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Furie, DEC, agree to compliance order
Company will pay civil assessment of $202,699; agreement resolves issues under APDES for violations since HEX took ownership of Kitchen Lights Kristen Nelson Petroleum News
A compliance order by consent, signed in early May by Furie Operating Alaska, the state of Alaska and the Alaska Department of Environmental Conservation's Division of Water, involves payment of a civil assessment of $202,699 by Furie for issues at the Kitchen Lights unit since HEX Cook Inlet LLC purchased Furie and Cornucopia and began operations under the new ownership on July 1, 2020. If Furie complies with requirements of the order, DEC will not institute civil enforcement action based on violations cited in the order.
If there are violations of the order, additional civil assessments will be assessed.
In 2014, Furie, then owned and operated by Cornucopia Oil and Gas Co., received an Alaska Pollutant Discharge Elimination System individual permit authorizing discharge of wastewater associated with offshore construction and operation of the platform at Kitchen Lights. That permit, which expired in 2019, did not cover produced water discharge, but in 2019 Cornucopia requested and received an amendment adding produced water and the permit was extended by DEC until reissuance.
In December 2020, after the purchase by HEX, Furie began discharging domestic wastewater exceeding effluent limits in the permit, which continued through February 2024.
DEC reissued the APDES permit to Furie in February 2021, effective April 1, 2021, and expiring March 31, 2026.
Noncompliance In December 2021, DEC notified Furie that the Environmental Protection Agency had placed the Kitchen Lights facility on its significant noncompliance list for violations of effluent limits in the permit.
Furie's performance on submission and notification of noncompliance improved, but other notifications did not improve until early 2023.
In 2022 Furie began working to resolve domestic wastewater exceedance at its RedFox wastewater treatment facility and began meeting with DEC's Permitting Program to discuss ongoing compliance challenges.
In May 2022 DEC performed a routine inspection of the platform, the first inspection by the agency after the EPA handed over inspection responsibility to the state, with an inspection report and notice of enforcement issued to Furie in September 2022.
Furie responded in October identifying items it found inaccurate or not applicable to current ownership. In February 2023 DEC issued a revised report and notice of violation adjusted to an evaluation period beginning July 1, 2020, the date current ownership began, through May 1, 2022.
In July 2023, Furie submitted for review a plan to modify its RedFox wastewater treatment facility, and in August 2023 DEC approved the modifications.
In December 2023, Furie submitted a complete general application to DEC's Permitting Program.
Violations In the compliance order, DEC identified violations subsequent to those identified in the notice of violations issued in 2022 and revised in early 2023.
These violations included:
*Failure to comply with domestic wastewater numeric effluent limits for the platform;
*Failure to comply with produced wastewater numeric effluent limits for the platform;
*Failure to submit certification that quality assurance project plan had been developed and implemented;
*Failure to submit certification that best management practices plan had been developed and implemented;
*Failure to analyze pollutants according to approved test procedures;
*Failure to conduct monitoring of domestic wastewater discharge during March 2021 and May 2022;
*Failure to analyze some samples according to EPA method;
*Failure to submit notice of noncompliance for a number of violations; and
*Failure to submit timely reports to DEC.
Corrective actions required A number of corrective actions are required:
*Written DEC approval required for any changes to existing DEC approved designs;
*Completion by June 30, 2024, of installation of additional filtration system on RedFox WWTF;
*Submittal of required information to obtain final approval for operation of WWTF filtration system;
*Submittal of completed quarterly progress report form within 30 days of end of each calendar quarter;
*Furie proposes less stringent copper effluent limits under general permit authorization and as long as Furie complies with proper operation and maintenance permit requirements and provides timely information, copper numeric effluent exceedances before change in copper effluent limits changes under general permit will not be subject to assessments;
*If Furie has not received authorization for produced water discharge under general permit within a year, but has otherwise complied with requirements, parties agree to confer on necessity of any additional corrective actions; and
*If DEC determines corrective actions in order are insufficient, DEC will request of Furie in writing any additional information or additional corrective actions, which will take effect immediately if parties agree, and be incorporated under order.
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