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Unocal working with EPA on NPDES permit renewal Company audited its work under existing permit, negotiated fines with agency Kristen Nelson Petroleum News Editor-in-Chief
In addition to Cook Inlet natural gas exploration and development, and work at its offshore oil fields (see Part 1 if this story in the April 25 issue of Petroleum News), Unocal Alaska has been working with the Environmental Protection Agency for the past 18 months on the renewal for its National Pollutant Discharge Elimination System permit for its Cook Inlet platform operations.
The NPDES permit is renewed every five years, Chuck Pierce, vice president of Unocal Alaska, told petroleum News April 19. Unocal has been working internally on the renewal for about two and a half years, he said, and has been working with the EPA for a year and a half in on-going project planning.
The company applied for a renewal of its NPDES permit in September. The old permit expired April 1.
“Once they accept your application you get an automatic extension as it’s under consideration,” he said.
Pierce said the EPA wants to issue a renewal by the end of the year. “We’re really working on their timeframe,” he said.
Unocal would like to get its permit renewed with the existing parts per million limitations, Pierce said, and is working through permit renewal issues with the EPA.
“I’m optimistic that we’re going to come out with a workable permit at the end of this process that allows us to continue to produce these assets that are very important for us,” as well as for the local community and for the state, he said. Public process under way The EPA is working through a public process for permit renewal, he said, meeting with Native organizations and environmental groups.
Cook Inlet Keeper, an environmental group, filed a petition with the EPA April 7 to have all of Unocal’s facilities shut down immediately. It filed on behalf of itself, the Native Village of Port Graham, the Chickaloon Village Traditional Council, the Native Village of Nanwalek and the Native Village of Eklutna.
The petition asked the EPA to revoke Unocal’s general permit for its Cook Inlet oil and gas operations, and to issue individual permits for the facilities, asserting that “Unocal’s violations harm the traditional resources the tribes of Cook Inlet depend on.”
Pierce said he “can only assume they’re referring to somehow affecting the salmon fishing… And the bottom line is, that’s just flat not true, not substantiated by any kind of science, any kind of study.”
Unocal tracks discharges and studies done on inlet conditions, he said, “and the fact is these allegations are totally unsupported by any studies and unsupported in fact.” Permit regulates discharge points The NPDES permit regulates multiple discharge points, Pierce said, ranging from sanitary waste to water from dishwashers to treated produced water discharge. “So it handles anything that we put into the water — into Cook Inlet — as part of our operations.”
The permit provides for limits on a parts-per-million basis, “for how much of a certain constituent can be in the water,” and then the company tests and reports the results of its tests for the discharge points.
Pierce said that Unocal has exceeded the permitted limits at times, which it reported to the EPA as those events occurred, “as per the permit requirements, but the EPA didn’t fine us for them.”
So as a first step in getting the permit renewed, Unocal wanted “to clean up any outstanding issues,” Pierce said.
Unocal did an audit to make sure “that all of our reporting was right, and to verify that our system was in compliance.
“And we found a couple of areas where the system was out of compliance through this audit process.”
Unocal told the EPA it wanted to pay the fines for the outstanding issues that it had reported, but the agency hadn’t taken action on, “before we move into the renewal permit process.”
And it told the EPA that in the course of doing a self audit it found that two pipes coming off the platforms which carried water from its dishwashers, and were supposed to be below the surface of the water, stopped above the water.
Unocal fixed that problem immediately, he said, as well as reporting it to the EPA.
Then the company negotiated with the EPA “a fine and penalty for those issues, under our previous permit, so we could make sure we were current.” Goal is total compliance Unocal takes its permit seriously, he said, denying statements by Cook Inlet Keeper that the company doesn’t take its permit seriously and just pays the fines and keeps polluting.
Pierce said such claims bother “a lot of the employees, because they’re out there really dedicated to having a safe and environmentally friendly operation” on Unocal’s platforms in Cook Inlet.
“And so that’s a little disheartening to the 200 dedicated guys offshore, who report individual drops of hydraulic fluid if they happen to blow over with the wind while they’re changing a pump or something.”
Pierce said that while Unocal’s goal is total compliance, “the reality is you’re going to have one or two (exceedances).”
Unocal reports “down to the drop” … “and I believe we’re in compliance with our permit — but it’s a challenge to achieve a zero exceedance, I’ll just tell you that: it’s a challenge.”
Pierce compared exceeding permit allowances to a traffic violation: “If you get a speeding ticket, you’re out of compliance with the law, but they don’t impound your car” but — if you have multiple violations, “well then you will lose the car.” Information for construction project Unocal is doing some innovative information work for its Happy Valley natural gas development project, where a pipeline will be required to bring the gas to the Ninilchik unit to connect with the Kenai Kachemak Pipeline. The pipeline will run along Oilwell Road out of Ninilchik.
Pierce said Unocal is working with local residents and is assuring residents along the road and those with businesses there, that “the road will never be closed.”
Unocal is “going to meet or has met with every person, one-on-one, who has property on that road to make sure they understand what the plan is. We want minimal disruption to their lives and their business there,” he said.
Unocal spokeswoman Roxanne Sinz said that Unocal has had community meetings, but in addition to that has hired a person to go door to door along Oilwell Road. “There are about 40 landowners there that are truly affected by what we’re doing out there and he has gone at least once to every single house in the area” and sat down with the residents to talk about the project, answer questions and address issues.
In addition, Unocal has an 800 number set up so that people in the area who have questions can call. Unocal has posters up in the Ninilchik community, giving the 800 number. The number is staffed “24/7,” and callers will get answers within 24 hours. People working on the project are also armed with information, she said, and have cards with the 800 number that they can hand out.
“So people are — hopefully they’re saturated with information.” Safety a focus Safety is the number one focus for the Happy Valley development work, Pierce said.
In fact, he said, safety is the number one priority within the company.
“We’ve got priorities for our business posted on the wall around the building, and the number one priority is safety,” he said.
In 2002 the Alaska business unit, for the first time, had zero Occupational Safety and Health Administration recordable incidents for Unocal employees. In 2003, Pierce said, the company had four recordable incidents, but they were minor.
The company started an operations management system in about 1999, “a comprehensive risk management program … designed to identify and prioritize risks in the business unit and then to verify that we have procedures in place — designed and in place … to mitigate the risks and then have an ongoing follow-up management of those risks,” he said.
The operations management system is a company-wide Unocal program, and is audited by corporate every other year.
About two years ago the company started “what we call field-focused risk management,” and the focus there, Pierce said, is “the guys in the field who have to do the work.”
Part of that field-focus is “building on a culture of safety and risk management,” and Unocal is using the DuPont STOP program — safety, training and observation program.
All of the company’s offshore employees and most of its office employees have been through the seven-hour training for the first phase of STOP, which “trains everyone … to observe safe and unsafe conditions and behaviors” and to take steps to change something unsafe when they see it, and also to write it down so that the information is in a database, shared with everyone.
“It’s a job requirement that we put safety as our first priority,” Pierce said, and the STOP program helps implement that priority.
Then, senior management rotates through weekly safety meetings with field facilities, that “gives everyone an opportunity twice a year to talk to management” about safety issues — and to be specifically asked if they have safety issues to bring up.
“Safety’s a never-ending … quest for improvement — and our goal is continuous improvement,” Pierce said.
Pierce said that some of Unocal’s contractors — Nabors and Kuukpik for example — already used the STOP program, and other contractors are implementing the program.
“I think it’s fair to say that we are working closer than ever with our contractors to ensure that their … programs and ours work together to create the safest possible work environment.”
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