Liberte Environmental Associates

Existing Cook Inlet General Permit (EPA AKG315000)
and Related Regulatory Documents for Oil and Gas Extraction


This existing permit was made effective by the EPA on July 2, 2007 with nominal expiration on July 2, 2012. EPA and ADEC are proposing to reissue the exploration component of the 2007 Permit as two general permits, one in the Federal Waters (AKG285100 for offshore) and one in the State Waters (AKG315100 for coastal) of Cook Inlet. These permits are presently in draft form (August 2013). The draft permits for exploration facilities are currently under review by EPA and ADEC relative to public comments.

EPA has informed LEA that the existing permit has been administratively extended. The exploration portion of the permit is presently in the renewal process with draft permits released March 22, 2013 by EPA (offshore) and by ADEC (coastal). The public comment periods ended on May 21, 2013 (EPA) and May 22, 2013 (ADEC). EPA is hoping to have the permits finalized by the end of 2013. The draft permit documents are indicated below in olive color.

The
original 2007 documents pertaining to the existing permit are indicated below in blue and have undergone revision through 2011 as indicated below in red. After the revision, EPA began referring to the general permit (AKG315000) as applying to "Exploration, Development and Production Facilities" rather than the catch-all phrase of "Extraction Facilities". The existing 2007 permit is also variously labeled as AKG-31-5000. The draft 2013 permits are also variously labeled as AKG-28-5100 for the EPA and AKG-31-5100 for the ADEC.

Environmental Protection Agency (EPA) and Alaska Department of Environmental Conservation (ADEC) Related Documents
EPA Region 10 is responsible for issuing permits for Cook Inlet for discharges from new sources, existing sources, and new dischargers in the Offshore and Coastal (now ADEC too) 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 Cook Inlet, Alaska.

Draft EPA and ADEC Permits for Exploration
EPA Public Notice for Draft 2013 NPDES General Permit AKG285100 (March 22, 2013).

ADEC Public Notice for Draft 2013 APDES General Permit AKG315100 (March 22, 2013).

EPA Draft 2013 NPDES General Permit AKG285100 (March 2013) with appendices, which includes Notice of Intent (NOI) to discharge form in Appendix D. Table 1 below lists the 13 types of discharges allowed under permit AKG285100.

ADEC Draft 2013 APDES General Permit AKG315100 (March 2013) with appendices and attachments, which includes NOI to discharge form in Attachment 1. Table 1 below lists the 13 types of discharges allowed under permit AKG315100.

EPA 2013 NPDES Fact Sheet for General Permit AKG285100 (March 2013).

ADEC Draft 2013 APDES Fact Sheet for General Permit AKG315100 (March 2013).

EPA Draft Ocean Discharge Criteria Evaluation (ODCE) for the Cook Inlet NPDES Permit No. AKG285100 (March 2013).


Existing EPA Permit for Extraction Facilities
Existing 2007 EPA NPDES General Permit AKG315000 (July 2007) with attachments, which includes Notice of Intent (NOI) to discharge form. See Table 2 below for a listing of the 19 different types of discharges allowed under permit AKG315000.

Final Re-proposed (2011) Effluent Limits for NPDES General Permit AKG315000 [EPA made effective December 7, 2011].

ADEC Original (2007) CWA 401 Water Quality Certification for EPA Permit AKG315000 [ADEC dated May 18, 2007].

ADEC Revised (2011) CWA 401 Water Quality Certification for EPA Permit AKG315000 [ADEC dated October 20, 2011].

Existing Fact Sheet (2006) for the 2007 EPA NPDES General Permit AKG315000. The EPA issue date of this fact sheet is February 23, 2006.

Fact Sheet (2011) for the re-proposed effluent limitations for the 2007 EPA NPDES General Permit AKG315000. The EPA issue date of this fact sheet is May 18, 2011.

EPA Response to Public Comments on the 2006 draft general permit AKG315000.

EPA Response to Public Comments for the Re-proposed Effluent Limitations for the 2007 NPDES permit AKG315000 .

Draft 2006 EPA NPDES General Permit AKG315000.

Previous 1999 EPA NPDES General Permit AKG285000 [nominally expired in 2004; note that the old permit number of AKG285000 was changed by EPA to AKG315000 for the 2007 permit].

Previous 1995 NPDES Fact Sheet for General Permit AKG285000 [complementary to the 1999 permit].

EPA Ocean Discharge Criteria Evaluation (ODCE) for the Cook Inlet NPDES Permit No. AKG315000 [EPA ODCE cover dated January 24, 2006; Revision 1].

EPA Biological Evaluation (BE) for the Cook Inlet NPDES Permit No. AKG315000 [EPA BE cover dated January 20, 2006].

EPA Draft Environmental Assessment (EA) for the Cook Inlet NPDES Permit No. AKG315000 [EPA EA cover labeled "Draft" dated March 2006].

EPA Essential Fish Habitat (EFH) for the Cook Inlet NPDES Permit No. AKG315000 [EPA BE cover dated January 20, 2006].

EPA Website for the Cook Inlet Oil and Gas Exploration General Permit No. AKG315000 contains additional information.

Table 1. Permitted Exploration Facilities Discharges
For the Draft (2013) Permit
Discharge
Number
Discharge
Description
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



Table 2. Permitted Extraction Facilities Discharges
For the Existing (2007) Permit
Discharge
Number
Discharge
Description
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 Waterflooding Discharges
015 Produced Water and Produced Sand
016 Completion Fluids
017 Workover Fluids
018 Well Treatment Fluids
019 Test Fluids


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