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Emergency

Alpine...............................................911 or 670-4900
Kuparuk ...................................................... 659-7300

North Slope
Badami ....................................................... 659-1200
Endicott....................................................... 659-2222
Milne Point .......................................911 or 670-3300

Environmental
Northstar......................................... 911 (from island)
Greater Prudhoe Bay (East) ............911 or 659-5300
Greater Prudhoe Bay (West) ...........911 or 659-4222

Field Handbook
Drilling ...................................... Use Contacts Above

To Report a Spill
Alpine* ............................................... 670-4002/4900
Kuparuk*........................................... “0” or 659-7997 February 2005
Badami ..................659-1200 or Badami Radio Ch. 1
Endicott................. 659-2222 or Endicott Radio Ch. 1
Milne Point ................. 670-3300 or MPU Radio Ch. 1
Northstar............. 670-3515 or Northstar Radio Ch. 2
Greater Prudhoe Bay.................................. 659-5700
Drilling & Wells.......................... Use Contacts Above
*Use emergency numbers (above) if unable to reach operator immediately

Field Environmental
Alpine................................................. 670-4200/4423
Kuparuk ............................................. 659-7212/7242
Badami ....................................................... 659-1243
Endicott....................................................... 659-6541
Milne Point .................................................. 670-3473
Northstar............................................ 670-3507/3508
Greater Prudhoe Bay (East) ....................... 659-5999
Greater Prudhoe Bay (West) ...................... 659-4789
Greater Prudhoe Bay (Services) ................ 659-5893
This handbook provides a general overview of
environmental regulations applicable to North
Slope oil fields. It summarizes procedures
developed by ConocoPhillips Alaska, Inc. (CPAI)
and BP Exploration (Alaska) Inc. (BP) to comply
with these regulations. This handbook should
not be used as a substitute for regulatory text
or detailed company procedures. Consult your
supervisor and Field Environmental office if
you have any questions about procedures or
regulations.

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Note: Click on an entry to go to that page.

Contents
SECTION 1 INTRODUCTION
Introduction page 6
Who to Call for Help page 7
SECTION 2 REGULATORY FRAMEWORK
Regulations / Permits page 10
Compliance / Penalties page 12
SECTION 3 AIR
North Slope Air Quality page 16
Air Quality Control Permits page 16
Flaring / Black Smoke page 18
Open Burning page 18
Gas and Vapor Leaks page 19
Idling Vehicles page 19
Halon / Halon Alternatives page 20
SECTION 4 LAND
Land Ownership page 22
Tundra Travel page 22
Snow Removal page 24
SECTION 5 WATER
Drinking Water page 28
Surface Waters / Wetlands page 28

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Note: Click on an entry to go to that page.

SECTION 6 WILDLIFE
Non-Interference Policy page 32
Birds page 33
Foxes page 33
Caribou page 34
Grizzly Bears page 35
Polar Bears page 36
SECTION 7 SPILLS
Spill Definition / Impact page 40
Fluid Transfer Guidelines page 42
Liner Use Procedure page 43
Secondary Containment page 45
Spill Reporting page 46
Reporting Procedure page 47
Internal Spill Reporting page 47
SECTION 8 WASTE MANAGEMENT
Introduction page 50
Waste Minimization page 50
Reuse and Recycling page 52
Waste Classification page 52
Segregation / Labeling page 57
Dumpsters page 58
Contaminated Gravel & Snow page 61
Accumulation Areas page 61
Injection Wells page 64
Drum / Barrel Management page 65
Waste Management Questions? page 67

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Notes

4
Intro.
Section 1
INTRODUCTION

5
Introduction

N orth Slope oil producers make every effort to minimize


the effect of our operations on the environment. We are
unified in a commitment to environmental excellence and
continuous improvement. We constantly assess our impact
on the environment, and we apply what we have learned over
the past decades to each new project.
Environmental management is not just the job of a few spe-
cialists — it is a crucial and integral part of our day-to-day
business on the Slope. Everyone can make a difference by
following a few simple practices:
• Plan ahead. Before starting a project, identify any
permit requirements, spill prevention practices, or other
environmental restrictions that might apply.
• Order supplies and materials carefully to avoid haz-
ardous materials and minimize waste.
• Make sure you know well in advance what to do with
any waste that is generated on your project. Remember
that many materials can be reused or recycled.
• Keep all vehicles and equipment in good working
condition, and get them repaired immediately if service
is required.
• Use portable liners under all fluid transfer points.
• Report spills immediately, according to the procedures
in your operating area.

6
Intro.
• Keep your job site clean. Manage trash carefully to
avoid attracting wildlife.
• Be aware of the general condition of the areas where
you work. If you see something that doesn’t look right,
report it!

Who to Call for Help

T he North Slope is divided into several operating units, or


asset areas. The legal boundaries between fields are very
distinct, and procedures vary from place to place.
If you need assistance, contact the Environmental staff in
your operating area. If they don’t have the answer right away,
they will find out for you, or direct you to the people who
can help you.

Alpine ....................................670-4200/4423
Kuparuk ................................ 659-7212/7242
Badami ......................................... 659-1243
Endicott ....................................... 659-6541
Milne Point .................................... 670-3473
Northstar ............................... 670-3507/3508
Greater Prudhoe Bay (East)................ 659-5999
Greater Prudhoe Bay (West) ................ 659-4789
Greater Prudhoe Bay (Services) ........... 659-5893

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Notes

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Section 2
REGULATORY

Regs.
FRAMEWORK

9
Regulations / Permits

M any laws and regulations control activities on the


North Slope. Federal, state, and local agencies have
varying degrees of jurisdiction. Some of the agencies that
will be mentioned in this handbook, and their primary areas
of authority, include:
• ADEC: Alaska Department of Environmental Conser-
vation (air quality, drinking water, spill response, waste
treatment and disposal, soil cleanup)
• ADNR: Alaska Department of Natural Resources (land
use, tundra travel, water use, habitat protection and
restoration, work in streams)
• AOGCC: Alaska Oil and Gas Conservation Com-
mission (reservoir management, flaring, oil and gas
resource protection, underground injection)
• BLM: U.S. Bureau of Land Management (tundra travel
and right-of-way approvals in National Petroleum
Reserve - Alaska)
• COE: U.S. Army Corps of Engineers (dredging and
filling in wetlands and water bodies)
• EPA: U.S. Environmental Protection Agency (water
quality, wastewater discharges, hazardous waste man-
agement, underground injection, oil storage containers)
• NSB: North Slope Borough (land use and pipeline sur-
veillance, subsistence resources, village coordination)

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Many activities require a permit, authorization, or notification
before initiating work, including:
• Activities and construction off the roads, pads, or
islands, even during winter (e.g., tundra travel)

Regs.
• Gravel pad and gravel road construction
• Excavation of gravel or other raw materials
• Withdrawal of water from any natural source, gravel
mine site, and some impoundments
• Alterations to natural drainage patterns
• Stormwater or meltwater discharge (dewatering)
• Wastewater discharge
• Air emissions from regulated facilities and equipment
• Burning that generates black smoke
• Flaring
• Modifications to drinking water, wastewater, or air
quality control equipment
• Wildlife hazing
Some activities only require a verbal notification. Others may
take weeks or even years to approve. It is important to plan
ahead, and to keep your Environmental staff informed about
new projects as far in advance as possible.

Always check with your supervisor or with the Field


Environmental office before beginning your work to
make sure you have all the permits you need!

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Compliance / Penalties

F ailure to comply with applicable regulations and permit


conditions can result in substantial penalties, including:
• Civil penalties. In several regulatory programs, compa-
nies may be fined as much as $25,000 per violation per
day.
• Administrative penalties. Under the Clean Air Act,
inspectors are authorized to issue field citations for any
permit violations. These “tickets” can be up to $5,000
per day per violation.
• Criminal penalties. Companies and individuals,
including corporate officers, may be charged criminally,
and punishment may be in the form of fines and impris-
onment.
A poor compliance record can delay new permits, damage
future prospects for oil and gas development in other areas,
and lead to even stricter regulations in the future.
Each North Slope worker, from the company president
down, must understand the responsibilities for compliance
related to his or her job. Things you can do to help ensure
compliance are:
• Follow approved job procedures. These should be
consistent with environmental regulations applicable to
your work.
• Be aware of the environmental concerns in your work
area.

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• Know the permits and the conditions that apply to your
operation. If you are unsure, contact your Field Envi-
ronmental office.
• Keep copies of all required permits at the work site and

Regs.
ensure that new workers or contractors are familiar with
the permit stipulations.
• Look for ways to reduce environmental liabilities on
the job, such as minimizing the generation of hazardous
waste and preventing spills.
• Contact your supervisor immediately if you see or
suspect something out of compliance.
• Agency personnel have the right to conduct unan-
nounced inspections at any time, unless doing so would
be unsafe. Cooperate fully with agency personnel
during compliance inspections. Your supervisor and, if
possible, someone from the Environmental staff should
be present.

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Notes

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Section 3
AIR

Air

15
North Slope Air Quality

F or several years, BP and CPAI have operated air monitor-


ing stations on the North Slope. These stations measure
standard meteorological parameters such as wind speed and
rainfall, and the levels of pollutants such as nitrogen oxides,
sulfur dioxide, ozone, carbon monoxide, and particulates.
Monitoring indicates that the air quality on the North Slope
is consistently better than national standards. Nonetheless,
we must continue our efforts to minimize the air pollutants
generated by our field operations.

Air Quality Control Permits

T he Clean Air Act (CAA) sets national air quality


standards and regulates the emission of hazardous air
pollutants. In Alaska, ADEC and EPA administer the CAA.
Major sources of air emissions, including several facilities
operated by BP and CPAI, must have Air Quality Control
permits from ADEC.
In the North Slope oil fields, the main sources of air emis-
sions are large turbines that generate power or reinject gas
at the production facilities. These turbines burn natural gas,
one of the cleanest fuels available. Combustion by-products
include carbon dioxide, nitrogen oxides, and small amounts
of sulfur dioxide.
Other emission sources include heaters, triethylene glycol
reboilers, storage tank vapor collection systems, and diesel
engines.

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Many “incidental” activities can lead to violations of air qual-
ity regulations or permit conditions. Examples include:
• Replacing a motor or pump in process equipment
• Firing a heater or reboiler at production rates greater
than 100% of design capacity
• Changing the horsepower output of equipment
• Allowing a stationary diesel engine to operate for an

Air
unusually long period of time
• Modifying existing equipment (including equipment
that monitors emissions), or changing its operating
parameters
• Placing a new storage tank in service
Before making any equipment modifications, or changing the
operating conditions, be sure to contact Environmental and
confirm that the changes comply with permit conditions and
regulations. In some cases, a new permit may be needed.
Production conditions in the oil field are constantly changing,
and existing facilities must meet new demands. Many facili-
ties that did not need permits in the past will need them in the
future, as a result of recent amendments to the CAA. There
are also new performance standards for turbines, heaters, and
storage tank emission control systems.

If you operate or maintain emission sources,


you must be aware of all applicable restrictions
and permit conditions.

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Flaring / Black Smoke

N atural gas is a by-product of the oil production process.


On the Slope, some gas is captured and used as fuel for
the power plants, while most of the natural gas is compressed
and reinjected into the reservoir. In the case of an upset or
shutdown, some of the additional gas is burned (“flared”) at
the point of generation to prevent dangerous pressure buildup.
The amount of flaring allowed is regulated by the AOGCC
and the ADEC.
Occasionally, incomplete combustion during a flare results in
black smoke. This black smoke may be a violation of air qual-
ity regulations and permits. Each facility has standard proce-
dures for recording and reporting black smoke incidents.

Black smoke from any source must be reported


if it is visible for more than three minutes in any
60-minute period, or if the average opacity of the
smoke is greater than 20% for any six minutes.

Open Burning

B lack smoke restrictions also apply to open burning of


wood, waste or other materials. Open burning sometimes
requires a state or borough permit, so be sure to check with
your Field Environmental staff well in advance.

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Gas and Vapor Leaks

G as leaks from wells, pipelines, valves, or other sources


are potentially serious safety hazards. Any evidence of
leaking gas should be reported to the site supervisor as soon
as possible. Stay out of the area until re-entry has been ap-
proved.
Releases of natural gas are considered a loss of state re-

Air
sources, and must be reported to the AOGCC. In the long
term, sustained leaks may contribute to local air pollution.

Idling Vehicles

D uring winter months, vehicles on the North Slope are


often left idling to avoid cold starts. Prolonged idling
wastes fuel, fouls engines, and releases air pollutants. In gen-
eral, the practice of leaving the engine running during cold
weather is discouraged. Be sure to check local policies on
idling vehicles. Your engine might be switched off if it is left
running for an extended period of time. Plug-ins for engine
block heaters are available at most facilities.
If a vehicle is left idling, avoid parking it near air intake vents.
Park upwind of any site where combustible atmospheres
might occur. Also, be sure to follow the field guidelines for
portable liner use under all parked vehicles (see Section 7).

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Halon / Halon Alternatives

H alon 1301 is a very efficient, low-toxicity fire-suppres-


sion agent. It can prevent explosions involving flam-
mable vapor/air mixtures in enclosed structures, and it is safe
for use around people. For this reason, the oil industry on the
North Slope relies heavily on Halon. However, when released
to the atmosphere, certain halogenated gases, including Ha-
lon, are believed to contribute to the depletion of stratospheric
ozone (which helps to filter out cancer-causing solar radia-
tion). Because of this, international restrictions have been
placed on the manufacture of Halon. The last year that new
Halon could be produced in the U.S. was 1993.
The oil industry has been actively participating in research
through the Halon Alternatives Research Corporation to
find suitable alternatives to Halon. However, we have not
yet found a satisfactory “drop-in” replacement that can be
retrofitted into existing facilities without extensive structural
modifications. For this reason, Halon continues to have an es-
sential use and be a safety necessity on the North Slope. New
facilities, including Badami, Northstar, and Alpine, rely on
alternative facility designs and protection methods.
When Halon is accidentally released due to a procedural
error, equipment malfunction, or false alarm, an extremely
valuable resource is lost. If you work in a facility where Ha-
lon is used, be familiar with the procedures that are in place
to prevent accidental releases.

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Section 4
LAND

Land

21
Land Ownership

T he oil and gas industry actually owns very little land on


the North Slope. Most of our operations are located on
state, federal, or Native-owned lands. State lands are admin-
istered by the ADNR, while the BLM oversees federal land
such as the National Petroleum Reserve - Alaska (NPR-A).
The NSB may place additional restrictions on land use within
Borough boundaries. Even activities on established pads may
require permits or approvals.
Most of the surrounding tundra is classified as wetlands,
which are protected under federal law as “waters of the United
States.” Discharge of pollutants to wetlands, streams, lakes, or
marine waters is strictly regulated by the EPA. Construction
in wetlands is regulated by the COE, and may involve ADNR
if fish habitat is affected.

Tundra Travel

A pproval is required for off-road and off-pad activities,


commonly called tundra travel. River and stream cross-
ings require special authorization by the ADNR.

Tundra travel may not occur outside of


approved routes. Damage to the tundra is
never approved!

22
Tundra travel is only allowed during certain times of the year.
The tundra is closed to all travel, except during periods ap-
proved by agencies.
Summer tundra travel opens annually on July 15. Travel is
limited to a few approved vehicles with smooth tracks, like
Rolligons, Argos, Hagglunds, and Tucker Snowcats.

Prior authorization is required for any tundra travel,


no matter what type of vehicle is used.

Winter tundra travel opens when the regulating agency


(ADNR or BLM) determines that there is adequate snow

Land
cover and frost depth to protect the tundra. There are no re-
strictions on the type of vehicles used in winter tundra travel;
however, prior notification is still required. Historically, the
winter tundra travel season has opened as early as November
and as late as January. The closing has occurred as early as
April and as late as June. In a few years, no winter tundra
travel was allowed at all, due to lack of snow cover. ADNR
gives a 72-hour notification before closing the winter tundra
travel season, allowing time to move vehicles and equipment
to the roads and pads.
No tundra travel of any kind is allowed during spring
breakup, because the tundra is critically sensitive to distur-
bance at this time. This “closed” period runs from the end of
the winter tundra travel season (as determined by the land-use
agencies), until the opening of the summer travel season (July
15). Damaged tundra can be very difficult to repair. Even
superficial marks can last for years, leaving observers with
negative impressions of our conduct on the Slope.

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Snow Removal

T he permits that allow us to build gravel roads and pads


(see Section 5) include very specific boundaries for
gravel placement. To comply with these permits, we must
minimize the amount of gravel that is washed off the pads by
erosion, or pushed off by graders and snow removal equip-
ment. Any impacted tundra or water must be restored to a
condition that is acceptable to the regulatory agencies.
At CPAI and BP facilities, snow removal is the responsibility
of the Equipment or Field Services Departments. Equipment
operators must maintain a minimum distance from flowlines,
and take every precaution to avoid contacting lines, valves, or
well houses. If snow blowers are used, snow is never blown
onto or into well houses, flow lines, high voltage equipment,
or manifold buildings.
Loose gravel, and gravel mixed with snow, is stockpiled in
designated areas on gravel pads so that the gravel will stay
on the pad when the snow melts. Snow that contains spills,
drill cuttings, or other contaminants must be segregated and
hauled to an approved location.
Good housekeeping at the site will help the snow removal
crew, and prevent potential spreading of contaminants off
the pad.
• Inspect sites frequently. Check for spills, debris, and
improperly stored materials.

24
• Report and clean up all spills promptly.
• Do not store materials near the edge of the pad.
• Be sure to point out any stained snow or concealed
objects to the snow removal crew.

Snow removal should be left to trained operators


from Equipment/Field Services.

For additional information about snow removal, call:

Land
Alpine .......................................... 670-4044
Kuparuk ................................ 659-7948/0238
Badami ........................................ 659-1243
Endicott ........................................ 659-6584
Milne Point .................................... 670-3499
Northstar ...................................... 670-3508
Greater Prudhoe Bay (East) ............... 659-5357
Greater Prudhoe Bay (West) ............... 659-4075

Any questions about contaminated gravel or snow should be


directed to your Field Environmental office.

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Notes

26
Section 5
WATER

Water

27
Drinking Water

O n the North Slope, most drinking water is obtained


from lakes, impoundments, and desalinated seawater
from the Beaufort Sea. Untreated lake water should never
be consumed, because it may contain naturally-occurring
microorganisms that can cause illness.
All drinking water systems that serve North Slope workers
are approved by ADEC and operated in accordance with state
drinking water regulations. BP and CPAI are responsible for
ensuring that their drinking water meets all applicable stan-
dards. Contact Environmental before making any changes to
drinking water systems — modifications may require ADEC
approval.

Surface Waters / Wetlands

W aters of the United States, including wetlands, are


protected by the Clean Water Act. Most of the coastal
lowlands on the North Slope are considered wetlands by state
and federal agencies. The ground surface typically remains
saturated during the summer because of the low relief and
the impermeable permafrost below. Permafrost can be more
than 1500 feet thick. During the brief summer, a thin “active
layer” at the surface thaws to a depth of about two feet. This
active layer is extremely sensitive to disturbance.
Several artificial water bodies, such as old gravel pits and
reservoirs, also have protected status. Unauthorized activities
around these sites may disrupt the rehabilitation process and
violate permit stipulations.

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The following operations are strictly regulated year-round,
and should be discussed well in advance with the Environ-
mental staff. If permits are required, be aware that it may take
several months to obtain them, and many agencies may be
involved. Most permit applications are open to public review
and comment, which may delay the permitting process.
• Surface water use. Withdrawal of fresh water from
rivers, streams, lakes, and ponds requires a permit. Sev-
eral water sources around the field have already been
permitted. These pre-approved sources should be used
whenever possible, since it can take up to 60 days to
permit a new source. Your Environmental staff can tell
you which water sources are approved, and what permit
conditions must be followed.
• Waste discharges. Discharge of any waste to surface
waters or land is strictly prohibited without a permit,

Water
including:
– Discharge of sewage or graywater
– Dewatering gravel pits or reserve pits, even if the
water appears clean
– Discharge of any chemicals or industrial wastes.
Chemicals and industrial wastes must never be
disposed of in sewage systems. They can upset the
sewage treatment plant and result in violations of our
wastewater discharge permits.
– Thermal discharges (discharges that would alter the
temperature of the receiving waters).
• Gravel placement. No gravel, overburden, or other fill
material (including structures like pilings and bridges)

29
may be placed in surface waters or wetlands without a
permit.
• Dredging and mining. Water bodies may not be
dredged, breached, culverted, or diverted without
permits. Permits are also needed to extract gravel from
river channels, beaches, and wetlands.
• Snowmelt and runoff. The Clean Water Act prohib-
its discharge of contaminated snowmelt and runoff.
Contaminated snow must be managed before breakup
to prevent the release of pollutants (see Section 4).
Accumulated meltwater may not be discharged without
approval. If de-watering is necessary, consult the Field
Environmental office.
Uncontaminated meltwater may be discharged from
pads and impoundments if the facility has a storm-
water discharge permit. Sampling may be required prior
to discharge. There must be no visible sheen on the
waters, or other evidence of contamination.
Consult your Field Environmental office if you have any
questions.

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Section 6
WILDLIFE

Wildlife

31
Non-Interference Policy

O n the North Slope, we are privileged to work in the midst


of a healthy and unique wildlife community. However,
company policy prohibits interfering with wildlife in any way.
Severe penalties, including loss of job, may be imposed on
any employee who violates this policy.
• Garbage control. This is one of the most important
things we can do to minimize our impact on wildlife.
Food and food waste should never be left in the open
bed of a pickup, or any place else where it is accessible
to wildlife. Never discard food wastes outdoors unless
you use designated dumpsters with animal-proof lids.
• Worker safety. Any encounters with large mam-
mals, like bears, are potentially dangerous. Even small
animals, such as arctic foxes, should be considered
dangerous, because they can carry serious diseases like
rabies. BP and CPAI require rabies awareness training
for all field workers on the Slope. Polar bear awareness
training is also required.
• Wildlife and habitat protection. Most birds and
mammals found on the Slope are protected by federal
or state regulations. “Protected” means they cannot be
hunted, harassed, captured, or killed without special
approval. Crucial habitats, like nesting areas, brood
rearing habitat, den sites, and feeding grounds, must not
be disturbed or created artificially.

Never feed, approach or harass any wildlife.

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Birds

I n May, vast numbers of birds begin to return to the North


Slope for the summer. Some species, such as spectacled
eiders, are protected under the Endangered Species Act.
Every effort should be made to minimize disturbance to
nesting birds. If disturbance cannot be avoided, or if injured,
oiled birds, or dead birds are found, call your Field Environ-
mental office for instructions.

Do not touch or capture dead, oiled, or injured birds.

Foxes

B oth arctic and red foxes occur on the North Slope. Arctic
foxes are common on the Arctic Coastal Plain, and red
foxes are most often found in the foothills and mountains of
the Brooks Range. Red foxes have been known to frequent Wildlife
major river banks (Colville, Sagavanirktok rivers), but are
less common than the arctic fox. In late March/early April
they begin to den and have their pups. Creation of artificial
den sites should be prevented wherever possible.
Because the arctic fox is a predator of nesting birds and small
mammals, and a major carrier of rabies, it is very important
that we minimize opportunities to attract foxes to our work
areas.

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Rabies is common in the fox population. Some studies have
shown that up to 80% of the animals carry the virus. Although
they may not show symptoms of the disease until close to
death, they are capable of transmitting it at any time. All foxes
should be avoided. Aggressive, unusually curious, or overly
friendly animals should be reported to Security. Do not feed
the foxes or leave food where it is accessible to them.

Caribou

C aribou are an important subsistence resource for local


residents on the North Slope. Four main caribou herds —
the Porcupine, Central Arctic, Teshekpuk, and Western Arctic
— migrate onto the North Slope coastal plain in summer.
Their calving season lasts from about mid-May to mid-June.
Maternal caribou with calves are sensitive to disturbance
from vehicles and pedestrian traffic, so it is important that
we minimize disturbance of these animals during this critical
time. Following calving, caribou movements are influenced
primarily by mosquitoes and oestrid flies. Harassment by
mosquitoes can last from mid- to late June through July, when
caribou seek relief by traveling to the coast. Harassment by
oestrid flies typically lasts from mid-July into August, when
caribou will seek relief in elevated areas such as drillsites or
beneath facility modules or pipelines.
As caribou move through the field, they must be given right-
of-way and should not be approached or harassed. Be ex-
tremely careful on the roads when caribou are present. Their
movements are unpredictable, and sometimes sudden. Drive
slowly, and expect the unexpected.

34
Grizzly Bears

T he North Slope oil fields harbor a small but growing


population of grizzly bears. The grizzly bear (also called
brown bear) occurs throughout northern Alaska from the
Brooks Range to the Arctic Ocean. Grizzly bears typically
occupy dens between late September/early October to mid-
May. All bears occupy winter dens, with females entering
dens earlier and emerging later with their cubs, compared to
single females and males. Bears can be curious but should
always be considered dangerous. The location of bears on
the Slope is monitored by the Alaska Department of Fish
and Game.
Bears have a keen sense of smell and are always on the look-
out for food. Once they find a food source, they will keep
coming back for more. If they learn to associate humans with
food, they will seek out places where humans live and work,
increasing the chances of an encounter. Allowing this to hap-
pen because of sloppy food-handling practices puts yourself,
Wildlife
your colleagues, and the bears at risk.
If a bear is sighted, keep your distance and alert other
workers. Look around for other bears (for example, cubs
accompanying their mothers) and move to a secure location.
Do not try to scare the bear away. Do not approach a grizzly
bear for any reason.

All grizzly bear sightings must be reported


immediately to Security.

35
Polar Bears

P olar bears are considered arctic marine mammals, pro-


tected from hunting or harassment under the Marine
Mammal Protection Act. They can weigh over 1,500 pounds
and measure 5 feet tall at the shoulder or 12 feet when stand-
ing on their hind legs. They are excellent swimmers and
can run 25 miles per hour. Because of their size, speed, and
curious nature, any encounter with these large carnivores is
potentially dangerous. About 2,000 polar bears can be found
in the Alaskan Beaufort Sea region.
During the summer, polar bears normally hunt seals for food
far out on the pack ice. When new ice bridges form in the
fall, their foraging routes may bring them to land. Their win-
ter range can include the oil fields of the North Slope. Only
pregnant females use dens during the winter months. Dens
can typically be found along river banks or bluffs, as well as
out on the sea ice. Mothers with cubs usually emerge from
the dens in March. When the icepack moves back offshore
in the spring, the bears usually move with it. However, ac-
tive polar bears can be found on land and sea ice at all times
of the year.
In their natural setting, polar bears eat only meat, mostly
seals. However, in the oil field setting, they may be attracted
to plastic, rubber, motor oil, and chemicals such as antifreeze.
These materials are toxic to the bears and should be stored in
bear-proof containers. Bears may visit work sites because of
curiosity or food odor, but their visits will be transitory if they
are not rewarded with food. Food waste should be transported
away from work sites daily.

36
Good work practices and site control will reduce the chances
of an encounter between humans and polar bears. If you are
working outdoors, make sure you are in a well-lighted area
and have a communications plan in place for bear sightings.
Consider having a designated bear watch to alert crews if
polar bears are sighted.

All polar bear sightings must be reported


immediately to Security.

If you see a polar bear anywhere on the field, look around for
other bears, move to a safe location, and alert other workers
in the area. Do not attempt to scare the bear away. Do not
approach a polar bear for any reason.

• CAUTION •
Only trained personnel are authorized to deal with animal
problems. Report any dead or injured animals immediately.
Do not attempt to capture or handle them yourself. Report Wildlife
any overly-aggressive foxes or any animals that are behaving
abnormally. Report all sightings of bears.

Alpine ................................... 670-4020/4900


Kuparuk .............................. “0” or 659-7997
Badami Control Room ...................... 659-1211
Endicott Security............................. 659-6516
Milne Point Operator ........................ 670-3300
Northstar ............................... 670-3507/3508
Greater Prudhoe Bay (East)................ 659-5631
Greater Prudhoe Bay (West) ............... 659-4441

37
For additional details about wildlife, regulations, and com-
pany policies, please refer to the BP and CPAI Wildlife
Interaction and Avoidance Plans. These plans are posted on
company web sites, and you can get a copy from the Field
Environmental staff. Wildlife Interaction and Avoidance Plan
training is mandatory for some projects and work sites.

38
Section 7
SPILLS

Spills

39
Spill Definition / Impact

A ny incident that releases a contaminant into the environ-


ment can be considered a spill and will be taken very
seriously by BP and CPAI.
• Oil: Includes crude and refined hydrocarbons such as
diesel, hydraulic fluid, and lube oil. It can also include
oily sludge, oil refuse, or other petroleum-related prod-
ucts or by-products.
• Hazardous substances: Include glycols, methanol,
drilling muds, seawater, corrosion inhibitors, produced
water — essentially anything other than potable water.
All chemical spills must be reported so that potential
exposure hazards can be evaluated, and disposal can be
managed properly.
• On pad: Includes gravel pads and roads, well houses,
and unlined well cellars. Depending on the type of
construction, some cellars are considered secondary
containment.
• Secondary containment: Means built-in pits, dikes,
berms, portable drip pans, liners, metal skids, imper-
vious module floors, or other impermeable devices.
Reporting is required to ensure proper cleanup and
disposal, but spills in secondary containment are not
necessarily reportable to agencies.

40
The regulations that apply to spill prevention, reporting, and
response are complex, and the penalties for noncompliance
are severe. Under federal and state law, we must be able to
respond quickly and effectively to any type of spill or emer-
gency. Comprehensive spill prevention and contingency plans
have been developed for the North Slope, and our highly
trained response teams are on call 24 hours a day. If neces-
sary, we can draw on resources throughout the world.
Most of our spills on the North Slope are small drips and
leaks onto gravel pads from vehicles and equipment, but we
are also prepared to respond to the most catastrophic event.
All spills in our operating areas must be cleaned up to the
satisfaction of BP or CPAI, and the appropriate regulatory
agencies.
Every worker on the North Slope should know how to prevent
spills and what to do if a spill occurs. Contact your Supervi-
sor if you need more information about your specific duties.
Prevention — our first and most effective line of defense
against spills — is everyone’s responsibility.
Spills

41
Fluid Transfer Guidelines

M any spills occur during routine fueling, pumping, and


other fluid transfer operations. Most of these spills can
be avoided by paying attention and taking simple precautions.
CPAI and BP have established field-wide fluid transfer guide-
lines, which are summarized below.
1. Check all vehicles and equipment. If a leak is apparent,
or there are other obvious problems with the equipment,
stop the job and have repairs done. Surface liners may
be used to contain leaks for a short time during critical
operations; however, liners are not an acceptable substi-
tute for maintenance.
2. Park vehicles and equipment away from water bodies,
tundra, and wildlife habitat. Do not park on the edges of
pads.
3. Position equipment so that valves, piping, tanks, etc., are
protected from damage by other vehicles or equipment.
4. Verify that adequate surface liners and sorbents are on
hand.
5. Inspect hoses, connections, valves, etc., before starting
any fluid transfers. Be sure that valves are in the proper
on/off position and each connection is tightened prop-
erly.
6. Before starting, check all tank and container levels,
valves, and vents to prevent overfilling or accidental
releases.
7. Surface liners are required under all potential spill
points.
8. Maintain a constant line-of-sight with critical compo-

42
nents throughout the transfer procedure. Be prepared to
stop the transfer immediately if you notice any leak. Do
not attempt to fix a leak while fluid is being transferred.
9. Never leave fluid transfer operations unattended.
10. After the transfer is complete, continue to take these
precautions while breaking connections.
11. When finished, check the area for spills. Report all
spills immediately to the appropriate number in your
operating area (see end of this section).

Liner Use Procedure

I n August 1993, the North Slope operators jointly issued a


Unified Operating Procedure (UOP) for liner use, which
must be followed in all fields. The UOP is summarized be-
low. Be aware that each operating area can add site-specific
requirements to the UOP.

Liners are not a substitute for good maintenance.


Any unit that is dripping or leaking must be repaired
as soon as possible.
Spills

1. Off the pad. Maximum protection of the tundra and


surface waters is the primary objective. Appropriately
sized liners must be placed under the radiator, engine, or
other areas of potential leakage whenever equipment is
operating, or parked and running. Liners should be used
as needed to prevent drips and small spills under parked
and non-operating equipment. Equipment with known
leaks must be immediately released from the job.
Liners are specifically required as follows:

43
– Under all support equipment (heaters, compressors,
generators, etc.)
– Under heavy and light duty parked equipment (doz-
ers, loaders, cranes, trucks, etc.)
– During all fluid transfers, at all connection points,
from the beginning of hook-up through disconnection
– Under fuel/fluid storage containers
2. On the pad. Gravel protection, good housekeeping, and
spill prevention are the primary objectives. Equipment
with known leaks must be immediately released from
the job if liners are not available and properly used.
Surface liners or drip pans should only be used as a tem-
porary measure until the equipment is repaired. “Known
leakers” that are not repaired promptly will be removed
from the job and may be banned from the Slope alto-
gether.
Appropriately sized liners must be placed under the
radiator, engine, or other areas of potential spills/leaks
as follows:
– Under well service equipment (wireline, slickline,
coil tubing, etc.)
– Under all support equipment without built-in con-
tainment systems (heaters, compressors, bleed tanks,
etc.)
– Under all stationary heavy equipment (loaders,
cranes, etc.)
– During all fluid transfers, at all connection points,
from the beginning of hook-up through disconnection
– Under all drums used as primary containment for

44
waste fluids (bleed backs, pressure relief, temporary
storage)
3. Parking areas and bullrails at all camps and fa-
cilities. Appropriately sized surface liners or drip pans
are required under any parked vehicle or equipment,
whether it is running or not, if it is dripping engine oil or
other fluids.

Secondary Containment
Tanks and Drums. Secondary containment is required by
law around many above-ground oil storage tanks. In general,
secondary containment for stationary oil tanks and non-sta-
tionary oil tanks larger than 10,000 gallons must be able to
hold 110% of the volume of the largest tank. Containment
must include sufficient freeboard to include precipitation.
All of these tanks must have placarding describing their
contents.
Oil storage tanks that can hold 55 gallons or more require
impermeable containment (e.g., dikes or catchment basins).
Tanks and drums should be located to ensure that oil will not
reach navigable waters or tundra.
Spills

Before new tanks are put into service, contact


Environmental to make sure the tank complies with
applicable regulations.

Well Cellars and Well Houses: Most new wells are equipped
with steel- or concrete-lined cellars that effectively contain
fluid. However, many older wells have unlined cellars that
are not considered secondary containment by ADEC. ADEC

45
feels that releases into unlined cellars may eventually mi-
grate through the pad and ultimately to the surrounding
environment. Well houses are not considered secondary
containment either.
Temporary Containment. Surface liners and drip pans
provide portable protection under leaking equipment or
connections.

Secondary containment that is damaged, collapsed,


or full of water cannot do its job.

Spill Reporting

F ailure to report spills is a violation of state and federal


regulations as well as company policy, and may result in
civil or criminal penalties. CPAI and BP Environmental Com-
pliance specialists are trained, and authorized, to determine
whether a spill is reportable to agencies or not. Company
reporting requirements may be more conservative than the
regulations to make sure that potential exposure hazards are
evaluated, the spill is properly cleaned up, and the waste is
properly handled.
In some cases, the “spiller” may be able to take care of the
cleanup, but Environmental should always be consulted.
Cleanup workers must have an appropriate level of training
for the circumstances, and must be equipped with the correct
personal protective equipment. All appropriate safety precau-
tions must be taken.

46
Reporting Procedure

T o report a spill, call the appropriate number and provide


the following information:
• Person and/or department responsible
• Contact phone number
• Substance spilled
• Location of spill
• Approximate amount spilled
• Possible cause of the spill
• Cleanup activities under way
A follow-up written report may be required. Documentation
procedures vary between fields.
If you need help in cleaning up the spill, contact your Field
Environmental office or designated spill technician.

Internal Spill Reporting

B P and CPAI require immediate reporting of all spills,


discharges, and releases of oil and hazardous substances
Spills

in our operating areas. This ensures proper response, cleanup,


disposal, and timely agency reporting. ADEC interprets “im-
mediate” to mean within 30 minutes.
Some spills are not reportable to regulatory agencies, and
some will not be counted as recordable incidents. The
Environmental staff will determine what is externally re-
portable.

47
Spill Reporting Numbers:
Spills must be reported to the following numbers imme-
diately:

Alpine* ................................. 670-4002/4900


Kuparuk* ............................. “0” or 659-7997
Badami ........... 659-1200 or Badami Radio Ch. 1
Endicott ......... 659-2222 or Endicott Radio Ch. 1
Milne Point ........... 670-3300 or MPU Radio Ch. 1
Northstar ...... 670-3515 or Northstar Radio Ch. 2
Greater Prudhoe Bay ....................... 659-5700
Drilling & Wells ................. Use Contacts Above

*Alpine and Kuparuk: Use emergency number (below) if unable to reach


operator immediately.

Emergency Reporting Numbers:


Injuries, fires or safety hazards, uncontrollable or continu-
ously releasing material, blowouts, or spills into waterways
must be reported to the appropriate emergency number im-
mediately:

Alpine ................................. 911 or 670-4900


Kuparuk ........................................ 659-7300
Badami ........................................ 659-1200
Endicott ....................................... 659-2222
Milne Point ........................... 911 or 670-3300
Northstar ............................ 911 (from island)
Greater Prudhoe Bay (East) ...... 911 or 659-5300
Greater Prudhoe Bay (West) ..... 911 or 659-4222
Drilling ............................ Use Contacts Above

48
Section 8
WASTE
MANAGEMENT

Waste

49
Introduction

H andling the by-products of our operations, from drill-


ing muds and chemical wastes to food and other camp
wastes, is one of our greatest challenges. We operate in a very
sensitive and highly regulated environment. Our access to
“public” facilities is limited. The costs and liability of ship-
ping wastes off the Slope are extremely high.
Therefore, CPAI and BP are constantly working to reduce
waste generation and improve waste management practices.
Our goal is to minimize our impact on the environment, im-
prove efficiency, and control costs.

This handbook is not a substitute for BP/CPAI waste


management training.

Waste Minimization

T he Arctic Green Star® chapter was established to help


North Slope service companies realize the benefits of
waste reduction, recycling, and energy conservation. These
benefits include substantial cost savings, better competi-
tiveness, efficiency, and community approval. Over 300
businesses, including BP, CPAI, and the Alaska Support
Industry Alliance, have joined Green Star® chapters.
BP and CPAI also support the Alaska Materials Exchange.
This is a state-wide catalog that helps match prospective
users with materials that would otherwise be thrown away.
Products like chemicals, construction materials, office sup-

50
plies, and heavy equipment are listed free of charge. The
supplier saves money on disposal costs and protects the
environment by keeping potentially hazardous materials out
of the landfill. The user picks up valuable commodities at a
fraction of the normal price — sometimes paying only the
cost of shipping.
At our own facilities, we promote waste minimization in
several ways.
• Source reduction. Through planning and inventory
control, it is possible to limit the amount of materials
and products that are kept on site. If there is no surplus,
there is no need to discard unwanted or outdated
products. We also encourage the use of more efficient
equipment and processes to reduce waste.
• Product substitution. Many products can be replaced
with alternatives that are less hazardous.
Before committing to a new “wonder” product, be
sure to evaluate potential health and disposal hazards.
Before a product will be approved for purchase and
use, both BP and CPAI use a New Chemical Evalua-
tion Procedure to identify potential health, safety, and
environmental considerations.

Caution! Some products are not as “environmentally


friendly” as their manufacturers claim.

• Source control. Good housekeeping, proper waste


Waste

segregation, and spill prevention help minimize waste


generation.

51
Reuse and Recycling

O n the North Slope, we are able to reduce waste by reus-


ing or recycling materials that might otherwise be dis-
carded. Contact the Environmental staff for more information
about recycling programs in your area.

Material that can be reused or recycled


is not a waste.

The materials that can be recycled in most locations in-


clude:
• Office paper
• Electronics (including computers)
• Scrap metal
Be sure to segregate materials, use the right container, and
follow any instruction placards.

Waste Classification

D isposal and reuse options depend on the way wastes are


legally classified. In this section, we will discuss the
major waste categories, and provide a brief overview of the
disposal and reuse facilities on the Slope.
The rules are very complex and the consequences of misman-
agement are serious, but tools are available to help workers
make the right decisions. These tools include training, written
procedures, and the Environmental staff.
CPAI and BP require Waste Management Certification
training for all personnel and contractors who are directly

52
involved with generating, transporting, or receiving wastes
(other than ordinary camp or office trash). The Certification
Program applies to all CPAI and BP facilities. It covers ba-
sic waste classification, disposal options, and proper use of
the North Slope Manifest. The Certification Program also
introduces the Alaska Waste Disposal & Reuse Guide (also
known as the “Red Book”) — a standard reference for waste
management on the Slope.

Do not attempt to classify wastes without proper


training. Direct any waste management questions to
the Environmental staff.

Hazardous Waste
Hazardous waste is subject to strict and complicated regu-
lations. Penalties can be severe for improper handling,
storage, transportation, and disposal. The Resource Conser-
vation and Recovery Act (RCRA) defines two categories of
hazardous waste.
Characteristic hazardous waste has one or more of the
following properties:
• Ignitability: Liquids with a flash point less than 140°F.
Examples: waste gasoline, thinner.
• Corrosivity: Liquids with a pH <2.0 or >12.5. Ex-
amples: strong acids or bases.
• Toxicity: Material that exceeds regulatory limits for
Waste

any of 39 designated compounds. Examples: benzene,


lead, cadmium.
• Reactivity: Material that reacts easily to produce heat,
explosions, or toxic gases.

53
Listed hazardous waste. EPA publishes lists of wastes that
are known to have hazardous characteristics. These include
certain chemical products, and by-products of specific manu-
facturing processes. Examples: methanol, spent chlorinated
solvents, some refinery wastes.
All hazardous waste generated on the North Slope must be
shipped, by licensed transporters, to licensed facilities in the
Lower 48. Between shipments, CPAI and BP collect haz-
ardous waste in designated locations, supervised by trained
waste technicians.
Satellite Accumulation Areas (SAAs), described later in this
section, allow generators to manage up to 55 gallons of non-
acute hazardous waste on-site until it can be delivered to the
appropriate storage location.

No hazardous waste may be transported from one


North Slope operating area to another!

Universal waste. Universal waste is a subcategory of haz-


ardous waste that is managed with the intention of recycling.
The most common universal wastes on the North Slope are
light bulbs (“lamps”) and batteries (NiCad, mercury, and
lithium). Note that alkaline batteries are not considered uni-
versal wastes — they may be discarded with ordinary trash
in waste baskets and landfill dumpsters

RCRA-Exempt Waste
EPA has decided that certain types of wastes are exempt from
regulation as hazardous waste under RCRA. These wastes
must still be managed carefully, but they are not subject to
the same storage, transportation, and disposal rules as haz-
ardous waste.

54
For example, hazardous waste generated in private house-
holds and camp bunkhouses is RCRA-exempt, but it may
require special management to keep it out of landfills and
sewage treatment systems.
There is an important RCRA exemption for wastes that are
uniquely associated with oil and gas exploration and pro-
duction (E&P). E&P exempt wastes include:
• Crude oil
• Produced water
• Returned muds
• Formation cuttings
• Flowed-back workover and stimulation fluids
• Downhole freeze-protection fluids (including used
diesel and methanol)
New and unused products, such as acids, methanol, seawater,
and diesel, are NOT E&P exempt.

The E&P exemption is based on the way the waste


was generated, not on its composition.

Residues remaining in containers may be exempt from regu-


lation as hazardous waste. A container is considered “RCRA
empty” if it has less than one inch of residue or, if the con-
tainer is larger than 110 gallons, less than 0.3% residue by
weight. Residues and rinsates removed from RCRA-empty
containers are not RCRA-exempt. They are subject to RCRA
Waste

regulation if they exhibit a hazardous characteristic.

55
Non-Exempt Waste
Many North Slope waste streams are not RCRA-exempt.
Non-exempt wastes include:
• Snowmelt and ponded water
• Unused seawater
• Unused chemical products
• Vehicle fluids (diesel, gasoline), lubricants, and anti-
freeze
• Gravel or absorbents contaminated with glycol, hydrau-
lic fluid, or motor oil
• Most maintenance and construction wastes
Non-exempt wastes must be classified as hazardous or non-
hazardous by trained and qualified personnel.

56
Segregation / Labeling

W aste management becomes very complicated if dif-


ferent “classes” of waste are mixed together. A small
amount of hazardous waste, mixed with a non-hazardous
waste or recyclable material, can make the whole mixture a
hazardous waste. Disposal costs and liabilities for hazardous
waste are very high, so it is extremely important to identify
your wastes and keep them segregated.
All containers must be labeled properly and clearly. This
is important to workers and to emergency response teams,
who need to know what they are dealing with. In some
cases, improper labeling is a violation of the law. If drums
or containers are found without labels, the contents must be
handled as hazardous until otherwise identified. The expense
of identifying unknown substances can raise the handling
cost significantly.
The site supervisor is responsible for ensuring that labels
are readable and intact. Missing or unreadable labels must
be replaced. Waste

57
Dumpsters

S everal types of dumpsters are available for solid waste


and recyclable materials on the Slope. Dumpsters should
only be used for their designated purpose. Be sure to read
the placards, and check with Environmental for the latest
procedures.
Landfill (“Construction & Debris”) Dumpsters are for
non-oily solid waste that cannot be recycled or burned on-
site. Loose trash should be bagged before it is thrown into a
dumpster. Acceptable wastes include:
• Alkaline batteries
• Concrete (solid, small amounts)
• Electrical cable, wire
• Empty containers (bottles, buckets) — free of oil or
liquid; no aerosol cans
• Glass
• Hoses (no oil, chemicals, or free liquids)
• Insulation (no asbestos)
• Metal scraps (if not recycled; non-oily)
• Paper products (if not recycled)
• Plastic
• Rubber
• Styrofoam
• Tires (must be cut up if larger than 20" in diameter)
• Wood scraps (if not recycled)
• Visqueen, pit liner (non oily)

Do not dispose of chemicals, hazardous wastes,


liquids, pressurized aerosol cans, snow, or gravel in
dumpsters.

58
Food Waste Dumpsters have animal-proof lids. Never dis-
card food waste in an open-top dumpster. Food waste should
be discarded in indoor receptacles whenever possible to avoid
attracting birds, foxes, and bears.

Never store food or food waste where it is accessible


to wildlife.

“Burnable” or Incinerator Dumpsters are provided in


some locations for kitchen/household waste and other
material that is burned on site. Always verify site-specific
procedures.
Open-Top (“Bulk”) Dumpsters are provided on request for
bulky wastes such as:
• Turbine inlet air filters
• Empty (dry) paint cans
• Tires (must be cut up if larger than 20" in diameter)
• Wood debris
• Foam insulation, concrete, cable, wire, and other con-
struction materials
Oily Waste Dumpsters are lined and are for non-hazardous
oily wastes with no free liquids, including:
• Grease or pipe dope cans, empty and wiped clean (no
liquids)
• Oil filters (must be punctured and hot-drained)
• Oily pit liner material (no free liquids, snow, dirt or
gravel) cut, rolled, and tied
Waste

• Sorbents, rags, wipes, floor sweepings, or other oily


debris (no hazardous wastes or free liquids)

59
All oily waste should be packed in oily waste bags (clear
with yellow stripe) before being placed in the dumpster. A
label with the bag’s contents and source may be required. Use
yellow-striped bags only for oily waste. Follow site-specific
procedures for labeling and logging oily waste bags.
Oily waste containers 55 gallons and larger must have sec-
ondary containment.
Scrap Metal (Recyclable) Dumpsters are usually marked
with the works “Recyclable Metal.” Acceptable materials
include:
• Banding (cut up and boxed or drummed)
• Cable (spooled or rolled)
• Conduit and fittings
• Pipe (oil-free; can have small amounts of insulation)
• Plate steel
• Stainless steel, copper, aluminum
• Valves
• Wire

Do not place asbestos, batteries, light bulbs,


hazardous or oily wastes, liquids, pressurized aerosol
cans, gravel, or food waste in scrap metal dumpsters.

Recyclable Wood Collection. As part of a growing effort to


keep usable wood out of the NSB landfill, many areas col-
lect pallets, plywood, wood scraps, and wood packaging in
designated locations.

60
Contaminated Gravel & Snow

E ach field has its own controlled-access storage areas for


solid wastes like contaminated gravel, contaminated
snow, and oily production solids. These include lined out-
door pits, lined containers, hoppers, and temporary stockpiles
where material is stored until it can be treated. Storage of
solid oily waste is regulated by ADEC.
Periodically, BP and CPAI treat these contaminated solids
so that they can be reused as fill or construction material.
Thermal treatment is the most common method, but biore-
mediation and other techniques are also options.

Accumulation Areas
Satellite Accumulation Areas (SAAs). Satellite Accumula-
tion Areas are for temporary storage of hazardous wastes,
are located at or near the point of waste generation, and are
under the control of the process operator. SAAs have been
established at many drill rigs, paint shops, laboratories, and
production facilities.
Examples of wastes that should be collected in SAAs are:
paints, thinners, solvents, rags with solvent residues, and
laboratory wastes. Each operating area has its own procedures
for managing SAAs, so contact your Field Environmental
Waste

61
office for more information. The following procedures apply
to all SAAs on the North Slope.
• Do not combine or mix wastes in the same container.
Store used solvent with used solvent, waste paint thin-
ner with waste paint thinner, etc.
• Label the container with the words “HAZARDOUS
WASTE” or as instructed by Environmental Staff. If
there is more than one container, be sure that the spe-
cific contents of each one are clearly identified on the
label.
• Keep containers closed at all times except when filling.
Lids and bungs must be on, and hand-tightened. Fun-
nels should be removed.
• The total volume of non-acute hazardous waste in any
SAA must not exceed 55 gallons (about 7 cubic feet).
• Once an SAA has reached its capacity, the contents
must be moved to a designated collection point within
3 days.
Recyclable Accumulation Areas (RAAs) are available for
used oil, glycol, and other recyclable materials.
Used oil from vehicles and equipment is recycled at several
North Slope production facilities. It can be blended into the
crude oil and sent to refineries downstream.

62
Other hydrocarbons and fluids may be recycled with approval
from the Environmental staff according to site-specific pro-
cedures. If the fluid consists of a hydrocarbon and non-hy-
drocarbon mix (such as oil and water), the hydrocarbon can
be separated at the production facility and mingled with the
crude stream, while the water-based fluid can be diverted to
EOR or an appropriate disposal well.
Contact your Field Environmental staff if you have any ques-
tions about used oil management or hydrocarbon recycling.

Hazardous waste may not be


added to used oil.

Universal Waste Accumulation Areas, sometimes called


UAAs, are used primarily to collect used batteries and light
bulbs (lamps). They are often located near SAAs or RAAs.

Waste

63
Injection Wells

O n the North Slope, stable geological conditions make it


possible to safely and permanently inject fluids thou-
sands of feet below the surface. This has tremendous envi-
ronmental benefits, because it eliminates the need for large
surface disposal facilities on or off the Slope.
Permits are required to drill and operate Underground In-
jection Control (UIC) wells, and there are restrictions on the
type of material that can be injected. Each of the North Slope
injection facilities has its own operating restrictions, training
requirements, and manifesting procedures.
Class I disposal wells may inject non-hazardous and exempt
wastes. They are located at Alpine, Greater Prudhoe Bay
(GPB), Badami, Northstar, and Milne Point. Many condi-
tions and restrictions apply.
Class II disposal wells are restricted to waste that has phys-
ically come out of an oil and gas well. This includes all pro-
duced fluids; muds and additives that have circulated in the
well; and solids that originate downhole, such as formation
cuttings. Class II disposal wells are located at Alpine, GPB,
Endicott, and Kuparuk.
The Grind and Inject (G&I) facility at Drill Site 4 in the GPB,
can process solids for disposal by grinding and mixing with
seawater to form an injectable slurry.
Class II Enhanced Oil Recovery (EOR) wells are used to
inject produced water and other approved fluids directly into
the oil-producing formation, to increase oil production. EOR,
also known as “waterflood,” is considered a beneficial use of
fluid rather than disposal.

64
Drum / Barrel Management

B P operates the North Slope Barrel Crushing Facility


at the A3W2 Warehouse on Santa Fe Pad, in the GPB.
Empty steel and plastic drums are cleaned at a high-pressure
washing station and then crushed. Residual liquids rinsed
from the drums are either recovered or evaluated for proper
disposal. Crushed drums are recovered as scrap metal if pos-
sible; otherwise they are landfilled.
All North Slope companies have made progress in reducing
the use of 55-gallon drums. By switching to bulk storage,
there is much less product wasted, and fewer empty drums
require handling and disposal.

GPB Collection Procedure


• Generators must contact BP Environmental at 659-4375
to arrange drop-offs.
• Baroid drums must be returned to Baroid in Deadhorse
and should not be delivered to A3W2.
• Drums are considered empty when there is no more
than 1 inch of residue. If there is more than 1 inch of
product, it must be used up or disposed according to
procedures for that product.
• All drums must be accompanied by proper paperwork,
including billing information and a description of the
last known material in the drum.
Waste

Kuparuk Collection Procedure


Barrels ready for disposal are handled by the Materials
Department. A Field Requisition (FR) must be prepared by
the user to identify the generator, identify previous contents,

65
and certify that all drums are empty (no more than 1 inch of
residue). FR number and previous contents must be marked
on the outside of the drum with a permanent marker.
When paperwork and drums are ready for transfer, contact the
Materials Warehouse to coordinate delivery to the Materials
Warehouse Drum Holding Area (KCS Pad). Accumulated
drums are then delivered to the GPB Barrel Crushing Facil-
ity.
Drums may not be placed into or removed from the drum
holding area without proper documentation and notification
of Materials Warehouse personnel.

Endicott Collection Procedure


Drums are delivered to the Endicott Materials Department. A
“Manifest for Drum” form is given to the warehouse techni-
cian. Endicott drums are then delivered to A3W2.
Drilling collection procedure: Tool Service picks up empty
drums from drilling rigs, and coordinates delivery to A3W2.
Drums ready for pickup should be inspected to make sure
there is no more than 1 inch of residue, then tightly closed and
staged in an upright position in the designated area. Contact
Tool Service when the drums are ready, and provide a cost
code or AFE.

Milne Point Collection Procedure


Drums from Milne Point drilling rigs are collected by Tool
Service and delivered to the Barrel Crushing Facility. Other
barrels are stored at D Pad by the Milne Point Environmental
staff until they can be delivered to A3W2.

No empty drums may be left at the barrel crushing


facility without prior approval.

66
Drum/Barrel Management Contacts

Alpine ................................... 670-4200/4423


Kuparuk ....................................... 659-7032
Badami ........................................ 659-1243
Endicott ....................................... 659-6541
Milne Point .................................... 670-3473
Northstar ...................................... 670-3508
Greater Prudhoe Bay (GPB) ................ 659-4375
Tool Services ................................. 659-4634

Waste Management
Questions?

I f you have a question about specific wastes, please contact


the Field Environmental staff at your location.

Alpine ....................................670-4200/4423
Kuparuk ................................ 659-7212/7242
Badami ......................................... 659-1243
Endicott ....................................... 659-6541
Milne Point .................................... 670-3473
Northstar ............................... 670-3507/3508
GPB (East) ..................................... 659-5999
GPB (West) ..................................... 659-4789
GPB (Services) ................................. 659-5893
Waste

GPB (Waste Coordinator) .................... 659-4810

67
Notes

68
Emergency
Alpine...............................................911 or 670-4900
Kuparuk ...................................................... 659-7300

North Slope
Badami ....................................................... 659-1200
Endicott....................................................... 659-2222
Milne Point .......................................911 or 670-3300

Environmental
Northstar......................................... 911 (from island)
Greater Prudhoe Bay (East) ............911 or 659-5300
Greater Prudhoe Bay (West) ...........911 or 659-4222

Field Handbook
Drilling ...................................... Use Contacts Above

To Report a Spill
Alpine* ............................................... 670-4002/4900
Kuparuk*........................................... “0” or 659-7997 February 2005
Badami ..................659-1200 or Badami Radio Ch. 1
Endicott................. 659-2222 or Endicott Radio Ch. 1
Milne Point ................. 670-3300 or MPU Radio Ch. 1
Northstar............. 670-3515 or Northstar Radio Ch. 2
Greater Prudhoe Bay.................................. 659-5700
Drilling & Wells.......................... Use Contacts Above
*Use emergency numbers (above) if unable to reach operator immediately

Field Environmental
Alpine................................................. 670-4200/4423
Kuparuk ............................................. 659-7212/7242
Badami ....................................................... 659-1243
Endicott....................................................... 659-6541
Milne Point .................................................. 670-3473
Northstar............................................ 670-3507/3508
Greater Prudhoe Bay (East) ....................... 659-5999
Greater Prudhoe Bay (West) ...................... 659-4789
Greater Prudhoe Bay (Services) ................ 659-5893

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