Liberte Environmental Associates

Previous 2006 Arctic Ocean General Permit (EPA AKG280000)
and Related Regulatory Documents

This previous permit was issued by the EPA on June 26, 2006 and expired on June 26, 2011.
The EPA administratively extended this permit in 2011.

The EPA released the General Permit Beaufort Sea Draft (NPDES AKG281000) in January 2012. The public comment period for the draft permit ended March 30, 2012 but the EPA did not list public comments until the intended final permit was made available on its webpage in October 2012. The 2012 draft permit was also variously labeled as AKG-28-2100. The EPA issued separate intended final permits for the Beaufort and Chukchi Seas in October 2012 with an effective date of November 28, 2012.

Environmental Protection Agency (EPA) Related Documents
EPA Region 10 is responsible for issuing permits for the Alaska Outer Continental Shelf of the Arctic Ocean (No. AKG280000) for discharges from new sources, existing sources, and new dischargers in the Offshore and Coastal Subcategories of the Oil and Gas Extraction Point Source Category in (40 CFR Part 435, Subparts A and D). The focus of this discussion is on wastewater permit conditions for the Arctic Ocean, particularly, in the Beaufort and Chukchi Seas off Alaska's north coastline.

Previous 2006 NPDES General Permit AKG280000 (EPA issued June 2006) with attachments, which includes Notice of Intent (NOI) to discharge form. See Table 1 below for a listing of the 14 different types of discharges allowed under permit AKG280000.

Previous Fact Sheet for the 2006 NPDES General Permit AKG280000 (EPA public comment on this fact sheet ended in May 2004)

EPA Response to Public Comments on the 2004 draft AKG280000.

EPA Previous Final Ocean Discharge Criteria Evaluation of the Arctic NPDES General Permit for Oil and Gas Exploration (Permit No.: AKG280000) [EPA ODCE, January 24, 2006].

EPA Assessment of Environmental Fate and Effects of Discharges from Offshore Oil and Gas Operations* [August 1985]. The EPA's ODCE (2006) numerously refers to this assessment.

EPA Arctic Oil and Gas Exploration Wastewater Discharge Permits Early Information Sheet [Arctic permits renewal schedule, EPA Winter-Fall 2010]. For the upcoming permit renewal, the information sheet makes clear EPA is intending to divide the Previous Arctic general permit and ODCE into two permits and two ODCEs. That is one permit and one ODCE each for the Beaufort Sea, and one permit and one ODCE each for the Chukchi Sea. The reader will find that EPA is considerably behind in releasing the draft permits and ODCEs for the Arctic Ocean. EPA's dated schedule says that the "Release draft permits and a fact sheet for 60-day public review" is "Late Winter 2011", which did not occur. EPA also said it would "Issue final permits and response to comments" in "Fall 2011". As of this writing (October 2011), the EPA has yet to release the draft permits or ODCEs, and has not taken public comments. The final permits release dates cannot possibly occur in "Fall 2011". EPA has yet to release an updated written schedule to the public.

EPA Website for Arctic Oil and Gas Wastewater General Permits contains additional information.

See LEA's Webpage on NOAA Fisheries progress on the Environmental Impact Statement (EIS) on the Effects of Oil and Gas Activities in the Arctic Ocean . Other documents are also referenced on this webpage relating to Arctic Ocean organisms and ecosystems.

See LEA's Webpage on the Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) Arctic Ocean oil and gas environmental assessments, discharger exploration plans and related documents for the Beaufort and Chukchi Seas.

See LEA's Webpage on Shell Offshore Inc.'s Notice of Intent (NOI) to Discharge to the Beaufort Sea in the Arctic Ocean at the Sivulliq N drill site. Conditions of the NOI are intended to be pursuant to EPA Arctic Permit AKG280000, which is the general permit for waste discharges into the Arctic Ocean related to oil and gas exploration.

Sea ice recession because of climate change is also a factor in oil and gas development in the Arctic Ocean. For additional information see Arctic sea ice reduction and sea ice recession.

Table 1. Permitted Discharges
001 Drilling Fluids and Drilling Cuttings
002 Deck Drainage
003 Sanitary Wastes
004 Domestic Wastes
005 Desalination Unit Wastes
006 Blowout Preventer Fluid
007 Boiler Blowdown
008 Fire Control System Test Water
009 Non-contact Cooling Water
010 Uncontaminated Ballast Water
011 Bilge Water
012 Excess Cement Slurry
013 Mud, Cuttings, Cement at Seafloor
014 Test Fluids

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