State Regulations: Alaska

The Alaska Oil and Gas Conservation Commission (AOGCC) regulates the drilling for and production of oil and gas resources, the principles of oil and gas conservation, and the underground injection for both waste management and enhanced recovery. The AOGCC is an independent, quasi-judicial agency of the State of Alaska. The Alaska Department of Natural Resources (ADNR), Oil and Gas Division, is responsible for leasing state lands for oil and gas exploration. The agency implements programs that encourage exploration and development activities on state and private lands. The Alaska Department of Environmental Conservation (ADEC) administers a wide array of programs to protect human health and safeguard the natural environment.

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Disposal Practices and Applicable Regulations

The Alaska Oil and Gas Conservation Commission (AOGCC) has developed a regulatory program for two subsurface (onshore/offshore) methods of drilling and production waste disposal: underground injection and annular disposal. Title 20, Chapter 25 of the Alaska Administrative Code (AAC) contains the regulations of the AOGCC. Waste management other than underground injection or annular disposal, from the state perspective, is regulated by the Alaska Department of Environmental Conservation (ADEC) under Title 18 (various Chapters) of the AAC.

• Underground Disposal of Oil Field Wastes and Underground Storage of Hydrocarbons. The regulations of the AOGC are found at 20 AAC 25.252. The operator must:
• file a letter of application with the AOGCC;
• demonstrate that the proposed disposal will not allow the movement of oil field wastes into sources of freshwater 20 AAC 25.990(27): water that has a total dissolved solids concentration of less than 10,000 mg/l, and occurs in a stratum not exempted, or water that occurs in a stratum that serves as a source of drinking water for human consumption);
• case the disposal wells and cement the casing to isolate the disposal zone and protect oil, gas, and freshwater;
• conduct mechanical integrity testing (MIT) of the well prior to disposal and conduct retesting at least once every four years (water – MIT every four years; slurry – MIT every two years; and more frequent testing if well integrity concerns are identified);
• monitor the injection pressure and rate, as well as the pressure in the casing-tubing annulus during actual disposal operations; and
• notify the AOGCC of an indication of pressure communication or leakage, and implement corrective action or increased surveillance at the discretion of the AOGCC.



• Freshwater Aquifer Exemption. The regulations of the AOGC are found at 20 AAC 25.440. The operator must file a letter of application requesting the exemption. The AOGCC will issue the exemption if the freshwater aquifer meets the following:
• Does not currently serve as a source of drinking water;
• Will not serve as a source of drinking water in the future;
• Sufficient data are provided to substantiate the water quality and use.



• Annular Disposal of Drilling Waste. The regulations of the AOG are found at found at 20 AAC 25.080. An operator holding a permit to drill a well may dispose of drilling waste through the well's annular space after filing with the AOGC an Application for Sundry Approvals, along with the information required by the regulations.
• The operator must file a very detailed request for authorization, Form 10-403AD.
• The disposal operation must not contaminate freshwater, cause drilling waste to surface, impair well integrity, damage a producing zone or potential producing zone, or circumvent 20 AAC 25.252.
• Regulatory limitations with respect to the duration of disposal operations (ninety days, actual injection within one year), the disposal volumes (35,000 barrels), and the well location (drill pad or platform of drilling waste generation) apply, unless the operator demonstrates that compliance with the limitations is imprudent.
• Quarterly performance reporting on Form 10-423.



• Drilling Waste Disposal Facilities. The relevant solid waste management regulations of the ADEC are found at 18 AAC 60.430, entitled Drilling Wastes. A drilling waste disposal facility shall accept only drilling waste that meets the federal exploration and production exclusion from the definition of hazardous waste. It may not accept certain wastes described in the regulations. The facility owner or operator shall keep to a minimum the introduction of extraneous liquids, proceed under a fluid management plan if a dry option is selected, and operate with a minimum of two feet of freeboard. The design of a drilling waste disposal facility must take into account the location of the seasonal high groundwater table, surface water, and continuous permafrost, as well as proximity to human population and to public water systems, with the goal of avoiding any adverse effect on these resources.



• Other ADEC Regulations. In addition to solid waste management regulations (18 AAC 60), the ADEC has promulgated regulations governing hazardous waste. (18 AAC 62), which adopt the federal exclusion from the definition of hazardous waste for oil and gas exploration and production waste.



• Offshore Surface Disposal. If surface disposal is proposed offshore, the operator has to secure a permit from the U.S. Environmental Protection Agency (EPA) through the National Pollutant Discharge Elimination System (NPDES). For example, EPA Region 10 has issued NPDES General Permit AKG285000 for the Cook Inlet. Discharge is allowed for water-based muds, but not for oil-based and synthetic muds.

Additional Resources

• The AOGCC has posted all active approved injection orders and aquifer exemptions for reference.