorobenzene 100.0 Chloroform 6.0 Tetrachloroethylene 0.7 Trichloroethylene 0.5 Vinyl chloride 0.2 Characteristic Analysis Limit (in mglL unless otherwise indicated) Toxicity (TCLP) Semivo1ati1e pyridine 5.0 Organics o-Cresol 200.0 m-Creso1 200.0 p-Creso1 200.0 . . Total Cresol 200.0 Hexachloroethane 3.0 Nitrobenzene 2.0 Hexach10robutadiene 0.5 2,4,6- Trich10rophenol 2.0 2,4,5- Trich10ropheno1 400.0 2,4-Dinitroto1uene 0.13 Hexach10robenzene 0.13 PentachJorophenol 100.0 . Fingerprint Analyses The following limits on hazardous fingerprint analyses must not be exceeded: Characteristic Analysis Limit (in mg/L unless otherwise indicated) Acidity pH >2.0 <12.5 units Color No significant change Appearance Solids/Liquid No significant change Phases/Homogeneity Sheen None Gasoline Range No significant change Organics Benzene 0.5 Diesel Range No significant change Total Organic Chlorides 1000 . . SUMMARY SAMPLING SCHEDULE* Parameter Initial 3-06 6-06 9-06 12-06 3-07 6-07 9-07 12-07 Corrosivity X X X X X X X (pH) Ignitability X Toxicity Metals X Toxicity X Volatiles Toxicity X Semivo1ati1es Organics X X X X X Appearance X X X X X X X * Assumes no differences in results from one reporting period to the next, that no significant process changes have occurred, and that the operators have no knowledge of hazardous wastes being introduced to the injection system. . . FIELD REPORTING FORM Date: Sample Number (must track to number used for laboratory analysis) Sample Components (e.g. sanitary, gray water, deck drainage, or KPF Stormwater; etc.) Parameter Results pH units Color Solids (present/absent) Clarity ( clear/turbid) Phases (separate/combined) Sheen (present/absent) ~18 . . SARAH PALIN, GOVERNOR AItAtliliA OIL AND GAS CONSERVATION COMMISSION 333 W. 7th AVENUE, SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 August 21, 2007 Mr. Robert Elder HSE Manager Forest Oil Corporation 310 K Street, Suite 700 Anchorage, AK 99501 RE: AOGCC Order No. 46 Dear Mr. Elder: The Alaska Oil and Gas Conservation Commission ("AOGCC" or "Commission") has received the 6th Progress Review summarizing work accomplishments under the Decision and Order (AOGCC Order No. 46) issued for a misinjection involving Redoubt Unit Dl. Included with the 6th Progress Review was a draft Waste Management Plan prepared for Forest's Alaska operations dated June I, 2007. The Commission is satisfied with the work Forest has completed on all the corrective actions outlined in AOGCC Order No. 46 and considers this enforcement action closed. We would appreciate receiving a copy of the Waste Management Plan when Forest has finalized the document. By letter dated July 20, 2007 the Environmental Protection Agency granted authorization to Forest Oil Corporation for the commencement of Class I injection to the subsurface under UIC Permit AK-lI007-A using Redoubt Unit well DI (and West McArthur River Unit well 4D). Please note that conversion of these two wells to Class I disposal injection service requires the submittal of a subsequent report of sundry operations, Form 10-404, to the Commission for each well. ~17 @ . . ~ Reply To Attn Of: OCE-127 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue Seattle, Washington 98101 2 0 JUL 2007 RECEIVED CERTIFIED MAIL - RETURN RECEIPT REQUESTED JUL 3 0 2007 Alaska Oil & Gas Cons. Commissi Anchorage Mr. Robert Elder Forest Oil Corporation/FOREST Health, Safety and Environment Manager 310 K Street, Suite 700 Anchorage, Alaska 99501 Re: Final Approval to Inject into VIC Class I West MacArthur River Unit #4D Well and Redoubt Unit #Dl Well, EPA VIC Permit No. AK-1I007-A Dear Mr. Elder: The U.s. Environmental Protection Agency, Region 10 (EPA) has received a Standby Trust Agreement betweén Forest Oil Corporation and First National Bank Alaska. This agreement establishes a trust fund in the form of a surety performance bond to provide financial assurance for the plugging and abandonment of the two Class I non-hazardous injection wells WMRU 4D and RU D 1 permitted under EPA UIC Permit number AK 1I007-A plus two EPA Form 7520-9 completion forms. This permit became effective October 12, 2006 and will expire midnight, October 11,2016. EPA grants final approval to inject under EP A UIC Permit No. AK.-lI007 -A at FOREST WMRU 4D and RU D 1 Class I wells. This document authorizes the referenced facilities to inject to the subsurface as indicated in the permit. We appreciate the cooperation of your staff during the planning, permitting, testing, and operating phases of the well. Their cooperation, under harsh sensitive environments, is a good example of leadership for industries involved with environmentål management of waste in the exploration and production field. If you have any questions, or need additional clarification, please contact Thor Cutler of my staff at (206) 553-1673. sm~ A/~( Michael A. Bussell, Director Office of Compliance and Enforcement cc: Jim Regg, AOGCC, Anchorage Trevor Fairbanks, ADEC, Anchorage Sharmon Stambaugh, ADEC, Anchorage Thor Cutler, OCE, EP A, Seattle Anita Frankel, EP A, Seattle Marcia Combes, EP A, Anchorage o PrInted on RecyCled Paper -*16 . . @ FOREST OIL CORPORATION .)10 dJ?:~(ßef. 67:u:(ø 700 OY¡;lch",nr~fI~' OYÍla:5ko !J!J.5Û1 (907) 258-8ô{)0 · (907) 2iJ8-8ôOI (cJPa.,) July 13, 2007 REC ~\li=D ' ,,'i f;"<,,... .JUL ] 7 '7 Mr. Jim Regg Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 Alaska Oil & Gas Commission AnchQraae Re: 6th Progress Review AOGCC Decision and Order No. 46 Dear Mr. Regg: Forest Oil Corporation (Forest Oil) received Decision and Order No. 46, issued on February 16,2007, from AOGCC. The 5th progress review describing the corrective action that Forest Oil is taking in response to that Decision and Order was submitted to AOGCC on June 5, 2007. This is the 6th Progress Review. The status and timing of the corrective actions that Forest Oil is implementing are described below: 1) Injection guidelines. Forest Oil provided the Commission with injection guidelines in the form of a Compliance Matrix. Forest has already implemented the above guidelines. We assume the Commission approves the guidelines and, unless we hear otherwise, will also assume that this item has been satisfactorily completed. Additional injection guidelines. Forest Oil is has completed a comprehensive waste management plan that encompasses all aspects of waste management, including underground injection control. A copy of that plan is enclosed for your reVIew. 2) Training: All Forest Oil employees and contractors were trained in 2006 and 2007 on the compliance guidelines. The training will be continue to be conducted annually and expanded to include the new waste management manual. We consider this item complete. 3) Other: Forest Oil has received a Class I permit from EP A for the injection of non- hazardous wastes into RU Dl and WMRU #4D. Mechanical Integrity Testing and other testing required by the Class I permit was successfully completed on . . both wells and witnessed by EPA. The required testing on RU Dl was completed successfully on May 11,2007. The financial assuredness requirements have been completed. We are awaiting final authorization for injection from EPA. The conversion of both of these wells from Class II to Class I is expected to be completed by the end of July 2007. Forest Oil will notify AOGCC when the change occurs. Forest Oil believes all the requirements stipulated by AOGCC Decision and Order No. 46 have been satisfactorily completed and, unless the Commission informs us otherwise, we will consider this the last and final monthly report to AOGCC. We appreciate your cooperation on this matter and the assistance in bringing the matter to a successful conclusion. If you have questions or additional concerns please contact me at 868-2166 or at rge Ider(â),forestoil. com. Sincerely, ß~ Bob Elder HSE Manager Enclosure: Waste Management Plan · e FOREST OIL WASTE MANAGEMENT PLAN Alaska Operations 6/1/07 7/13/2007 · e Table of Contents Section Scope....................................................... ........................ ....... ..... Introduction........................................... ............... ......... ................ Regulatory. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . General Waste Management Guidelines. . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . .. . . . . . . . . . . . . . ... Waste Minimization. . .. . .. . .. . .. . .. . .. . .. . .. . .. ... . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. Labeling........... ........................... ...... ... ............ ...................... Storage and Segregation of Solid Waste............................................ Transportation of Solid Wastes......................... ............................. Summary Guidelines.................................................................. Available Recycle/Reuse/Waste Disposal/Storage Facilities.......................... Identification of Waste Streams and. ... .................................. ................ Environmental Standard Operating Procedures.. ........................... ........ ..... Training and Awareness. . .. . .. . .. .. . . .. . .. . .. . .. . . . . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .... Compliance Personnel................ ................................................ ....... Inspections and Audits. . . . . .. . .. . .. . .. . .. . .. . .. . .. . . . . . . . .. . . .. .. . .. . .. . .. . .. . .. .. . .. . . .. . .. Pa2e 3 3 4 4 4 5 5 6 6 7 8 9 9 10 10 APPENDICES Appendix I. Forest Oil Waste Manifest.. . .. .. .. .. .. . .. .. .. .... . .. . .. . .. .. .. .. .. .. . .. ... 12 Appendix II. Waste Analysis Plan for CLASS I wells................................ 13 Appendix III. List of Approved Class I Waste Streams.. .. . .. . .. . .. . .. .. .. .. .. .. .. .... 41 Appendix IV. UIC Compliance Matrix. . . . . . . . . . . . . . . . . .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . .... 44 Appendix V. Waste Analysis Plan for Osprey EO R. . .. . .. .. . . .. .. . . .. .. . . .. . .. . .. .... 45 2 7/13/2007 . e Forest Oil Waste Management Plan Alaska I. Scope. This Plan encompasses all waste management and associated activities conducted by Forest Oil Corporation (FST) in Alaska. It addresses the management of all solid wastes (under the RCRA definition of "solid waste" even liquid and gaseous wastes are considered solid waste) and the management of wastes injected into Class I and Class II underground injection control (UIC) wells. The plan does not address the management of emissions that are managed under air quality permits, or liquid discharges that are managed under federal (NPDES) permits or State wastewater discharge permits. II. Introduction. The Plan outlines the policies, procedures, guidelines, standard operating procedures and other system used for appropriately managing wastes generated during exploration and production. Management of wastes extends to all facets of waste handling including generation, storage, transportation, recycling and disposal. Forest Oil follows waste management procedures that are designed to assure compliance with Federal and state regulations and solid waste disposal and underground injection permits. To accomplish this objective, the Plan incorporates procedures to: · encourage the minimization of wastes and recycling of materials wherever possible, · reduce the possibility of uncontrolled releases of wastes to the environment and exposure of personnel to potential hazards associated with wastes, · eliminate unnecessary expense and liability associated with waste generation, storage, transportation and disposal, · ensure that wastes are stored, transported and disposed of properly. This Plan is composed of the following elements: · Regulatory · General Waste Management Guidelines o Waste minimization o Labeling o Storage and segregation of solid wastes o Transportation of solid wastes o Summary Guidelines · Recycle/Reuse/Waste Disposal/Storage Facilities · Identification of Waste Streams and Disposal Options · Standard Operating Procedures · Training and awareness · Compliance personnel · Inspections and audits 3 7/13/2007 . . III. Regulatory. Waste management at Forest's Alaska operated properties is impacted by several government agencies, including those at the federal, State and local levels. Examples include: · Federal o Pollution Prevention Act of 1990 o Resource Conservation and Recovery Act (RCRA) of 1976 o Hazardous and Solid Waste Amendments of 1984 o Safe Drinking Water Act (Underground Injection Control (UIC)) of 1974 o Area and Facility Permits · State o Solid Waste Management Regulations o Drinking Water Regulations o Underground Injection Control Regulations o Area and Facility Permits · Local o Kenai Peninsula Borough (Landfill) o Matanuska Susitna Borough (Landfill) o Municipality of Anchorage (Landfill and wastewater) o Area and Facility Permits IV. General Waste Management Guidelines. The following guidelines are designed to be general practices only for handing wastes and recyclable materials. They do not replace detailed procedures in place for individual and specific waste streams and recyclable materials. For detailed information on how to manage specific materials refer to Standard Operating Procedures and other plans and compliance tools found in the appendices to this document. In any and all cases, call Environmental for guidance if questions or confusion occur. Waste Minimization Declare nothing a waste until it has been determined that the material must be discarded. The following waste minimization procedures should be employed to reduce the amount of waste generated: · Prevention. Planning assures that only the amount of substances that are needed for a job are on-site thus reducing the amount of waste generated. All chemicals and other materials are, to the extent possible, must be entirely used for their intended purpose. Do not discard unused chemicals without notifying the Environmental Department. · Product Substitution. Wherever possible, materials with lower toxicities are substituted for others that would pose greater heath, safety and environmental risks. Avoid substances that would become hazardous wastes when discarded if other products are available. 4 7/13/2007 . . · Recycle and Beneficial Reuse. Wherever possible substance that would otherwise become wastes are recycled or used beneficially. Labelin2lManifestin2: · Labeling o All containers for wastes and recyclables must be labeled the appropriate label type, the name of the waste, the date it was first generated or placed in the container o Universal wastes must be labeled with the name of the contents (lamps, batteries, etc.) and the area where they are stored must be identified with a sign saying "Universal Waste Storage Area". o Containers of used oil must be labeled as "Used Oil". Do not deviate from these actual words. o Any hazardous waste container must be labeled "Hazardous Waste". Do not deviate from these actual words. o Dumpsters must be labeled with the actual contents. · Manifesting o All fluid wastes that are recycled or disposed of at Forest Oil operated facilities must be manifested from the point of generation to the site of disposition with the "Forest Oil Waste Manifest-Alaska Operations" (Appendix I). o All wastes being shipped off-site must be accompanied by an appropriate manifest. Ensure that the shipper has and uses appropriate manifests. Stora2e and Se2re2ation of Solid Wastes · Storage. FST's operations and contractors use the following types of waste storage facilities: o Temporary storage area for muds and cuttings (permitted) o Universal Waste Accumulation Areas (UAAs) o Dumpsters (NSB) · Metal · Oily Waste · Kitchen Waste · Trash · Segregation. The above storage areas are clearly marked and all FST and contractor personnel are instructed not to mix wastes, either between storage areas or between containers within each storage area. Personnel are also instructed not to mix wastes in transportation vehicles unless they are destined for disposal able at the same facility. 5 7/13/2007 . . Transportation of Solid Wastes . Transportation Companies. FST contracts with transportation companies that are familiar with and experienced at hauling Alaska waste loads. . Alaska Waste Manifest. The Forest Oil Manifest must be used for all waste fluids destined for disposal/recycle/beneficial reuse at facilities operated by Forest Oil. Summary Guidelines for Waste Mana2ement In general, the following guidelines should be followed when handling recyclables and waste: · Minimize the volume of waste whenever possible. This can be accomplished by insuring that all existing chemicals are completely used and that containers are completely empty (call Environmental for the definition of "empty") before being sent to waste disposal facilities. If possible, return all unused chemicals to the vendor for credit. · Recycle materials where possible. Many lubricants and other hydrocarbons (as long as they would otherwise be classified as hazardous waste) may be recycled into the production streams. · Never mix wastes unless authorized by Environmental. Wastes which may otherwise be recycled or disposed of as non-hazardous wastes are much more expensive to dispose of when mixed with hazardous wastes. · Wastes should be stored on pallets, within secondary containment, away from surface waters, and protected from accidental damage. Designated areas for all wastes at each facility should be identified and constructed as appropriate and with signs identifying what they are. · Keep labels on containers in good condition and with as much information on the contents as possible. Re-Iabel ifthey show signs of deterioration. · Seal or cap all containers tightly. Drums must have tightly fitting lids. · Transfer wastes from containers that are leaking or that show signs of deterioration into intact ones as soon as possible. · Never use "short-cuts" to expedite waste removal. If any questions arise, consult with Environmental immediately. · Manifests are required for all off-site shipments of waste and all wastes going to Class I injection: o When a waste is generated, immediately label the container and complete the manifest as fully and as accurately as possible. o Never deposit a waste at any facility without the approval ofthe foreman or lead operator at that facility and making sure that he/she signs the manifest upon receipt. o Never accept wastes without either initiating a manifest or completing the necessary information on a manifest already in existence. 6 7/13/2007 . . V. Available Recycle/Reuse/Waste Disposal/Storage Facilities · Federal o Pollution Prevention Act of 1990 o Resource Conservation and Recovery Act (RCRA) of 1976 o Hazardous and Solid Waste Amendments of 1984 o Safe Drinking Water Act (Underground Injection Control (UIC)) of 1974 o Area and Facility Permits Facilities Responsible Agency · Forest operated facilities in Alaska Temporary oily waste storage-WMRU ADEC Incinerator-WMRU EPA Class I Disposal wells EP A (Converted from Class II in 2007) (See App. II and III for required W AP and list of approved waste streams) WMRU 4D RUD#l Class II Disposal wells AOGCC (Converted to Class I in 2007) (See App. IV for UIC compliance matrix of approved waste streams) WMRU 4D RUD#l Class II EOR wells AOGCC (See App IV and V for UIC compliance matrix of approved EPR fluids and required W AP for RU #6) WMRU #2A RU#6 Universal waste storage areas-WMRU, KPF, Osprey EPA · In-State facilities Wastewater treatment, oily waste incineration, and landfill facilities owned and operated by Alaska Boroughs KPB. MSB Wastewater treatment. Municipalities Anchorage Recycle, non haz waste disposal. Emerald/AIM/Raven (Private) EPA, ADEC · Out-of-State Disposal (Private) EPA, ADEC FST has contracts in place with certified hazardous waste shippers and out-of-state deposal facilities. 7 7/13/2007 . . Identification of Waste Streams and Disposal Options Table 1 contains a list of potential waste streams which could be generated at Forest Oil- operated facilities and recommended management/disposal options. Table 1. Waste Management Options Forest Oil, Alaska Operations List of Wastes Management Options acids None. Call HSE if occurs. aerosol cans Use entire contents. Puncture in designated puncture drum. Recycle in metal dumpster. aluminum Soft trash dumpster. Ash, incinerator Soft trash dumpster but only after testing for HAWA characteristics caustics None. Call HSE if occurs. construction waste Bv proiect or metal/wood/soft trash dumpsters. contaminated soil chemical Call HSE. Lined mud boxes. Segregate by material. To Emerald or Qrind and inject if NOT HAZARDOUS. gasoline Call HSE. Segregate in lined mud box. Treat as Hazardous Waste. To Emerald/AIM/Raven. glycol Lined mud boxes. May commingle with oil contaminated soil. To Emerald or arind and iniect. Includes diesel, lube, and crude, hydraulic. Lined mud boxes. oil Segregate by material. To Emerald/AIM/Raven or grind and inject. e&p waste Class I or Class II injection. e-waste Send to Total Reclaim for recycle. filters Incinerator. glass Soft trash dumpster. glycol EG Do not use for freeze protection. Class I injection or to Emerald/AIM/Raven. Call Emerald/AIM/Raven to verify. TEG Do not use for freeze protection. Class I injection or to Emerald/AIM/Raven. Call Emerald/AIM/Raven to verify. Call Environmental. IF ALL CHEMICALS ARE ENTIRELY Hazardous Waste (HAZWA) USED AND USED PRO PERL Y HAZWA SHOULD NOT OCCUR hydrotest water Discharge to surface only after applying for permit (call Environmental) or Class I iniection kitchen wastes Incinerator. metal Metal dumpsters (rented)-Qoes to KPB landfill. paint Use all. paint cans Use all and to metal dumpster. plastics Incinerator or soft trash dumpster. rags/sorbents chem ical Call HSE ASAP to determine if Hazardous Waste and disposal options. gasoline Send out as Hazardous Waste-Benzene. 8 7/13/2007 . . oil/diesel/crude/lube/ hydraulic Incinerate. soft trash Incinerator or soft trash dumpsters and to KPB landfill if incinerator not workinQ. Use all. Keep out of sumps. Get rid of all chlorohydrocarbons solvents (e.g. Brakeclean, Lectraclean with 1,1,1, TCE, etc.). Review MSDSs. spilled chemical Call HSE ASAP to determine if Hazardous Waste and disposal options. universal waste batteries All (lead acid, nilcad, lithium, alkaline) to universal waste area in totes. Send to KPB landfill for recvcle. Hg switches None. light bulbs Everything but incandescent to universal waste area unbroken. Send to Total Reclaim. used oil Includes diesel, lube, crude, hydraulic. Recycle- test for haloQens Chi or-detect Kit. used PPE Incinerator. used/unused chemicals Use all. Don't leave anvthinQ unused. Otherwise call HSE. welding rods Metal dumpsters (rented)-Qoes to KPB landfill. wood waste Burn permit or wood dumDsters and to KPB landfill. Quantity of HAZWA /calendar month-must be kept under 100 kg/mo (220 Ibs/mo) Environmental Standard Operating Procedures (SOPs) and Plans The following SOPs are available to ensure that wastes are appropriately managed: · THIS PLAN · W AP for Class I wells · UIC Matrix · U sed Oil Management · Used Aerosol Can Management · Universal Waste Management · Incinerator Use · Vac Truck Use · Wildlife Deterrence Plan Personnel must familiarize themselves with these procedures prior to handling any materials addressed in the SOPs. Training! Awareness · Training. All FST and contract personnel responsible for waste management decisions on the Alaska are required to attend annual waste management training. · Safety Meetings. Regular safety meetings are conducted for all FST operations. Environmental subjects, including proper waste management, are included at those meetings. 9 7/13/2007 . . Compliance Personnel · Production Manager. In the event that waste management option/procedures are unclear, always ask the Production Manager for advice. · Health, Safety, Environment Manager. The HSE manager in Anchorage is available at all times to help with decisions on waste management issues that cannot be solved by the Production Manager. Inspections/Audits · Environmental Inspections. FST HSE personnel routinely inspect all facilities to identify and resolve potential waste management issue with field personnel. · Audits. Periodic EHS audits are conducted ofFST's operations by qualified personnel from the Corporate Office. 10 7/13/2007 . . APPENDICES 11 7/13/2007 . . Appendix 1. Forest Oil Waste Manifest Forest Oil Class IIRecycleÆO For Fluids Rec cIed or Destined 1. GENERATOR INFORMATION Field/ Asset Rig/ Facility Source / Well No. osition must e ual100% . use whole numbers) % % % % % % % % Gl col Acid Line Pi in Material Diesel/Water Gel Scale / Corrosion Inhibitor Boiler Blowdown Used Oil Check one: S. REUSE/RECYCLE: o YES Select method at DNO GOloPART6 % Solids % Water Signature Date Signature Type (Truck, Boat. Helicopter. elc.) Date 13. RECEIVER Signature Offloaded at: o BbJ 0 Gal Date o Cn d COMMENTS If this is a mixed load. cr(¡ss-r e (¡ther manifest numbers here: Form Revised 9/1 012005 ORIGINAL - Receiving Facility COPIES: Yellow· Generator Blue. - Transporter Pink. - Environmental, Anchorage 12 7/13/2007 . . Appendix II. Waste Analysis Plan for CLASS I wells Waste Analysis Plan Class I Disposal Wells Forest Oil Corporation Cook Inlet Alaska Fall 2006 CONTENTS 1.0 Purpose/Scope................................................................................................................................. ..14 1.1 Description of Facilities ...........................................................................................................14 1.2 Description of Cook Inlet Wastes ............................................................................................14 2. 0 Definitions ........................................................................................................................................ .15 3.0 Gener al Requirements .... ........................................................ ........................................................ .15 3.1 Contents ofW AP ...................... ...............................................................................................15 3.2 Criteria for Underground Injection ..........................................................................................16 4.0 Key Responsibilities........................................................................................................... ............. ..16 5. 0 Procedures....................................................................................................................................... ..17 5 .1 Waste Classification..... ...... ............... .............................................. ....................... ..... ............ .17 5.2 Analysis of RCRA-Exempt Wastes .........................................................................................18 5.3 Analysis of Non-Exempt Wastes .............................................................................................19 5.4 Mixed Wastes............ ........................................................................ .......................................20 5.5 Sampling Methods...................................................................... .............................................20 5.6 Sampling Frequency............................................................. .................................................. .21 5.7 Record Keeping and Documentation .......................................................................................21 5.8 Quality Assurance and Quality Contro1...................................................................................22 6.0 Key Documen ts/T oolsIRef erences ................................................................................................. ..11 Waste Analvsis Plan - Revisi 0 n Log........................................................................................................... 24 Exhibit 1 Waste Disposal Flow Schematic (WMRU).............................................................13 Exhibit 2 Waste Disposal Flow Schematic (Redoubt Platform)...............................................14 Exhibit 3 Wastes Identified in Permit Application ................................................................................27 Exhibit 4 Cook Inlet Waste Streams .......................................................................................................2 7 Exhibit 5 Cook Inlet Class I Waste Sources ...........................................................................................32 Exhibit 6 Analytical Requirements for N on-Exempt Waste Streams ..................................................33 Exhibit 7 Analytical Methods.................................................................................................................. 34 Exhibit 8 Hazardous Waste Characteristics ..........................................................................................35 E xhibi t 9 Reactivity Checklist ............................................................................................................ ..... 3 6 Exhibit 10 Hazardous Waste T oxicity Characteristics............................................................................3 7 Exhibit 11 Waste Manifest Form ..............................................................................................................38 13 7/13/2007 . . 1.0 Purpose/Scope This Waste Analysis Plan (W AP) outlines procedures for classifying, sampling, and analyzing wastes prior to disposal in the Forest Class I injection wells located in the Cook Inlet. Forest has prepared this W AP to fulfill the requirements of Section ----- of Underground Injection Control (DIe) Permit AK---------. 1.1 Description of Facility The two Class I disposal wells are located on the following oil production facilities: . West McArthur River Unit (WMRU) onshore production and processing pad. . Redoubt Platform, offshore West Foreland land fa11. Wastes are injected into the Tyonek Formation at a subsea depth of approximately 5200 feet at WMRU and at approximately 8200 feet at Redoubt. Exhibits 1 and 2 are simplified waste flow diagrams for these Cook Inlet facilities. A complete description of the disposal process is contained in Forest's UIC Permit Application of July 2006. 1.2 Description of Wastes 1.2.1 Waste Volume and Composition Several million barrels of waste could be injected in each Class I well over an anticipated 7-10 year life. Exhibit 3 lists the wastes that were described by Forest in the DlC permit application. About 98 percent of the total volume projected to be disposed of will be produced water or domestic wastewater as indicated below. One percent could be drilling related waste and 0.002 percent industrial non-hazardous waste. Waste Stream Composition (Projected) Component Produced water Camp wastewaters and storm water Well workovers and flowbacks Miscellaneous production wastes Drilling mud/slurry and flush (potential) Industrial non-hazardous wastes (Class I) Approx. % of Total 97 1 0.5 0.5 1 0.002 1.2.2 Waste Streams Primary oil and gas operations in general generate similar types of wastes. These can be grouped into broad categories, or "waste streams", that are reasonably consistent over time. Exhibit 4 lists typical waste streams on the North Slope of Alaska that analytical data have been collected on for several years to support injection of these streams at Class I facilities on the North Slope; which includes facilities at Northstar, Pad 3, Badami, and Alpine. These streams are applicable to the similar Cook Inlet facilities. 1.2.3 Cook Inlet Waste Sources Exhibit 5 lists the primary sources of Class I wastes at the Forest facilities in Alaska. Wastes enter the Class I disposal streams by two routes. 1) Hardlined from Production Facility. Most major fluids are hard-lined to the disposal wells from the production and drilling facilities and include the following sources. 14 7/13/2007 . . . Produced water for disposal. . Treated sanitary wastewater, domestic waste, and deck drainage from the platform wastewater treatment plant. The WMRU plant may not be hard piped as it is planned to be an intermittent standby alternative. 2) Batch Injection at Wellhead. "Batch wastes" are generated by intermittent processes that are not permanently connected to the injection well. These wastes are either injected directly at the well through temporary hookups or into feed tanks through temporary hookups. 1.2.4 Waste Ownership Forest assumes ownership of all wastes generated on the Redoubt platform and at the several onshore pads on the West Forelands operated by Forest staff or by contractors under Forest's supervision. Wastes generated outside of the Forest production, processing, or exploration facilities, or wastes generated by non-Forest activities, are considered Non-Unit or Third Party wastes. On a case-by-case basis, Forest will evaluate Non-Unit or Third Party wastes for injection at the injection site. As directed by the Forest Environmental Manager, the Non-Unit or Third Party generator must provide information needed to characterize the waste. 2.0 Definitions Class I: Class I disposal wells inject wastes below the deepest underground source of drinking water (USDW). They are subdivided into industrial and municipal categories based on their ownership, and into hazardous and non-hazardous based on the nature of the injected waste. The Forest wells are industrial, non-hazardous Class I wells. There are no USDWs in the disposal and confining zones and the overlying aquifers are generally exempted as a source for public water supply because of the high salinity. VIC: Underground Injection Control. A program authorized by the Safe Drinking Water Act to protect USDWs by regulating the disposal of waste fluids through underground injection wells. Regulations are published in Title 40 of the Code of Federal Regulations, primarily in Parts 144 through 146. 3.0 General Requirements The Environmental Protection Agency (EP A) regulates the construction and operation of the Forest Class I disposal wells through Underground Injection Control (DIC) Permit AK--------. (The Alaska Department of Environmental Conservation (ADEC) is also involved through a General Wastewater Disposal Permit 2005DB0001 generated through provisions of Alaska statutes 46.03). These permits are posted at each facility and are also available electronically. 3.1 Contents of the WAP Section ----- of the EP A permit requires a plan for obtaining "detailed chemical and physical analysis of representative samples of the injected wastes which includes the following: 1) The parameters for which the waste will be analyzed and the rationale for the selection of these parameters; 2) The test methods that will be used to test for these parameters; and 3) The sampling method that will be used to obtain a representative sample of the waste to be analyzed." Waste streams that are hard-piped continuously from the production facilities to the wellhead require "such sampling and testing as may be necessary to provide a description of the nature and composition of all 15 7/13/2007 . . injected fluids, and to support any statements that the waste is exempt from regulation as hazardous waste as defIned by 50 CFR 261.4". 3.2 Criteria for Underground Injection Wastes must meet the following criteria for underground injection. 1) The waste is included in the Forest Class I permit application (see W AP Exhibit 3). Note that this list includes broad categories that encompass virtually all waste streams anticipated. Any waste that is not on this list requires approval from a Forest Environmental Manager or Advisor. 2) The waste is classifIed as non-hazardous or exempt from hazardous waste management regulations under the Resource Conservation and Recovery Act (RCRA). (See W AP Section 2). 3) The waste meets the injection facility's safety and operational criteria. 4) Disposal is properly documented (see W AP Section 5). 4.0 Key Responsibilities Forest Oil Health, Safety and Environment Manager, or Designee · Supervises the collection of samples and coordinates analysis as specifIed in Section 5 of the WAP. · Makes hazardous waste determinations using laboratory data and/or generator knowledge. In making these determinations, consults with the Environmental Manager and/or a UIC Class I/Class II Regulatory ClassifIcations Technical Authority (TA) as needed. · Periodically reviews manifests and waste analysis records. · Maintains waste analysis records as specifIed in Section 5 of the W AP. · Submits W AP initially to EP A and makes subsequent revisions available to EP A. · Reviews W AP and related documents for technical accuracy. · Coordinates updates to W AP and related documents · Obtains ADEC General Disposal Permit 2005DB0001 as required by State of Alaska regulation. · Provides regulatory guidance relating to waste classifIcation and management options. · Provides regulatory guidance related to waste classifIcation and management options. 16 7/13/2007 . . 5.0 Procedures Wastes are evaluated for injection in the Class I disposal wells according to the following procedures. 5.1 Waste Classification Wastes injected in the Class I wells must be classified as non-hazardous or exempt from regulation as hazardous waste under the Resource Conservation and Recovery Act (RCRA), Subtitle C. A hazardous waste determination must be made before wastes are introduced into the disposal system if it is not an exempt waste. Hazardous waste determinations are made primarily by the Environmental Specialist and/or Environmental Compliance Manager. 5.1.1 Hazardous Wastes A waste is considered hazardous under RCRA if it is listed in 40 CFR(I) 261, Subpart D, or if it displays any of the characteristics described in 40 CFR 261, Subpart C. Hazardous waste characteristics, outlined in Exhibit 8, include ignitability, corrosivity, reactivity, and toxicity. Toxicity is measured by the Toxicity Characteristic Leaching Procedure (TCLP). Thresholds for regulation due to toxicity are summarized in Exhibit 9. 5.1.2 Decharacterized Hazardous Wastes Decharacterized hazardous waste may be approved for direct iniection at the wellhead if it no longer displays a hazardous characteristic at the point of injection. Examples of hazardous wastes that could potentially be decharacterized include: · Turbine wash water (cadmium, flash point) · Glycol (selenium, other contaminants) · Acids, bases ( corrosive) 5.1.3 RCRA-Exempt Wastes Some broad categories of wastes are excluded from strict management under RCRA. In most cases, the exemption is based on the process that generates the waste, not on its actual composition or properties. Exempt wastes must still be managed properly, but they are not subject to RCRA's full storage, documentation, transportation, and disposal restrictions. Important exemptions applicable to Cook Inlet include: . RCRA Exploration and Production (E&P) Exemption The RCRA E&P exemption applies to certain wastes associated with oil and gas exploration and production. Exhibit 4 lists examples of Cook Inlet wastes covered by the RCRA E&P exemption, and numerous non-exempt wastes. Additional guidance may be found in the references cited in Section 6. . Empty Container Exemption Residues remaining in containers are not regulated as hazardous waste if the container is empty as defined by 40 CFR 261.7(b): 1) All wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container, e.g., pouring, pumping, and aspirating; and 2) No more than 2.5 centimeters (one inch) of residue remain on the bottom ofthe container or inner liner; or (I) Code of Federal Regulations 17 7/13/2007 . . 1. No more than 3 percent by weight of the total capacity of the container remains in the container or inner liner if the container is less than or equal to 110 gallons in size; or 11. No more than 0.3 percent by weight of the total capacity of the container remains in the container or inner liner if the container is greater than 110 gallons in size. NOTE: The waste is exempt when it remains in an empty container, but when it is removed from the empty container by rinsing, EP A considers it to be a new waste (no longer exempt). A hazardous waste determination must be made to determine whether or not the removed rinsate is hazardous. If the container has held an acutely hazardous waste, it is considered empty if the container has been triple-rinsed with an effective solvent, or the inner liner (if present) has been removed. The initial rinsates and/or inner liner must be managed as hazardous waste. 5.1.4 Non-Exempt Wastes Exhibit 5 lists several Cook Inlet wastes that are not RCRA-exempt. The exemption does not apply to products that have not actually been used for their intended purpose in exploration or production. Wastes are generally not RCRA E&P exempt if they have not been brought to the surface during oil and gas operations or have not come into direct contact with the production stream. Wastes generated by the wastewater treatment plants and other support operations, such as facility and vehicle/boat maintenance, are typically RCRA non-exempt. 5.1.5 Non-Exempt Sales Pipeline Wastes Wastes recovered from DOT regulated Cook Inlet crude oil and gas transportation pipelines must be evaluated as non-exempt wastes since the RCRA E&P exemption includes only production process facilities and associated offshore and on shore gathering lines. For the oil stream going to Cook Inlet Pipeline, the exemption ends at the point of custody transfer which is the Cook Inlet LATC meter. For the gas sales line going to Marathon, the exemption ends at the point of custody transfer at meter # 6106. The Redoubt platform fuel gas line is supplied by gas routed directly from the onshore processing equipment; therefore, liquids, gas, and residues in this line are exempt. 5.1.6 Consequences of Mixing Wastes Mixture rules are complicated, and should be used with caution. For guidance, consult the references provided in Section 6 and the regulations cited below. Three conservative mixture rules are: 1) Hazardous waste + non-hazardous waste = hazardous waste (40 CFR 261.3(a)(2) 2) Non-hazardous/non-exempt waste + exempt waste = exempt waste (U.S. EP A, 1995) 3) Hazardous waste + exempt waste = hazardous waste (40 CFR 261.3 (a)(2)(iii) Wastes must be classified before they are conuning1ed with other materials in sumps, pits, or containers. 5.2 Analysis of RCRA-Exempt Wastes RCRA exempt waste streams (Exhibit 4) are approved for injection without prior sampling and analysis, providing the activity is clearly identified as generating exempt wastes. The same material, generated by a non-exempt process, may be regulated as hazardous waste. All processes and facilities are subject to audit by the HSE staff to verify that waste-generating activities are accurately described as RCRA-exempt. (Note that wastes generated from the transportation of crude oil and gas are not RCRA-exempt ). Exempt wastes may actually have properties that make them dangerous to handle. Therefore, they must meet all applicable safety, compatibility, and operational restrictions at the injection well. 18 7/13/2007 . . 5.3 Analysis of Non-Exempt Wastes Non-exempt wastes must undergo a hazardous waste determination before they enter the disposal system. 5.3.1 Characterization Without Analysis Sampling is not always necessary to characterize a waste. . Commercial Chemical Products Conunercia1 chemical products can sometimes be adequately characterized by generator knowledge in accordance with 40 CFR 262. 11 (c)(2). Generator knowledge may be based on a Materials Safety Data Sheet (MSDS) or other applicable data. Before sending the material to the injection well, the generator should provide a copy of the MSDS (or other data) to the Environmental Specialist for review. «(Does Forest maintain a computerized MSDS database for products used in Cook In1et»( MSDSs can also be obtained from the product manufacturer, or the contractor providing the material. If the MSDS for a product clearly indicates that it is not RCRA hazardous when discarded, and it has not been mixed with any unknown material, the waste will generally be approved for injection without further analysis. Generator knowledge is also sufficient to characterize seawater or fresh water that has not been mixed with anything else. . Existing Analytical Data Wastes submitted under an approved, "current" waste stream (see following section) do not have to be analyzed on a 10ad-by-10ad basis. At the discretion of the Environmental Specialist, analytical data from other locations may be used to characterize a conunon, recurring waste stream. 5.3.2 Characterization by Analysis Sampling and laboratory analysis are required for any non-exempt waste that either (a) does not fit into a current, established waste stream, or (b) cannot be characterized by generator knowledge to the satisfaction of the Environmental Specialist, in consultation with the Environmental Manager. Non-exempt waste streams must be sampled and analyzed as indicated on Exhibit 6. Non-exempt wastes will be evaluated as follows. 1) Initial characterization. A representative sample of the waste will be collected by the Environmental Specialist or a professional person under the Specialists supervision, and it will be sent to a conunercia11aboratory for full hazardous waste characterization. Analytical parameters are listed on Exhibit 6. Methods, sample containers, and holding times are summarized on Exhibit 7. Results will be compared to the hazardous waste characteristic limits in Exhibits 8 and 9. See Exhibit 9 for special instructions on the characteristic of reactivity. . More than one sample may be necessary to characterize the waste stream, particularly if there are several different sources. Waste streams should be re-samp1ed if the waste- generating process changes over time. . Waste streams that were analyzed before the Class I wells were conunissioned do not have to be re-tested if there is reasonable assurance that: a) The sample (as collected) is representative of the current process. Database is currently accessible on the Forest Intranet Site. ???????? 19 7/13/2007 . . b) The sampling procedures and analytical methods were consistent with those described in this W AP. . Once initial profiling is complete, testing requirements can be reduced for subsequent loads of the same waste. As long as the waste stream remains consistent, testing will consist of periodic fingerprint analysis as indicated on Exhibit 6. 2) Fine:erprintine:. "Fingerprinting" involves testing a sample for a few indicator parameters to confirm that the waste stream remains non-hazardous over time. Fingerprinting focuses on the most likely hazardous characteristics, based on generator knowledge and previous analytical results. Fingerprint parameters and acceptable ranges are indicated on Exhibit 6. Some fmgerprint tests can be done on-site using field test kits. . Any waste that "fails" a fmgerprint test should be sampled and sent to a laboratory for complete characterization. 3) Spot-checks. Any waste load is subject to spot-checks at the discretion ofthe Environmental Specialist. Spot-checks may consist of selected fingerprint parameters (such as pH or flash point), or full analysis. 5.4 Mixed Wastes Mixtures of exempt and non-exempt wastes should not be sampled or analyzed. Many exempt wastes have characteristics that would actually "fail" RCRA analysis, and their presence in the mixture would produce meaningless and misleading results. Mixing wastes of different classifications is generally discouraged unless the non-exempt waste has been adequately characterized before mixing. 5.5 Sampling Methods Samples for waste characterization or fingerprinting will be collected or supervised by the Environmental Specialist, commercial laboratory personnel, or other qualified individuals. In most cases, these will be grab samples taken directly from the waste container. Wastes from different sources should always be segregated until sample results are received. 5.5.1 Containers Exhibit 7 shows the minimum sample volumes and container types required for various analyses. Pre- cleaned containers should be obtained from the analytical lab or a reputable supplier of laboratory goods. Disposable containers should not be re-used. 5.5.2 Representative Samples and Composites For initial characterization, waste stream samples from different locations should not be combined for testing unless the waste-generating processes are virtually identical. Each source should be analyzed separately to establish a "track record". This is especially true for waste streams such as sump fluids, facility wash waters, and lubrication oils and glycols, which may come from several different locations. For fingerprint analysis of established waste streams, composite samples from several sources are acceptable, providing all wastes are derived from the same process. Waste should be visually examined, if possible, before sampling. If it appears homogeneous, a composite sample may be taken. If the waste appears stratified or contains more than one phase (sludge plus liquid, for instance), each layer or phase should be sampled and analyzed separately. The approximate volume of each phase should be estimated. Different phases may be combined into a single composite if (1) the phases cannot or will not be separated for disposal and (2) samples from each phase are combined in 20 7/13/2007 . . proportion to their estimated volume in the container. (Note that if one phase proves hazardous and the other does not, the entire container must be handled as a hazardous waste.) If a composite sample shows any RCRA hazardous waste characteristics, individual containers must be analyzed to isolate the source of hazardous waste. If there are measurable levels of toxic components (Exhibit 10) in the composite, the TCLP concentration must be multiplied by the number of samples in the composite. If this level exceeds RCRA limits (Exhibit 10), the individual containers must be evaluated to isolate the hazardous material; otherwise, the entire batch is a hazardous waste. 5.5.3 Sampling Tools Various sampling tools are available. For fluids in drums or relatively shallow sumps, a coliwasa or "drum thief' may be most effective. For larger containers, such as boat tanks, tiger tanks, etc., fluid may be pumped or siphoned through clean tubing into a sample container. It may be necessary to improvise equipment for a particular situation. Sludges or solids may be sampled with clean hand tools or coring devices (such as clean PVC tubing). 5.5.4 Analytical Methods Analytical parameters are listed on Exhibit 6. Methods, sample containers, and holding times are summarized on Exhibit 7. 5.6 Sampling Frequency 5.6.1 Exempt Waste Streams Exempt waste streams are not sampled. However, the Environmental Specialist in consultation with the Environmental Manager will conduct periodic process reviews to ensure that wastes have been properly characterized· as RCRA-exempt. 5.6.2 Non-Exempt Waste Streams After the initial characterization, waste streams will be fingerprinted semi-annually. The Environmental Supervisor may approve reduced sampling frequency for established waste streams that have been consistently non-hazardous over time. If a waste stream has not been generated during a semi-annual period, no fingerprint is required until the next semi-annual period in which the waste is actually generated. Generator knowledge and/or manufacturer's data may be substituted for laboratory analysis as appropriate. 5.7 Record Keeping and Documentation According to Forest UIC Permit Section ------, Forest must keep records concerning the nature and composition of all injected fluids until three years after the well is plugged and abandoned. Manifests and analytical records should be kept on-site at the appropriate Cook Inlet facility for at least three years; then they may be forwarded to the central compliance files in Anchorage. 5.7.1 Manifests A Manifest (Exhibit 11) is required of all batch loads injected directly at the wellhead. The designated receiver is responsible for keeping the signed copy of the manifest and for filing as directed by the Environmental Specialist. The manifests will be periodically reviewed by the Environmental Department and may be required for EP A quarterly reports, audits, or other purposes. 21 7/13/2007 . . 5.7.2 Analytical Data Records of analytical data must include: 1) The date, exact place, and time of sampling or measurements 2) The name(s) of the individua1(s) who performed the sampling or measurements 3) The date(s) analyses were performed 4) The name(s) of the individua1(s) who performed the analyses 5) The analytical techniques or methods used; and 6) The results of such analyses 5.8 Quality Assurance and Quality Control The following Quality Assurance/Quality Control (QA/Qc) requirements are consistent with EP A's Guidelines for Quality Assurance Project Plans (see Section 6 ofW AP for complete citation). 5.8.1 Field QAlQC Sample Handling and Custody Procedures Sampling procedures are outlined in Section 5.5. For each analytical method, the appropriate containers, preservation methods, and holding times are outlined in Exhibit 7. Before collecting or sending any samples, field personnel should always contact the receiving laboratory to confirm procedures and to make the necessary logistical arrangements. The laboratory will indicate whether trip blanks are required. Each container will be labeled with the sample number, date and time sampled, sampler's initials, and required analyses. A Chain-of-Custody form will accompany each sample, and will be verified and signed by each person handling the sample until its [mal disposition. Quality Control Samples QA/QC for any analyses performed on site will include, at a minimum: · Equipment calibration according to manufacturer's instructions · Periodic duplicate testing to verify consistency The Environmental Specialist should keep a file of calibration records and any duplicate testing performed on-site. Training An appropriate level of training will be provided for all personnel involved with waste generation, transportation, and disposal. «(What about personnel at other facilities such as the east side warehousing and docks 71?») Training records will be maintained by the Training Department and/or by the contract employee's company. 5.8.2 Laboratory QAlQC Conunercial1aboratories are expected to maintain QA/QC plans, which will be provided to Forest upon request. Laboratories may be asked to provide the following QA/QC documentation along with sample results. · Method blank 22 7/13/2007 . . · Surrogate recovery (if applicable) · Matrix spike and matrix spike duplicate results (if applicable) · Duplicate results Laboratory reports will be reviewed by the Environmental Specialist with assistance, as required, by the HSE staff in Anchorage. Each report will be reviewed for: · Correct sample number and location · Correct analytical parameters · Values within acceptable ranges · Any reported QA/QC discrepancies · Forest may, at any time, conduct audits of contract laboratories as well as internal audits of field procedures. 6.0 Key Documents/Tools/References ASTM Standards Online. http://www.astm.org/ U.S. Environmental Protection Agency (EP A). July 6, 1988. Regulatory Determination of Oil and Gas and Geothermal Exploration, Development, and Production Waste. Federal Register Vol. 53 No. 129. U. S. EP A. October 2002. Exemption of Oil and Gas Exploration and Production Wastes from Federal Hazardous Waste Regulations. EP A Publication EP A530-K-01-004. «( This is an update to EPA's "1995 Brown Book on Guidance to the oil Industry" ») http://www.epa.gov/epaoswer/other/oil/oi1-gas.pdf U.S. EP A. December 2002. Guidance for Quality Assurance Project Plans (EP A QA/G5). EP A Publication EP A/240/R-02/009. http://www.epa.gov/qualitv/qs-docs/g5-final.pdf U.S. EP A: Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. EP A Publication SW 846. http://www.epa.gov/epaoswer/hazwaste/test/main.htm 23 7/13/2007 . . WAP Revision Log - Changes to the Document 1. 2. 3. 24 7/13/2007 Class I Disposal Wells Waste Analysis Plan Exhibit 1 Waste Disposal Flow Schematic ..I "'I ~I :* 21 1 1 1 (NOTE I) CHEMICAL INJECTION GAS SALES GAS OIL OIL SALES I I I I I T PRODUICED \lATER DISPOSAL STORAGE TANKS SlOP OIL TANKS ~___________________________J TRUCK OFf" LOADING \lELL IIIJRKOVERS MP STAND BY SHUT IN Page 25 of 52 e INJECTION PUMP e TRUCK OFF lOADING \lMRU 4- D CLASS I DISPOSAL \lELL WIEi I. NDRMALL Y NO FLO\l Print Date: 7/13/2007 Class I Disposal Wells Waste Analysis Plan CHEMICAL INJECTION SUBMERSIBLE PUMP OIL/\fATER EMULSION \fELL \fORKOVERS Exhibit 2 Waste Disposal Flow Schematic SE\fER PLANT E"LUENT SOLIDS DISPOSAL iiiN "~!i" ;" .~ ...........,c.· .;..'..'...'...'...'...'...'...'...'...'...'...'...'...,...;l!I;.;;;:;¡...,...... NC I I I I I I ~I 5' "-, vI I I I I I I I HIGH PRESSURE PRODUCED \fATER I I Þ<1 NC INTERMITTENT GAS Ef'dïUENT f...~~E INJE PUMP Page 26 of 52 NPDES DISCHARGE . NPDES DISCHARGE (STAND BY) KUSTATAN PROCESSING , ACILITY . PUNP STAND BY . RUD-I CLASS I DISPOSAL \fELL ~ I. NORMALLY NO ,LOIol Print Date: 7/13/2007 . Class I Disposal W ells Waste Analysis Plan . Exhibit 3 Cook Inlet Wastes Identified on Permit Application The following wastes were identified on the Forest VIC application as examples that constitute the majority of wastes that will be injected in the Class I wells. Waste General Description Acid Used widely as cleaning fluid in well work and chemical processes. Low pH. Usually exempt but may be considered hazardous if not from downhole. Boiler blowdown Fresh water used in boilers, typically to make steam for drilling rigs. It is collected water when the boiler is taken out of service. Caustic fluid A wide range of high-pH materials normally generated by cleaning operations, as off- specification chemical compounds, or as the result of chemical combinations. Cement and cement Variations of standard Portland cements, consisting of limestone, clay, and other rinsate additives (accelerators, retarders, fluid loss additives). Rinsate comes from cleaning tanks, pumps, and associated equipment. Clean-up fluids Predominantly water which has been contaminated in the process of washing down (washwaters) an area, engine, etc. Condensate Effluent from the normal process separation of oil, water, and gas. Collected from drain sumps, blow case discharge, and knockout pots. Crude oil Generated as waste from a well workover or from spills. A blend of many types of hydrocarbons with some impurities. May be contaminated with water. Diesel Diesel wastes may be generated as contaminated fuel, solvent, workover fluid, or freeze protection fluid. May be contaminated with small amounts of chemicals or water. Usually exempt but considered hazardous if not from downhole operations. Domestic waste Originally potable water; comes from the kitchen, showers, lavatories, laundry, water toilets, and any camp floor drains. See further comments below. Drilling muds, oil- Used for cooling and for the flushing of cuttings during well drilling. Typically a based. mixture of a hydrocarbon fluid (usually mineral oil or diesel), clay or asphalt, some Well flowbacks water, and dissolved chemicals, which enhance certain properties of the mud. The odor is characterized by the hydrocarbon fluid. Primarily from flowbacks on new wells and workovers. Drilling muds, water- Used for cooling, lubricating the drill bit, and flushing cuttings to the surface. based. Consists of water, clay (usually bentonite), and additives such as barium compounds Well flowbacks that enhance certain properties. Primarily from flowbacks on new wells and workovers. . Class I Disposal Wells Waste Analysis Plan . Waste General Description Glycol An alcohol that is widely used in circulating fluid systems to prevent freezing. May be contaminated with water, hydrocarbons, or solids. Also used for dehydration of natural gas. Laboratory waste Various chemicals, products, and contaminants that are non-hazardous Line Pigging Materials that have built up on the walls of crude oil pipelines and produced water or Material seawater pipelines. Normally pushed through the pipelines to the production onshore facilities and deposited in facility vessels, from which it is later removed as vessel sludge/sand. Occasionally pigging waste will be removed directly from pipelines. Can include crude, produced or seawater, biomass, paraffin, formation solids, calcium scale, and iron sulfide. Minor amounts of solids. Lubricating oils and Produced as wastes from engines and power transmission systems. Contain small hydraulic fluids amounts of metal and chemical additives to enhance their properties. Methanol Light alcohol used widely as a freeze prevention fluid. May be used in combination with other materials, such as glycol. Primarily from well flowbacks. Usually exempt but considered hazardous if not from downhole operations. Only exempt methanol will be injected for injection. Miscellaneous Includes seawater, rain, snowmelt, and fresh water which is not considered clean-up wastes fluid. May contain small amounts of contaminants. Natural gas liquids Petroleum products (propane, butane, etc.) which are disposed of as wastes when (NGLs) they become contaminated with water, solids or some other hydrocarbon. Ignitable. Produced water Brine produced from the oil reservoir during the oil recovery process, separated from the oil and gas during onboard testing and sampling. Production Broad category that includes chemicals used in production or transportation of crude chemicals to achieve certain desirable effects. Examples include corrosion inhibitors, emulsion breakers, foam suppressants, and proprietary compounds used in drilling fluids, muds, and cleaning products. Only exempt or non-hazardous production chemicals will be accepted for injection. Radioactive tracer Fluid containing a low-level, short half-life radioactive substance used downhole for periodic mechanical integrity tests. This process is not considered disposal - it is part of the well operation. Solvents A wide range of products that may be contaminated with grease, solids, and/or water. All solvents must be carefully evaluated for disposal options - only those classified as non-hazardous will be accepted for disposal. Source water Cook Inlet seawater. Potentially used for making drilling mud and left over from EOR operations. Used as toilet flush water and for flushing disposal wells. Stimulation fluids Chemical compounds which are injected into producing or injection zones to enhance the productivity or injectivity of a well. May contain various chemicals to enhance its properties. Primarily from well flowbacks. Transformer oil Used as a non-conducting medium in electrical power transformers. Discarded when the equipment is abandoned. Vessel sludge/sand Fine solid particles from the oil producing formation, biomass, pipe scale. Can accumulate in test separators, tanks, production facility vessels, and heat exchangers. These solids are periodically removed and frequently hauled off; however, can be associated with crude oil, fresh or seawater, and production chemicals or solvents. . Class I Disposal Wells Waste Analysis Plan . Waste General Description Wastewater Opaque fluid with very low solids. The platform plant typically discharges with a treatment plant BOD of about 6 Mg/liter and a total suspended solids ranging from 2-30 Mg/liter, effluent average of 4 Mg/liter. Waste water Semi-solid residue from treating camp domestic wastewater. Not currently planned treatment plant for Class I disposal. sludge Workover fluids Wastes from the maintenance of a hydrocarbon production well. Predominantly water; may contain small amounts of chemicals, crude oil and minor solids. Also present during well flowbacks. Storm Water Rain collected in catchment basins and selected platform sumps. NORM Natural occurring radioactive material. A scale that deposits inside production lines and vessels. It has very low radioactivity and has been judged safe for handling. It is a Class II exempt waste. . Class I Disposal Wells Waste Analysis Plan . Exhibit 4 Cook Inlet Waste Streams Boiler blowdown Commercial product Contained snowl ponded water Facility wash water Glycol 1 heat exchange media Hydrotest fluid (water or glycol only) Photo processing fluid Sanitaryl domestic wastewater Spill clean-up Sump fluids Tank cleaning 1 drum rinsate Turbine wash water Used oil Other · Rig or production facility boilers · Products left over, spilled, outdated, off- specification, or no longer usable · Drilling mud and additives that have not been circulated downhole · Gel, barite, calcium carbonate, polymers · Fresh or seawater rinsate with product residual · Outdoor containment around fuel and chemical storage tanks · Depressions on or between skids, etc. · Internal or external washdown of skids, modules · Equipment cleaning (using non-hazardous detergents or degreasers) · Vehicles, boats, & equipment (antifreeze) Water Varies Typically non-hazardous; remote possibility of heavy metals Varies - check for listed wastes, solvents, heavy metals. Cement rinsates, acids and caustics must be non-hazardous for pH (spot check and neutralize as needed). Non- exempt methanol or diesel not approved for disposal. Typically non-hazardous Water, possible traces of hydrocarbon or chemicals if there have been spills Water, possible traces of Typically non-hazardous; possibly hydrocarbon, chemicals, detergent benzene or flash point (from hydrocarbons) Glycol (MEG, DEG, TEG, propylene) Water, glycol, possible product residual in existing lines, traces of chlorine or other biocide · Pressure test of new or non-exempt process lines, vessels · Non-exempt methanol or diesel must be recovered for re-use, not disposal · Spent developer solution from x-ray equipment Water (corrosion tests, medical), after passing through silver recovery unit · Camp wastewater treatment plant(s) and site enviro-vacs · Fluids recovered from cleanup of non-exempt spills · Contaminated soil or snow · Snowmelt and external dirt from equipment, collected in floor drains · Floor washings · Incidental equipment leaks & spills · Drum rinsing/crushing · Wash bay sumps · Residues removed from RCRA-empty containers 2 · Routine cleaning of turbine fins · Motor oil · Transmission fluid · Hydraulic oils · Any waste not covered by another waste stream Water, soap residuals, human waste Water, snow, soil, with hydrocarbon or chemical products Water, grit, possible traces of hydrocarbon. Water, possible traces of hydrocarbons, chemical residues, glycol, unused drilling products Water, detergent, sometimes methanol Hydrocarbon Varies 1. Wastes from DOT-regulated pipelines are not RCRA E&P exempt. (See Section 5.1.5). Typically non-hazardous; remote possibility of heavy metals at specifically identified locations Typically non-hazardous unless methanol or diesel are used Typically non-hazardous; silver removed and recovered Typically non-hazardous Depends on product spilled - benzene (diesel or gasoline spills), flash point, listed constituents Typically non-hazardous as long as sumps are properly managed. Process control is critical - hazardous wastes should never be dumped or drained to floor sumps. Typically non-hazardous, subject to fingerprint - flashpoint, pH, benzene, organic chlorides as necessary Possible flash point (if methanol used), cadmium or other metals Typically non-hazardous; possible flash point or organic chlorides from solvent or fuel contamination. Usually recycled - not discarded. Varies · . Class I Disposal W ells Waste Analysis Plan 2. Residues removed from RCRA empty containers must be evaluated as non-exempt waste. They were previously considered RCRA exempt «???)). 3. Note that similar wastes may be RCRA exempt, depending on waste-generating process. . Class I Disposal Wells Waste Analysis Plan . Exhibit 5 Cook Inlet Class I Waste Sources Wastewater Treatment Non-Exempt NO Plant Effluent (WWTP) · Sanitary Wastewater (Toilets) Domestic Wastewater Non-Exempt NO · Camp drains, showers, kitchen, etc. Normally an NPDES discharge Production Facility RCRA Exempt (E&P) NO · Crude oil, gas, and produced water from separation process · Process fluids from integral facility piping and associated sumps Drilling and Wells RCRA Exempt (E&P) NO Returned muds, returned stimulation & workover fluids Platform Structure Non-Exempt YES · Non-exempt spill cleanup WMRU Pad · Contained snow/ponded water · Stormwater Drilling and Wells Non-Exempt YES · Non-exempt products (unused, leftover, not returned from downhole) · Rig boiler blowdown Other Examples Non-Exempt YES · Decharacterized hazardous waste · Glycol/heat exchange media · Hydrotest fluids · Non-hazardous photo processing fluid · Source water «????».. ...??? · Sump fluids (Shop, top deck, etc) · Turbine wash water . Class I Disposal W ells Waste Analysis Plan . Exhibit 6 Analytical Requirements for Non-Exempt Waste Streams Parameter Initial Testing Fingerprine Acceptable Range (See Exhibit 6 for Methods) Requirement Appearance X Descriptive only - no pass/fail criteria pH X X 2<pH<12.5 Flash point X X >60°C (>140°F) Reactivity X Nonreactive TCLP Metals X See Exhibit 8 TCLP Volatiles X See Exhibit 8 TCLP Semi-Volatiles X See Exhibit 8 Benzene, Total or TCLp4 X < 0.5 (mgll) Total Organic Chlorides5 X ~1000 (ppm) Fingerprint semi-annually if waste is generated during that 6-month period. Environmental Advisor may approve reduced fingerprint frequency for established waste streams. Any solid sample that exceeds 10 mg/L total benzene (20 times the TCLP limit of 0.5 mg/L) must be re-analyzed by TCLP method. Required only for used oil that will be injected or recycled. . Class I Disposal Wells Waste Analysis Plan . Exhibit 7 Analytical Methods6 Analysis and Method7 Recommended Acceptable Range Alternative methods NOT permitted for Container Preservative Holding Time for Non-Hazardous parameters with asterisk (*) Material Ignitability (flash point) 250 ml glass, Chill to 4°C 7 Days Flash point> 140°F 1010A* (Pen sky-Martens closed cup) Teflon-lined cap (60°e) 1 020A * (Setaflash closed cup) Corrosivity (pH) 250 ml None As soon as 2 < pH< 12.5 9040C* (Electronic meter8) polyethylene/glass possible9 90450* (Soil and waste pH) Reactivity Nonreactive Generator knowledge (See Exhibit 7B) Toxicity Characteristics Leaching See below See below See below See Exhibit 8 Procedure (TCLP) Extraction 1311* TCLP Metals Arsenic ......... 7060A/7061A. 1 ea. 1 L amber Acidify with 180 days except See Exhibit 8 Barium .......... 7080Al7081 glass, Teflon-lined HN03 to pH<2 mercury (28 days) Cadmium ...... 7130/7131A cap Lead ............. 7420/7421 Mercury.........7470A/7471A Selenium....... 7740/7741 A Silver ............ 7760A/7761 Chromium..... 7190/7191 TCLP Volatile Organics 40 ml VOA vials, Chill to 4°C 14 days See Exhibit 8 8260B or equivalent no headspace Benzene <0.5 mg/L Benzene onl/o: 8021 b, 8260B TCLP Semi-volatile Organics 1 ea. 1 L amber Chill to 4°C Extract w/in 7 days, See Exhibit 8 8270C glass, analyze w/in 40 Teflon-lined cap days of extraction Organic Chlorides 500 ml glass, Acidify with 28 days ::;1000 ppm EPA 8021 B Teflon-lined cap HßO 4 to pH<2 Chlor-in-oil test or equivalent 12 100 ml glass, Chill to 4°C Teflon cap Appearance (color, homogeneity, etc.) Clear container As soon as possible Visual observation against clear or white background NOTE: Contact laboratory for specific instructions. For routine fingerprints, the following containers are usually sufficient: · 1 ea. 500 ml glass w/Teflon-lined cap (pH, flash point, appearance) · (Additional 500 ml glass w/Teflon-lined cap if organic chlorides are analyzed) · 2 ea. 40 ml VOA vials (benzene) 10 Methods shown are promulgated as of the date of this document. All methods from SW-846 unless otherwise indicated. On July 14,2005, EPA promulgated the Methods Innovation Rule (70 FR 34538), http://www.epa.gov/epaoswer/hazwaste/test/mir.htm). which deletes the requirement to use SW-846 test methods from the RCRA regulations, except for 27 method-defmed parameters. Method-detined parameters in this table are indicated by the "*,, symbol. Note that pH indicator paper is NOT an approved method for RCRA determinations of cOlTosivity. In the tield, pH should be measured as soon as possible after the sample is collected. For samples analyzed by a commercial laboratory, the holding time is 24 hours following collection. Total benzene is appropriate for liquids that do not require TCLP extraction, and as a screening method for solids. Total benzene provides worst-case concentration. Any non-liquid sample that exceeds 0.5 mglL total benzene must be re-analyzed by TCLP. Used as an indicator oflisted chlorinated solvent. The analytical method measures aromatic and halogenated volatiles by gas chromatography. Halogens are presumed to be chlorides. Field screening kit with appropriate sensitivity may be used. 11 12 · Class I Disposal Wells Waste Analysis Plan e Exhibit 8 Hazardous Waste Characteristics Ignitability Alcohol content of greater than 24 percent, or Flash point less than 140 deç¡rees Fahrenheit (60 deqrees Centiqrade) Corrosivity pH less than or equal to 2 or greater than or equal to 12.5, or Corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.250 inch) per year at a test temperature of 55°C (130°F) Reactivity Normally unstable and readily undergoes violent change without detonating Reacts violently with water Forms potentially explosive mixtures with water When mixed with water, generates toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment Is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5 can generate toxic gases; Is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement Is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure; or Is a forbidden explosive as defined in 49 CFR 163.51, a Class A explosive as defined in 49 CFR 163.53, or a Class B explosive as defined in 49 CFR 163.88. Toxicity Contains anv of the contaminants listed on Exhibit 2 above the indicated concentration . Class I Disposal Wells Waste Analysis Plan . Exhibit 9 Reactivity Checklist Initial Waste Characterization for Underground Injection in Class I well For the initial hazardous waste determination, a waste stream must be evaluated for the characteristic of reactivity. A waste is a reactive hazardous waste if it exhibits one or more of eight properties described below (40 CFR Section 261.23). EP A's Methods Innovation Rule1 (6/14/05) withdraws various reactivity test methods from SW -846. Instead, "generators and other persons can use other appropriate methods or process knowledge in determining whether a particular waste is hazardous due to its reactivity". The checklist is to be completed by the waste generator and submitted to the ACS Environmental Specialist for review. A copy ofthis checklist should be filed with the analytical data for the waste stream. Description of Waste Source Generator (Print) Generator (Sign and Date) To the best of your knowledge, do any of the following criteria apply to this waste stream? YES NO 1. Normally unstable and readily undergoes violent change without detonating 2. Reacts violently with water 3. Forms potentially explosive mixtures with water 4. When mixed with water, generates toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment 5. Is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5 can generate toxic gases 6. Is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement (example: pressurized aerosol cans) 7. Is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure 8. Is a forbidden explosive as defined in 49 CFR 163.51, a Class A explosive as defined in 49 CFR 163.53, or a Class B explosive as defined in 49 CFR 163.88. . Class I Disposal Wells Waste Analysis Plan . Exhibit 10 Hazardous Waste Toxicity Characteristics As determined by Toxicity Characteristics Leaching Procedure (TCLP) Source: 40 CFR 261.24 Maximum Maximum Contaminant concentration Contaminant concentration (mg/L) (mg/L) TCLP Metals TCLP Semi-Volatiles Arsenic 5.0 o-Cresol 200.0* Barium 100.0 m, p-Cresol 200.0* Cadmium 1.0 m, p-Cresol 200.0* Chromium 5.0 Cresol (total) 200.0* Lead 5.0 2,4-Di nitrotol uene 0.13** Mercury 0.2 Hexachlorobenzene 0.13** Selenium 1.0 Hexachlorobutadiene 0.5 Silver 5.0 Hexachloroethane 3.0 Nitrobenzene 2.0 TCLP Volatiles Pentachlorophenol 100.0 Benzene 0.5 Pyridine 5.0** Carbon tetrachloride 0.5 2,4,5-Trichlorophenol 400.0 Chlorobenzene 100.0 2,4,6- T richlorophenol 2.0 Chloroform 6.0 1,4-Dichlorobenzene 7.5 TCLP Pesticides/Herbicides*** 1,2-Dichloroethane 0.5 Chlordane 0.03 1,1-Dichloroethylene 0.7 2,4-0 10.0 Methyl ethyl ketone 200.0 Endrin 0.02 Tetrachloroethylene 0.7 Heptachlor 0.008 Trichloroethylene 0.5 Lindane 0.4 Vinyl chloride* 0.2 Methoxychlor 10.0 Toxaphene 0.5 2,4,5-TP (Silvex) 1.0 * If 0-, m-, and p-cresol concentrations cannot be differentiated, the total cresol concentration is used. Method quantitation limit is higher than regulatory limit. Use quantitation limit as maximum allowable level. Pesticides and herbicides are not used or expected to be present at Cook Inlet. No testing is required. ** *** . Class I Disposal Wells Waste Analysis Plan Exhibit 11 Waste Manifest Form . . Class I Disposal Wells Waste Analysis Plan . FOREST MANIFEST EXHIBIT 11 1 GENERATOR INFORMATION HeidI I OWner I Date Asset Contact Rig{ Time 0 AM 0 F'M (Print Name) Facility Phonel Søurce} Cost CQdelAétlvilyCOdElI Pagø( Well No. AFEfApprover 10 2. GENERATING ACTIVITY OR PROCESS 3. VOLUME 0 Bbl (estimate) 0 Gal 0 cuyd 4. DESCRIPTION (Compositløl'ì must é(Jua' 100% - use whole number's) Crude Oil % Glycol % ¡F'tes~~nt WðshWale( ~ Produced Water % Acid 0/0 ~ Drillir¡g Mud % Une Pigging Material °/0 Chemicals ~ Cuttings 0/0 Diesel/Water Gel 0/0 $umP FlUid ~ CementlCor¡taminate % Scale/Corrosion Inhibitor °/0 Snow % Diesel % Boiler Blowdown % Soil/Sand % Methanol % Used Oil % DomestiéWaslewater % OTHER % Cheékone: o Listed in Waste Dispøsal & Reuse Guide OR % 0 Approved by (Name/Date) 5. REUSEf RECYCLE: WiII.tbe material bereU$èdfre¢ycledin an approved manner ? 0 YES Select methodattightal1d go to PART 8 I - Waler Recycle/EOR .,.......". Hydrocarboh Recy¢le 0 NO Go tø PART 6 - Qtber Beheficial Reuse (De$þlÍbe) 6. Waste Classification: Was the Waste bJ'oQght to the surface from doWnhole or used tJudngdlrect protJuction opera¡iol')$? 0 YES Go 10 PART 7 if Class tfaCility will be used 0 NO Gø to PART 7 or øohtact Environmental ·7. CLASS I DISPOSAL: Is ¡be Waste either non-hazardous or eXempt ftorn regQlation as hazardous Wasb;l (40CFR261 .4)? 0 YES Indicate classificatIon ¡;It right ¡;IntJgo tø PART 8 I - RCRA Exempt 0 NO NØtapþrøved for Class I disposal - contact Environmental - Non.EXElmpt, Noh.Ha;;ardous 8. DESTINATION (N¡tmeöf F¡tcìlity) Redoubt Platform Well Name: WMRU Pad Well Name: Comments: 9, TEST DATA IF REQUIRED BY RECEIVING FACILITY Flð$h point % Orgahlochl.orldes (ppm) % % Solids % pH % percent. hYdrocarbons .% % Water % 10. GENERATOR Name Signature (Print) Certification: This consignment. to theOO/lfófmy knowledge and OOlief. is ªccurr¡tølY(1!.>/lcribed Date above and I haveli/pplied the prpviSions of/he Waste Analysis Planl Guide in making dèèiSÎons çonceming the reUSe or (1isposal of thiS material. 11. TRANSPORTER Name Signature Company: (Print) J3oatlHeliCOpler Date Tank No: 12. RECEIVER Name Sign¡;lture (Print) Oflloaded at: Vblume Received: D Bbl D Gal Date 0 Cuyd COMMENTS If this is a mixed load, cross-reference other manifest numbers here: Form Revised 9/10/2005 ORIGINAL - Receiving Facility COPIES - Follow site-specific flUng Instructions . Class I Disposal Wells Waste Analysis Plan . Forest MANIFEST INSTRUCTIONS This form is valid ONLY if it is signed by "certified" Generators, Transporters, and Receivers who have completed the Certification Training Program. Parts 1 through 10 are completed by the GENERATOR PART 1 PART 2 GENERATOR INFORMATION: Fill in all sections legibly. GENERATING ACTIVITY OR PROCESS: Clearly describe the activity or process that generated the material. PART 3 PART 4 VOLUME: Estimate the quantity in barrels, gallons, or cubic yards. DESCRIPTION: Estimate the percentage of all components, and be sure numbers add up to 100%. Use "trace" when percentage is significantly less than I %. (These percentages are only estimates, and should not be used in calculations to detennine RCRA compliance.) Do not use "Other" without providing a complete description. PART 5 REUSEIRECYCLE: Check with the HSE staff on recycle options if your particular activity is new. Environmental staff will review on a case-by-case basis. PART 6 CLASS II: Waste must be specifically listed for Class II disposal as shown in ......??.... Note Class II waste may also be sent to a Class I disposal facility providing it meets the facility's operating requirements. PART 7 CLASS I: Waste must be listed as RCRA-exempt or non-hazardous in ....??... If not, it must be specifically approved by the HSE staff on the basis of testing or other infonnation. You must check either RCRA-Exempt or Non-Exempt, Non-Hazardous in Part 7. PART 8 DESTINATION: Check the appropriate box or write the name of the facility where this load will be managed. Be sure to check .........71...... for site-specific restrictions and requirements. PART 9 SCREENING OR TEST DATA: Check with the facility in advance to find out if any special testing or screening is required. Provide results, or attach supporting data (lab results, MSDS, etc.) as instructed. PART 10 GENERATOR CERTIFICATION: Generators must read, sign, and date this section. PART 11 TRANSPORTER SECTION: By completing and signing this section, the Transporter certifies that helshe has picked up only the material described by the Generator and delivered it only to the designated facility. PART 12 RECEIVER SECTION: The Receiver must review the manifest for completeness, and verify that the Generator and Transporter are currently certified. Contact the Generator if there are any questions or discrepancies. Indicate the actual location where the material is offIoaded, and the volume received. By signing this section, the Receiver acknowledges that the material, as described by the Generator, meets the criteria for acceptance at the facility. COMMENTS SECTION: To be used as required by Generator, Transporter, and/or Receiver. Cross-reference other manifest numbers here for "mixed loads". . Class I Disposal Wells Waste Analysis Plan . Appendix III. List of Approved Class I Waste Streams Waste General Description Acid Used widely as cleaning fluid in well work and chemical processes. Low pH. Usually exempt but may be considered hazardous if not from downhole. Boiler blowdown Fresh water used in boilers, typically to make steam for drilling rigs. It is collected water when the boiler is taken out of service. Caustic fluid A wide range of high-pH materials normally generated by cleaning operations, as off- specification chemical compounds, or as the result of chemical combinations. Cement and cement Variations of standard Portland cements, consisting of limestone, clay, and other rinsate additives (accelerators, retarders, fluid loss additives). Rinsate comes from cleaning tanks, pumps, and associated equipment. Clean-up fluids Predominantly water which has been contaminated in the process of washing down (washwaters) an area, engine, etc. Condensate Effluent from the normal process separation of oil, water, and gas. Collected from drain sumps, blow case discharge, and knockout pots. Crude oil Generated as waste from a well workover or from spills. A blend of many types of hydrocarbons with some impurities. May be contaminated with water. Diesel Diesel wastes may be generated as contaminated fuel, solvent, workover fluid, or freeze protection fluid. May be contaminated with small amounts of chemicals or water. Usually exempt but considered hazardous if not from downhole operations. Domestic waste Originally potable water; comes from the kitchen, showers, lavatories, laundry, water toilets, and any camp floor drains. See further comments below. Drilling muds, oil- Used for cooling and for the flushing of cuttings during well drilling. Typically a based. mixture of a hydrocarbon fluid (usually mineral oil or diesel), clay or asphalt, some Well flowbacks water, and dissolved chemicals, which enhance certain properties of the mud. The odor is characterized by the hydrocarbon fluid. Primarily from flowbacks on new wells and workovers. Drilling muds, water- Used for cooling, lubricating the drill bit, and flushing cuttings to the surface. based. Consists of water, clay (usually bentonite), and additives such as barium compounds Well flowbacks that enhance certain properties. Primarily from flowbacks on new wells and workovers. Glycol An alcohol that is widely used in circulating fluid systems to prevent freezing. May be contaminated with water, hydrocarbons, or solids. Also used for dehydration of natural gas. Laboratory waste Various chemicals, products, and contaminants that are non-hazardous Line Pigging Materials that have built up on the walls of crude oil pipelines and produced water or Material seawater pipelines. Normally pushed through the pipelines to the production onshore facilities and deposited in facility vessels, from which it is later removed as vessel sludge/sand. Occasionally pigging waste will be removed directly from pipelines. Can include crude, produced or seawater, biomass, paraffin, formation solids, calcium scale, and iron sulfide. Minor amounts of solids. . Class I Disposal W ells Waste Analysis Plan . Waste General Description Lubricating oils and Produced as wastes from engines and power transmission systems. Contain small hydraulic fluids amounts of metal and chemical additives to enhance their properties. Methanol Light alcohol used widely as a freeze prevention fluid. May be used in combination with other materials, such as glycol. Primarily from well flowbacks. Usually exempt but considered hazardous if not from downhole operations. Only exempt methanol will be injected for injection. Miscellaneous Includes seawater, rain, snowmelt, and fresh water which is not considered clean-up wastes fluid. May contain small amounts of contaminants. Natural gas liquids Petroleum products (propane, butane, etc.) which are disposed of as wastes when (NGLs) they become contaminated with water, solids or some other hydrocarbon. Ignitable. Produced water Brine produced from the oil reservoir during the oil recovery process, separated from the oil and gas during onboard testing and sampling. Production Broad category that includes chemicals used in production or transportation of crude chemicals to achieve certain desirable effects. Examples include corrosion inhibitors, emulsion breakers, foam suppressants, and proprietary compounds used in drilling fluids, muds, and cleaning products. Only exempt or non-hazardous production chemicals will be accepted for injection. Radioactive tracer Fluid containing a low-level, short half-life radioactive substance used downhole for periodic mechanical integrity tests. This process is not considered disposal - it is part of the well operation. Solvents A wide range of products that may be contaminated with grease, solids, and/or water. All solvents must be carefully evaluated for disposal options - only those classified as non-hazardous will be accepted for disposal. Source water Cook Inlet seawater. Potentially used for making drilling mud and left over from EOR operations. Used as toilet flush water and for flushing disposal wells. Stimulation fluids Chemical compounds which are injected into producing or injection zones to enhance the productivity or injectivity of a well. May contain various chemicals to enhance its properties. Primarily from well flowbacks. Transformer oil Used as a non-conducting medium in electrical power transformers. Discarded when the equipment is abandoned. Vessel sludge/sand Fine solid particles from the oil producing formation, biomass, pipe scale. Can accumulate in test separators, tanks, production facility vessels, and heat exchangers. These solids are periodically removed and frequently hauled off; however, can be associated with crude oil, fresh or seawater, and production chemicals or solvents. Wastewater Opaque fluid with very low solids. The platform plant typically discharges with a treatment plant BOD of about 6 Mg/liter and a total suspended solids ranging from 2-30 Mg/liter, effluent average of 4 Mg/liter. Waste water Semi-solid residue from treating camp domestic wastewater. Not currently planned treatment plant for Class I disposal. sludge Workover fluids Wastes from the maintenance of a hydrocarbon production well. Predominantly water; may contain small amounts of chemicals, crude oil and minor solids. Also present during well flowbacks. Storm Water Rain collected in catchment basins and selected platform sumps. . Class I Disposal Wells Waste Analysis Plan . Waste General Description NORM Natural occurring radioactive material. A scale that deposits inside production lines and vessels. It has very low radioactivity and has been judged safe for handling. It is a Class /I exempt waste. . Class I Disposal W ells Waste Analysis Plan . Appendix IV. Class II DIC Compliance Matrix The following waste streams are approved for injection at the designated Class II wells Well Fluid RU #D1 WMRU 4D RU #6 EOR WMRU 2A EOR Class II Fluids Related to OK OK Only produced water Only produced water Osprey Class II Fluids from Any Facility NO OK NO NO Class II Fluids from WMRU OK OK Only produced water Only produced water Class II Fluids from OK OK NO Only produced water KPF Class II Fluids from Exploration OK OK NO NO Wells Sanitary waste from Osprey OK NO OK NO Gray Water from Osprey NO NO OK NO Deck Drainage from Osprey OK NO OK OK Produced Water from Redoubt OK OK OK OK Produced Water from WMRU OK OK OK OK Produced Water from West OK OK OK OK Forelands 2° Containment Water-KPF NO Only if contaminated OK OK with Class II 2° Containment Water-WMRU NO Only if contaminated OK OK with Class II . Class I Disposal Wells Waste Analysis Plan . Appendix V. Waste Analysis Plan for Osprey EOR Analysis Plan "Other" Injection Fluids RU#6 EOR Forest Oil-Osprey Platform 1/30/06 Purpose Forest Oil Corporation (Forest Oil) is permitted to inject produced water from the Hemlock Formation into well RU #6 for enhanced oil recovery (EOR) according to Enhanced Recovery Injection Order (ERO) No. 2, issued on August 26,2004. Subsequent to the issuance ofERO No.2, Forest Oil was issued administrative approvals ERO 2.001 and ERO 2.001A, which allow the use of "other" fluids for EOR operations in RU #6. As a condition for subsequent approvals, Forest Oil "must continue to collect and analyze representative samples of the mixed fluid stream at the Redoubt Unit injection manifold to demonstrate its non-hazardous characteristics and its continued suitability for EOR injection". This sampling plan was developed to satisfy that condition in ERO 2.001 and ERO 2.001A. Fluids ReQuirin2 Testin2 The "other" fluids permitted by ERO 2.001 and ERO 2.001A are: 1. treated sanitary waste from the Osprey 2. gray water from the Osprey 3. produced water from WMRU 4. storm water from secondary containment areas at KPF 5. storm water from secondary containment areas at WMRU 6. storm water from secondary containment areas on the Osprey Platform (deck drain fluids) ERO 2.001 and ERO 2.001A require analysis of the "mixed fluid stream". The wording is confusing because the largest volume of water being injected for EOR is Redoubt produced water. Produced water is exempt from RCRA hazardous waste regulations and not subject to RCRA testing. Likewise, produced water from WMRU is exempt from RCRA testing. In an e-mail onAugust24.2005.Mr. Jim Regg of AOGCC clarified that the intent ofERO 2.001 and ERO 2.001A was for Forest Oil to test only fluids that are not exempt from RCRA hazardous waste regulations. Accordingly, the only fluids that will be analyzed to satisfy the testing requirement ofERO 2.001 and ERO 2.001A are the following: · treated sanitary waste from the Osprey · gray water from the Osprey · storm water from secondary containment areas at KPF · storm water from secondary containment areas at WMRU · storm water from secondary containment areas on the Osprey Platform (deck drain fluids) . Class I Disposal Wells Waste Analysis Plan . Samplin2 Point (Osprey) Samples should be taken at a point at which as many of the streams as possible are commingled, exclusive of produced water. This would most likely be the manifold pump in the marine sanitation device room on the Osprey for 1) treated sanitary waste, 2) gray water and 3) storm water from secondary containment areas (deck drain fluids) on the Osprey. Storm water from secondary containment areas at KPF and WMRU will have to be sampled separately if, and when, necessary. General Approach: Analysis of the above fluids will consist of testing for hazardous waste characteristics, using knowledge of the fluids, and fingerprint analyses. Testingfor Hazardous Waste Characteristics Initially, the above fluids will be analyzed for a full set of hazardous waste characteristics except for reactivity and herbicides/pesticides. Knowledge of the fluids indicates that it is extremely unlikely that either of these is present but the initial analyses will consist of the following: Characteristic Analysis Method Sample Location of Container Analysis Corrosivity pH pH meter NA Field Ignitabi1ity Flash Point SW1010 1 x 40z Lab glass As SW13111SW60 10 Ba SW13111SW601O Cd SW13111SW601O 1 x 500 m1 Toxicity (TCLP) Cr SW13111SW601O HDPE, Lab Metals Pb SW13111SW601O unpreserved Se SW13111SW6010 Ag SW13111SW6010 Hg SW13111SW7470A Characteristic Analysis Method Sample Location of Container Analysis 1,1- Dichloroethylene 1,2- Dichloroethane 1,4- Dichlorobenzene Methy1ethy1 ketone 3x40 m1 Toxicity (TCLP) Benzene septa vial, Volatiles Carbon tetrachloride SVV1311/SVV8260B unpreserved, Lab Chorobenzene no Chloroform headspace Tetrachloroethylene Trichloroethylene Vinyl chloride . Class I Disposal Wells Waste Analysis Plan . Characteristic Analysis Method Sample Location of Container Analvsis o-Creso1 Pyridine m-Creso1 p-Creso1 Total Cresol Toxicity (TCLP) Hexachloroethane 2 x 1 liter Nitrobenzene SW13111SW8270C amber glass, Lab Semivolati1es Hexach10robutadiene unpreserved 2,4,6- TricWoropheno1 2,4,5- Trich10ropheno1 2,4-Dinitroto1uene Hexachlorobenzene Pentachlorophenol Samples will be collected from the mixed fluids prior to injection at the manifold and commingling with produced water. After the initial analyses for hazardous waste characteristics, additional analyses for hazardous waste characteristics will be conducted only if knowledge of the source or constituents of the fluids becomes questionable or if fingerprint analyses (see below) indicate that the characteristics of the fluids have changed from those exhibited during initial testing. Knowledge of the Fluids Forest Oil will document the source of each of the fluids used for EOR. If the known source and constituents of the fluids changes or become questionable, hazardous waste testing for characteristics will be performed according to the suspected source of the alteration. Initially, as mentioned above, and in the future, unless knowledge of the fluids indicates otherwise, reactivity and herbicides/pesticides will not be analyzed. Fingerprint Analyses At the same time that the initial analysis for hazardous waste characteristics is conducted, the samples will be analyzed for fingerprint characteristics. The intent is to correlate the results of the analyses for hazardous waste characteristics with simpler and less expensive fingerprint characterization. Fingerprint analyses will then be conducted routinely in the future unless fingerprint characteristics of the combined fluid streams change. Changes in fingerprint characteristics, if they occur, will be treated as a presumptive change from the initial hazardous waste characteristics and as a possibility that the fluid may have become hazardous. In that case, a full analysis of the initial hazardous waste characterization would be conducted again to confirm that hazardous waste criteria had not been exceeded. . Class I Disposal Wells Waste Analysis Plan . Fingerprint analyses will consist of the following: Characteristic Analysis Method Sample Location of Container Analysis Corrosivity pH pH meter NA Field Color Appearance Solids/Liquid Visual NA Field PhaseslHomogeneity Sheen Gasoline Range 3 x 40 m1 AK10 septa vial, (including benzene) HCL 2 x 1 liter Diesel Range AK102 amber Organics glass, HCL Lab 1 x 500 m1 Total Organic Chlorides glass, (Total Halogens as SW9020 preserved c Chloride) H2S04, 28 day holding Samplin2 FrequenCY · Hazardous Waste Characteristics Full testing for hazardous waste characteristics will be done once initially, each time that fingerprint analyses demonstrate the characteristic of the fluid stream may have changed significantly, and each time a previously untested fluid stream is injected. · Fingerprint Analyses Fingerprint analyses will be done initially and then each quarter for the first year, each time that the characteristics of the fluid stream may have changed significantly, and each time a previously untested fluid stream is injected. After the first year, if no significant changes in the fluid stream are detected, fingerprint analyses will be performed semiannually at which time they will consist only of corrosivity and appearance. Replicate Samples and Volumes · Hazardous Waste Characteristics See tables above. · Fingerprint Analyses See tables above. Sample Containers · Hazardous Waste Characteristics See tables above. · Fingerprint Analyses See tables above. . Class I Disposal Wells Waste Analysis Plan . Holdin2 Times. · Hazardous Waste Characteristics Samples must be received by the laboratory within 2 days of collection. · Fingerprint Analyses Samples must be received by the laboratory within 2 days of collection. Shippin2 · Glass sample jars should be wrapped in bubblewrap, placed in a cooler with plenty of ice and a temperature blank, and shipped to Northern Test Laboratories with a fully executed chain-o¡'custody form. (Instructions for filling out COCs will be included with the bottle kit.) Results · Results must be sent to the Forest Oil HSE Manager in Anchorage as soon as possible: HSE Manager Forest Oil Corporation 310 K Street Anchorage, AK 99501 · Hazardous Waste Characteristics The following limits on hazardous waste characteristics must not be exceeded: Characteristic Analysis Limit (in mglL unless otherwise indicated) COITosivity pH >2.0 <12.5 units Ignitability Flash Point <140°F As 5.0 Ba 100.0 Cd 1.0 Toxicity (TCLP) Metals Cr 5.0 Pb 5.0 Se 1.0 Ag 5.0 Hg 0.2 1,1- Dich10roethy1ene 0.7 1,2- DicWoroethane 0.5 1,4- Dichlorobenzene 7.5 Methylethy1 ketone 200.0 Toxicity (TCLP) Volatile Benzene 0.5 Carbon tetrachloride 0.5 Organics Chorobenzene 100.0 Chloroform 6.0 Tetrachloroethylene 0.7 Trichloroethylene 0.5 Vinyl chloride 0.2 Characteristic Analysis Limit (in mg/L unless otherwise indicated) Toxicity (TCLP) Semivolatile Pyridine 5.0 Organics o-Creso1 200.0 m-Creso1 200.0 p-Cresol 200.0 . Class I Disposal Wells Waste Analysis Plan . Total Cresol 200.0 Hexachloroethane 3.0 Nitrobenzene 2.0 Hexach10robutadiene 0.5 2,4,6- TricWoropheno1 2.0 2,4,5- Trichloropheno1 400.0 2,4- Dinitroto1uene 0.13 Hexach10robenzene 0.13 Pentachlorophenol 100.0 . Fingerprint Analyses The following limits on hazardous fingerprint analyses must not be exceeded: Characteristic Analysis Limit (in mg/L unless otherwise indicated) Acidity pH >2.0 <12.5 units Color No significant change Appearance Solids/Liquid No significant change Phases/Homogeneity Sheen None Gasoline Range No significant change Organics Benzene 0.5 Diesel Range No significant change Total Organic Chlorides 1000 . Class I Disposal Wells Waste Analysis Plan . SUMMARY SAMPLING SCHEDULE* Parameter Initial 3-06 6-06 9-06 12-06 3-07 6-07 9-07 12-07 Corrosivity X X X X X X X (PH) Ignitabi1ity X Toxicity Metals X Toxicity X Volatiles Toxicity X Semivo1ati1es Organics X X X X X Appearance X X X X X X X * Assumes no differences in results from one reporting period to the next, that no significant process changes have occurred, and that the operators have no knowledge of hazardous wastes being introduced to the injection system. . Class I Disposal Wells Waste Analysis Plan . FIELD REPORTING FORM Sample Number (must track to number used for laboratory analysis) Date: Sample Components (e.g. sanitary, gray water, deck drainage, or KPF Stonnwater; etc.) pH units Color Solids (present! absent) Clarity (clear/turbid) Phases (separate/combined) Sheen (present! absent) Parameter Results :if 15 . . @ FOREST OIL CORPORATION 510 Q/(' Ó7tJ(f?ø{:. ç'jfuru 700 Qc;f;,<:¡fO~"/;'lf?, Q9t&oka ,9.9501 (907) .258-8600 · (.907) 2:;8-86'0/ (dØru) June 5, 2007 RECE\\lEJ) JtJi\\ l 1 1M1 ,C" '.<1' COO1mÎ$Slí:m ~\a$\I.ª 01\ & GaS orb. . Am;horagt Mr. Jim Regg Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 Re: 5th Progress Review AOGCC Decision and Order No. 46 Dear Mr. Regg: Forest Oil Corporation (Forest Oil) received Decision and Order No. 46, issued on February 16, 2007, from AOGCC. The 4rd progress review describing the corrective action that Forest Oil is taking in response to that Decision and Order was submitted to AOGCC on May 15, 2007. This is the 5th Progress Review. The status and timing of the corrective actions that Forest Oil is implementing are described below: 1) Injection guidelines. Forest Oil provided the Commission with injection guidelines in the form of a Compliance Matrix. Timing: The matrix will continue to be updated when additional injection orders are received and, as necessary, as milestones within existing injection orders are reached or completed and as injection orders are amended. We consider this item completed. Forest has already implemented the above guidelines. We are awaiting final approval from the Commission before closing this item out. Additional injection guidelines. Forest Oil is in the process of creating a comprehensive waste management plan that will encompass all aspects of waste management, including underground injection control. Timing: The waste management plan is in draft format. It will be completed by the end of the second quarter 2007. 2) Training: All Forest Oil employees and contractors were trained in 2006 on the compliance guidelines. The training will be conducted annually and expanded when the waste management manual is completed. . . Timing: Annual trainingfor 2007 was completed on the Osprey platform on April 12, 2007. Annual trainingfor our on-shore facilities was conducted on April 17, 2007. 3) Other: Forest Oil has received a Class I permit from EP A for the injection of non- hazardous wastes into R U D 1. That permit will not go into effect until EP A witnesses the successful conclusion of Mechanical Integrity Testing and other testing required by the Class I permit. Timing: The required testing on RU DI was completed successfully on May 11, 2007. We are awaitingfinal approval of the testingfrom EPA. The Waste Analysis Planfor the WMRU#4D and RUD #1 Class I wells has been completed and approved by EP A. The conversion of both of these wells from Class II to Class I is expected to be complete by the end of July 2007. Forest Oil will notifY AOGCC when the change occurs. If you have any questions, please contact me at 868-2166 or at rgelder(a¿forestoil.com. Sincerely, ß~ Bob Elder HSE Manager #14 . . @ FOREST OIL CORPORATION .J 1 0 dYC cfl};N'Æ'Æ . cf1;~Uè 700 Qytnch(ÞJCf~ýØ, Q9'tIa:Jka ,9.9501 (.907) 258-86'00 · (907) 2/¡8-86'O1 (c2Þa.r) May 15, 2007 RËCI2IV€D MAY 1 6 Alaska 0., 2001 'BtG as Cons. C . Anchorage 0ffltn/8$iOI] Mr. Jim Regg Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 Re: 4th Progress Review AOGCC Decision and Order No. 46 Dear Mr. Regg: Forest Oil Corporation (Forest Oil) received Decision and Order No. 46, issued on February 16, 2007, from AOGCC. The 3rd progress review describing the corrective action that Forest Oil is taking in response to that Decision and Order was submitted to AOGCC on April 13, 2007. This is the 4th Progress Review. The status and timing of the corrective actions that Forest Oil is implementing are described below: 1) Injection guidelines. Forest Oil provided the Commission with injection guidelines in the form of a Compliance Matrix. Timing: The matrix will continue to be updated when additional injection orders are received and, as necessary, as milestones within existing injection orders are reached or completed and as injection orders are amended. We consider this item completed. Forest has already implemented the above guidelines. We are awaiting final approval from the Commission before closing this item out. Additional injection guidelines. Forest Oil is in the process of creating a comprehensive waste management plan that will encompass all aspects of waste management, including underground injection control. Timing: The waste management plan is in draft format. It will be completed by the end of the second quarter 2007. 2) Training: All Forest Oil employees and contractors were trained in 2006 on the compliance guidelines. The training will be conducted annually and expanded when the waste management manual is completed. . . Timing: Annual trainingfor 2007 was completed on the Osprey platform on April 12, 2007. Annual training for our on-shore facilities was conducted on April 17, 2007. 3) Other: Forest Oil has received a Class I permit from EP A for the injection of non- hazardous wastes into RU Dl. That permit will not go into effect until EPA witnesses the successful conclusion of Mechanical Integrity Testing and other testing required by the Class I permit. Timing: The required testing on RU Dl was completed successfully on May 11, 2007. We are awaitingfinal approval of the testingfrom EPA. The Waste Analysis Planfor the WMRU#4D and RUD #1 Class I wells has been completed and approved by EP A. The conversion of both of these wells from Class II to Class I is expected to be complete by the end of July 2007. Forest Oil will notify AOGCC when the change occurs. If you have any questions, please contact me at 868-2166 or at rgelder(cl¿forestoil.com. Sincerely, ßÄ¥¿þ~ Bob Elder HSE Manager ~13 "-' --/ @ FOREST OIL CORPORATION .!f ~ 0 dYC ¿;;Z~A}t. ~~'te 700 OYÍnchÆÞFüllÆ3, OQfta5ka .9.9501 (.907) 2/;/5-86'00 · (.907) 25/5-/56'01 (c;JX;.r) April 13, 2007 RECEIVED APR 1 6 2007 Alaska Oil & Gas Cons. Commission Anchorage Mr. Jim Regg Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 Re: 3rd Progress Review AOGCC Decision and Order No. 46 Dear Mr. Regg: Forest Oil Corporation (Forest Oil) received Decision and Order No. 46, issued on February 16,2007, from AOGCC. The 2nd progress review describing the corrective action Forest Oil is taking in response to that Decision and Order was submitted to AOGCC on March 22,2007. This is the 3rd Progress Review. The status and timing of the corrective actions that Forest Oil is implementing are described below: 1) Injection guidelines. Forest Oil provided the Commission with injection guidelines in the form of the aforementioned Compliance Matrix. Timing: The matrix will continue to be updated when additional injection orders are received and, as necessary, as milestones within existing injection orders are reached or completed and as injection orders are amended. We consider this item completed. Additional injection guidelines. Forest Oil is in the process of creating a comprehensive waste management plan that will encompass all aspects of waste management, including underground injection control. Timing: The waste management plan will be completed by the end of the second quarter 2007. "'.~ ..~ Implementation of Guidelines. Forest has already implemented the above guidelines. We are awaiting final approval from the Commission before closing this item out. 2) Training: All Forest Oil employees and contractors were trained in 2006 on the compliance guidelines. The training will be conducted annually and expanded when the waste management manual is completed. Timing: Annual training for 2007 was completed on the Osprey platform on April 12, 2007. Training for our on-shore facilities will be conducted on April 17, 2007. 3) Other: Forest Oil has received a Class I permit from EP A for the injection of non- hazardous wastes into RU D1. That permit will not go into effect until EPA witnesses the successful conclusion of Mechanical Integrity Testing and other testing required by the Class I permit. Timing: The required testing on RU Dl is expected to be initiated on MaylO, 2007. If you have any questions, please contact me at 868-2166 or at rgelder@forestoil.com. Sincerely, ß~ Bob Elder HSE Manager #12 . ~ FOREST OIL . CORPORATION ,'NO dYC cfliræte ¿¡¡;Mc'te 700 Q9ÝnclwrrÆllÆ3 ~ Q9Ílaâka·.9.9.501 (907)2.5'8-,?600 · (.907) 2.5'8'-8601 (r;j:JÇax) March 22, 2007 ·RECEIVED MAR 2 7 Z007 Mr. Jim Regg Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 Alaska Oil & Gas Cons. Commission Anchorage Re: 2nd Progress Review AOGCC Decision and Order No. 46 Dear Mr. Regg: On January 30, 2007 Forest Oil Corporation (Forest Oil) received Proposed Decision and Order No. 46 from AOGCC, dated January 29,2007. A progress review describing the corrective action Forest Oil is taking was submitted to AOGCC on February 15,2007. That review provided AOGCC with 1) a VIC Compliance Matrix that Forest Oil is now using to ensure compliance with all injection order stipulations, and 2) a training roster documenting that all Forest Oil employees and contractors are receiving waste management training. The final Decision and Order was issued on February 16,2007. This is the second Progress Review. The status and timing of the corrective actions that Forest Oil is implementing are described below: 1) Injection guidelines. Forest Oil provided the Commission with injection guidelines in the form of the aforementioned Compliance Matrix. Timing: The matrix will continue to be updated when additional injection orders are received and, as necessary, as milestones within existing injection orders are reached or completed and as injection orders are amended. Additional injection guidelines. Forest Oil is in the process of creating a comprehensive waste management plan that will encompass all aspects of waste management, including underground injection control. Timing: The waste management plan will be completed by the end of the second quarter 2007. . . 2) Implementation of Guidelines. Forest has already implemented the above guidelines but is awaiting approval from the Commission before it finalizes them. 3) Training: All Forest Oil employees and contractors were trained in 2006 on the compliance guidelines. The training will be conducted annually and expanded when the waste management manual is completed. Timing: Annual trainingfor 2007 will be completed by the end of the 2nd quarter. 4) Other: Forest Oil has received a Class I permit from EP A for the injection of non- hazardous wastes into RV Dl. That permit will not go into effect until EPA witnesses the successful conclusion of Mechanical Integrity Testing and other testing required by the Class I permit. Timing: The required testing on RU Dl is expected to be completed by the end of May 2007. If you have any questions, please contact me at 868-2166 or at rgelder@forestoil.com. Sincerely, /) /" / Jf /,/' " ,. /'f f?Ê J , ,.t'r ~~c" ,: \_' .. Bob Elder HSE Manager #11 . . @ FOREST OIL CORPORATION S 1 0 ciJ{Q9t~e(; - &:UÆe 700 QÇ:/nc¡;ßr~"7ø ~ Qyf¡,.£5ka .9.9501 (907) 2.5/?-SCOO · (907) 25S-SCOt (Q'Þa.;¿) February 15,2007 RECEIVED FEB 1 6 Z007 Mr. John Norman, Chair Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 Alaska Oil & Gas Cons. Commission Anchorage Re: Response to AOGCC Proposed Decision and Order No. 46 Improper Class II Injection at Redoubt Dl Dear Commissioner Norman: On January 30,2006 Forest Oil Corporation (Forest Oil) received Proposed Decision and Order No. 46 from AOGCC, dated January 29,2007. Forest Oil is grateful that the Commission has recognized our efforts toward improving our injection program, and for waiving the proposed civil penalty in this case. In the Proposed Decision and Order the Commission ordered that Forest Oil: 1. Provide the Commission with underground injection guidelines within 90 days that ensure Forest Oil's compliance with regulatory requirements and implementation of best management practices for disposal and enhanced recovery injection at all Forest-operated facilities in Alaska; 2. Implement the injection guidelines upon their approval by the Commission; and 3. Provide the Commission with written confirmation that all personnel involved in injection operations and decisions have received the training consistent with the new best practices guidelines. Please find Forest Oil's proposed injection guidelines in Attachment 1. These guidelines are presented in the form of a compliance matrix ofUIC Permit Stipulations. The matrix summarizes the requirements of all of Forest Oil's disposal and enhanced recovery injection orders, which wells they apply to, which substances may be injected into each well, and the associated reporting and monitoring requirements. The monitoring and reporting requirements for each injection well are color-coded to indicate the personnel responsible for acquiring the necessary information to generate reports. A summary . . matrix of Permissible Injection Fluids for each ofthe Class II wells operated by Forest Oil is presented as Attachment II. Also, please find an attached training roster (Attachment III) documenting that all employees and contractors involved in injection operations and decisions have received the appropriate training on waste management, including VIC and RCRA. Forest Oil will modify the guidelines and training program as appropriate pending final approval by the Commission. Additionally, Forest Oil is initiating work on constructing a comprehensive waste management manual that will instruct all employees on proper waste management and disposal practices, including compliance with UIC and RCRA requirements. Forest Oil regrets that this incident occurred and thanks the Commission for its efforts to help us resolve the matter in a constructive fashion. If you wish to discuss any aspect of the proposed guidelines, or have any questions, please contact me at 868-2166 or rgel der(cV,forestoil. com. Sincerely, ß~~ Bob Elder HSE Manager cc: Jim Regg Attachments: 3 A TT ACHMENT I. UIC Permit Class I Order I Issue Date I Exp Date I Approved Formation Reporting Fluids Middle Tyonek below 6500' Produced Water from RD Sanitary Waste (003) from Osprey separated at KPF Only Class II (from "downhole") Fluids related to Osprey none none 4/10/2003 8/9/2001 010 No. 26 010 No 22 20 20 Well#- RU #01 KF No. Well # Class Order Issue Date Exp Date Approved Formation Fluids Class II Fluids Tyonek DIONo. (from between WMRU 4D 2D 16 9/3/1998 none "downhole", 570B'and from any 6305' facility) Produced Water -RD Produced Water- WMRU Deck Drainage (002) from Osprey within 90 days of start- up anniversary Sanitary Waste (4/25/05) (003) from Hemlock Submit by RU #6 EOR 2 EOR ERIO 8/26/2004 9/30/2007 Osprey between July 1 ea yr NO.2 15,130' and 15,890' Domestic Waste (Gray Water-004) from Osprey Order Conservation Order NO.566 (spacing exception) Issue Date Exp Date Rule Field and Pool Name Pool Definition 8/24/2006 none Drilling Unit Extent, Well Spacing and Gas Pooling Common Production Facilities and Surface Commingling Reservoir Pressure Monitoring Annual Reservoir Review KF No.1 S ~~:# ~~~oo The field is the Kustatan Field. Hydrocarbons under the affected area and in the defined interval is the Kustatan Field :# 1 Gas Pool: 2 Tyonek 5,367'-5,352" MD Not more than one well may be completed in the KF #1 Gas Pool. 3 If additional information indicates the KF #1 Gas Pool extends beyond the effected area described in the order, notify AOGCC by close of business the next day. 4 Meter by a dedicated custody transfer metering system prior to entering the gas gathering system. 5a 5b Obtain pressure surveys as needed to effectively manage hydrocarbon recovery subject to annual plan (see 5d). The reservoir pressure datum is 5,353' MD. Pressure surveys may consist of stabilized static pressure measurements at bottom hole, pressure fall-off, pressure buildup, multi- other appropriate technical pressure transient or static tests. 5e 5f Intra Intro 6a 6b 6c Overview of reservoir performance, Future delopment and reservoir depletion plans, Surveillance information for the prior calendar year, including: Reservoir maps at datum; Summary and analysis of reservoir pressure surveys; Estimates of reservoir pressure; Results and, where appropriate, analysis 0 production, temperature, tracer surveys, observation well surveys, and any 0 monitorin surve s: Estimates of yearly production; Progress of plans and tests to expand the productive limits of the pool; and Results of surface safety valve testing. 6d 6e 6f 69 Order Issue Date Exp Date Rule Conservation Order NO.566 8/24/2006 (cont'd) none Well Mechanical Integrity and Annulus Pressures KF No.1 S Stipulation Rule # 7a Conduct and document a pressure test of tubulars and completion equipment in each devlopment well at the time of installation or réplacement. 7b Monitor each development well daily to check for pressure, 7c 7d 7e 7f Unless otherwise approved by AOGCC under 7C or 7e, before any shut-in well is placed in service annulus pressure must be relieved to a sufficient degree that: (1) the inner annulus pressure at operating temperature will below 2000 psig, and (2) the outer annulius pressure will be below 1000 psig. A well subject to 7c but not to 7e may reach an annulus operating pressure at operating temperature that is decribed in the operator's notification to AOGCC under 7c, unless AOGCC prescribes a different limit. Defintions OGCC can amend or waive any rule stated above. Well # Class WMRU 2A EOR 2 EOR Order ERIO NO.03 Issue Date Exp Date 11/6/2006 11/6/2008 Approved Fluids Produced Water- WMRU Deck Drainage (002) from Osprey Produced Hemlock Water from Redoubt Produced Tyonek Water from West Foreland Secondary Containment Water from KPF, WMRU Formation West McArthur River Oil Pool ATTACHMENT II. SUMMARY OF PERMISSIBLE INJECTION FLUIDS Well Fluid RU #D1 WMRU 4D RU #6 EOR WMRU 2A EOR Class II Fluids Related to Osprey OK OK Only produced water Only produced water Class II Fluids from Any Facility NO OK NO NO Sanitary waste from Osprey OK NO OK NO Gray Water from Osprey NO NO OK NO Deck Drainage from Osprey OK NO OK OK Produced Water from Redoubt OK OK OK OK Produced Water from WMRU NO OK OK OK Produced Water from West Forelands NO OK NO OK 12° Containment Water-KPF NO Only if contaminated with OK OK Class II 2° Containment Water-WMRU NO Only if contaminated with OK OK Class II . . #10 . . @ FOREST OIL CORPORATION ,'NO QX(j-Jí:¡cee( . 97:Út.e 700 Q9ÍnChÆÞJca¿f€f QQ/lajka .9.9.S01 (907) 2.95-8600 · (907) 2.?r5'-r5'6'01 (Q'ßa.,) June 15, 2006 RECEIVED JUN 1 9 l006 Alaska Oil & Gas Cons. Commission Anchorage Mr. John Norman Chairman Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, AK 99501 Re: Update on Forest Oil's Response to Notice of Proposed Enforcement Action Dear Mr. Norman: The Commission's letter of January 12,2006, proposing an enforcement action relative to Disposal Injection Order (DIO) No. 22, contained a proposal to order Forest to correct deficiencies in its disposal injection management practices. On February 23,2006 we participated in an Informal Review with you, the other Commissioners, and Mr. Jim Regg. At the conclusion of that Review, AOGCC agreed to reconsider the proposed enforcement action. We have not yet received a reply from the Commission but would like for you to be aware of what steps Forest has taken to prevent a reoccurrence of improper injection incidents. The following waste management controls have been developed and implemented: · Compliance Matrix. All of Forest Oil's injection and EOR orders have been thoroughly reviewed and a compliance matrix has been created showing the respective injection orders, what wells they apply to, what substance can be disposed of in each well, and what the reporting and monitoring requirements of each are. . Training. Forest has conducted training for all employees and contractors on waste management including UIC and RCRA. The training will continue annually. . W AP. Forest developed a Waste Analysis Plan (W AP) for RU# 6, the EOR well on the Osprey Platform. That plan was implemented in 2005 and incorporates initial comprehensive testing of all non-exempt injection streams for hazardous waste characteristics followed by quarterly sampling for fingerprint characteristics and key hazardous waste parameters. . . . Class I Conversion. Forest has begun to convert RUD#l and WMRU 4D, two Class II disposal wells, to Class I non-hazardous waste wells. We have already submitted a request to EP A for a determination of non-underground sources of drinking water (USDW) and are in the process of preparing an application for a Class I permit( s). This will expand the list of wastes that may be currently injected into RUD#1 and WMRU 4D. Please call if you have questions or if you would like to inspect documentation of any of the above. Sincerely, ;¡;4vf2Y~ Bob Elder HSE Manager 907-868-2139 rgelder@forestoil.com #9 . . ~ FOREST OIL CORPORATION .'11097Ccf/tJrær. cf/:uUi 700 o9Ínckr'"'.[1le~ O9ÍIadka. ,9,9.501 (907) 2:;/1-86'00 · (907) /2,5/1-86'01 (Q'ßax) March 3,2006 RECE'VED MAR 0 7 2006 Alaska Oil & Gas Cons. Commission Anchorage Mr. Jim Regg Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 Re: Request for Additional Information Redoubt Unit #D I DIO No. 22 Dear Mr. Regg: At the Commission's request during our meeting on February 23, Forest Oil has itemized the costs incurred for the injection of gray water on the Osprey. The attached cost summary includes both equipment and labor. Also attached is a hand-drawn diagram showing the configuration of the equipment in relation to other components of the injection system. Basically, the system consists of domestic waste water (gray water, discharge #004) from camp sinks, showers and laundry that is currently being injected into RU-6 EaR. The diagram shows domestic waste water being discharged overboard through leg #1. That was the disposal option before RU-6 became available for injection. The diagram also shows a connection to RU #DI, which is the way the system was configured during the mistaken injection of gray water. In that case, gray water was commingled with deck drain (#002) water and treated sanitary waste (#003) in an oily water separator before being further commingled with produced water and injected into RU #D 1. A closed valve now prevents that from occurring. We appreciate your reconsideration of the issue. Please call me at 686-2139 with any questions or if you need additional information. Sincerely.. I<~/ß~~ Bob Elder HSE Manager. Man/hrs $1,736.00 6 $1,736.00 6 o o o o 4 6 24 12 20 7 o o 85 Total man hours 3825 Total man hour cost @ 45/hr Forest Oil Osprey Platfrom Gray Water Injection Assembly Cat Pump #1 Pump Model 70RS Motor Mod 991778 Cat Pump #2 Pump Model 70RS Motor Mod 991778 (Each rated 5000 psi at 1096 rpm, 2.8 gpm at 8.5 amps. 460 volt, 3 phase) Spare pump parts inventory $350.00 4"Suction Basket strainer Suction valves and fittings Discharge valves, hoses and fittings 500 gal holding tank 1 000 gal holding tank 4" PCV Valves and fittings $475.00 $230.00 $450.00 $615.00 $874.00 $575.00 Chemicals Lab Testing Equipment $350.00 $480.00 $7,871.00 e $7,871 $3,825 Total cost $ $11.696 . ·~.~"/~¡ ".,;:1:';............. ',' .':.:....'. '?:'~.:;. '..::.....::.. .: ." .. ::::.', " i:r .......... , " '. .J - . :~,.. ::1 .. ·::::·'l·:ì9~iIf::·i:i~ ~.. "P' ,- ,-.' . ", .','. - ,." ',!f~~!, ,: .... ... .)!i,{t~~f~îiì~ ì . . ,.... . . ., .,.. ..11;..... 1(', . . ....... .: .. .: . ...... "'."'" . .... '.' . '." ..,. .... "'_'. ':ð.1'!". :-'. .C·· . :'.,."': '..... ... ,.';...,....::. ··'··.:~~f· r" . . ......-. -,.. .. '. . ", . .... ,:0" ,,,. " :,"'::.::,.,:;.:.,:,.:;:":,::.:"'-,,,-::::..,,;.,:.: .......:....>'.,¡.;".,. ~~, þj.:[iii:i¡;;ú;~,j!ii",· I) 'J , ) ) ';,';:; ~ f ;r.¡ ,j .. I .I. ...., ".'., .. 5 oj ~ ..¡';', .. L #8 RE: Itemized Injection Costs-Osprey . . I should have you something on this tomorrow, Jim. Bob -----Original Message----- From: James Regg [~~l} ts>: j irr.'...E_"'ß3~admiE_.:~_~.~_~.~.~ a~_~~~] Sent: Tuesday, February 28, 2006 2:52 PM To: Bob Elder Subject: Re: Itemized Injection Costs-Osprey Thank you for the itemized costs. Do you have any information on the labor cost for installation of this equipment? I would like to have something more formal than an email message. A brief report with a description of the equipment, cost, and timeline for the completed installation would be sufficient. I believe you previously provided us a flow schematic of the facility for the waste stream - suggest integrating that into the report as supporting information with any updates as needed. Jim Regg AOGCC Bob Elder wrote: Jim- At the Commission's request during our meeting on February 23, we've itemized the costs incurred for the injection of gray water on the Osprey. Please review the summary below and let me know if it satisfies your needs. Thanks Bob Cat Pump #1 Pump Model 70RS Motor Mod 991778 $1,736.00 Cat Pump #2 Pump Model 70RS Motor Mod 991778 $1,736.00 (Each rated 5000 psi at 1096 rpm, 2.8 gpm at 8.5 amps. 460 volt, 3 phase) Spare pump parts inventory $350.00 4"Suction Basket strainer $475.00 Suction valves and fittings $230.00 Discharge valves, hoses and fittings 500 gal holding tank $615.00 1000 gal holding tank $874.00 4" PCV Valves and fittings $575.00 $450.00 Chemicals lof2 3/8/20063:16 PM Rb: Itemized Injection Costs-Osprey $350.00 Lab Testing Equipment $480.00 $7,871.00 20£2 . . TOTAL 3/8/20063:16 PM #7 . . ÚzgJ~ STATE OF ALASKA /,t.. 7~ OIL AND GAS CONSERV A TION COMMISSION Redoubt Unit Dl- Informal Review /7/J... . Febru~;:)06atl:30pm r /J. £'. .__ ~~d/¿f..<LJ_ ::O{~A'--L;t4~ NAME - AFFILIATION ADDRESS/PHONE NUMBER TESTIFY (Yes or No) (PLEASE PRINT) ~J k/'J-p-z.?ý 210 Ie.... Sv/'.J<-; '700 J. eO/l/O f'rJ G (Á r vl F0I'(?-S I" 0 r ( I /fo.6't"f'r E I dp r ;ZÕR'£5~T , ðìf- 2.l3? 86 r? - :</ ó-ô 8"6cT -c? 13 7' #6 ~1f~1fŒ mJr ~~~~æ~ . ALASKA. OIL AND GAS CONSERVATION COMMISSION FRANK H. MURKOWSKI GOVERNOR 333 W. 7'" AVENUE. SUITE 100 ANCHORAGE, ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 January 26, 2006 Bob Elder HSE Manager Forest Oil 310 K Street #700 Anchorage, AK 99501 Re: Improper Class II Injection in Redoubt D 1 Enforcement Action Dear Mr. Elder: The Alaska Oil and Gas Conservation Commission ("Commission") acknowledges receipt of your request for Informal Review of the Commission's proposed enforcement action regarding the Improper Class II Injection in Redoubt Dl. An Informal Review meeting has been scheduled for February 23, 2006 at 1:30 pm at the Commission's Offices at 333 West 7th Avenue, Suite 100, Anchorage, Alaska. Should you have any additional documentary evidence you wish to provide to the Commission, please submit it at least one week prior to the informal review meeting. If you have any questions you may contact the Commission's Special Assistant Ms. Jody Colombie at 793-1221. Sincerely, cq(f;;~ Commissioner cc: AOGCC Commissioners #5 . . @ FOREST OIL CORPORATION January 25, 2006 310 dYC cfJ(-"7wÆé. ¿;;uw 700 Q9Ínchon71lÆJ QQ{¡u6ka .9.9501 (.907) 2/¡/I-(?600 · (.907) 2.5/1-/1601 (~CE'VED JAN 2 7 l.1:mG A\a$ka 0" & Ga$ CQO$· cQII1IisSion ~ncbof198 ~.._-4 Mr. Jim Regg Alaska Oil and Gas Conservation Commission 333 West ih Avenue, Suite 100 Anchorage, AK 99501 Re: Response to Notice of Proposed Enforcement Action Dear Mr. Regg: Forest Oil Corporation (Forest) received the Commission's letter of January 13,2005, proposing an enforcement action relative to Disposal Injection Order (DIO) No. 22. Forest requests an informal review ofthe proposed action to ensure that all relevant information has been considered and that the factors used in the determination of the proposed penalty are accurate. Forest agrees that domestic waste water was inappropriately injected into a Class II disposal injection well (Redoubt Unit Well Dl) on the specified dates. Forest would like to emphasize, however, that the injection occurred under the mistaken beliefthat it was acceptable. As you are aware, DIO 22.002 authorizes the injection of sanitary waste commingled with produced water. The mistake occurred when it was assumed that domestic waste was part of the sanitary waste stream and, thus, acceptable for injection. This mistaken assumption occurred because both sanitary waste (discharge 003) and domestic waste (discharge 004) were originally reported on EPA pre-printed discharge monitoring report (DMR) forms (see attached example) as one combined discharge (discharge 003, 004). Forest accepts full responsibility for the mistake but wanted the Commission to understand how the error occurred. The delay in notifying AOGCC was an oversight that Forest also accepts responsibility for. Forest requests that the Commission, in calculating the final penalty, consider as a mitigating factor, in addition to those already mentioned in the January 13,2005 letter, the fact that Forest self-reported the error when it realized that it had not been reported and stopped the practice when it was realized that it was still occurring on November 30, 2005. Forest would also like the Commission to consider that domestic waste consists of only sink and shower drain water, has been demonstrated to be non-hazardous by a comprehensive testing procedure, and did not harm the environment or the public. One of the arguments that the Commission uses for the imposition of a significant penalty is "benefits derived by the Operator". Forest has been working to develop a zero surface discharge facility on the Osprey Platform for some time. Weare pleased to announce . . that this goal, with the exception of fire control system test water, has been achieved. Fire control system test water is simply recycled water from Cook Inlet discharged through our fire water pumps once a month during testing. The zero discharge goal was achieved with the issuance ofERO 2.001 on July 14,2005. However, at no time did Forest realize benefits by injecting domestic water. In fact, it cost Forest more to inject the waste in question than to discharge it into Cook Inlet. The necessary tanks and pump for injection cost approximately $8,000 whereas the ability to discharge into Cook Inlet has always existed and currently is still an option. Finally, the Commission listed four questionable practices in footnote #2 in the January 13,2005 letter. Clarification is required on two of these: . Iniection of fluid mixture into WMRU 4D prior to Commission approval (DIO 16.001). This, in fact, did not occur. Forest requested approval for injection of the fluids in question but did not inject them until after DIO 16.001 was issued. . Missing annual iniection performance report for 2005. Forest has a copy of this report with a cover letter (see attached) to the Commission signed by Mr. Ted Kramer on June 29, 2005. If it was not received, Forest would be glad to send another. It is our understanding that the proposed penalty of $39,000 is based on the maximum daily fine allowable. Forest's opinion is that the proposed fine is excessive based on the nature ofthe discharge, Forest's self reporting of the incident, and Forest's continued efforts to achieve a zero-discharge facility to reduce environmental impacts. It is our belief that Forest's good-faith efforts to remedy the error and improve operations on the Osprey should be given weight in considering a reduction of the fine. Forest respectfully requests the Commission to consider these factors in calculating the final penalty with the hope that the amount can be reduced from the proposed $39,000. Thank you for your consideration of this matter. Please contact me if you have questions or need additional information. We would be glad to meet with you informally for further discussion if you think it would be beneficial. Sincerely, ø~ Bob Elder HSE Manager 907-868-2139 rgelder@forestoil.com Attachments: 2 PERMm-ee NAMElADu.. J: (Includ' F.cili!l N.melf..ocøtion If different) NAME: FOREST OIL CORP ADDRESS: 310 K STREET ANCHORAGE AK 99501 NA TI0NA" PO""UT ANT DISCHAI'! .MINA TION SYSTEM (NPDES) DISCHARGE MOr.n'ORING REPORT (DM~ P:~~;~~~~~R I ~DISCH~~~E ~~MBER MONITORING PERIOD F""M APPROVED NO.2040-0004 ','vO'" FACILITY: OSPREY PLATFORM LOCATION: COOK INLET ATTN: ROBERT ELDER PARAMETER AK YEAR MO DAY FROM 02101101 YEAR MO DAY 02101131 QUANTITY OR WADING QUALITY OR ... NO DISCHARGE [=:J NOTE: Read Instructions befora completing this form. CONCENTRATION ... EX OF ANA" YS IS AVERAGE MAXIMUM MINIMUM AVERAGE MAXIMUM UNITS FLOW RATE (MONTHLY AVG) ***** <It..'it. M"'N"'H"'y···· ;ji[Â~Q;tii:-:· FLOATING SOLIDS ****** FOAM FECAL COLIFORM CHLORINE, TOTAL RESIDUAL BOD SOLIDS. TOTAL SUSPENDED .', S1· ;::;;::¡:iH>: :::!i: ¡j6~lLY'MXn "," <.;.:. :::::.: .:.:.:. NAME I TITLE PRINCIPAL EXECUTIVE OFFICER I ccniry IInderpenallY 01 law IhI. thi5ðocllJI\Cnl .ndallllllehll\Cl\lS were prep.lred Undllll'ly dir$CtlonOflllp;M.lonllllCQlrdlntICwilh.S)'llllnduilnIl4101l.urclhllqUlIIficdpcrsonncl G'B ry Carlson / pro,trly Jltlll' .nd c."I¡¡ale tilt illrOn"llion IlItlll\iltocl. Based 0110 Ihe illl1l1iry orllle person or IIU$ON wllo In~nl.e tile Symm. 01 tholll penon1 dircaly n:lpon.ible tor ,llhen"" 'he inlonn.lloft, the Sen i or V ice PresideD t ¡I\I'OMlUllion IIIbmillod ii, to Ihe belt 01 "L~ knowJod.O Ind belief, 11\10. ICClII'lle, .nd COfI'iplelC. I.m IWlre IMllhclC an: li,ninÇanl pnWll.. for '''Inlllinl Mil: ¡ÑonIllLlon. IlKIlldinl 1M PDllibillty of TYPED OR PRINTED ftnelndirnpriIOMlCmforknowln.viollljON. COMMENT AND EXPLANATION OF ANY VIOLATIONS (Refe,ence .11.Horh",ents here) ] SIGNATURE OF PRINCIPAL EXECUTIVE OFFICER OR AUTHORIZED AGENT 907-258-8600 .... cod, NUMBER YEAR I MO I DAY EPA Form 3320-1 PAGE 1 OF 1 · e (,- G ~ FOREST OIL CORPORATION .j I (/ r;)((-5íJ~,yd . ,~Y5N/(' ;I;(I 0'¡;'''¡;''N~7('' Dr:lill.;/II .9.'6(1/ (.907) .?.is_Sf/O(i . (9(;7) ,.....;S-J6·r: / (r-.';¡;;.,.) June 29, 2005 Alaska Oil and Gas Conservation Commission 333 W. 7th Avenue, Suite 100 Anchorage, Alaska 99501 Attn: Mr. Tom Maunder Re: Redoubt Unit #D1 - Annual Report 2004 - 2005 Dear Mr. Maunder, This report is in response to the requirements for annual surveillance reporting on the Redoubt Unit #D1 Class II disposal we/!. Rule #4 of the Disposal Injection Order #22 requires this surveillance. This well has been used for disposal of Class \I drilling wastes generated from the drilling of all Redoubt Unit wells after Redoubt Unit #2. The well has been operating within what we consider normal parameters and has shown no sign of integrity problems. A slick line tag performed on May 1,2005 encountered fill at 8,056' MD. If there are any questions, please contact me at 907-868-2137. Sincerely, d-{,~ Ted E. Kramer Production Manager Forest Oil Corporation #4 @¡¡':-;:;:¡!N~;¡--"' ',- II 1'\;' !r ~, í" , J;:::J in"'\ '. \., ~! ff.~ \. I, I. I ~ U lJlj' l!::! . rñàf? ¡Hili IlüLF . ,....., {¡, \ I U ,. lJ-lJ FRANK H. MURKOWSKI, GOVERNOR AIJASIiA OIL AlÐ) GAS CONSERVATION COMMISSION 333 W. T'" AVENUE. SUITE 100 ANCHORAGE. ALASKA 99501-3539 PHONE (907) 279-1433 FAX (907) 276-7542 January 12, 2006 Certified Mail Return Receipt Requested 70050060000157537116 Mr. Bob Elder Forest Oil Corporation 310 K Street, Suite 700 Anchorage, AK 99501 Re: Notice of proposed enforcement action Improper Class II Injection in Redoubt D 1 Dear Mr. Elder: Pursuant to 20 AAC 25.535, the Alaska Oil and Gas Conservation Commission ("Commission") hereby notifies Forest Oil Corporation ("Forest") of a proposed enforcement action including required corrective actions and a $39,000 civil penalty. The Commission considers that Forest has violated provisions of Disposal Injection Order No. 22 ("DIO 22"), Rule 2 (Authorized Fluids) in connection with operating Redoubt Unit ("RU") Well Dl. Specifically, it appears that Forest violated Rule 2 of DIO 22 by injecting domestic wastewater generated at the Osprey Platform into RU Well D1, designated a Class II disposal injection well under provisions of the Underground Injection Control ("UIC") program. Rule 2 of DIO 22 provides: This authorization is limited to Class II waste fluids as follows: produced water, drilling, completion and workover fluids, rig wash, drilling mud slurries, NORM scale, tank bottoms, and other fluids brought to the surface in connection with oil and gas development activity on the Osprey platform. Three administrative approvals under DIO 22 further define the fluids eligible for injection into RU Well D1.1 I DIO 22.001 authorizes injection of storm water collected on Osprey platform; 01022.002 authorizes injection of a mixed stream of treated sanitary effluent and produced water; DIO 22.004 authorizes the commingling of appropriate Class II oilfield wastes trom West McArthur River Unit Production Facility, Kustatan Production Facility, and various planned exploration drilling activities on the West side of Cook Inlet for the purpose of disposal injection into RU Well 01. Bob Elder January 12, 2006 Page2of3 . . In a letter dated December 15, 2004 Forest acknowledged that domestic wastewater was injected into RU Well DI from October 23, 2004 until November 30, 2004. Forest further reported that the total volume of domestic wastewater injected was 5,389 gallons (approximately 128 barrels). There is no record that Forest obtained Commission approval to inject domestic wastewater into RU Well D1. Forest requested authorization to inject non-hazardous domestic waste into Well D 1 subsequent to discovering the apparent deficiency but at that time failed to notify the Commission of ongoing domestic wastewater injection into Well D1. The Commission's administrative action DIO 22.003 dated November 8, 2005 denied Forest's request on the basis that domestic wastewater is not included in the array of approved and appropriate Class II fluids and is properly disposed of into a Class I disposal well according to the UIC regulations administered by the EP A. The Commission proposes to order Forest to correct deficiencies in its disposal injection management procedures as follows: 1. Within 90 days, Forest shall be required to provide the Commission with underground injection guidelines that ensure the operator's compliance with regulatory requirements and implementation of best management practices for disposal and enhanced recovery injection actions taken at all Forest-operated facilities within Alaska; 2. Upon approval of the guidelines by the Commission, Forest shall be required to implement the injection guidelines; 3. Forest shall be required to train all field personnel engaged in injection activities with the new best practices guidelines, and shall provide the Commission with written confirmation that all personnel have received this training; 4. Forest shall be required to provide written progress reviews detailing corrective actions completed, and updating the status and timing for the completion of unfinished corrective actions. The report shall be due on or before the 15th of each month following the effective date of the enforcement order, and until all corrective actions have been completed. In addition, the Commission proposes to impose civil penalties on Forest under AS 31. 05 .150( a). The Commission is authorized to assess a civil penalty of up to $5000 per day per infraction. In determining the amount of a civil penalty, the Commission has generally considered: (1) the good or bad faith of an operator in violating the law; (2) injury to the public resulting from the violation; (3) the benefits derived by the operator from its violation; (4) the operator's ability to pay a penalty; (5) the need to deter similar behavior and to protect the integrity of regulations, orders, and other Commission requirements, and (6) the history of violations by the operator. Bob Elder January 12, 2006 Page 3 of3 . . Mitigating factors regarding the civil penalty amount proposed in this case are (1) Forest's good faith effort to reconfigure domestic wastewater disposal systems to ensure compliance with Commission regulation and orders, and EPA's National Pollutant Discharge Elimination System requirements; (2) the lack of injury to the public as demonstrated by the good mechanical integrity of RU Well Dl; and, (3) the confinement to the intended injection zone of all fluids injected into RU Well Dl, as most recently confirmed by the Commission as part of administrative action DIO 22.004. However, other factors argue for a significant civil penalty amount including (1) the benefits derived by the Operator (continued operation) and (2) the need to deter similar behavior and protect the integrity of the regulatory process. In particular, regarding the need to deter, failure to comply with disposal injection regulatory requirements is a significant noncompliance category of violation as identified by the EP A under UIC guidance. Forest also has a recent history of other questionable compliance practices involving disposal injection.2 Therefore, Forest shall be ordered to pay a civil penalty to the Commission in the amount of $39,000 ($1,000 per day for 39 days3). This penalty shall be due thirty (30) days from the date the Commission's Order becomes final. As provided by 20 AAC 25.535(c), within 15 days after receipt of this notification Forest may file with the Commission a written response that concurs in whole or in part with the proposed action described herein, requests informal review, or requests a hearing under 20 AAC 25.540. If informal review is requested and Forest disagrees with the Commission's proposed decision or order after that review, Forest may then request a hearing within 10 days after the proposed decision or order is issued. If Forest does not file a timely written response to this notification, the Commission will consider Forest to have accepted by default the proposed action described above. If Forest requ' s more than 15 days to respond, you may for good cause shown request an extensio of t e -day response period. ---Daniel T. Seamount, Jr. Commissioner Cathy P oerster Commissioner 2 Injection offIuid mixture into WMRU 4D prior to Commission approval (DIO 16.001); unauthorized perforated interval in WMRU 4D (DIO 16.002); missing annual injection performance reports (2001 and 2005) per DIO 22, Rule 4. 339 days tram October 23, 2004 through November 30,2004. ~",---"--.."",.""".,,---,,,,--., ..._.....,~,.._....--_._- 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 · ~{){§jJ ~AN.L'1 2 AOGCC . . . T ,,,'Ifff 333 W 7th Ave, St .' . ~Ia. GaB .Cons £ Anchorage, AK 9 \IW Jfílè¡f(,P8~; 'w Anchora-,i /1,/,,1, i 1"/' i, ¡¡"", 11,,/ I"I,I! I,!,i" I /"I! /,I! I, ,I,ll · 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 maìlpiece, or on the front if space permits. 1. Article Addressed to: 1306 ¿\C\ey ço'(~t:- 0\ L 3\0 ~ ~-\- {Fl00 H '(lcV"" 'A 'L C\~ 1 3. ~Type ~ertified Mail 0 Express Mail · o Registered ~turn Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from service label, PS Form 3811, August 2001 7005 1160 0001 5753 7116 Domestic Return Receipt 102595-02-M-0835 ~ UNITED ST..17Ej: Iflr POST..1L SERV/ë¡f ***** WELCOME TO ***** 5TH AVENUE POSTAL STORE ANCHORAGE, AK 99501-2351 01/12/06 10:14AM Store USPS Trans 6 \~kstn sys5002 Cashier KGS::Jh'l Cashier's Name DENISE Stock Unit Id WINDENISE PO Phone Number 800-275-8777 USPS # 0203150535 1. First Class Destination: Weight: Postage Type: Aft ix. Post.: Total Cost: Base Rate: SERVICES Certified Mail 70051160000157537116 Rtn Recpt (Green Card) O.dO 99501 0.80 oz. Aft ixed -4.64 4.64 0.39 Subtotal Total 2.40 1.85 0.110 0,;10 Number of Items Sold: 1 We here at the Posta 1 Store appre, :iate You as our customer and wish you a Happy Holiday and a Safe Nm~ Yedr ..D Ñ Ñ I"'- m U' I"'- U' U.S. Postal ServiceTM CER,TIFIEDrMAlbM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) ~'r 1;.. InC·, I A L USE Postage $ /\ '1r, ¡ r !T~ '.t",,, ."~r:'-r'7 Ñ c::J Certified Fee c::J c::J Retum Receipt Fee (Endorsement Required) t:J Restricted Delivery Fee ~ (Endorsement Required) Ñ U' t:J t:J I"'- n "'··0 ¡ '¡r" PS Form 3800, June 2002 See Reverse for Instructions #3 . . ~ FOREST OIL CORPORATION .J 1 0 dYC 9J7?<ee? CX1~de 700 Q~tckw~j Q9Ílad-a c9.9501 (.907) 2.58-86YJO · (907) 2,5'8-,,'6'01 f;Jßæc) January 4, 2005 Mr. Jim Regg Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Anchorage, Alaska 99501 RECEIVED JAN 0 4 2005 Alaska Oil & Gas Cons. Commission Anchorage Re: Notification oflmproper Class II Injection Redoubt Unit #Dl DIO No. 22 Dear Mr. Regg: As I reported to you on December 15,2004, Forest Oil Corporation (Forest) has become aware of possible improper Class II injection of waste into the Redoubt Unit D 1 well. Gray water from sinks and showers on the Osprey Platfonn was mistakenly injected into D 1 well from October 23,2004 until November 30,2004. The total volume injected into the Dl well during this period was 5,389 gallons. The Osprey Platform operates under an NPDES permit. Sanitary waste and domestic waste (gray water) are two of the permitted discharges in that permit. At one time both sanitary waste and domestic waste were commingled and reported on Monthly Discharge Monitoring Reports (DMRs) as one waste stream. Because of difficulties in meeting discharge limitations with sanitary waste, Forest requested permission from the Commission to inject sanitary waste into the Dl well. Subsequently, AOGCC issued administrative approval DIO No. 22.002 on February 3,2004 to allow treated sanitary waste to be commingled with produced water and injected into Dl well. Gray water continued to be discharged separately into the Cook Inlet. In September 2004 a pH reading from the gray water system was slightly lower (6.0) than the NPDES permit limit of 6.5- 8.5. This was the only instance in the history of the platform where the gray water system exceeded the NPDES allowable limits for pH but to avoid further NPDES violations Forest management instructed field operations personnel to inject gray water into well Dl. The basis for this decision was that because both domestic and sanitary wastes were combined at one time and reported as a singled commingled discharge on the DMRs, it was thought that that DIO No. 22.002 applied to gray water as well as to sanitary. The injection started on October 23,2004. In November 2004 Forest began a comprehensive internal environmental audit of all the DMRs from the Osprey Platform from November 2000 until present. During the course of that audit it . . became evident that gray water may not qualify as part of the sanitary waste stream under the provisions ofDIO No. 22.002, even though both were included as one discharge on earlier DMRs. On November 19,2004 Forest sent a letter to the Commission requesting authorization to inject gray water into the DI well but inadvertently failed to notify the Commission of the improper injection that had already taken place. Forest immediately began reconfiguring for an overboard discharge of gray water again but to prevent further NPDES violations ordered two holding tanks (a 1000-gallon and a 500-gallon) so that appropriate testing and treatment could be made before discharging. That installation was not complete until November 30, 2004 at which time injection ceased. The Osprey is currently discharging gray water into Cook Inlet again but the process of taking pH measurements and adjusting pH to meet NPDES permit limits is laborious and time consuming. The pH issue did not become problematic until recently when the platform was preparing for a significant increase in personnel (from about 6 to over 40) for a workover which is currently in progress. During an inspection offield records aboard the Osprey in December 2004 it was realized that injection of gray water had occurred until November 30 and that AOGCC had not been notified of the event. Forest fully understands the requirement to dispose of only Class II fluids into the Dl well and sincerely apologizes for the misinterpretation of the injection order and for the failure to notify the Commission in a timely manner. At your request I am enclosing a hand-drawn schematic of the discharge plumbing for deck drains, fire water, gray water and sanitary waste. The only overboard discharges currently occurring from the Osprey are firewater (test) and domestic waste. Please call me at 686-2139 with any questions or if you need additional information. Sincerely, ßkéPA Bob Elder HSE Manager Enclosure: 1 #2 . . Misinjection at Redoubt Dl (Class 2D Well) Phone Records - J. Regg All conversations with Robert Elder, Forest (907-868-2139; rgelder@forestoi1.com) Date Time Summary Mr. Elder called to report injection of domestic waste water into RU Dl - Class II-D well; appears to be a misinjection; authorized to inject Treated sanitary waste but not domestic waste; unclear how this happened- 12/15/2004 10:00 AM possibly because 2 fluid streams are commingled when go overboard; he explained that Forest would like to be zero discharge, and is concerned with ability to operate under tight boundaries for pH in NPDES; asked for a written report; he requested mtg - told him I would check on staff availability and dates and call back 2:43 PM Left msg for Mr. Elder - Commissioner will not participate in mtg since it willlikley involve adjudication 12/15/2004 matter; Tom Maunder and I are available to meet; would like written report ofmisinjection before mtg 2:50 PM He returned my call; we agreed on mtg 12/27 at 10 am; written report will be submitted by end ofwk 12/21/2004 3:27 PM Will send letter tomorrow providing info about misinjection at Redoubt Dl; percursor to mtg next Monday 12/29/2004 9:53 AM He said could not locate a flow diagram of the waste streams as requested in Monday's mtg; will have engineer pull something together next week; I agreed to timing Asked if we have progressed further on misinjection at RU Dl; told him I have not completed the review- 4/1/2005 ]0:26 AM working on other priorities; he also advised that compatibility info in support of placing sanitary waste into EOR at Osprey will be provided possibly next week; told him we would close out the Admin Approva] aspect when info received #1 . . @ FOREST OIL CORPORATION .3 -10 QYC cfJt-¡¿eet - ~ite 700 QQ!;u::h01<cZ¡;re, QS2{¡a4ka ..9.950-1 (.907) 258-86'00 · (907) 258-86'01 (c;jÆo) November 19,2004 . .)'f 23 ?"11 , Commissioner John Norman Alaska Oil and Gas Conservation Commission 333 West 7th Avenue, Suite 100 Þ.Ilchorage, AK 99501 Re: Request for Authorization to Inject Gray Water into Redoubt Unit #Dl Class II Disposal Well Dear Commissioner Norman: Forest Oil Corporation (Forest) submitted a request to AOGCC on November 5, 2004 for approval to inject several types of fluids into Redoubt Unit #6 (RU-6) on the Osprey Platform for enhanced oil recovery under Enhanced Recovery Injection Order No.2, issued to Forest on August 26,2004. One specific fluid is gray water from sinks and showers on the platform. Gray water is permitted to be discharged under the terms of Osprey Platform's NPDES permit. However, Forest prefers to operate the Osprey as close as possible to a zero surface discharge facility to reduce the risk of exceeding NPDES discharge limitations. To accomplish this objective Forest continues to seek a favorable response from the Commission on our August 26, 2004 request to use gray water and other alternate fluids for EOR operations in RU-6. This letter is to request, in addition, approval to injectgray water into the Redoubt Unit #D 1 Class II disposal well as a backup to using gray water in EOR. This request is for the same reasons cited in DIO No. 22.001, issued on June 19, 2002 allowing the disposal of storm water collected on the Osprey deck to be injected into RUD #1, and in DIO No. 22.002, issued on February 3,2004, allowing treated sanitary waste to be commingled with produced water and injected into RUD #1. ... . . Gray water from the Osprey Platform is filtered through strainers for solids removal and would be commingled with treated sanitary waste before injection into RUD #1. Approximately 4000 gallons per day or less is produced. The pH of the water ranges from 6.0 to 8.5. Forest respectfully requests the Commission's approval to inject this fluid into RU-6 as make-up water for the EOR project authorized under Enhanced Recovery Injection Order No.2. Please contact me if you have questions or need additional information. Sincerely, J5tJl-~ Bob Elder HSE Manager 907-868-2139 rgelder@forestoil.com