EmergencyAlpine...............................................911 or 670-4900Kuparuk ......................................................659-7300Badami .......................................................659-1200Endicott.......................................................659-2222Milne Point .......................................911 or 670-3300Northstar......................................... 911 (from island)Greater Prudhoe Bay (East) ............911 or 659-5300Greater Prudhoe Bay (West) ...........911 or 659-4222Drilling ...................................... Use Contacts Above

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

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

February 2005

North SlopeEnvironmentalField Handbook

1

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.

2 3

Contents

SECTION 1 INTRODUCTION

Introduction page 6Who to Call for Help page 7

SECTION 2 REGULATORY FRAMEWORK

Regulations / Permits page 10Compliance / Penalties page 12

SECTION 3 AIR

North Slope Air Quality page 16Air Quality Control Permits page 16Flaring / Black Smoke page 18Open Burning page 18Gas and Vapor Leaks page 19Idling Vehicles page 19Halon / Halon Alternatives page 20

SECTION 4 LAND

Land Ownership page 22Tundra Travel page 22Snow Removal page 24

SECTION 5 WATER

Drinking Water page 28Surface Waters / Wetlands page 28

2 3

SECTION 6 WILDLIFE

Non-Interference Policy page 32Birds page 33Foxes page 33Caribou page 34Grizzly Bears page 35Polar Bears page 36

SECTION 7 SPILLS

Spill Definition / Impact page 40Fluid Transfer Guidelines page 42Liner Use Procedure page 43Secondary Containment page 45Spill Reporting page 46Reporting Procedure page 47Internal Spill Reporting page 47

SECTION 8 WASTE MANAGEMENT

Introduction page 50Waste Minimization page 50Reuse and Recycling page 52Waste Classification page 52Segregation / Labeling page 57Dumpsters page 58Contaminated Gravel & Snow page 61Accumulation Areas page 61Injection Wells page 64Drum / Barrel Management page 65Waste Management Questions? page 67

4 5

Notes

4 5

Section 1 INTRODUCTION

Intr

o.

6 7

Introduction

North 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 7

• 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

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

Intr

o.

8 9

Notes

8 9

Section 2 REGULATORY FRAMEWORK Re

gs.

10 11

Regulations / Permits

Many 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)

10 11

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)

• 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!

Regs

.

12 13

Compliance / Penalties

Failure 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.

12 13

• 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 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.

Regs

.

14 15

Notes

14 15

Section 3 AIR

Air

16 17

North Slope Air Quality

For 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

The 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.

16 17

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

unusually long period of time• Modifying existing equipment (including equipment

that monitors emissions), or changing its operating parameters

• Placing a new storage tank in serviceBefore 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.

Air

18 19

Flaring / Black Smoke

Natural 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

Black 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.

18 19

Gas and Vapor Leaks

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

Idling Vehicles

During 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).

Air

20 21

Halon / Halon Alternatives

Halon 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.

20 21

Section 4 LAND

Land

22 23

Land Ownership

The 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

Approval 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 23

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 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.

Land

24 25

Snow Removal

The 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 25

• 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:

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

Any questions about contaminated gravel or snow should be directed to your Field Environmental office.

Land

26 27

Notes

26 27

Section 5 WATER

Wat

er

28 29

Drinking Water

On 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

Waters 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.

28 29

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, 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)

Wat

er

30 31

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.

30 31

Section 6 WILDLIFE

Wild

life

32 33

Non-Interference Policy

On 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.

32 33

Birds

In 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

Both 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 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.

Wild

life

34 35

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

Caribou 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 35

Grizzly Bears

The 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, 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.

Wild

life

36 37

Polar Bears

Polar 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 37

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 any overly-aggressive foxes or any animals that are behaving abnormally. Report all sightings of bears.

Alpine ................................... 670-4020/4900Kuparuk .............................. “0” or 659-7997Badami Control Room ...................... 659-1211Endicott Security............................. 659-6516Milne Point Operator ........................ 670-3300Northstar ............................... 670-3507/3508Greater Prudhoe Bay (East)................ 659-5631Greater Prudhoe Bay (West) ............... 659-4441

Wild

life

38 39

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 39

Section 7 SPILLS

Spill

s

40 41

Spill Definition / Impact

Any 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 41

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.

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Fluid Transfer Guidelines

Many 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-

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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

In 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.

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:

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– 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

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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 ContainmentTanks 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.

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

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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

Failure 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.

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Reporting Procedure

To 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

BP and CPAI require immediate reporting of all spills, discharges, and releases of oil and hazardous substances

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.

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

Alpine* ................................. 670-4002/4900Kuparuk* ............................. “0” or 659-7997Badami ........... 659-1200 or Badami Radio Ch. 1Endicott ......... 659-2222 or Endicott Radio Ch. 1Milne Point ........... 670-3300 or MPU Radio Ch. 1Northstar ...... 670-3515 or Northstar Radio Ch. 2Greater Prudhoe Bay ....................... 659-5700Drilling & 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 670-4900Kuparuk ........................................ 659-7300Badami ........................................ 659-1200Endicott ....................................... 659-2222Milne Point ........................... 911 or 670-3300Northstar ............................ 911 (from island)Greater Prudhoe Bay (East) ...... 911 or 659-5300Greater Prudhoe Bay (West) ..... 911 or 659-4222Drilling ............................ Use Contacts Above

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Section 8 WASTE

MANAGEMENT

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Introduction

Handling 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

The 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-

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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 segregation, and spill prevention help minimize waste generation. W

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Reuse and Recycling

On 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 recycledis 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

Disposal 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

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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 WasteHazardous 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 any of 39 designated compounds. Examples: benzene, lead, cadmium.

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

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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 WasteEPA 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.

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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 regulation if they exhibit a hazardous characteristic. W

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Non-Exempt WasteMany 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.

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Segregation / Labeling

Waste 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.

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Dumpsters

Several 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.

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

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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.

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Contaminated Gravel & Snow

Each 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 AreasSatellite 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

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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.

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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 beadded 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.

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Injection Wells

On 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.

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Drum / Barrel Management

BP 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.

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,

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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 ProcedureDrums 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.

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Drum/Barrel Management Contacts

Alpine ................................... 670-4200/4423Kuparuk ....................................... 659-7032Badami ........................................ 659-1243Endicott ....................................... 659-6541Milne Point .................................... 670-3473Northstar ...................................... 670-3508Greater Prudhoe Bay (GPB) ................ 659-4375Tool Services ................................. 659-4634

Waste Management Questions?

If you have a question about specific wastes, please contact the Field Environmental staff at your location.

Alpine ....................................670-4200/4423Kuparuk ................................ 659-7212/7242Badami ......................................... 659-1243Endicott ....................................... 659-6541Milne Point .................................... 670-3473Northstar ............................... 670-3507/3508GPB (East) ..................................... 659-5999GPB (West) ..................................... 659-4789GPB (Services) ................................. 659-5893GPB (Waste Coordinator) .................... 659-4810

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Notes

EmergencyAlpine...............................................911 or 670-4900Kuparuk ......................................................659-7300Badami .......................................................659-1200Endicott.......................................................659-2222Milne Point .......................................911 or 670-3300Northstar......................................... 911 (from island)Greater Prudhoe Bay (East) ............911 or 659-5300Greater Prudhoe Bay (West) ...........911 or 659-4222Drilling ...................................... Use Contacts Above

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

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

February 2005

North SlopeEnvironmentalField Handbook