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EPA prepares to issue OSA a UIC permit
Kay Cashman Petroleum News
The U.S. Environmental Protection Agency, EPA, is proposing to issue an underground injection control Class I non-hazardous permit to Oil Search (Alaska) LLC, a subsidiary of Santos NSW PTY Ltd.
The 10-year permit will allow Oil Search (Alaska), or OSA, to construct and operate up to three injection wells to insert non-hazardous waste into geologic formations deeper than 5,000 feet below ground surface -- specifically into the Lower Torok or Ivishak formations. Exact bottomhole locations will be determined following the construction of the wells, the federal agency said in a Sept. 27 public notice.
Injection will occur at the Nanushuk Processing Facility pad within the Pikka unit west of the central North Slope of Alaska. EPA has determined that the proposed injection wells will not impact underground sources of drinking water.
Alternative disposal methods include transportation to off-site treatment facilities and direct discharge to surface waters, both of which are costly and/or harmful to the environment, EPA said.
The wastes that will be injected may include produced water: desalination brine; domestic wastewater; drilling fluids and drill cuttings; stormwater; and other non-hazardous wastes.
The NPF pad is approximately 12 miles northeast of the village of Nuiqsut.
EPA said that no injection wells currently exist for the Pikka project.
Background EPA said it received an application from OSA on July 5, 2022, for a permit to construct and operate up to three Class I wells at the NPF pad within the Pikka unit.
While Nuiqsut is the nearest residential community to the NPF pad, "the primary commercial, industrial, and transportation hub in the region is Prudhoe Bay," EPA said, noting that the surface location of the NPF pad is approximately 52 miles west of Prudhoe Bay.
Regulatory framework The underground injection control, or UIC, program is authorized by Part C of the Safe Drinking Water Act for the principal purpose of protecting USDWs from pollution by injection through wells. A USDW is defined as an aquifer that is currently serving as a source of potable water or could potentially serve as a public water supply based on its productivity and natural water quality.
Primary responsibility for implementing the UIC program in Alaska is shared between EPA and the Alaska Oil and Gas Conservation Commission.
AOGCC regulates Class II injection wells, which are defined as those wells used (1) to dispose of waste fluids brought to the surface from oil and gas production operations, (2) for enhanced recovery of oil and gas or (3) for storage of hydrocarbons that are liquid at standard temperature and pressure. Wastes that do not meet these criteria cannot be injected into Class II wells but may be eligible for Class I well injection.
EPA regulates all other classes of UIC wells in Alaska, including Class I injection wells. Applicable regulations concerning injection well requirements can be found in 40 CFR Parts 144 and 146. Criteria and standards applicable to Class I wells are found at 40 CFR Part 146 Subpart B.
How to comment Persons wishing to comment on this proposed Class I UIC permit AK-1I024-A may do so during the public comment period. The public comment period began Sept. 27 and will end Oct. 27 at 5:00 p.m. Alaska Time. Comments received outside of the public comment period will not be considered, EPA said.
All comments made by email must contain the phrase "Public Comment" in the subject line and should be submitted to: James Robinson, [email protected].
A public hearing will be scheduled if there is a significant degree of public interest in the draft permit and a hearing is requested during the public comment period. If scheduled, EPA will provide public notice of the public hearing time and location.
After the public comment period ends and all comments have been considered, the branch manager for the Permitting, Drinking Water, and Infrastructure Sections of the Water Division at EPA Region 10 will make a final decision regarding permit issuance.
If no substantive comments are received, the tentative conditions in the draft permit will become final, and the permit will become effective upon issuance. If substantive comments are received, EPA will address the comments and determine whether to issue the permit.
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