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MONITORING

Monitoring provides data to evaluate the effectiveness of
permit conditions and lease stipulations. It may

demonstrate the need to modify environmental requirements or
operating methods and may help identify areas where
additional study is needed. Monitoring also allows a
determination of whether operations are in compliance with
these requirements and with other environmental standards.
For example, data from water quality monitoring under the
new drilling mud disposal regulations will show whether
contamination is occurring. If it is, the regulations
require corrective measures.

CONCLUSION

Governor Cowper has taken a firm position that ANWR exploration and development must be done right, that the environment and the special values of ANWR must be protected. I have outlined some of the steps that can be taken to achieve this goal. These are just highlights, of course. Oil and gas development in the Arctic is a complicated business and I have only touched on the major environmental issues to be addressed.

Mr. Chairman, the Department of Environmental Conservation
is available to the members and staff to discuss the details
of environmental matters affecting your decision about ANWR.
Thank you for the opportunity to testify. We look forward
to working with you.

Attachment

T

SUMMARY OF WASTE STREAM MANAGEMENT
AND OTHER ENVIRONMENTAL PROTECTION ISSUES
RELEVANT TO OIL AND GAS DEVELOPMENT
IN THE ARCTIC NATIONAL WILDLIFE REFUGE

AIR QUALITY

The principal air pollutants discharged during oil and gas development are sulphur dioxide, suspended particulate matter, carbon monoxide, and nitrogen oxides.

Concentrations of these four types of emissions depend, in large part, on the type and volume of fuel burned in the turbines, generators, and other internal combustion engines, the and the amount of flaring in the area.

Flaring is a significant contributor to visibility

impairment. Flaring during exploratory flow testing and operational phases is potentially a major source of emission of soot primarily unburned hydrocarbons -- and other materials. Technology exists to prevent such problems in future developments.

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The primary source of NOx at Prudhoe Bay is the more than 100 gas turbines, each rated at more than 10,000 horsepower. This may be the greatest concentration of large turbines in the world. Approximately 20 air quality permits have been issued, and three are pending. The cumulative annual discharge allowed under these permits is more than 90,000 tons of NOx. Actual emissions are approximately 70 to 90 percent of the permitted values. Modeling has been used to predict the ground level concentrations of NOx and ground level monitoring is now underway to verify the modeling effort and measure ambient levels.

LIQUID WASTE MANAGEMENT

Liquid waste discharges include domestic wastewater, reserve pit fluids, brine discharges, hydrostatic test discharges, vessel rinsates, radiographic wastes, excavation discharges, oily wastewater streams, equipment washing runoff, workover fluids, waste oil solvents, and a wide range of other wastewater streams. Each needs to be identified with a provision made for proper disposal.

Zero discharge of non-domestic (industrial) wastewater streams, with the possible exception of excavation dewatering, should be carefully considered for ANWR. Based upon current experience on the North Slope, alternatives to dewatering of reserve pits should be used in ANWR. The management regime selected for drilling wastes could eliminate the need to discharge to the tundra or roads. Conventional dust control measures or water should be used instead of wastewater. The planning stage should identify specific disposal methods for liquid waste streams classified under the Federal Resource Conservation and Recovery Act (RCRA) and non-RCRA liquid oily-waste streams. Rinsates from tank, vessel and truck cleaning also must be disposed properly. Consequently, both the oil field operators, and the oil field support service industry must have access to appropriate facilities. Underground injection, potentially an acceptable disposal solution for many of these waste streams, should be considered. Produced water disposal should be limited to subsurface techniques.

Unlined gravel impoundments have been used in other North Slope oil and gas developments to contain various wastewater streams. This technique may not be appropriate in ANWR because of its limited effectiveness and its requirement for large amounts of gravel.

Comprehensive planning is needed to ensure that liquid waste disposal solutions are available for all users. This would allow all liquid waste streams to be accurately identified, characterized, and quantified along with an acceptable method for disposal. For example, subsurface disposal options should be available for use by the support service industry.

SOLID WASTE MANAGEMENT

Major sources of solid waste are drilling wastes, scrap metal, oily wastes, construction debris, drums, junked vehicles, tires and a host of other materials. It is critical that proper management of all these wastes be addressed from the beginning. Drilling wastes are of particular concern. The State's new regulations governing drilling waste disposal provide an appropriate starting point.

Disposal of solid waste is another area for which careful planning can lead to development of proper facilities at the outset. Provisions for picking up "off-site" litter and other debris should be addressed by stipulation placed on successful tract bidders. Because it is often difficult to determine the source of off-site litter or debris, it may be desirable to implement a "no fault" policy by which litter and debris are routinely collected regardless of origin.

Plans for management of drums should be required as condition of operation. They should include inventory and tracking, cleaning, crushing, backhaul and disposal of waste liquids or residues from cleaning.

Garbage and other wastes which may attract wildlife should be incinerated. Collection and storage of such wastes must also avoid attracting wildlife. Plans for collection of these wastes and for central incineration should be prepared and adopted as a condition of field exploration and development.

Disposal methods for solid oily wastes from tank bottoms, sludges, hydrocarbon waxes, oil contaminated muds and cuttings and spill debris require very careful evaluation. At Prudhoe, the North Slope Borough operates one of two permitted non-RCRA solid oily waste disposal sites in Alaska. Results from the operation of this site are mixed. Additional work and technology review are needed to develop acceptable solutions for this very difficult waste stream management issue. Incineration would provide the most reliable and complete solution to the problem. However, this is also more costly to the operators.

Comprehensive waste material management plans could minimize the amount of waste to be disposed and could incorporate salvaging, reusing, and recycling materials. Backhaul of scrap metal and crushed drums are additional tools which could make most landfills in ANWR unnecessary. Ash and residue from incinerator operation could easily be consolidated into a single facility.

Comprehensive planning to develop solutions for solid waste disposal must also enable the support service industry to have access to proper disposal options. Regional disposal facilities can also help prevent unnecessary proliferation of landfills. Ultimate disposal of pipelines, flow stations, camps and related facilities should be addressed at the outset of ANWR planning so that a financial mechanism is in place to provide for proper disposal upon completion of use.

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ous waste management is governed by stringent .rements under the Federal Resource Conservation and very Act (RCRA). Transportation of hazardous substances regulated by the Federal Department of Transportation. ne State has adopted hazardous waste regulations and is currently in the process of implementing them through a cooperative agreement with the Environmental Protection Agency.

As with other waste streams, it is essential that acceptable disposal methods be available both to the oil field operators and to the support service industry. Comprehensive planning is needed to develop appropriate management facilities at the outset.

OIL SPILL PREVENTION AND RESPONSE

Coordinated response capability should be required. Adequate oil spill contingency plans and secondary containment requirements for drums and small facilities are also important. Buffer zones should be established to isolate these facilities from sensitive areas.

If field gas or refining capacity is available to supply fuels it should be made available to the support service industry. This will significantly reduce the occurrence of spills by eliminating fuel storage and piping for space heating and electrical generation. Local availability of refined products to all users would eliminate haul road tanker spills.

AREA OF IMPACT

Many of the tools developed in other North Slope fields are directly applicable to minimize the "footprint" of individual drill sites and of the overall production effort. Appropriate facility siting criteria and buffer distances will also help maintain adequate levels of environmental protection.

Development plans should include the following: a design to minimize the number of drill sites and production facilities while optimizing the layout of roads and pipelines; provisions for a limited number of intensive use material sites; and plans to centralize and consolidate support facilities. Consolidation of the service industry at Kuparuk provides an example of centralized support services in planning for ANWR.

Ice pads should be considered for all exploratory drilling. Ice pads may also be used for temporary stockpiling of overburden and muds and cuttings.

Restoration of the site at each stage from exploration through production can reduce the cumulative impact of development activities. Adequate drainage must be provided for all facilities to prevent impoundments.

The CHAIRMAN. Thank you very much, Mr. Dietrick.

Finally, Bill Van Dyke, who is Petroleum Manager of the Division of Oil and Gas.

STATEMENT OF WILLIAM D. VAN DYKE, PETROLEUM MANAGER, DIVISION OF OIL AND GAS, ALASKA DEPARTMENT OF NATURAL RESOURCES

Mr. VAN DYKE. Mr. Chairman, members of the committee, my name is Bill Van Dyke, Petroleum Manager in the Alaska Department of Natural Resources. I would like to cover two points.

First, given our 20 years experience in Prudhoe Bay, we think both exploration and development can go forward on the coastal plain. It has really been the hundreds of little things we have learned that are going to allow this. There have not been that many giant revelations. It is really the hundreds of little things that are going to make this possible as far as the design and implementation of the mitigating measures.

Second, the State does not support the exploration-only option for ANWR. I think the actual outlay of public funds, the lost revenues and bonuses in leasing, I do not think exploration-only supports that.

There are going to be land management conflicts with the adjacent landowners. Acreage can be condemned, and other landowners are going to want to protect their interests, the State and the native corporations. And I do not think that you will get a fair evaluation of the geologic potential.

Interior has identified 26 prospects, the State has identified other prospects. I am sure industry has their own idea of where they would like to drill. I think it would take dozens of wells to really evaluate the geologic potential of the coastal plain.

And if you want to drill that many and pay for that many, that is fine. But otherwise, I do not think it is fair to the potential of the coastal plain to go out and drill a few and maybe false condemn it.

Thank you.

Senator MURKOWSKI. And what?

Mr. Van Dyke. To maybe falsely condemn the oil and gas potential. If you drill two or three dry holes, do not assume that it is over with.

[The prepared statement of Mr. Van Dyke follows:]

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