Recently, the Justice Department levied a fine totaling $1.9-million in penalties and cleanup costs against UniSea Inc., for what could be gathered from local new articles, violations against federal and state environmental laws. It appears that what was missing this action that made it illegal was the fact that UniSea did not have the required permits for these particular discharges, including discharges of propylene glycol. There appears to be “grave” injustice this fine, as there are other “Clean Water Act” violators operating in Alaska that are getting away with far less fines and penalties for malfeasance well above and beyond what UniSea was indicted upon. In most cases, in no way shape or form a fine that spells it out that this kind of irresponsible behavior will be tolerated, as a deterrent. In a case of interest against Pioneer Natural Resources, the end result, it certainly does not send an important message of deterrence and accountability for environmental violations. Pioneer Natural Resources(PNR), a Texas based petroleum exploration corporation, was the 1st Independent to operate on Alaska's North Slope, starting up the Oooguruk Island production facility back in 2008, located in Harrison Bay of the Colville River Delta, Beaufort Sea. As a direct employee during the early part 2010, I filed complaints internally with Pioneer's management with respect to illegal injection of used glycol, leftover from the warm-up start-up of the production facility's pipelines. Upon receiving my complaint titled “Alaska's Deadliest Sin”, PNR filed a counter-report with the State of Alaska AOGCC(Alaska Oil & Gas Conservation Committee), the regional EPA and the State of Alaska Attorney General, denying all and any illegal injection allegations, based on those complaints mentioned earlier. When I provided PNR and the AOGCC and the EPA further proof that the illegal injection did indeed take place, as documented in PNR's own “Operations Log Book” - a legal document - PNR amended their original report with the AOGCC, this time admitting to the injection of 49,000 gallons of used propylene glycol, without a permit. This is probably the largest illegal injection on record that ever occurred on Alaska's North Slope in 30-years of operation, with respect to the oil & gas industry. But in the end, PNR was fined only $10,000 dollars, or based on oil prices at the time the fine was levied, about 20-minutes worth of oil production time. The fine was meager and confusing, due the fact that the AOGCC could not determine how many days the illegal activity went on, evidence lacking, so PNR was fined the maximum daily fine of $5000, for two days only, or something to that effect. Had I not been persistent and had not before me the overruling evidence to prove that the illegal injections took place without the proper permits, as PNR's AIO(Area Injection Order) did not allow for glycol injection, PNR management would never had reported this and probably would have continued this illegal discharging until such time all of the questionable glycol was hidden away. And this “sham” recycling as it is called, it was done as a means to get rid of contaminated fluids(used glycol with elevated ph levels) that could not be sold for re-use. To properly dispose of this chemical fluid, it would have been a very costly venture, but it is the cost of doing business on the “slope”. It was not a mistake, I repeat, not a mistake or a defense that the “operators” thought it was OK from past experiences as the AOGCC report delivered by PNR finds so convenient an excuse as a lullaby. The operations' staff was instructed to do this by the PNR Operations Superintendent, through verbal orders, to get rid of the stuff he could not sell. The matter was of such concern to the AOGCC, it instigated a 3rd party investigation upon PNR and the AOGCC's oversight capabilities, yet even today we see that PNR was levied nothing close to what could be righteously considered a deterrent. I have filed two complaints with the EPA over this matter, they have the reports from PNR, they have been in the loop, but nothing has come of my concern. Not even any feedback, as if they would rather not touch this one. I believe that the EPA is staying clear their responsibilities this issue for reasons that are not consistent its mission and goals, to protect the environment and prosecute violators. There is a lot of pressure from the Alaska legislature to make the Independents feel comfortable here in Alaska, to fill the so-called void in the pipeline, by developing “marginal” fields. Our own D.C. Delegation is behind the “Independents” success. I believe this is getting in the way of environmental stewardship. With that in mind, I have requested that the Justice Department in its authority, look into this matter as to what went on between PNR and the AOGCC and EPA, in efforts to make sure preferential treatment has not placed the oversight in a weak position. Once again, when one compares what PNR did illegally to that conviction upon UniSea, there is something drastically wrong this equation, with respect to the outcome. UniSea's fine, it is a deterrent. With Pioneer, more like a bonus!
For Our Environment ~ Uncovering Public Trust Doctrine Violators on Alaska's Frontier
THIS SITE HISTORICAL:
In 2008 through 2010, an "Independent mom & pop" oil company violated the "Alaskan Public Trust" doctrine, allowing malfeasance and environmental atrocities upon the "Last Frontier". This "blog" is dedicated to follow the outcome of the illegal activities that have now become front and center attention before the regulators in charge of making sure the "Public Trust" is upheld, as a centralized forum to make sure Alaskans and others are kept abreast of penalties and fines upon those that feel Alaska is the "Last Frontier Dumping Grounds".
The above image depicts a crude oil well flow-back test, wherein for days hydrocarbon saturated "wet" natural gas was allowed to vent to the atmosphere out a safety relief valve, with temperatures and ambient conditions such that the "wet" vapors most likely condensed and fell upon the pristine waters of Harrison Bay of the Colville River delta, a place so far removed from man-made pollution. This image is also the cover photo of the report called "Alaska's Deadliest Sin", a culmination of malfeasance and environmental corruption evidence upon this Independent, collected by an ex-employee who has made it a personal "mission" to make sure this kind of irresponsible behavior is stopped and never again repeated on this "Frontier". To date, the company – Pioneer Natural Resources - has attempted to deny all allegations, but the evidence allowing denial is too strong. With that, the company has started to admit true so serious these violations. They have admitted their actions are indeed a violation of "Public Trust". With a 3rd party ongoing investigation following the submittal of the "Sin", the end result should be stiff fines and penalties upon the perpetrators, that which sends a message to those that want to "Go North" for oil exploration and exploitation.
"Drill Baby Drill" is upon us, thanks to Sarah Palin and others, and we must stand up against this all out blitzkrieg assault upon the ecosystem, to protect the environment from continued malfeasance and environmental atrocities, as it is not worth another Love Canal!
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In 2008 through 2010, an "Independent mom & pop" oil company violated the "Alaskan Public Trust" doctrine, allowing malfeasance and environmental atrocities upon the "Last Frontier". This "blog" is dedicated to follow the outcome of the illegal activities that have now become front and center attention before the regulators in charge of making sure the "Public Trust" is upheld, as a centralized forum to make sure Alaskans and others are kept abreast of penalties and fines upon those that feel Alaska is the "Last Frontier Dumping Grounds".
The above image depicts a crude oil well flow-back test, wherein for days hydrocarbon saturated "wet" natural gas was allowed to vent to the atmosphere out a safety relief valve, with temperatures and ambient conditions such that the "wet" vapors most likely condensed and fell upon the pristine waters of Harrison Bay of the Colville River delta, a place so far removed from man-made pollution. This image is also the cover photo of the report called "Alaska's Deadliest Sin", a culmination of malfeasance and environmental corruption evidence upon this Independent, collected by an ex-employee who has made it a personal "mission" to make sure this kind of irresponsible behavior is stopped and never again repeated on this "Frontier". To date, the company – Pioneer Natural Resources - has attempted to deny all allegations, but the evidence allowing denial is too strong. With that, the company has started to admit true so serious these violations. They have admitted their actions are indeed a violation of "Public Trust". With a 3rd party ongoing investigation following the submittal of the "Sin", the end result should be stiff fines and penalties upon the perpetrators, that which sends a message to those that want to "Go North" for oil exploration and exploitation.
"Drill Baby Drill" is upon us, thanks to Sarah Palin and others, and we must stand up against this all out blitzkrieg assault upon the ecosystem, to protect the environment from continued malfeasance and environmental atrocities, as it is not worth another Love Canal!
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