STATE OF ALASKA

ALASKA OIL AND GAS CONSERVATION COMMISSION

333 West Seventh Avenue, Suite 100

Anchorage Alaska 99501

 

ADMINISTRATIVE APPROVAL NO. DIO 22.002

Re: Disposal Injection of Treated Sanitary Waste and Produced Water

Mr. John Amundsen
HSE Manager
Forest Oil Corporation
310 K Street, Suite 700
Anchorage, AK 99501

Dear Mr. Amundsen:

By letter dated January 15, 2004, Forest Oil Corporation (“Forest”) requested authorization to inject into Redoubt Unit #D1 a mixture of “non-hazardous treated sanitary waste with produced water.” Well D1 is a Class II disposal well supporting operations at the Osprey platform located in the Cook Inlet. Disposal Injection Order (DIO) 22 does not list treated sanitary waste as eligible for injection into a Class II disposal well. Administrative Approval DIO 22.001 dated June 19, 2002, grants approval to Forest for the injection of storm water collected in the Osprey Platform deck drain system into Well #D1. Forest identifies problems with meeting overboard discharge permit limits as the primary reason for the request; transportation to shore has been studied and determined economically infeasible.

Confinement of fluids to the intended injection zone in Well D1 has been demonstrated by injection performance data provided by Forest. Injection of a commingled produced water and treated sanitary waste stream will have no detrimental effect on the confinement of fluids or well integrity.

Exploration and production wastes associated with oil and gas development are exempt from the requirements of Section 3001(b)(2) of the Resource Conservation and Recovery Act (RCRA). The exemption provides for mixing a non-hazardous waste with an exempt waste; the resulting commingled stream is considered exempt. Forest’s proposed action to mix treated sanitary waste (non-hazardous, non-exempt) with the Osprey produced water waste stream (exempt) is consistent with the provisions of the RCRA exemption. Injection of the commingled stream into Well D1 is the preferred alternative and is approved by the Commission.

DONE at Anchorage, Alaska and dated February 3, 2004.

The Alaska Oil and Gas Conservation Commission

John K. Norman, Chair
Alaska Oil and Gas Conservation Commission

Daniel T. Seamount, Jr., Commissioner
Alaska Oil and Gas Conservation Commission

BY ORDER OF THE COMMISSION


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