CHUKCHI SEA 

REGIONAL EXPLORATION 

OIL DISCHARGE PREVENTION 

AND 

CONTINGENCY PLAN 

SHELL 

ANCHORAGE, ALASKA 

MARCH 2010 


Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Management Approval and Manpower Authorization 

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Record of Revisions 

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RECORD OF REVISIONS 

REVISION 

NUMBER 

REVISION 

DATE 

DATE 

ENTERED SUMMARY OF REVISION 

 
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Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

Shell v March 2010 

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OIL POLLUTION ACT OF 1990 (OPA 90) 

U.S. MINERALS MANAGEMENT SERVICE 

U.S. COAST GUARD 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

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Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

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U.S. MINERALS MANAGEMENT SERVICE 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

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Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

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CHUKCHI SEA REGIONAL EXPLORATION 

OIL DISCHARGE PREVENTION AND CONTINGENCY PLAN 

CROSS REFERENCE TO 

U.S. MINERALS MANAGEMENT SERVICE RESPONSE PLAN REQUIREMENTS 

[30 CODE OF FEDERAL REGULATIONS (CFR) 254, SUBPART B] 

REGULATION SECTION 

(30 CFR) SECTION TITLE PLAN SECTION 

254.22 Introduction and Plan Contents Introduction and Table of Contents 

(a) Identification of Facility, Including Location and Type Introduction and Section 3.1 

(b) Table of Contents Table of Contents 

(c) Record of Changes Oil Pollution Act (OPA 90) Addendum

(d) Cross-Reference Table This section 

254.23 Emergency Response Action Plan Section 1.0 

(a) Designation of Trained Qualified Individual (QI) (with full 

authority to implement removal actions and notify federal 

officials and response personnel) 

Sections 1.2 and 3.3 

(b) Designation of Trained Spill Management Team Available 

24 hours (hr) (including organizational structure and 

responsibilities and authorities of team members) 

Sections 1.2 and 3.3 

(c) Description of Spill Response Operating Team, Including 

Numbers and Types of Personnel (trained and available on 

24-hr basis) 

Figure 1.1-1, Table 1.2-1, Sections 

1.1 and 3.1 

(d) Locations and Primary and Secondary Communications for 

Spill Response Operations Center (including phone 

numbers and radios) 

Section 1.4, Table 1.2-1 

(e) List of Types of Oil Handled, Stored or Transported Introduction and Appendix F 

(f) Procedures for Early Detection of a Spill Sections 2.1 and 2.5 

(g) Procedures for Spill or Substantial Threat of a Spill for 

Differing Spill Sizes 

Sections 1.6 and 1.6.13 

(g)(1) Notification Procedures (including reporting form from the CPlan) Section 1.2.1 

(g)(1)(i) Contact Information for QI, Spill Response Coordinator and 

Alternates, and Other Spill Response Management Team 

Members 

Section 1.2.1 

(g)(1)(ii) Names and Addresses for Oil Spill Removal Organizations 

(OSRO) and Regulatory Agencies to be Notified and 

Contacted for Environmental Information 

Sections 1.2.2 and1.2.3 

(g)(2) Methods to Monitor and Predict Spill Movement Sections 1.6.4 and 1.6.13 

(g)(3) Methods to Identify and Prioritize Sensitive Areas Sections 1.6.5, 3.2 and Appendix E 

254.23 (g)(4) Methods to Protect Sensitive Areas Sections 1.6.5, 1.6.11, 1.6.12 and 

Appendix E 

(g)(5) Methods to Mobilize and Deploy Equipment and Personnel Sections 1.5 and 1.6.13 

(g)(6) Methods for Storage of Recovered Oil (to allow containment 

and recovery to continue without interruption) 

Sections 1.6.9, 1.6.10, 1.6.13, and 

Appendix D 

(g)(7) Procedures to Remove Oil and Oiled Debris from Shallow 

Areas and Along Shorelines and to Rehabilitate Oiled 

Waterfowl 

Sections 1.6.12 and 1.6.13, 

Appendix E 

(g)(8) Storage, Transfer, and Disposal Procedures Sections 1.6.9, 1.6.10, and 

Appendix D 

(g)(9) Methods to Implement Dispersant Use Plan and In situ 

Burning Plan 

Sections 1.7 and 3.7 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

CHUKCHI SEA REGIONAL EXPLORATION 

OIL DISCHARGE PREVENTION AND CONTINGENCY PLAN 

CROSS REFERENCE TO 

U.S. MINERALS MANAGEMENT SERVICE RESPONSE PLAN REQUIREMENTS 

[30 CFR 254, SUBPART B] 

(CONTINUED) 

Shell MMS-2 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

REGULATION SECTION 

(30 CFR) SECTION TITLE PLAN SECTION 

254.24 Equipment Inventory Section 3.6 

(a) Inventory of Spill Response Materials and Supplies, 

Services, Equipment, and Response Vessels Available 

Locally and Regionally (identify supplier, location, and 

telephone number) 

Sections 3.6.1 and 3.8 

(b) Procedures for Inspecting and Maintaining Spill Response 

Equipment (inspected monthly; records of inspections and 

maintenance kept for at least 2 years) 

Section 3.6.2 

254.25 Contractual Agreements (copies of contracts or membership 

agreements or certification that they are in effect; must 

ensure 24 hr availability) 

Section 3.8 and Appendix B 

254.26 Worst Case Discharge Scenario Section 1.6.13 

(a) Volume and Assumptions/Calculations Section 1.6.13 

(b) Trajectory Analysis (including maximum extent of oil travel) Sections 1.6.13 and 3.2 

(c) List of Sensitive Areas That Could Be Affected (from C-Plan) 

and Strategies for Protecting Them 

Sections 1.6.13, 3.10 and Appendix E

(d) Response to Worst Case Scenario in Adverse Weather 

Conditions 

Sections 1.6.13 and 3.4.1 

(d)(1) Response Equipment Used for a 30-day Blowout (types, 

locations, owners, quantity, capabilities, and daily recovery 

capacities derated to 20%) 

Section 1.6.13 

(d)(2) Personnel, Materials, and Support Vessels (Locations, 

Owners, Quantities, and Types) 

Section 1.6.13 

(d)(3) Description of Oil Storage, Transfer, and Disposal 

Equipment (Location, Owners, Quantities, and Capacities) 

Section 1.6.13 

(d)(4) Estimate of Response Times Section 1.6.13 

(d)(4)(i) Procurement of Identified Containment, Recovery, and 

Storage Equipment 

Section 1.6.13 

(d)(4)(ii) Procurement of Equipment Transportation Vessels Section 1.6.13 

(d)(4)(iii) Procurement of Personnel to Load and Operate the 

Equipment 

Section 1.6.13 

(d)(4)(iv) Equipment Loadout Section 1.6.13 

(d)(4)(v) Travel to Deployment Site Section 1.6.13 

(d)(4)(vi) Equipment Deployment Section 1.6.13 

(e) Equipment, Materials, Support Vessels, and Strategies Must 

be Suitable to Range of Environmental Conditions. 

Discussion in (d) Must Use Standardized Defined Terms in 

American Society for Testing and Materials (ASTM) F625-94 

and F8 18-93 

Section 1.6.13 

254.27 Dispersant Use Plan Sections 1.7 and 3.7 

(a) Inventory and Location of Dispersants and Other Spill 

Response Chemicals 

Sections 1.7 and 3.7 

(b) Summary of Toxicity Data Section 3.7 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

CHUKCHI SEA REGIONAL EXPLORATION 

OIL DISCHARGE PREVENTION AND CONTINGENCY PLAN 

CROSS REFERENCE TO 

U.S. MINERALS MANAGEMENT SERVICE RESPONSE PLAN REQUIREMENTS 

[30 CFR 254, SUBPART B] 

(CONTINUED) 

Shell MMS-3 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

REGULATION SECTION 

(30 CFR) SECTION TITLE PLAN SECTION 

(c) Application Equipment and Time to Deploy Sections 1.7 and 3.7 

(d) Application Procedures Sections 1.7 and 3.7 

(e) Conditions Under Which Product Use May be Requested Sections 1.7 and 3.7 

(f) Outline of Procedures for Obtaining Approval Sections 1.7 and 3.7 

254.28 In situ Burning Plan Sections 1.7 and 3.7 

254.28(a) Description of Equipment, Including Availability, Location, 

and Owner 

Section 1.7 

(b) In situ Burning Procedures, Including Ignition Section 1.7 

(c) Environmental Effects of Burn Section 1.7 

(d) Guidelines for Well Control and Personnel Safety Sections 1.3, 1.6.2, 1.6.3, 1.7, and 

3.7 

(e) Circumstances When Burning is Appropriate Section 1.7 

(f) Guidelines for making Decision to Ignite Section 1.7 

(g) Outline of Procedures for Obtaining Approval Section 1.7 

254.29 Training and Drills Sections 2.1.1 and 3.9 

(a) Training: Describe Dates and Types of Training Given to 

Response Team Personnel; Location of Certificates, annual 

hands-on training of spill response operating team, annual 

training for spill response management team, including 

locations, intended use, deployment strategies, and 

operation and logistics of response equipment; spill 

reporting; trajectory analysis; responsibilities [QI sufficiently 

trained] (keep training certificates and attendance records 

for at least 2 years) 

Sections 2.1 and 3.9 

(b) Exercise Plans (for Annual Spill Management Team 

Tabletop, Annual Deployment of Equipment Staged 

Onshore, Annual Notification Exercise, Semiannual 

deployment for Equipment and Facility) (entire plan must be 

exercised once every 3 years); (National Preparedness for 

Response Exercise Program [PREP] can be used) 

Sections 2.1 and 3.9 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

Shell MMS-4 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

The Worst Case Discharge (WCD) volume and storage capacities are calculated to address Minerals 

Management Service (MMS) and Alaska Department of Environmental Conservation (ADEC) 

requirements. ADEC regulations (18 Alaska Administrative Code [AAC] 75.434) establish the Response 

Planning Standard (RPS) for an exploration facility to be 5,500 barrels of oil per day (bopd), or best 

producing well data, for the duration of fifteen (15) days. MMS references a 30 day timeframe [30 CFR 

254.47(b)]. Therefore, the WCD volume is presented as 5,500 bbl x 30 days to total 165,000 bbl. 

To determine the storage capacity requirements based upon ADEC guidance, an emulsion factor of 1.54 

and a percentage of free water (20 percent) have been added to the initial RPS of 165,000 for a total 

storage volume of 287,100 bbl. 

WORST CASE DISCHARGE VOLUME 

ELEMENT CAPACITY (BBL) REFERENCE 

Sum of Capacity of Oil Storage Tanks 319,646 Table 1.6-8 

Estimated Daily Volume of Highest 

Capacity Well 5,500 18 AAC 75.434(b) 

Total WCD (Daily Volume X 30-Days) 165,000 30 CFR 254.47(b) 

Total Storage Capacity Requirements 

(165,000 x 1.54) + 

(165,000 x 20%) = 

287,100 

Part 5 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

Shell USCG-i March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

U.S. COAST GUARD 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

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Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

Shell USCG-1 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

CHUKCHI SEA REGIONAL EXPLORATION 

OIL DISCHARGE PREVENTION AND CONTINGENCY PLAN 

CROSS REFERENCE TO 

U.S. COAST GUARD AND DEPARTMENT OF HOMELAND SECURITY 

RESPONSE PLANS FOR OIL FACILITIES 

TRANSFERRING OIL OR HAZARDOUS MATERIAL IN BULK 

[33 CFR 154] 

REGULATION 

SECTION 

(33 CFR 154) SECTION TITLE PLAN SECTION 

1035(a) Introduction, Plan Contents, and Cross Index OPA 90 Addendum, Introduction 

(a)(1) Facility name, address, telephone and fax numbers, mailing 

address 

Introduction 

(a)(2) Facility’s geographic location Introduction, Figure I-1, and Section 3.1 

(a)(3) 24-hr procedure for contacting facility owner OPA 90 Addendum, Sections 1.1, and 

1.2 

(a)(4) Table of contents Table of Contents 

(a)(5) Cross index This document 

(a)(6) Record of changes Record of Revisions 

(b) Emergency Response Action Plan Section 1 

(b)(1) Notification procedures Sections 1.1, 1.2, and 3.3 

(b)(1)(i)(A) List of response personnel (include QI) OPA 90 Addendum, Sections 1.1, 1.2 

and 3.3 

(b)(1)(i)(B) Government agencies Section 1.2.3, Tables 1.1-2, 1.1-3, and 

1.2-1 

(b)(1)(ii) Notification form Figure 1-2 

(b)(2)(i)(A) Average most probable discharge Page USCG-3 

(b)(2)(i)(B) Maximum most probable discharge Page USCG-3 

(b)(2)(i)(C) Worst case discharge Page USCG-3 

(b)(2)(i)(D) Worst case discharge from non-MTR portion Not applicable 

(b)(2)(ii)(A) Failure of manifold, loading arm, hoses, other Section 1.6 

(b)(2)(ii)(B) Tank overfill Sections 2.1.9 and 3.1 

(b)(2)(ii)(C) Tank failure Not applicable 

(b)(2)(ii)(D) Piping rupture Not applicable 

(b)(2)(ii)(E) Piping leak Not applicable 

(b)(2)(ii)(F) Explosion or fire Section 1.6.2 

(b)(2)(ii)(G) Equipment failure Sections 1.6 and 2.1.6 

(b)(2)(iii) List of equipment and responsibilities for mitigation of average 

most probable discharge 

Sections 3.5 and 3.6 

(b)(3)(i) Facility’s personnel responsibilities Sections 1.1, 3.3; Table 1.1-1; and 

Figure 1.1-1 

(b)(3)(ii) QI’s responsibility and authorities Sections 1.1 and 3.3 

(b)(3)(iii) Personnel to manage response actions Sections 1.1and 3.3 

(b)(3)(iv)(A) OSRO and spill management team capabilities Sections 1.1, 1.2, and 3.3 

(b)(3)(iv)(A)(1) Provide equipment and supplies for the average most probable 

discharge 

Section 3.6 

(b)(3)(iv)(A)(2) Trained personnel for 7 days Section 3.8 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

CHUKCHI SEA REGIONAL EXPLORATION 

OIL DISCHARGE PREVENTION AND CONTINGENCY PLAN 

CROSS REFERENCE TO 

U.S. COAST GUARD AND DEPARTMENT OF HOMELAND SECURITY 

RESPONSE PLANS FOR OIL FACILITIES 

TRANSFERRING OIL OR HAZARDOUS MATERIAL IN BULK 

[33 CFR 154] 

(CONTINUED) 

Shell USCG-2 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

REGULATION 

SECTION 

(33 CFR 154) SECTION TITLE PLAN SECTION 

(b)(4)(i) Sensitive areas Sections 1.6.5 and 3.10 

(b)(4)(ii) Worst case discharge Sections 1.0 and 1.6.13 

(b)(4)(ii)(A) List of sensitive areas Sections 1.6.12 and 3.10.2 

(b)(4)(ii)(B) Procedures to protect sensitive areas Sections 1.6.5, 1.6.12, and 3.10 

(b)(4)(ii)(C) Depict response actions on map Section 1.6.12 

(b)(4)(iii)(A) Personnel and equipment to protect sensitive areas Sections 1.6.12 and 1.6.13 

(b)(4)(iii)(B)(1), (2) Persistent oils: distance traveled Section 1.6.13 

(b)(4)(iii)(B)(3) Distance spill reaches in 24 hr at maximum current for discharge 

to non-tidal waters 

Not applicable; no discharge possible to 

streams 

(b)(4)(iii)(B)(4) Distance spill reaches in tidal waters Section 1.6.13 

(b)(4)(iii)(B)(5) Trajectory model Section 1.6 

(b)(4)(iii)(B)(6) Additional areas Section 1.6 

(c)(1) Training procedures Sections 2.1.1 and 3.9 

(c)(2) Drill procedures Sections 2.1.1 and 3.9 

(d) Plan review and update procedures Introduction 

(e)(1)(i) Physical description of facility Section 3.1 

(e)(1)(ii) Vessels transferring at facility Section 2.1.5 

(e)(1)(iii) Location of first valve in secondary containment Not applicable 

(e)(1)(iv) Information on oil Appendix F 

(e)(2)(i) 24-hr contact for QI and alternate OPA 90 Addendum and Table 1.1-2 

(e)(2)(ii) 24-hr contact for OSRO Sections 1.1 and 3.3 

(e)(2)(iii) 24-hr contact for agencies Section 1.2.2 

(e)(3)(i) Equipment and personnel for average most probable discharge Sections 1.1, 3.3, and 3.6.1 

(e)(3)(ii) & (iii) Other equipment information Section 3.6 

(e)(4) Communications Plan Sections 1.4 and 4.1 

(e)(5) Site-specific Health and Safety Plan Section 1.3 

(e)(6) List of acronyms and definitions Acronyms List 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

Shell USCG-3 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

CHUKCHI SEA REGIONAL EXPLORATION 

OIL DISCHARGE PREVENTION AND CONTINGENCY PLAN 

CROSS REFERENCE TO 

U.S. COAST GUARD AND DEPARTMENT OF HOMELAND SECURITY 

RESPONSE PLANS FOR OIL FACILITIES 

TRANSFERRING OIL OR HAZARDOUS MATERIAL IN BULK 

[33 CFR 154] 

POTENTIAL DISCHARGES 

Average Most Probable Discharge 

The average most probable discharge is calculated as approximately 0.5 bbl of diesel fuel, based on the 

definition contained in 33 CFR 154.1020 (the lesser of 50 bbl or 1 percent of the volume of the worst case 

discharge [WCD]). 

Maximum Most Probable Discharge 

The maximum most probable discharge is 5.0 bbl of diesel fuel, calculated from the definition contained in 

33 CFR 154.1020 (the lesser of 1,200 bbl or 10 percent of the volume of the WCD). 

Worst Case Discharge 

The WCD (for the purposes of the U.S. Coast Guard [USCG]) is 2,000 gallons (gal) (48 bbl), as calculated 

in Section 1.6 based on the definition contained in 33 CFR 154.1029(b)(2), using the following values: 

 Maximum Time to Discover Release: 5 minutes 

 Maximum Time to Shutdown Pumping: 0.5 minutes (30 seconds) 

 Maximum Transfer Rate: 320 gallons per minute (gpm) (based on representative fuel transfer 

pumps on the oil spill response vessel (OSRV) = 7.6 bbl/minute (min) 

 Total Line Drainage Volume: 163 gallons [premising 4-inch by 820 feet (ft) marine hose 

between the pump manifold on the fuel barge and the delivery flange on the inlet piping at the 

drillship] or 3.9 bbl. 

Type of product spilled: Low-sulfur Arctic diesel (Refer to Appendix F) 

Cause: Hose flange cracks and/or hose ruptures during diesel fuel transfer 

operations to the Frontier Discoverer

Environmental conditions: Winds 10 knots northeast (prevailing wind direction), clear skies, average 

temperature 44 degrees Fahrenheit (°F) (average for August) 

Spill trajectory: Approximately 10 percent of the spill is contained on the deck of the 

fueling barge, and 90 percent of the spilled diesel enters the water. 

Current is assumed to be 0.75 knots to the west-northwest (WNW). 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Oil Pollution Act of 1990 – U.S. Minerals Management Service/ 

U.S. Coast Guard 

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Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Table of Contents 

Shell T-i March 2010 

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SHELL 

OIL DISCHARGE PREVENTION AND CONTINGENCY PLAN 

TABLE OF CONTENTS 

MANAGEMENT APPROVAL AND MANPOWER AUTHORIZATION ......................................................... i 

RECORD OF REVISIONS ........................................................................................................................... iii 

OIL POLLUTION ACT OF 1990 (OPA 90) ................................................................................................... v 

U.S. Minerals Management Service ...................................................................................... MMS-1 

Worst Case Discharge Volume .............................................................................................. MMS-4 

U.S. Coast Guard ................................................................................................................. USCG-1 

Potential Discharges ............................................................................................................ USCG-3 

LIST OF ACRONYMS .............................................................................................................................. T-vi 

INTRODUCTION ......................................................................................................................................... I-1 

Objectives ...................................................................................................................................... I-3 

Alaska Clean Seas Technical Manual and Shell Beaufort and Chukchi Seas 

Regional Tactics Manual ................................................................................................................ I-3 

Plan Distribution ............................................................................................................................. I-4 

Updating Procedures ..................................................................................................................... I-4 

PART 1 RESPONSE ACTION PLAN [18 AAC 75.425(e)(1)] ................................................................ 1-1 

 1.1 EMERGENCY ACTION CHECKLIST [18 AAC 75.425(e)(1)(A)] ..................................... 1-1 

 1.2 REPORTING AND NOTIFICATION [18 AAC 75.425(e)(1)(B)] ....................................... 1-5 

 1.2.1 Initial Reporting ................................................................................................... 1-5 

 1.2.2 External Notification Procedures ....................................................................... 1-10 

 1.2.3 Written Reporting Requirements ....................................................................... 1-10 

 1.3 SAFETY [18 AAC 75.425(e)(1)(C)] ................................................................................ 1-13 

 1.4 COMMUNICATIONS [18 AAC 75.425(e)(1)(D)] ............................................................ 1-14 

 1.4.1 Communications Plan ....................................................................................... 1-14 

 1.4.2 Communications Equipment ............................................................................. 1-14 

 1.4.3 Equipment Maintenance ................................................................................... 1-18 

 1.5 DEPLOYMENT STRATEGIES [18 AAC 75.425(e)(1)(E)] ............................................. 1-19 

 1.5.1 Transport Procedures [18 AAC 75.425(e)(1)(E)(i)] ........................................... 1-20 

 1.6 RESPONSE STRATEGIES [18 AAC 75.425(e)(1)(F)] .................................................. 1-21 

 1.6.1 Procedures to Stop Discharge [18 AAC 75.425(e)(1)(F)(i)] .............................. 1-21 

 1.6.2 Fire Prevention and Control [18 AAC 75.425(e)(1)(F)(ii)] ................................. 1-21 

 1.6.3 Blowout Control/Relief Well Plan ...................................................................... 1-22 

 1.6.4 Discharge Tracking [18 AAC 75.425(e)(1)(F)(iv)] ............................................. 1-24 

 1.6.5 Protection of Sensitive Areas [18 AAC 75.425(e)(1)(F)(v)] .............................. 1-25 

 1.6.6 Containment and Control Strategies [18 AAC 75.425(e)(1)(F)(vi)] ................... 1-25 

 1.6.7 Recovery Strategies [18 AAC 75.425(e)(1)(F)(vii)] ........................................... 1-28 

 1.6.8 Lightering, Transfer, and Storage of Oil from Tanks 

 [18 AAC 75.425(e)(1)(F)(viii)] ............................................................................ 1-30 

 1.6.9 Transfer and Storage Procedures [18 AAC 75.425(e)(1)(F)(ix)] ...................... 1-30 

 1.6.10 Temporary Storage and Disposal [18 AAC 75.425(e)(1)(F)(x)] ........................ 1-30 

 1.6.11 Wildlife Protection [18 AAC 75.425(e)(1)(F)(xi)] ............................................... 1-31 

 1.6.12 Shoreline Cleanup [18 AAC 75.425(e)(1)(F)(xii)] .............................................. 1-31 

 1.6.13 Spill Response Scenarios ................................................................................. 1-42 

 1.7 NON-MECHANICAL RESPONSE OPTIONS [18 AAC 75.425(e)(1)(G)] ...................... 1-99 

 1.7.1 Obtaining Permits and Approvals ..................................................................... 1-99 

 1.7.2 Decision Criteria for Use ................................................................................... 1-99 

 1.7.3 Implementation Procedures ............................................................................ 1-100 

 1.8 FACILITY DIAGRAMS [18 AAC 75.425(e)(1)(H)] ........................................................ 1-101 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Table of Contents 

Shell T-ii March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

PART 2 PREVENTION PLAN [18 AAC 75.425(e)(2)] ........................................................................... 2-1 

 2.1 PREVENTION, INSPECTION, AND MAINTENANCE PROGRAMS 

 [18 AAC 75.425(e)(2)(A)] ................................................................................................. 2-1 

 2.1.1 Prevention Training Programs [18 AAC 75.020] ................................................. 2-1 

 2.1.2 Substance Abuse Programs [18 AAC 75.007(e)] ............................................... 2-1 

 2.1.3 Medical Monitoring [18 AAC 75.007(e)] .............................................................. 2-2 

 2.1.4 Security Program [18 AAC 75.007(f)] ................................................................. 2-2 

 2.1.5 Fuel Transfer Procedures [18 AAC 75.025] ........................................................ 2-3 

 2.1.6 Maintenance Programs ....................................................................................... 2-5 

 2.1.7 Operating Requirements for Exploration [18 AAC 75.045] ................................. 2-5 

 2.1.8 Blowout Prevention and Emergency Shutdown [18 AAC 75.425(e)(1)(I)] .......... 2-6 

 2.1.9 Oil Storage Tanks [18 AAC 75.065] .................................................................. 2-13 

 2.1.10 Emergency Tow and Escort Vessels Program ................................................. 2-14 

 2.2 DISCHARGE HISTORY (>55 GAL) [18 AAC 75.425(e)(2)(B)] ...................................... 2-14 

 2.3 ANALYSIS OF POTENTIAL DISCHARGES [18 AAC 75.425(e)(2)(C)] ........................ 2-14 

 2.3.1 Potential Areas for Discharge ........................................................................... 2-14 

 2.4 OPERATIONAL CONDITIONS INCREASING RISK OF DISCHARGE 

 [18 AAC 75.425(e)(2)(D)] ............................................................................................... 2-17

 2.4.1 Severe Weather ................................................................................................ 2-17 

 2.4.2 Ice Conditions ................................................................................................... 2-18

 2.4.3 Structural Icing .................................................................................................. 2-19 

 2.4.4 Critical Operations and Curtailment Plan .......................................................... 2-19 

 2.4.5 Hours of Light at 71°N ....................................................................................... 2-20 

 2.5 DISCHARGE DETECTION [18 AAC 75.425(e)(2)(E)] ................................................... 2-21 

 2.5.1 Drilling Operations ............................................................................................ 2-21 

 2.5.2 Automated Methods .......................................................................................... 2-21 

 2.6 RATIONALE FOR CLAIMED PREVENTION CREDITS [18 AAC 75.425(e)(2)(F)] ...... 2-21 

 2.7 COMPLIANCE SCHEDULE [18 AAC 75.425(e)(2)(G)] ................................................. 2-21 

PART 3 SUPPLEMENTAL INFORMATION [18 AAC 75.425(e)(3), 30 CFR 254.22(a), 

 30 CFR 254.23(e), AND 30 CFR 254.26] ................................................................................. 3-1 

 3.1 FACILITY DESCRIPTION AND OPERATIONAL OVERVIEW 

 [18 AAC 75.425(e)(3)(A)] ................................................................................................. 3-1 

 3.1.1 Facility Description .............................................................................................. 3-1

 3.1.2 Bulk Storage Containers ..................................................................................... 3-3 

 3.1.3 Transfer Procedures ........................................................................................... 3-3 

 3.1.4 Vessel Plans and Diagrams ................................................................................ 3-3 

 3.2 RECEIVING ENVIRONMENT [18 AAC 75.425(e)(3)(B)] ................................................ 3-3 

 3.3 COMMAND SYSTEM [18 AAC 75.425(e)(3)(C)] ............................................................. 3-7 

 3.3.1 Incident Management Team ............................................................................... 3-8 

 3.3.2 Unified Command ............................................................................................... 3-8 

 3.4 REALISTIC MAXIMUM RESPONSE OPERATING LIMITATIONS 

 [18 AAC 75.425(e)(3)(D)] [30 CFR 254.26(D)] .............................................................. 3-15 

 3.4.1 Adverse Weather Conditions ............................................................................ 3-18 

 3.4.2 Sea States, Tides and Currents ........................................................................ 3-20 

 3.4.3 Hours of Daylight and Visibility ......................................................................... 3-28 

 3.5 LOGISTICAL SUPPORT [18 AAC 75.425(e)(3)(E)] ...................................................... 3-29 

 3.6 RESPONSE EQUIPMENT [18 AAC 75.425(e)(3)(F)] .................................................... 3-31 

 3.6.1 Equipment Lists................................................................................................. 3-31 

 3.6.2 Maintenance and Inspection of Response Equipment ..................................... 3-32 

 3.7 NON-MECHANICAL RESPONSE INFORMATION [18 AAC 75.425(e)(3)(G)] ............. 3-32 

 3.7.1 Assessment of Environmental Consequences and Monitoring ........................ 3-40 

 3.7.2 Non-mechanical Response Equipment ............................................................ 3-41 

 3.7.3 Identification of Necessary Approvals and Application for Nonmechanical Response Options. ........................................................................ 3-42 

 3.7.4 Identification of Permits, Approvals or Authorizations ...................................... 3-42 
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 3.7.5 Plan for Protection Environmentally Sensitive Areas and Areas of Public 

Concern ............................................................................................................. 3-42 

 3.8 RESPONSE CONTRACTOR INFORMATION [18 AAC 75.425(e)(3)(H)] ..................... 3-43 

 3.8.1 Statement of Contractual Terms ....................................................................... 3-43 

 3.9 TRAINING PROGRAM [18 AAC 75.425(e)(3)(I)] .......................................................... 3-43 

 3.9.1 Incident Management Team Member Training ................................................. 3-44 

 3.9.2 Other Training ................................................................................................... 3-45

 3.9.3 Record Keeping ................................................................................................ 3-45 

 3.9.4 Spill Response Exercises ................................................................................. 3-45 

 3.10 PROTECTION OF ENVIRONMENTALLY SENSITIVE AREAS AND AREAS OF 

PUBLIC CONCERN [18 AAC 75.425(e)(3)(J)] .............................................................. 3-46 

 3.10.1 Sensitive Wildlife Areas .................................................................................... 3-46 

 3.11 ADDITIONAL INFORMATION [18 AAC 75.425(e)(3)(K)] .............................................. 3-47 

 3.12 BIBLIOGRAPHY [18 AAC 75.425(e)(3)(L)] ................................................................... 3-47 

PART 4 BEST AVAILABLE TECHNOLOGY [18 AAC 75.425(e)(4)] .................................................... 4-1 

 4.1 COMMUNICATIONS [18 AAC 75.425(e)(4)(A)(i)] ........................................................... 4-2 

 4.2 SOURCE CONTROL [18 AAC 75.425(e)(4)(A)(i)] ........................................................... 4-3 

 4.2.1 Well Source Control ............................................................................................ 4-3 

 4.2.2 Tank Source Control ........................................................................................... 4-7 

 4.3 TRAJECTORY ANALYSES [18 AAC 75.425(e)(4)(A)(i)] ................................................. 4-8 

 4.4 WILDLIFE CAPTURE, TREATMENT, AND RELEASE PROGRAMS 

 [18 AAC 75.425(e)(4)(A)(i)] .............................................................................................. 4-8 

 4.5 CATHODIC PROTECTION [18 AAC 75.076(h)(4)(A)(ii) ................................................. 4-8 

 4.6 LEAK DETECTION TANKS [18 AAC 75.425(e)(4)(A)(ii)] ................................................ 4-8 

 4.7 TANK LIQUID LEVEL DETERMINATION [18 AAC 75.425(e)(4)(A)(ii)] .......................... 4-9 

 4.8 MAINTENANCE PROCEDURES FOR BURIED STEEL PIPING 

 [18 AAC 75.425(e)(4)(A)(ii)] ........................................................................................... 4-12

 4.9 PROTECTIVE WRAPPING OR COATING FOR TANKS AND PIPELINE 

 [18 AAC 75.425(e)(4)(A)(ii)] ........................................................................................... 4-12

 4.10 CORROSION SURVEYS FOR AN EXISTING INSTALLATION ................................... 4-12 

 4.11 PIPELINE LEAK DETECTION ....................................................................................... 4-12 

PART 5 RESPONSE PLANNING STANDARDS [18 AAC 75.425(e)(5)] .............................................. 5-1 

LIST OF TABLES 

Table I-1 Renewal Requirement ........................................................................................................ I-4 

Table I-2 Leases Owned by Shell in the Chukchi Sea (as of February 2008) .................................. I-6 

Table 1.1-1 Emergency Action Checklist ............................................................................................... 1-1 

Table 1.1-2 Initial Spill Response and Notification Process – Tier I Spill ............................................... 1-2

Table 1.1-3 Initial Spill Response and Notification Process – Tier II or Tier III Spill .............................. 1-3 

Table 1.2-1 Emergency Contact List ...................................................................................................... 1-6 

Table 1.2-2 Agency and External Notification Information ..................................................................... 1-7 

Table 1.2-3 Agency Reporting Requirements for Oil Spills .................................................................. 1-11 

Table 1.4-1 Summary of Alaska Statewide Frequency Plan Channels ................................................ 1-15 

Table 1.5-1 Transportation Options ...................................................................................................... 1-20 

Table 1.6-1 Shoreline Protection Assessment for Point Barrow to Cape Lisburne .............................. 1-36 

Table 1.6-2 Summary of How the Worst Case Discharge Scenario Complies with MMS 

 Regulations ....................................................................................................................... 1-46 

Table 1.6-3 Well Blowout in Summer Scenario Conditions .................................................................. 1-55

Table 1.6-4 Well Blowout in Summer Scenario Response Strategy .................................................... 1-57 

Table 1.6-5 Well Blowout in Summer Derated Potential Recovery Capability ..................................... 1-64 

Table 1.6-6 Major Equipment For Offshore Response during the Drilling Season .............................. 1-66 

Table 1.6-7 Major Equipment for Nearshore And Operations .............................................................. 1-67 

Table 1.6-8 Storage Equipment for Recovery Operations ................................................................... 1-68

Table 1.6-9 Staff to Operate Oil Recovery and Transfer Equipment For Offshore, Nearshore 

 and Shoreline Operations.................................................................................................. 1-69 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Table of Contents 

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Table 1.6-10 Response Strategy Subsea Well Blowout in Varying Ice Conditions ............................... 1-76 

Table 1.6-11 Fuel Transfer Release During Summer Response Strategy ............................................. 1-88 

Table 1.6-12 ADEC Specific Scenario Uncontrolled Sub-Sea Well Release During Summer 

 Months ............................................................................................................................... 1-91 

Table 1.6-13 ADEC Specific Scenario Uncontrolled Sub-Sea Well Release During Summer 

 Months ............................................................................................................................... 1-93 

Table 2.3-1 Summary of Potential Discharges ..................................................................................... 2-15 

Table 2.3-2 Potential Discharge for Alaska Offshore Drilling (1997 to 2003)....................................... 2-16 

Table 3.1-1 Frontier Discoverer Service Facilities .................................................................................. 3-2 

Table 3.3-1 Command Staff Contact Information ................................................................................. 3-10 

Table 3.3-2 IMT Checklist ..................................................................................................................... 3-12 

Table 3.4-1 Ice Alert Levels .................................................................................................................. 3-16 

Table 3.4-2 Ice Alert Roles and Responsibilities .................................................................................. 3-17 

Table 3.4-3 Average and Maximum Wind Speeds ............................................................................... 3-19 

Table 3.4-4 Percentages of Days per Month that Temperature Could Reduce Response 

Effectiveness For Worker Threshold Limit Values ........................................................... 3-20 

Table 3.4-5 Beaufort Wind Force and Sea State Relationship Between Wind and Wave 

 Conditions in Fully Developed Seas ................................................................................. 3-21 

Table 3.5-1 Logistical Support Contractors .......................................................................................... 3-30 

Table 3.7-1 Minimum Ignitable Oil Thickness on Water (Adapted from Buist et al. 2003) .................. 3-34 

Table 3.7-2 Burn Removal Rates for Large Fires on Water (Adapted from Buist et al. 2003) ............. 3-34 

Table 3.7-3 Fire Extinguishing Slick Thickness (Adapted From Buist et al. 2003) .............................. 3-35 

Table 3.7-4 Inventory of In situ Burning Equipment (Shell and ACS) .................................................. 3-36 

Table 3.7-5 Safe Working Distances From the Fire ............................................................................. 3-38 

Table 4.2-1 Best Available Technology Analysis Well Blowout Source Control .................................... 4-5 

Table 4.6-1 Best Available Technology Analysis Leak Detection for Tanks ........................................ 4-10 

Table 4.7-1 Best Available Technology Analysis Tank Liquid Level Determination System ............... 4-11 

LIST OF FIGURES 

Figure I-1 Chukchi Sea Lease Blocks February 2008 .......................................................................... I-5 

Figure 1.1-1 Tier II and Tier III Incident Response Organization Chart ................................................... 1-4 

Figure 1.1-2 Internal Emergency Notification Process Diagram ............................................................. 1-5

Figure 1.2-1 Shell Report of Offshore Environmental Incident Form ...................................................... 1-8 

Figure 1.6-1 Chukchi Sea Shoreline Protection ACS Map Atlas Sheet Index ..................................... 1-38 

Figure 1.6-2 Shoreline Containment and Protection ............................................................................. 1-39 

Figure 1.6-3 Shoreline Containment and Recovery Operations ............................................................ 1-39 

Figure 1.6-4 Shoreline Cleanup and Backwater Protection .................................................................. 1-40 

Figure 1.6-5 Nearshore Diversion and Recovery of Oil ......................................................................... 1-40 

Figure 1.6-6 Nearshore Recovery in Broken Ice ................................................................................... 1-41 

Figure 1.6-7 Nearshore Ignition of Oil In Ice .......................................................................................... 1-41 

Figure 1.6-8 Predicted Subsea Blowout Trajectory (Without Containment and Recovery) .................. 1-70 

Figure 1.6-9 Offshore Blowout Tactical Operations Organization ......................................................... 1-71 

Figure 1.6-10 Primary Response to an Offshore Blowout ....................................................................... 1-72 

Figure 1.8-1 Frontier Discoverer Drillship Outboard Profile Schematic .............................................. 1-102 

Figure 1.8-2 Frontier Discoverer Drillship Main Deck and Above Schematic...................................... 1-103 

Figure 1.8-3 Frontier Discoverer Drillship Main Deck View ................................................................. 1-104 

Figure 1.8-4 Frontier Discoverer Drillship Lower Deck Schematic ...................................................... 1-105 

Figure 1.8-5 Frontier Discoverer Drillship Lower Deck View 2 ............................................................ 1-106 

Figure 2.1-1 Models for Site-Specific Well Control .................................................................................. 2-8 

Figure 2.1-2 Real Time Operations Center ........................................................................................... 2-10 

Figure 2.1-3 Example of a BOP ............................................................................................................. 2-11 

Figure 2.1-4 Frontier Discoverer Drillship Blowout Prevention Equipment System .............................. 2-12 

Figure 3.1-1 Oil Spill Response Vessel Nanuq Deck and Profile View ................................................... 3-5 

Figure 3.1-2 Oil Spill Response Barge Endeavor Deck View .................................................................. 3-6 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Table of Contents 

Shell T-v March 2010 

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Figure 3.3-1 Incident Command System ................................................................................................. 3-9 

Figure 3.4-1 Comparison of Regional Ice Conditions ............................................................................ 3-23 

APPENDICES 

Appendix A: General Specifications for Marine and Aerial Support Vessels 

Appendix B: Contractual Terms with Primary Responders 

Appendix C: Fuel Transfer Procedures 

Appendix D: Oil and Debris Disposal Procedures 

Appendix E: Wildlife Capture, Treatment and Release Programs Chukchi Sea Oil Response 

Planning 

Appendix F: Production Specification for Low Sulfur Diesel Fuel Oil 
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Acronyms 

Shell T-vii March 2010 

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LIST OF ACRONYMS 

AAC Alaska Administrative Code 

ABR ABR Inc. Environmental Research & Services 

ACP Area Contingency Plan 

ACS Alaska Clean Seas 

ACRT Auxiliary Contract Response Team 

ADEC Alaska Department of Environmental Conservation 

ADF&G Alaska Department of Fish and Game 

ADNR Alaska Department of Natural Resources 

AES ASRC Energy Services 

AES-RTS ASRC Energy Services – Regulatory and Technical Services 

AES-RO ASRC Energy Services – Response Operations, LLC 

AEWC Alaska Eskimo Whaling Commission 

AIMS Alaska Incident Management System 

ANS Alaska North Slope 

AOGCC Alaska Oil and Gas Conservation Commission 

APD Application for Permit to Drill 

API American Petroleum Institute 

ARRT Alaska Regional Response Team 

ASA Applied Science Associates, Inc. 

ASI Airborne Support, Inc. 

ASRC Arctic Slope Regional Corporation 

ASTM American Society for Testing and Materials 

ATV all-terrain vehicle 

BAT Best Available Technology 

bbl barrel(s) 

BD Branch Director 

BLM U.S. Department of the Interior, Bureau of Land Management 

BMPs best management practices 

BOP Blowout Preventer 

bopd barrels of oil per day 

BOPE Blowout Prevention Equipment 

boph barrels of oil per hour 

BPXA BP Exploration (Alaska) Inc. 

°C Degrees Centigrade 

CAA Conflict Avoidance Agreement 

CFR Code of Federal Regulations 

cm centimeter 

CMT Crisis Management Team 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Acronyms 

Shell T-viii March 2010 

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CO2 carbon dioxide 

COCP Critical Operations and Curtailment Plan 

CPAI ConocoPhillips Alaska Inc. 

C-Plan Oil Discharge Prevention and Contingency Plan 

cSt centiStoke(s) 

cu m cubic meters 

cu m/hr cubic meter per hour 

DIC Deputy Incident Commander 

DNV Det Norske Veritas 

DOI U.S. Department of the Interior 

DOI-OEPC Department of Interior, Office of Environmental Policy and Compliance 

DOR dispersant-to-oil ratio 

DOT U.S. Department of Transportation 

DWOP Drill-the-Well-on-Paper 

E east 

EMT Emergency Medical Technician 

ENE east-northeast 

EPA U.S. Environmental Protection Agency 

EPW Exploration and Production - West 

ERT Emergency Response Team 

ESD Emergency Shut Down 

ESI Environmental Sensitivity Index 

ETA estimated time of arrival 

EU Environmental Unit 

°F Degrees Fahrenheit 

FEIS Final Environmental Impact Statement 

FLIR forward-looking infrared radar 

FOSC Federal On-Scene Coordinator 

ft foot/feet 

FTW fitness to work 

gal gallon(s) 

GMDSS Global Maritime Distress and Safety System 

gph gallons per hour 

gpm gallons per minute 

GPS Global Positioning System 

H2S hydrogen sulfide 

HAZCOM hazard communication 

HAZWOPER Hazardous Waste Operations and Emergency Response 

HDPE high-density polyethylene 

HF high frequency 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Acronyms 

Shell T-ix March 2010 

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hp horsepower 

hr hour(s) 

HR High Frequency 

HSSE Health, Safety, Security, and Environment 

HT Hazard Time 

Hz hertz 

IA Ice Advisor 

IAP Incident Action Plan 

IBRRC International Bird Rescue and Rehabilitation Center 

IC Incident Commander 

ICP Incident Command Post 

ICS Incident Command System 

ID inside diameter 

IMO International Maritime Organization 

IMP Ice Management Plan 

IMT Incident Management Team 

IR infrared radar 

IRIC Initial Response Incident Commander 

ISB in situ burning 

ISO International Organization for Standardization 

IWC Ice and Weather Information Center 

kbps kilobits per second 

km kilometer(s) 

km/day kilometers per day 

kph kilometers per hour 

Ku Kurtz-under 

kW kilowatt 

lb/lbs pound/pounds 

L/T Level/Temperature 

LMRP Lower Marine Riser Package 

LOA Letter of Authorization 

LOSC Local On-Scene Coordinator 

LRB Lamor Recovery Bucket (skimmer) 

LS Level Sensors 

m meter(s) 

m/sec meters per second 

MAD Mutual Aid Drill 

MARPOL International Convention for the Prevention of Pollution from Ships, 1973, as modified by 

the Protocol of 1978 

mcf million cubic feet 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Acronyms 

Shell T-x March 2010 

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MESA Most Environmentally Sensitive Area 

MHz megahertz 

mi mile(s) 

min minute 

MLC mudline cellar 

mm millimeter 

MMPA Marine Mammal Protection Act 

MMO Marine Mammal Observer 

mm/min millimeter per minute 

MMS U.S. Department of the Interior, Minerals Management Service 

mmscf/d million standard cubic feet per day 

MODIS moderate resolution imaging spectroradiometer 

MODU Mobile Offshore Drilling Unit 

mph miles per hour 

MSAT Mobile Satellite System 

MSDS Material Safety Data Sheet 

MSRC Marine Spill Response Corporation 

MT Move Off Time 

MWD Measurement-While-Drilling 

NCP National Contingency Plan 

NE northeast 

NIMS National Incident Management System 

NMFS National Marine Fisheries Service 

n mi nautical mile(s) 

NNE north-northeast 

NOAA National Oceanic and Atmospheric Administration 

NOFO Norwegian Clean Seas Association for Operating Companies 

NPR-A National Petroleum Reserve – Alaska 

NPREP National Preparedness for Response Exercise Program 

NRC National Response Center 

NRDA Natural Resources Damage Assessment 

NSB North Slope Borough 

NSSAWG North Slope Sensitive Areas Work Group 

NSSRT North Slope Spill Response Team 

NSTC North Slope Training Cooperative 

NW northwest 

OCS Outer Continental Shelf 

OEPC Office of Environmental Policy and Compliance 

OIM Offshore Installation Manager 

OOPS O’Brien’s Oil Pollution Services 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Acronyms 

Shell T-xi March 2010 

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OPA 90 Oil Pollution Act of 1990 

OSC On-Scene Commander 

OSHA Occupational Safety and Health Administration 

OSR Oil Spill Response 

OSRB Oil Spill Response Barge 

OSRO Oil Spill Removal Organization 

OSRV Oil Spill Response Vessel 

OST Oil Storage Tanker 

PIC person in charge 

PM Primary Maintenance 

PPE personal protective equipment 

ppt parts per thousand 

PREP Preparedness Response Exercise Program 

psi pounds per square inch 

PWD Pressure-While-Drilling 

QI qualified individual 

RAR Rig Anchor Release 

RCRA Resource Conservation and Recovery Act 

ROV remotely operated vehicle 

RP Responsible Party 

RPS Response Planning Standard 

RQ reportable quantity 

RTOC Real Time Operations Center 

RTTI Real Time Tracking Information 

SAR Synthetic Aperture Radar 

SCAT Shoreline Cleanup Assessment Technology 

Shell Shell Gulf of Mexico Inc. 

SHPO State Historic Preservation Officer 

SIMOP Simultaneous Operations Manager 

SMART Special Monitoring of Applied Response Technologies 

SMT Spill Management Team 

SOLAS International Convention for the Safety of Life at Sea 

SOSC State On-Scene Coordinator 

SPCC Spill, Prevention, Control, and Countermeasure 

SPCO State Pipeline Coordinator’s Office 

SSB Single Sideband 

ST Secure Time 

SW southwest 

t tons 

TF Task Force 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Acronyms 

Shell T-xii March 2010 

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T-Time total time to secure well and leave location 

TVD true vertical depth 

UC Unified Command 

UHF Ultra High Frequency 

Unified Plan Alaska Federal and State Preparedness Plan for Response to Oil and Hazardous 

Substance Discharges and Releases

USACE U.S. Army Corps of Engineers 

USCG U.S. Coast Guard 

USFWS U.S. Fish and Wildlife Service 

VFR Visual Flight Rules 

VHF Very High Frequency 

VMT Vessel Management Team 

VOSS Vessel of Opportunity Skimming System 

VRT Village Response Team 

VSAT Very Small Aperture Terminal 

W west 

WAN Wide Area Network 

WBS Web-based system 

WCC Woodward-Clyde Consultants 

WCD worst case discharge 

WNW west-northwest 

WP working pressure 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

Shell I-i March 2010 

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INTRODUCTION........................................................................................................................................... 1

Objectives ................................................................................................................................................. 3

Alaska Clean Seas Technical Manual and Shell Beaufort and Chukchi Seas Regional Tactics Manual 3

Plan Distribution ........................................................................................................................................ 4

Updating Procedures ................................................................................................................................ 4

LIST OF TABLES 

Table I-1 Renewal Requirement ................................................................................................................... 4

Table I-2 Leases Owned by Shell in the Chukchi Sea (as of February 2008) .............................................. 6

LIST OF FIGURES 

Figure I-1 Chukchi Sea Lease Blocks February 2008 .................................................................................. 5
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Introduction 

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Introduction 

Shell I-1 March 2010 

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INTRODUCTION 

Shell has prepared this C-Plan for exploration drilling operations on current and future lease holding with 

the Chukchi Sea. This C-Plan is one important element of Shell’s overall commitment to conduct its 

operations in a safe and environmentally sensitive manner. After personnel safety, oil spill prevention is 

Shell’s first priority. That commitment is evident throughout Shell’s plans, policies, and procedures for 

exploration drilling operations, as well as the many local, state, and federal permit applications Shell has 

submitted or will submit to secure required authorizations prior to initiating their drilling program. This 

C-Plan is specifically designed to aid Shell in their efforts to prevent spills and, in the unlikely event of a 

spill, mitigate the impacts of that spill on the marine environment. 

The addresses and telephone numbers of Shell are provided below: 

P.O. Box 576 3601 C Street, Suite 1000 

Houston, TX 77001-0576 Anchorage, AK 99503 

Telephone: (877) 273-2443 Telephone: (907) 770-3700 

This C-Plan addresses planned exploration drilling facilities located on Shell leases within the Chukchi 

Sea (see regional map Figure I-1 and Table 1-2) generally bounded by the following coordinates: 

 70o 15’ 0” north (N) and 71o 53’ 0” N Latitude; 

 161o 34’ 0” west (W) and 168o 50’ 0” W Longitude. 

Specifically, the primary drill sites are at the Burger Prospect at the following locations: 

 Burger C − 71o 18’ 17.27” N, 163o 12’ 45.99” W; and 

 Burger F − 71o 20’ 13.96” N, 163o 12’ 21.75” W. 

In the event that these proposed well sites change in the course of the permitting process, Shell commits 

to providing updated well location(s) and spill trajectory(ies), as appropriate, as a revision to this 2010 

Plan. 

Planned drilling and bottom hole locations are located on leases within the federal Outer Continental 

Shelf (OCS) as regulated by the MMS, and all exploration activities will be conducted in compliance with 

applicable local, state, and federal laws. 

Shell recognizes the sometimes harsh conditions associated with operating in the Arctic and is committed 

to preventing oil spills of any size. To achieve this goal, Shell has developed a comprehensive program 

which includes personnel training and the use of arctic-grade equipment to maintain primary well control 

and prevent discharges: 

 Fuel transfers will be conducted in strict accordance with USCG-approved procedures onboard 

each vessel. 

 Pollution prevention equipment, maintenance, and surveillance will focus on the prevention of 

unauthorized discharges. 

 The design of drilling procedures will ensure Shell’s ability to maintain primary well control at all 

times throughout drilling operations. 

 Equipment utilized for secondary well control will be maintained in top condition, including 

functional testing and pressure testing as required. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

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 A weather and ice forecasting and monitoring program will be in place to ensure safe continued 

operations or, if necessary, cessation of operations and protection of personnel and assets. 

 Deployment of ice management vessels and the use of dynamic ice management will protect the 

drilling fleet, enabling the drillship to maintain station or secure the well and move off in a timely 

way ensuring the safety of personnel and operations. 

 Real-time operations monitoring using state-of-the-art equipment will ensure early recognition of 

subsurface pressure increases and provide for a timely response to subsurface conditions. 

Shell plans to conduct its exploration drilling activity using the drillship Frontier Discoverer, or similar. The 

Frontier Discoverer has been refurbished for use in the arctic and will be operated by Frontier Drilling, 

under Shell’s supervision. In the very unlikely event of a subsea blowout, the drillship could be moved 

quickly, allowing that vessel to drill its own relief well. 

The Frontier Discoverer would be mobilized into the Chukchi Sea on or after July 1. The drillship and 

supply vessels would be stocked with most of the drilling supplies necessary to complete one well. The 

drillship would be resupplied with drilling materials, fuel, deliveries and remaining items by vessel and 

helicopter during the season. Arctic-class ice management and anchor-handling vessels will accompany 

the drillship. Personnel access to the sites will be via helicopter and support vessels. 

This C-Plan is developed to serve as a regional oil spill response plan for Shell’s multiyear Chukchi Sea 

Regional Exploration Drilling Program. Each year’s drilling operations are planned to total depth at 

multiple locations. Operations would begin as early as possible depending upon conditions, and continue 

into freezeup; however, well drilling activities will not be conducted after October 31st. Well drilling 

activities are complete when the well is plugged and abandoned in accordance with MMS regulations, 

and there are no exposed formations capable of flowing oil or gas. 

Shell’s Chukchi Sea Regional Exploration C-Plan regional applicability is based upon responding to a 

WCD from an exploration well with an OSRV located nearby the drillship at all times during critical drilling 

operations into hydrocarbon zones. The OSRV would possess sufficient capacity to provide containment, 

recovery, and storage for the initial 24-hr operational period. An Arctic Oil Storage Tanker (OST) would 

be staged within 24 hr [240 nautical miles (n mi)] of the Chukchi Sea drill site. The OSRV and OST would 

be capable of transit speeds of 10 knots. Using 10 knots as a realistic transit speed for planning 

purposes, the OST would arrive at the recovery site within 24 hr of departure from the staging area. A 

second vessel, the anchor handler or similar vessel staged with the drillship, would be mobilized to act as 

a Vessel of Opportunity Skimming System (VOSS). The VOSS would possess sufficient skimming 

capability and liquid storage capacity (minimum of 3,200 bbl) to relieve the OSRV for eight hr during 

which time it lighters recovered fluids to the OST. After Day 1, the OSRV and VOSS would set up a 

consistent rotation cycle with the OSRV skimming for 16 hr and the VOSS for another eight hr while the 

OSRV lighters to the OST. The OST would possess a minimum liquid storage capacity of 287,100 bbl, 

sufficient capacity to store all recovered liquids (oil and emulsified oil/water) from a 30-day blowout. 

Additional personnel may also be transported via helicopter or vessel from a land- or vessel-based 

staging area. 

The C-Plan is based on the deployment of the OSRV and equipment “on the water,” capable of providing 

an immediate response to oil spills in two discrete planning regimes: 

 A spill response scenario written in compliance with MMS and ADEC regulations, based upon 

conditions likely to be encountered during the drilling season; and 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

Shell I-3 March 2010 

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 An associated response strategy that demonstrates regional response capability under different 

criteria and assumptions. 

This C-Plan is intended to be a planning document to help identify and establish the basis for Shell’s oil 

spill prevention and recovery in the event of an oil spill, and as such, by its very nature, it cannot 

anticipate all possible contingencies. Shell plans to submit permit applications to local, state, and federal 

agencies containing site-specific drill site and other data in advance of drilling. Federal and state 

regulators will be able to review the drilling campaign updates for a specified season and determine 

whether the Shell Chukchi Sea Regional Exploration C-Plan is applicable for the individual well(s). 

Depending on the outcome of its exploration activities, Shell anticipates, in due course, to submit future 

applications for permits to proceed with development of its leases. Any subsequent development would 

require a separate C-Plan to address the facilities and activities related to such development. The C-Plan 

follows the ADEC format set forth in Title 18 of the AAC Chapter 75, Part 425 (18 AAC 75.425). 

Controlled copies of the plan are available at the ADEC office located at 555 Cordova Street, Anchorage, 

Alaska, 99501. 

The C-Plan addresses federal oil spill planning regulations of the MMS and the USCG. 

OBJECTIVES 

The objective is to minimize potential environmental impacts and to provide for the safety of personnel 

during drilling operations by preventing petroleum hydrocarbon releases. Safety is a core value for Shell 

and is not compromised. This C-Plan also provides Shell with the background information and response 

planning guidelines necessary to implement an efficient, coordinated, and effective spill response. 

The following types of facilities and operations are covered by this plan: 

 Drillships and facilities, support vessels, and related operations; 

 Storage operations (including recovered oil spill fluids); 

 Transfer options (including fuel and recovered oil spill fluids) involving Shell exploration and 

related support vessels; and 

 Related support vessels. 

ALASKA CLEAN SEAS TECHNICAL MANUAL AND SHELL BEAUFORT AND CHUKCHI 

SEAS REGIONAL TACTICS MANUAL 

Shell is also a member of Alaska Clean Seas (ACS). ACS would be used as primary response contractor 

for all spill response activities. ACS will be available while critical drilling operations into hydrocarbon 

bearing zones are underway; and will provide response in the event of an actual oil spill incident, 

including related maintenance, ongoing assurance of response capabilities, and coordination of training 

activities. This C-Plan incorporates references to the ACS Technical Manual, available online at 

http://www.alaskacleanseas.org/techmanual.htm and consisting of Volume 1, Tactics Description; Volume 

2, Map Atlas; and Volume 3, Incident Management System. 

Shell provides response equipment for the offshore response. Response activities will be conducted 

using ACS tactics, as defined in the ACS Technical Manual, and Shell tactics as defined in the Shell 

Beaufort and Chukchi Seas Regional Tactics Manual. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

Shell I-4 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

PLAN DISTRIBUTION 

The C-Plan is distributed to Shell management, staff, and regulatory agencies as appropriate. This 

C-Plan is accessible to Shell employees and contractors on Shell’s intranet Web site. 

UPDATING PROCEDURES 

The C-Plan is reviewed and updated when major changes occur in the ability to respond to the WCD, or 

when such changes could affect the implementation of the C-Plan. Below is a list of key factors that may 

cause revisions to the C-Plan: 

 Changes to RPS; 

 Change in oil spill response organizations; 

 Change in QI; 

 Changes in a National Contingency Plan or Area Contingency Plan that have a significant impact 

on the appropriateness of response equipment or response strategies; 

 Change in response procedures; or 

 Change in ownership. 

In addition, it is Shell’s intent to provide administrative updates to drill site locations, vessel names, and 

other routine information of a project-specific nature, in advance of each drilling campaign, either as an 

update to the C-Plan or as part of annual permit applications, as appropriate. Renewal requirements are 

listed in Table I-1 below. 

TABLE I-1 

RENEWAL REQUIREMENT 

AGENCY CITATION REQUIREMENT 

ADEC 18 AAC 75.415 Every five (5) years from the date of approval or when changes are 

made that diminish the ability to respond. 

MMS 30 CFR Part 254.30 Every two (2) years or when there is a reduction in response 

capabilities. 

USCG 33 CFR Part 154 Annual review by operator. Resubmit every five (5) years. 

Shell will notify MMS and ADEC, via plan amendment, of specific and applicable update information prior 

to commencing drilling activities. Amendment or updates to the C-Plan are submitted to the appropriate 

regulatory agency for review and approval. Once the amendment or update has been approved, it is 

posted on the intranet site, and hard copies are distributed to all plan holders. Plan holders are requested 

to replace the hard copy pages. Revisions are documented in the Record of Revisions history table, 

which is included with each approved amendment distribution. It is the responsibility of each plan holder 

to incorporate amendments or updates into the plan. 

Leases owned by Shell in Chukchi Sea (as of February 2008) are listed in Table I-2. 
Barrow

Atqasuk

Point Lay

Wainwright

Point Hope

160°W 165°W 170°W

71°N

70°N

69°N

68°N

0 40 20 

C h u k c h i S e a

Scale: 

Datum: NAD83

Projection: Alaska Albers Equal Area

A r c t i c O c e 

Block No: 6714 

Lease: Y2267

Block No: 6764

Lease: Y2280

National Petroleum Reserve - Alaska

(NPR-A)

Village

Shell Leases Y2267 & Y2280

Shell OCS Lease Blocks Chukchi 

Oil Discharge P

CHUKCHI SEA L

Alaska Maritime National Wildlife Refuge

National Petroleum Reserve - Alaska

National Park System & Wildlife Refuge
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

Shell I-6 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

TABLE I-2 

LEASES OWNED BY SHELL IN THE CHUKCHI SEA (AS OF FEBRUARY 2008) 

PROTRACTION AREA OPD NO. BLOCK NO. MMS LEASE # OCSCOLBERT NR03-03 6007 Y2351 

COLBERT NR03-03 6008 Y2352 

COLBERT NR03-03 6009 Y2353 

COLBERT NR03-03 6010 Y2354 

COLBERT NR03-03 6017 Y2355 

COLBERT NR03-03 6018 Y2356 

COLBERT NR03-03 6020 Y2357 

COLBERT NR03-03 6056 Y2362 

COLBERT NR03-03 6057 Y2363 

COLBERT NR03-03 6058 Y2364 

COLBERT NR03-03 6059 Y2365 

COLBERT NR03-03 6067 Y2367 

COLBERT NR03-03 6068 Y2368 

COLBERT NR03-03 6070 Y2370 

COLBERT NR03-03 6108 Y2375 

COLBERT NR03-03 6219 Y2393 

COLBERT NR03-03 6560 Y2412 

COLBERT NR03-03 6561 Y2413 

COLBERT NR03-03 6609 Y2414 

COLBERT NR03-03 6610 Y2415 

COLBERT NR03-03 6611 Y2416 

COLBERT NR03-03 6658 Y2417 

COLBERT NR03-03 6659 Y2418 

COLBERT NR03-03 6660 Y2419 

COLBERT NR03-03 6709 Y2420 

COLBERT NR03-03 6721 Y2421 

COLBERT NR03-03 6722 Y2422 

COLBERT NR03-03 6723 Y2423 

COLBERT NR03-03 6759 Y2424 

COLBERT NR03-03 6771 Y2425 

COLBERT NR03-03 6772 Y2426 

COLBERT NR03-03 6773 Y2427 

COLBERT NR03-03 6823 Y2428 

HANNA SHOAL NR04-01 6352 Y2342 

HANNA SHOAL NR04-01 6401 Y2343 

HANNA SHOAL NR04-01 6402 Y2344 

HANNA SHOAL NR04-01 6452 Y2345 

HANNA SHOAL NR04-01 6453 Y2346 

HANNA SHOAL NR04-01 6503 Y2347 

HANNA SHOAL NR04-01 6504 Y2348 

HANNA SHOAL NR04-01 6554 Y2349 

HANNA SHOAL NR04-01 6604 Y2350 

KARO NR03-01 6105 Y1987 

KARO NR03-01 6106 Y1988 

KARO NR03-01 6155 Y1990 

KARO NR03-01 6156 Y1991 

KARO NR03-01 6161 Y1993 

KARO NR03-01 6162 Y1994 

KARO NR03-01 6211 Y2004 

KARO NR03-01 6212 Y2005 

KARO NR03-01 6261 Y2013 

KARO NR03-01 6363 Y2021 

KARO NR03-01 6364 Y2022 

KARO NR03-01 6413 Y2026 

KARO NR03-01 6414 Y2027 

KARO NR03-01 6415 Y2028 

KARO NR03-01 6418 Y2029 

KARO NR03-01 6419 Y2030 

KARO NR03-01 6462 Y2031 

KARO NR03-01 6463 Y2032 

KARO NR03-01 6464 Y2033 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

 

TABLE I-2 (CONTINUED) 

LEASES OWNED BY SHELL IN THE CHUKCHI SEA (AS OF FEBRUARY 2008) 

Shell I-7 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

PROTRACTION AREA OPD NO. BLOCK NO. MMS LEASE # OCSKARO NR03-01 6465 Y2034 

KARO NR03-01 6467 Y2035 

KARO NR03-01 6468 Y2036 

KARO NR03-01 6469 Y2037 

KARO NR03-01 6512 Y2038 

KARO NR03-01 6513 Y2039 

KARO NR03-01 6514 Y2040 

KARO NR03-01 6515 Y2041 

KARO NR03-01 6516 Y2042 

KARO NR03-01 6517 Y2043 

KARO NR03-01 6518 Y2044 

KARO NR03-01 6519 Y2045 

KARO NR03-01 6562 Y2048 

KARO NR03-01 6563 Y2049 

KARO NR03-01 6564 Y2050 

KARO NR03-01 6565 Y2051 

KARO NR03-01 6567 Y2052 

KARO NR03-01 6568 Y2053 

KARO NR03-01 6569 Y2054 

KARO NR03-01 6612 Y2057 

KARO NR03-01 6613 Y2058 

KARO NR03-01 6614 Y2059 

KARO NR03-01 6615 Y2060 

KARO NR03-01 6616 Y2061 

KARO NR03-01 6617 Y2062 

KARO NR03-01 6618 Y2063 

KARO NR03-01 6665 Y2066 

KARO NR03-01 6666 Y2067 

KARO NR03-01 6667 Y2068 

KARO NR03-01 6668 Y2069 

KARO NR03-01 6705 Y2072 

KARO NR03-01 6706 Y2073 

KARO NR03-01 6712 Y2074 

KARO NR03-01 6715 Y2075 

KARO NR03-01 6716 Y2076 

KARO NR03-01 6717 Y2077 

KARO NR03-01 6753 Y2080 

KARO NR03-01 6754 Y2081 

KARO NR03-01 6755 Y2082 

KARO NR03-01 6756 Y2083 

KARO NR03-01 6761 Y2084 

KARO NR03-01 6762 Y2085 

KARO NR03-01 6765 Y2086 

KARO NR03-01 6766 Y2087 

KARO NR03-01 6767 Y2088 

KARO NR03-01 6803 Y2091 

KARO NR03-01 6804 Y2092 

KARO NR03-01 6805 Y2093 

KARO NR03-01 6810 Y2094 

KARO NR03-01 6811 Y2095 

KARO NR03-01 6812 Y2096 

KARO NR03-01 6813 Y2097 

KARO NR03-01 6814 Y2098 

KARO NR03-01 6815 Y2099 

KARO NR03-01 6816 Y2100 

KARO NR03-01 6817 Y2101 

KARO NR03-01 6853 Y2104 

KARO NR03-01 6854 Y2105 

KARO NR03-01 6855 Y2106 

KARO NR03-01 6860 Y2107 

KARO NR03-01 6861 Y2108 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

 

TABLE I-2 (CONTINUED) 

LEASES OWNED BY SHELL IN THE CHUKCHI SEA (AS OF FEBRUARY 2008) 

Shell I-8 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

PROTRACTION AREA OPD NO. BLOCK NO. MMS LEASE # OCSKARO NR03-01 6862 Y2109 

KARO NR03-01 6863 Y2110 

KARO NR03-01 6864 Y2111 

KARO NR03-01 6865 Y2112 

KARO NR03-01 6866 Y2113 

KARO NR03-01 6903 Y2116 

KARO NR03-01 6904 Y2117 

KARO NR03-01 6905 Y2118 

KARO NR03-01 6908 Y2119 

KARO NR03-01 6909 Y2120 

KARO NR03-01 6910 Y2121 

KARO NR03-01 6911 Y2122 

KARO NR03-01 6912 Y2123 

KARO NR03-01 6913 Y2124 

KARO NR03-01 6914 Y2125 

KARO NR03-01 6915 Y2126 

KARO NR03-01 6916 Y2127 

KARO NR03-01 6953 Y2128 

KARO NR03-01 6954 Y2129 

KARO NR03-01 6955 Y2130 

KARO NR03-01 6956 Y2131 

KARO NR03-01 6957 Y2132 

KARO NR03-01 6958 Y2133 

KARO NR03-01 6959 Y2134 

KARO NR03-01 6960 Y2135 

KARO NR03-01 6961 Y2136 

KARO NR03-01 6962 Y2137 

KARO NR03-01 6963 Y2138 

KARO NR03-01 6964 Y2139 

KARO NR03-01 6965 Y2140 

KARO NR03-01 7006 Y2141 

KARO NR03-01 7007 Y2142 

KARO NR03-01 7008 Y2143 

KARO NR03-01 7009 Y2144 

KARO NR03-01 7010 Y2145 

KARO NR03-01 7011 Y2146 

KARO NR03-01 7012 Y2147 

KARO NR03-01 7013 Y2148 

KARO NR03-01 7014 Y2149 

KARO NR03-01 7056 Y2150 

KARO NR03-01 7057 Y2151 

KARO NR03-01 7058 Y2152 

KARO NR03-01 7059 Y2153 

KARO NR03-01 7060 Y2154 

KARO NR03-01 7061 Y2155 

KARO NR03-01 7062 Y2156 

KARO NR03-01 7063 Y2157 

KARO NR03-01 7106 Y2158 

KARO NR03-01 7107 Y2159 

KARO NR03-01 7108 Y2160 

KARO NR03-01 7109 Y2161 

KARO NR03-01 7110 Y2162 

KARO NR03-01 7119 Y2163 

POSEY NR03-02 6114 Y2167 

POSEY NR03-02 6115 Y2168 

POSEY NR03-02 6161 Y2171 

POSEY NR03-02 6163 Y2172 

POSEY NR03-02 6164 Y2173 

POSEY NR03-02 6165 Y2174 

POSEY NR03-02 6213 Y2180 

POSEY NR03-02 6214 Y2181 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

 

TABLE I-2 (CONTINUED) 

LEASES OWNED BY SHELL IN THE CHUKCHI SEA (AS OF FEBRUARY 2008) 

Shell I-9 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

PROTRACTION AREA OPD NO. BLOCK NO. MMS LEASE # OCSPOSEY NR03-02 6215 Y2182 

POSEY NR03-02 6220 Y2183 

POSEY NR03-02 6259 Y2185 

POSEY NR03-02 6261 Y2187 

POSEY NR03-02 6263 Y2189 

POSEY NR03-02 6264 Y2190 

POSEY NR03-02 6265 Y2191 

POSEY NR03-02 6270 Y2192 

POSEY NR03-02 6271 Y2193 

POSEY NR03-02 6321 Y2200 

POSEY NR03-02 6322 Y2201 

POSEY NR03-02 6359 Y2204 

POSEY NR03-02 6360 Y2205 

POSEY NR03-02 6371 Y2210 

POSEY NR03-02 6372 Y2211 

POSEY NR03-02 6409 Y2212 

POSEY NR03-02 6410 Y2213 

POSEY NR03-02 6422 Y2218 

POSEY NR03-02 6423 Y2219 

POSEY NR03-02 6459 Y2220 

POSEY NR03-02 6508 Y2226 

POSEY NR03-02 6558 Y2233 

POSEY NR03-02 6608 Y2241 

POSEY NR03-02 6658 Y2248 

POSEY NR03-02 6671 Y2255 

POSEY NR03-02 6672 Y2256 

POSEY NR03-02 6708 Y2261 

POSEY NR03-02 6713 Y2266 

POSEY NR03-02 6714 Y22671

POSEY NR03-02 6715 Y2268 

POSEY NR03-02 6721 Y2269 

POSEY NR03-02 6722 Y2270 

POSEY NR03-02 6757 Y2274 

POSEY NR03-02 6761 Y2277 

POSEY NR03-02 6762 Y2278 

POSEY NR03-02 6763 Y2279 

POSEY NR03-02 6764 Y22802

POSEY NR03-02 6765 Y2281 

POSEY NR03-02 6766 Y2282 

POSEY NR03-02 6771 Y2286 

POSEY NR03-02 6807 Y2290 

POSEY NR03-02 6811 Y2293 

POSEY NR03-02 6812 Y2294 

POSEY NR03-02 6813 Y2295 

POSEY NR03-02 6814 Y2296 

POSEY NR03-02 6815 Y2297 

POSEY NR03-02 6816 Y2298 

POSEY NR03-02 6817 Y2299 

POSEY NR03-02 6856 Y2304 

POSEY NR03-02 6862 Y2308 

POSEY NR03-02 6863 Y2309 

POSEY NR03-02 6864 Y2310 

POSEY NR03-02 6865 Y2311 

POSEY NR03-02 6866 Y2312 

POSEY NR03-02 6905 Y2317 

POSEY NR03-02 6912 Y2321 

 

1 OCS Lease Block location for proposed drill site: Burger F

2 OCS Lease Block location for proposed drill site: Burger C
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

 

TABLE I-2 (CONTINUED) 

LEASES OWNED BY SHELL IN THE CHUKCHI SEA (AS OF FEBRUARY 2008) 

Shell I-10 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

PROTRACTION AREA OPD NO. BLOCK NO. MMS LEASE # OCSPOSEY NR03-02 6913 Y2322 

POSEY NR03-02 6914 Y2323 

POSEY NR03-02 6915 Y2324 

POSEY NR03-02 6916 Y2325 

POSEY NR03-02 6962 Y2334 

POSEY NR03-02 6963 Y2335 

POSEY NR03-02 6964 Y2336 

POSEY NR03-02 6965 Y2337 

TISON NR02-02 6819 Y1959 

TISON NR02-02 6820 Y1960 

TISON NR02-02 6821 Y1961 

TISON NR02-02 6822 Y1962 

TISON NR02-02 6868 Y1963 

TISON NR02-02 6869 Y1964 

TISON NR02-02 6870 Y1965 

TISON NR02-02 6871 Y1966 

TISON NR02-02 6872 Y1967 

TISON NR02-02 6918 Y1968 

TISON NR02-02 6919 Y1969 

TISON NR02-02 6920 Y1970 

TISON NR02-02 6921 Y1971 

TISON NR02-02 6922 Y1972 

TISON NR02-02 6968 Y1973 

TISON NR02-02 6969 Y1974 

TISON NR02-02 6970 Y1975 

TISON NR02-02 6971 Y1976 

TISON NR02-02 6972 Y1977 

TISON NR02-02 7018 Y1978 

TISON NR02-02 7019 Y1979 

TISON NR02-02 7020 Y1980 

TISON NR02-02 7021 Y1981 

TISON NR02-02 7022 Y1982 

TISON NR02-02 7023 Y1983 

TISON NR02-02 7068 Y1984 

TISON NR02-02 7069 Y1985 

TISON NR02-02 7072 Y1986 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

 

Shell I-11 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

MMS Approval 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

 

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95-2000.01-25.201-001/09-018 Rev. 0 

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Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

 

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Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

 

Shell I-15 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

State Consistency Approval 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

 

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Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

 

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Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Introduction 

 

Shell I-18 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-i March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

PART 1 RESPONSE ACTION PLAN [18 AAC 75.425(e)(1)] ................................................................ 1-1

1.1 EMERGENCY ACTION CHECKLIST [18 AAC 75.425(e)(1)(A)] ..................................... 1-1

1.2 REPORTING AND NOTIFICATION [18 AAC 75.425(e)(1)(B)] ....................................... 1-5

1.2.1 Initial Reporting ................................................................................................... 1-5

1.2.2 External Notification Procedures ....................................................................... 1-10

1.2.3 Written Reporting Requirements ....................................................................... 1-10

1.3 SAFETY [18 AAC 75.425(e)(1)(C)] ................................................................................ 1-13

1.4 COMMUNICATIONS [18 AAC 75.425(e)(1)(D)] ............................................................ 1-14

1.4.1 Communications Plan ....................................................................................... 1-14

1.4.2 Communications Equipment ............................................................................. 1-14

1.4.3 Equipment Maintenance ................................................................................... 1-18

1.5 DEPLOYMENT STRATEGIES [18 AAC 75.425(e)(1)(E)] ............................................. 1-19

1.5.1 Transport Procedures [18 AAC 75.425(e)(1)(E)(i)] ........................................... 1-20

1.6 RESPONSE STRATEGIES [18 AAC 75.425(e)(1)(F)] .................................................. 1-21

1.6.1 Procedures to Stop Discharge [18 AAC 75.425(e)(1)(F)(i)] .............................. 1-21

1.6.2 Fire Prevention and Control [18 AAC 75.425(e)(1)(F)(ii)] ................................. 1-21

1.6.3 Blowout Control/Relief Well Plan ...................................................................... 1-22

1.6.4 Discharge Tracking [18 AAC 75.425(e)(1)(F)(iv)] ............................................. 1-24

1.6.5 Protection of Sensitive Areas [18 AAC 75.425(e)(1)(F)(v)] .............................. 1-25

1.6.6 Containment and Control Strategies [18 AAC 75.425(e)(1)(F)(vi)] ................... 1-25

1.6.7 Recovery Strategies [18 AAC 75.425(e)(1)(F)(vii)] ........................................... 1-28

1.6.8 Lightering, Transfer, and Storage of Oil from Tanks 

[18 AAC 75.425(e)(1)(F)(viii)] ............................................................................ 1-30

1.6.9 Transfer and Storage Procedures [18 AAC 75.425(e)(1)(F)(ix)] ...................... 1-30

1.6.10 Temporary Storage and Disposal [18 AAC 75.425(e)(1)(F)(x)] ........................ 1-30

1.6.11 Wildlife Protection [18 AAC 75.425(e)(1)(F)(xi)] ............................................... 1-31

1.6.12 Shoreline Cleanup [18 AAC 75.425(e)(1)(F)(xii)] .............................................. 1-31

1.6.13 Spill Response Scenarios ................................................................................. 1-42

1.7 NON-MECHANICAL RESPONSE OPTIONS [18 AAC 75.425(e)(1)(G)] ...................... 1-99

1.7.1 Obtaining Permits and Approvals ..................................................................... 1-99

1.7.2 Decision Criteria for Use ................................................................................... 1-99

1.7.3 Implementation Procedures ............................................................................ 1-100

1.8 FACILITY DIAGRAMS [18 AAC 75.425(e)(1)(H)] ........................................................ 1-101

LIST OF TABLES 

Table 1.1-1 Emergency Action Checklist ............................................................................................ 1-1

Table 1.1-2 Initial Spill Response and Notification Process – Tier I Spill ........................................... 1-2

Table 1.1-3 Initial Spill Response and Notification Process – Tier II or Tier III Spill ........................... 1-3

Table 1.2-1 Emergency Contact List ................................................................................................... 1-6

Table 1.2-2 Agency and External Notification Information .................................................................. 1-7

Table 1.2-3 Agency Reporting Requirements for Oil Spills ............................................................... 1-11

Table 1.4-1 Summary of Alaska Statewide Frequency Plan Channels ............................................ 1-15

Table 1.5-1 Transportation Options .................................................................................................. 1-20

Table 1.6-1 Shoreline Protection Assessment for Point Barrow to Cape Lisburne .......................... 1-36

Table 1.6-2 Summary of How the Worst Case Discharge Scenario Complies with MMS 

Regulations .................................................................................................................... 1-46

Table 1.6-3 Well Blowout in Summer Scenario Conditions .............................................................. 1-55

Table 1.6-4 Well Blowout in Summer Scenario Response Strategy ................................................. 1-57

Table 1.6-5 Well Blowout in Summer Derated Potential Recovery Capability .................................. 1-64

Table 1.6-6 Major Equipment For Offshore Response during the Drilling Season ........................... 1-66
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-ii March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

Table 1.6-7 Major Equipment for Nearshore And Operations ........................................................... 1-67

Table 1.6-8 Storage Equipment for Recovery Operations ................................................................ 1-68

Table 1.6-9 Staff to Operate Oil Recovery and Transfer Equipment For Offshore, Nearshore 

and Shoreline Operations .............................................................................................. 1-69

Table 1.6-10 Response Strategy Subsea Well Blowout in Varying Ice Conditions ............................ 1-76

Table 1.6-11 Fuel Transfer Release During Summer Response Strategy ......................................... 1-88

Table 1.6-12 ADEC Specific Scenario Uncontrolled Sub-Sea Well Release During Summer 

Months ........................................................................................................................... 1-91

Table 1.6-13 ADEC Specific Scenario Uncontrolled Sub-Sea Well Release During Summer 

Months ........................................................................................................................... 1-93

LIST OF FIGURES 

Figure 1.1-1 Tier II and Tier III Incident Response Organization Chart ............................................... 1-4

Figure 1.1-2 Internal Emergency Notification Process Diagram .......................................................... 1-5

Figure 1.2-1 Shell Report of Offshore Environmental Incident Form ................................................... 1-8

Figure 1.6-1 Chukchi Sea Shoreline Protection ACS Map Atlas Sheet Index .................................. 1-38

Figure 1.6-2 Shoreline Containment and Protection .......................................................................... 1-39

Figure 1.6-3 Shoreline Containment and Recovery Operations ........................................................ 1-39

Figure 1.6-4 Shoreline Cleanup and Backwater Protection ............................................................... 1-40

Figure 1.6-5 Nearshore Diversion and Recovery of Oil ..................................................................... 1-40

Figure 1.6-6 Nearshore Recovery in Broken Ice ................................................................................ 1-41

Figure 1.6-7 Nearshore Ignition of Oil In Ice ...................................................................................... 1-41

Figure 1.6-8 Predicted Subsea Blowout Trajectory (Without Containment and Recovery) ............... 1-70

Figure 1.6-9 Offshore Blowout Tactical Operations Organization ...................................................... 1-71

Figure 1.6-10 Primary Response to an Offshore Blowout .................................................................... 1-72

Figure 1.8-1 Frontier Discoverer Drillship Outboard Profile Schematic .......................................... 1-102

Figure 1.8-2 Frontier Discoverer Drillship Main Deck and Above Schematic .................................. 1-103

Figure 1.8-3 Frontier Discoverer Drillship Main Deck View .............................................................. 1-104

Figure 1.8-4 Frontier Discoverer Drillship Lower Deck Schematic ................................................... 1-105

Figure 1.8-5 Frontier Discoverer Drillship Lower Deck View 2 ......................................................... 1-106
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-1 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

PART 1 RESPONSE ACTION PLAN [18 AAC 75.425(e)(1)] 

The Response Action Plan provides a guide for personnel in an emergency discharge event. In all 

actions taken during an emergency, safety remains the first and highest priority. The following sections 

describe the steps that personnel must take to properly respond to a reportable spill. Section 1.6.13 

contains a hypothetical scenario describing the strategies and tactics for the WCD for an exploration 

drilling program occurring outside State of Alaska waters on the Federal OCS. For planning purposes, 

the hypothetical blowout involves oil that travels upwards from the well at the ocean floor to the water 

surface. The resulting plume of oil is driven by wind and ocean currents. Stochastic spill modeling based 

on wind and current data predicts that spilled oil is not likely to reach land (0 to 10 percent occurrence). 

In the unlikely event that oil reaches shorelines, it is predicted to not contact the shoreline in less than six 

days, even if no containment and recovery operations were conducted. More detailed information is 

presented in the Scenario 1 discussion. 

These time frames have been used to plan the mobilization of ACS equipment and response personnel to 

implement priority protection site strategies along the shoreline (see Section 1.6.12). 

1.1 EMERGENCY ACTION CHECKLIST [18 AAC 75.425(e)(1)(A)] 

The person reporting an oil spill to the immediate supervisor or QI may be required to supply minimum 

spill assessment information to provide as complete an understanding of the incident as possible. Some 

initial spill response actions and information that may be reported are included in Table 1.1-1 and Table 

1.1-2. 

TABLE 1.1-1 

EMERGENCY ACTION CHECKLIST 

EMERGENCY ACTION CHECKLIST 

INITIAL SPILL RESPONSE ACTIONS 

1. Protect people: Safety is first priority. 

 Sound alarm. 

 Shut off ignition sources. 

 Restrict access. 

 Evaluate as necessary and initiate rescue and 

response actions. 

2. Notify your supervisor. 

3. Stop the spill at source, if safe to do so. 

4. Assess possible hazards: 

 Fire and explosion potential of vapors at or near the 

source, 

 Potential toxic effects of the discharge, 

 Damage to facility affecting safety, and 

 Recovery of the spilled product. 

5. For a blowout, implement well control and evacuation 

procedures and activate Tier Ill Incident Command 

System (ICS). 

WHAT TO REPORT TO YOUR SUPERVISOR 

1. Was anyone hurt? 

2. Where is the spill? 

3. What time did it happen? 

4. What was spilled? 

5. How much was spilled? 

6. What is the rate of release? 

7. What is the source? 

8. What are the weather conditions? 

9. What actions have you taken? 

10. What equipment do you need? 

11. Are there any immediate environmental impacts? 

12. Who did you notify? 

The emergency action and notification sequence varies depending on the size of the spill and required 

response. The spill classifications described below apply only to the emergency phases of containment 

and initial recovery of a spill. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-2 March 2010 

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Spill Classification Guidelines 

Tier I Spill: Local spill that the affected asset can respond to effectively with equipment and personnel 

onboard (such as deploying absorbent containment and recovery materials) (Table 1.1-2). No immediate 

off-site assistance is needed. 

TABLE 1.1-2 

INITIAL SPILL RESPONSE AND 

NOTIFICATION PROCESS – TIER I SPILL 

TIER I SPILL 

PERSONNEL ACTION TO BE TAKEN 

FIRST PERSON TO SEE THE SPILL Assess safety of situation, determine whether source can be stopped, and stop the 

source of spill if possible. 

Immediately notify your supervisor. If your supervisor is not available, notify the Drilling 

Foreman. 

INITIAL ON-SCENE INCIDENT 

COMMANDER 

(Drilling Foreman) 

From a safe distance, determine whether the spill is stopped or contained. 

Start agency and corporate notifications. Call the Incident Commander (IC). Call the 

Drilling Superintendent (if not available, call the Wells Manager). 

Complete applicable spill report form (Figure 1.2-1). 

Respond as directed by the Incident Commander (IC) to contain and recover the spill. 

INITIAL RESPONSE INCIDENT 

COMMANDER (IRIC)/QI 

(Asset Manager or designee) 

Activate appropriate components of Incident Management Team (IMT). Determine if 

Tier l, Tier II, or Tier III spill actions must be taken. 

Ensure the National Response Center (NRC) has been notified (1-800-424-8802). 

Tier II Spill: Large spill that would require mobilization of the IMT and/or all dedicated response 

resources identified in this C-Plan. 

Tier III Spill: Large spill with potential to require mobilization of all resources listed above for Tier II plus 

additional national or international resources not specified in this C-Plan. 

If the Initial On-Scene Incident Commander or the Initial Response Incident Commander (IRIC) 

determines that the spill is a Tier-II or -III event (Figure 1.1-1), additional responses and notifications 

should take place (Figure 1.1-2, Table 1.1-3). The names, positions, and telephone numbers of facility 

personnel responsible for spill notification are listed in Table 3.3-1. A summary of the emergency actions 

described in this C-Plan is available for field personnel. During Tier II or Tier III spill events, Shell’s IMT 

will normally assemble at Shell’s Anchorage Command Center located at 3601 C Street, Suite 1000, or 

otherwise as agreed with the Unified Command (UC). 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-3 March 2010 

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TABLE 1.1-3 

INITIAL SPILL RESPONSE AND 

NOTIFICATION PROCESS – TIER II OR TIER III SPILL 

TIER II OR TIER III SPILL 

PERSONNEL ACTION TO BE TAKEN 

IC/QI Gather information; assess magnitude/severity of the spill; and ensure notification of 

dedicated response resource and Shell management. 

Ensure appropriate internal and external notifications are implemented. 

Verify notification of the NRC (1-800-424-8802). 

Establish objectives and response strategies. Monitor status of incident, facility, and 

personnel. 

Work closely with Safety Officer to: 

 assess any and all risks of accidental ignition of the blowout hot zone and safe 

operating distances for all operations; and 

 need and practicality of safely and deliberately igniting the vapors over the 

surfacing oil plume. 

Mobilize additional resources (in addition to on-site equipment and personnel) if 

necessary. 

LIAISON OFFICER Confirm that all state and federal agencies and appropriate Native village authorities 

and corporations have been notified. 

Ensure notification of the NRC (1–800–424–8802). 

Request safety zones for air and water. 

Request Notice to Mariners (USCG). 

Obtain USCG approval to decant. 

Prepare written reports to agencies. 

PUBLIC INFORMATION OFFICER Establish Joint Information Center. 

Prepare for media interest. 

Keep the public informed. 

Coordinate media efforts through the Joint Information Center. 

Identify community concerns. 

SAFETY OFFICER Evaluate and monitor hazards. 

Notify off-site operators. 

Obtain Material Safety Data Sheets (MSDS) and prepare initial Site Safety Plan. 

Establish first aid posts. 

Coordinate post-incident debriefing. 

Conduct air monitoring as may be needed. 

Establish initial site safety plan. 

Ensure Hazardous Waste Operations and Emergency Response (HAZWOPER) 

compliance. 

Investigate safety-related accidents and report to IC. 

Conduct safety inspections. 

OPERATIONS SECTION CHIEF Mobilize and direct on-scene response equipment and personnel. 

Coordinate all operations with dedicated response resources and Shell’s on-site 

response personnel. 

Coordinate search and rescue operations. 

Ensure Shell representation at site / staging areas. 

Coordinate shoreline protection prior to impact. 

Contact wildlife specialists and refuge managers for information. 

Oversee preparation of Air Operations Plan. 

PLANNING SECTION CHIEF Collect, process, and display incident information. 

Provide basic environmental support. 

Supervise development of Incident Action Plan (IAP). 
Oil Discharge Prevention and Contingency Plan Chukchi Se

Part 1 – Response Action Plan Shell 1-4 

95-2000.01-25.201-001/09-018 

FIGURE 1.1-1 

TIER II AND TIER III INCIDENT RESPONSE 

ORGANIZATION CHART 

On-Scene IC/Branch Director (BD)* 

Deputy IC/BD 

ICS Support

 Scribe (On-Scene Command Post)  If needed: 

 Logistics from Deadhorse/Anchorage  Planning/IAP Support (Anchorage)  Information Officer (Anchorage) 

N

(Alaska 

Coo

* On-Scene IC initiates the response and is responsible for developing and implementing initial IAP (ICS 201 s

assembled, the On-Scene IC is relieved by the IC and becomes BDin the Operations Section. 

Safety Officer

 Floating Health, Safety, Secu

Environment (HSSE) Technic

 Drillship/ OSRV HSSE Techn

coordinated by Safety Officer to respective Group] 

On-Water Response Group

 Oil Spill Response (OSR) Operations Specialist 

(Group Leader) 

 ACS Superintendent (Deputy Group Leader) 

Source Control Group – Fron

 Drilling Foreman (Group Lead Drillship Manager  Drillship Marine Coordinator  Support Vessels 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-5 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

FIGURE 1.1-2 

INTERNAL EMERGENCY NOTIFICATION PROCESS DIAGRAM 

1.2 REPORTING AND NOTIFICATION [18 AAC 75.425(e)(1)(B)] 

1.2.1 Initial Reporting 

Any Shell contractor or employee is required to report the spill to their immediate supervisor. The person 

in charge receiving the initial spill report will assess the situation and then make appropriate agency and 

corporate notifications as established in the onboard procedures. 

The IRIC will then continue the internal and external reporting sequence to ensure proper notification of 

response personnel, appropriate company management, and government agencies. Emergency contact 

telephone numbers for Shell, response action contractors, and Mutual Aid (if required) are included in 

Table 1.2-1. Table 3.3-1 lists names, positions, and telephone numbers of facility personnel responsible 

for spill notification. Agency and External Notification Information (including Native corporations and 

villages) is included in Table 1.2-2. 

The Shell spill report form (Figure 1.2-1) must be completed for any reportable spills. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-6 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.2-1 

EMERGENCY CONTACT LIST 

SHELL CONTACT LIST 

Security 

Alaska Emergency Response Coordinator 

Wells Manager 

Drilling Superintendent 

Regulatory Affairs Manager 

HSSE Manager 

Environmental / SD Advisor 

Drilling Engineer 

(907) 264-7777 

(907) 771-7221 

(218) 544-2151 

(907) 646-7176 Cell (504) 874-4697 

(504) 728-4252 

(907) 646-7121 

(281) 544-6166 

A (713) 546-6675 Cell (281) 507-6963 

B (713) 948-1169 Cell (713) 382-6434 

OIL SPILL RESPONSE CENTERS 

Deadhorse Facility 

Anchorage 

Shell Headquarters 

(907) 382-4130 

(907) 770-3700 

(504) 728-4369 

OIL SPILL RESPONSE ORGANIZATIONS 

ACS - Primary 

Address: Pouch 340022, Prudhoe Bay, Alaska 99734 

 Main Number Prudhoe Bay 

 ACS Operations Manager 

North Slope Mutual Aid (if applicable) handled through ACS 

(907) 659-2405 

(907) 659-3202 

(907) 659-2405 

ASRC Energy Services Response Operations, LLC (AESRO) – Equipment and Tactics 

Address: 3900 C Street, Anchorage, Alaska 99503 

Main number Anchorage 

AES-RO Operations Manager 

(907) 339-6200 

(907) 339-6200 

Technical Advisor, Spiltec (Al Allen) (425) 869-0988 

NOTE: PLEASE REFER TO TABLE 1.2-2 AGENCY AND EXTERNAL NOTIFICATION INFORMATION 

FOR ADDITIONAL EMERGENCY CONTACT NUMBERS. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-7 March 2010 

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TABLE 1.2-2 

AGENCY AND EXTERNAL NOTIFICATION INFORMATION

AGENCY TELEPHONE FACSIMILE (FAX) 

NRC (800) 424-8802 

EPA (NRC will call) (907) 271-5083 (907) 271-3424 

Matt Carr (EPA) direct line (907) 271-3614 (907) 271-3424 

ADEC - Business Hours (907) 451-2121 (907) 451-2362 

ADEC - after hours and on weekends call ALASKA STATE 

TROOPERS 

(800) 478-9300 

ADEC - Sewage Spills Only (Abigail Ogbe) (907) 451-2130 (907) 451-2187 

ADNR - Oil Spill Hotline Recording (907) 451-2678 (907) 451-2751 

DOI-OEPC (Pamela Bergmann) (907) 271-5011 (907) 271-4102 

NSB (907) 561-5144 (907) 562-1940 

NSB Waska Williams (Office) (907) 852-0440 (907) 852-5991 

NSB Waska Williams (Cell Phone) (907) 367-3930 

NSB Permitting and Zoning Division (907) 852-0320 (907) 852-5991 

NSB Risk Management (907) 852-0248 (907) 852-0356 

NSB Disaster Coordinator (Pat Patterson) (907) 852-2822, 

(907) 852-6111 (24 hrs on call) 

(907) 852-2475 

USCG (907) 271-6700 (907) 271-6765 

USFWS (Alaska Maritime National Wildlife Refuge) (907) 235-6546 (907) 271-1630 

MMS (907) 250 - 0546 (907) 334-5302 

ADF&G – Fairbanks (907) 459-7242 (907) 452-6410 

BLM Anchorage - NPR-A (907) 267-1210 (907) 267-1304 

BLM Fairbanks - NPR-A (Lon Kelly) 

Report seismic spills to Fairbanks only; other spills to both 

Fairbanks and Anchorage 

(907) 474-2200 (907) 474-2281 

NSB Mayor’s Office (907) 852-0200 

City of Barrow 

Inupiat Community of the Arctic Slope 

(907) 852-5211 

(907) 852-4227 

Wainwright Mayor Office 

Traditional Council 

(908) 763-2815 

(907) 763-2535 

Native Village of Point Lay 

Cully Corporation 

(907) 833-2775 

(907) 833-2705 

City of Point Hope 

Tikigaq Corporation 

Village of Point Hope 

(907) 368-2537, 368-2836 

(907) 368-2235 

(907) 368-2330 

ADEC = Alaska Department of Environmental Conservation 

ADF&G = Alaska Department of Fish and Game 

ADNR = Alaska Department of Natural Resources 

BLM = U.S. Department of the Interior, Bureau of Land Management 

DOI-OEPC = Department of Interior, Office of Environmental Policy and Compliance 

EPA = U.S. Environmental Protection Agency 

MMS = U.S. Department of the Interior, Minerals Management Service 

NPR-A = National Petroleum Reserve – Alaska 

NRC = National Response Center 

NSB = North Slope Borough 

OEPC = Office of Environmental Policy and Compliance 

USCG = U.S. Coast Guard 

USFWS = U.S. Fish and Wildlife Service 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-8 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

FIGURE 1.2-1 

SHELL REPORT OF OFFSHORE ENVIRONMENTAL INCIDENT FORM 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-9 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

FIGURE 1.2-1 (CONTINUED) 

SHELL REPORT OF OFFSHORE ENVIRONMENTAL INCIDENT FORM 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-10 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

1.2.2 External Notification Procedures 

Appropriate agency verbal notifications and written reports may include: 

 NRC 

 MMS 

 BLM 

 USFWS 

 EPA 

 USCG 

 U.S. Department of Interior (DOI) 

 U.S. Department of Transportation (DOT) 

 ADEC 

 ADF&G 

 ADNR 

 National Oceanic and Atmospheric Administration (NOAA), National Marines Fisheries Service 

(NMFS) 

 NSB 

 Village of Barrow 

 Village of Wainwright 

 Village of Point Lay 

 Village of Point Hope 

See Table 1.2-2 for contact information. 

1.2.3 Written Reporting Requirements 

Depending on the type and amount of material spilled, individual government agencies have 

requirements for written reporting, which are the responsibility of Shell. MMS, USCG, and ADEC reporting 

requirements will be met in the following procedures. Agency and external notification contacts and 

agency reporting requirements are summarized above in Table 1.2-2 and in the following Table 1.2-3, 

respectively. 

MMS regulations require all applicable federal, state, and regulatory agencies be notified. 

ADEC regulation 18 AAC 75.300 requires notification of any spill on state lands or waterways. After 

notification of the discharge has been made to ADEC, the department will, at its discretion, require interim 

reports until cleanup has been completed [(18 AAC 75.300(d)]. A written final report must be submitted 

within 15 days of the end of cleanup operations, or, if no cleanup occurs, within 15 days of the discharge 

[18 AAC 75.300(e)]. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Re

Part 1 – Response Action Plan Shell 1-11 

95-2000.01-25.201-001/09-018 

TABLE 1.2-3 

AGENCY REPORTING REQUIREMENTS FOR OIL SPILLS

ENVIRONMENTAL COMPLIANCE 

INITIAL AGENCY NOTIFICATION

AS SOON AS POSSIBLE 

WITHIN 

48 HR MONTHLY 

IMMEDIATE 

OR AS 

SHOWN BELOW 

SPECIFIC 

CONDITIONS 

NRC

(EPA) 

ADEC

ADNR NSB 

USCG4

MMS5

ADF&G6 BLM10

ADEC 

NSB 

ADNR 

ADEC 

NSB 

ADNR 

FEDERAL

LAND ONLY 

BLM10 DOT 

SPCO 

FAX 

W/IN 

48 HR 

AOGCC3

CRUDE

GAS 

OFFSHORE (DISCHARGES TO WATER)1 

Sewage9 Any quantity X X Any oil or chemical spill 

(e.g., oil, drilling fluids, glycol, produced water, or brine) X X X X X X X 

Seawater 

To seawater environment (no report) 

Any amount seawater to freshwater environment X X X X X X 

STAGING AREA 

Chemicals 

Exceeds federal RQ2 X X >55 

gal 

>100 

bbl 

 X 

Less than RQ, or has no RQ X >55 gal X5 X 

Selected Hazardous Substances13

>55 gal X X X 

10 to 55 gal X X <10 gal (no report) 

Seawater 

To seawater environment (no report) 

>55 gal to freshwater environment >100 bbl X X 10 to 55 gal to freshwater environment X X <10 gal to freshwater environment (no report) 

Sewage9 Any quantity X9 Oil 

>55 gal X X 

>100 

bbl or 

500 mcf 

gas 

 X X 

10 to 55 gal X X >25 gal 1 to 10 gal (<1 gal = no report) X X 

IN CONTAINMENT 

Chemicals Air release, with RQ X X X 

Less than RQ or has no RQ13 

Sewage9 Any quantity (no report) Oil, Glycol, and Select Hazardous Substances13

>55 gal (less than = no report) X 

>100 

bbl or 

500 mcf 

gas 

 X X 

AOGCC = Alaska Oil and Gas Conservation Commission hr = hour(s) gal = gallon(s) mcf = million cubic feet RQ = reportable quantity SPCO = State Pipeline Coordinator’s Office 
Oil Discharge Prevention and Contingency Plan Chukchi Se

Part 1 – Response Action Plan Shell 1-12 

95-2000.01-25.201-001/09-018 

TABLE 1.2-3 (CONTINUED) 

AGENCY REPORTING REQUIREMENTS FOR OIL SPILLS 

Notes: “Oil” includes crude, diesel, gasoline, hydraulic fluid, transmission fluid, and therminol. 

1. Reporting requirements for discharges within State of Alaska Territorial Waters. 2. Chemicals with federal RQs include ethylene glycol at 540 gal; methanol (pure) at 750 gal. Chemicals without RQs include sewage, produced 

3. For State regulated wells: Crude oil spills >25 gal; notify AOGCC North Slope Representative. Crude oil spills >10 bbl, notify AOGCC North Sl4. All oil spills to or threatening navigable waters. 5. Offshore rig spills <42 gal, call NRC. Notify MMS (Regional Field Supervisor) for oil spills >42 gal. 6. Any release to fish-bearing water bodies. 7. EPA letter required for oil spills >1,000 gal, all off-pad oil spills and storm water releases of oil or chemicals >RQ. 8. Sewage spills, including domestic wastewater and gray water, spills are reportable to ADEC Wastewater Program; written report due 7 days af9. No notification required for snow-covered tundra unless >100 bbl, or unless penetrates tundra. 10. See off-pad, on-pad, ice pad/ice roads, and in-containment reporting requirements to determine reporting to these agencies.

11. Glycols, brines, drilling fluids, seawater, produced water, or methanol diluted with 40% or more water. 12. Detailed report must be submitted to EPA within 60 days if oil discharge is over 1,000 gal in a single event or more than 42 gal of oil in each of 

month period. 

13. Field Environmentalist must evaluate available information (MSDS, test data, or process knowledge) to determine if spilled substance is a haza

is not required if a non-hazardous determination is made. 

14. MMS requires written report 15 days after loss for spills greater than 42 gal.
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-13 March 2010 

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Interim and final written reporting requirements are specified in 18 AAC 75.300. The report must contain 

the following information: 

 Date and time of discharge; 

 Location of discharge; 

 Name of facility or vessel; 

 Name, mailing address, and telephone number of person or persons causing or responsible for 

the discharge and the owner and the operator of the facility or vessel; 

 Type and amount of each hazardous substance discharged; 

 Cause of the discharge; 

 Description of any environmental damage caused by the discharge or containment to the extent 

the damage can be identified; 

 Description of cleanup actions taken; 

 Estimated amount of hazardous substance cleaned up and hazardous waste generated; 

 Date, location, and method of ultimate disposal of the hazardous substance cleaned up; 

 Description of actions being taken to prevent recurrence of the discharge; and 

 Other information ADEC requires to fully assess the cause and impact of the discharge. 

1.3 SAFETY [18 AAC 75.425(e)(1)(C)] 

Based on applicable safety standards, a description of the steps necessary to develop an incidentspecific safety plan for conducting a response are included in the following documents: 

 Shell Beaufort and Chukchi Seas Regional Tactics Manual, Tactics S-1 through S-4; 

 ACS Technical Manual, Tactics S-1 through S-8, which include site entry procedures, site safety 

plan development, and personnel protection procedures 

 Shell Contractor Safety Handbook; and 

 Shell’s HSSE Policy Statement and HSSE Management System. 

Mandatory safety orientations are conducted for all Shell employees and contractors working at Shelloperated facilities, including additional training for employees in safety-critical positions. 

The Shell well plans, prepared for each drilling operation conducted in the Chukchi Sea, are designed to 

ensure drilling activities are performed in a safe and environmentally sound manner. Each well plan 

identifies the procedures, systems, and equipment employed in drilling; uses the best technical 

information available concerning subsurface formation characteristics and pressures; and provides 

information critical to the success and safety of the drilling program. The site-specific evacuation plan is 

maintained on all Shell-owned or ShelI-contracted drillships and is posted throughout these facilities as 

part of the “Station Bill.” Weekly drills are held to assure compliance. 

Additionally, Shell has prepared a Critical Operations Curtailment Plan (COCP), which establishes the 

procedures to follow when storm conditions or hazardous ice conditions are anticipated. The COCP 

serves to ensure personnel safety onboard, while minimizing any risk of damage to equipment and the 

possibility of a discharge resulting from operations during severe environmental conditions. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-14 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

In the event that conflicts arise with the above-referenced documents while developing an incident 

specific safety plan, Shell procedures will take precedence as identified by the IMT Safety Officer. 

1.4 COMMUNICATIONS [18 AAC 75.425(e)(1)(D)] 

1.4.1 Communications Plan 

Effective communication during a spill response requires that all parties understand and use the assigned 

radio frequencies and telephone numbers. Use of pre-programmed and designated frequencies ensures 

that emergency communications are established immediately for a response. As spill response efforts 

grow, additional frequencies and telephone numbers may be added to a complete Communications Plan 

that is distributed to all parties. 

The Communications Unit Leader is responsible for establishing a plan that provides coverage in the field 

and between the field and a command post. Communication requirements are determined by many 

factors, the most important of which are the location and nature of the spill response activities, and the 

number of staff placed in the field. Specific requirements include: 

 Communications systems must be self-contained, compact, highly portable, and capable of 

providing all on-site and off-site communication links for the duration of the response. 

 Communication equipment used in the immediate vicinity of spilled or recovered product must be 

intrinsically safe (explosion proof). 

Field teams will work in close proximity to each other, and generally require only a single tactical 

communication link operating over a distance of several miles. A repeater radio link would be required to 

bridge worst-case distances from the field to the staging area and support teams. 

A description of the statewide communications plan developed by the crude oil spill cooperatives (ACS, 

Cook Inlet Spill Response, Inc., Ship Escort Response Vessel System) is provided in Table 1.4-1. The 

frequencies noted have been licensed for use statewide on oil spills. The radio plan also provides up to 

20 very high frequency (VHF) tactical channels and includes VHF marine channels. The plan has 

provisions for adding other area-specific channels unique to individual cooperatives or Member 

Companies and uses exclusively VHF channels in the 150 to 174 megahertz (MHz) band. 

The Alaska Statewide Frequency Plan consists of 48 channels, designated OS-29 through OS-76. When 

referring to these channels, the channel number is always prefixed with the letters “OS.” This clarifies the 

identity of the channel under discussion and minimizes potential confusion that the channel might 

represent a marine channel, or some other internal company channel. 

1.4.2 Communications Equipment 

The Shell Oil Spill Response (OSR) vessels will be equipped with radio subscriber units that will be tuned 

to the assigned frequencies. OSR vessels also may use radio channels on the ACS communication 

network. Also, all vessels will have standard marine radio systems. Additional ACS subscriber units are 

available for use in OSR or drills. ACS provides for an extensive communications network in the North 

Slope region, built on the basis of VHF radio coverage. Also, ultra high frequency (UHF) radio can be 

linked to VHF systems via an ACS UHF-VHF link. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-15 March 2010 

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Descriptions of communications resources and systems are provided in the ACS Technical Manual (see 

Tactics L-5 and L-11A) and the Shell Beaufort and Chukchi Seas Regional Tactics Manual (Tactic LE-2). 

The following communication frequencies could be used depending upon the location and emergency 

situation. 

TABLE 1.4-1 

SUMMARY OF ALASKA STATEWIDE FREQUENCY PLAN CHANNELS 

CHANNEL TYPE DESCRIPTION 

OS-1 through OS-28 Reserved for individual and unique use by Member Companies 

and cooperatives. 

OS-29 through OS-32 Tactical channels Match marine radio channels. 

OS-33 through OS-52 

Fixed repeater channels (and 

associated talk-around 

channels) 

Located on the North Slope, along the Alyeska Pipeline corridor, 

and in Cook Inlet or Prince William Sound. The talk-around 

channels are available for tactical use when operating in an area 

not covered by the associated repeater channel. 

OS-53 through OS-64 

Portable repeater channels (and 

associated talk-around 

channels) 

Licensed for use statewide. The talk-around channels are 

available for tactical use when operating in an area not covered 

by the associated portable repeater channel. 

OS-65 through OS-76 

Marine Channels 

OS-72 is Marine 11 

OS-75 is Marine 80A 

OS-76 is Marine Repeater 85 

For both tactical, operations, and logistics use, as required. Note 

that marine channels are specifically given OS designations that 

do not reflect the actual marine channel number. 

OS-77 through OS-100 Reserved for potential future expansion of the Plan. 

The communication systems that may be employed in a given location or spill situation include: 

 Telephone Circuits. Telephone systems at many company facilities are generally sufficient to 

handle the volume of telephone calls associated with most spills. Sparsely populated areas, 

however, may have very limited telephone service, or the reserve capacity of the system may be 

so small that temporary service to remote control centers cannot be quickly provided. Solutions to 

such potential telephone bottlenecks might include establishing microwave or satellite links to 

these areas using contracted resources. 

 Cellular Telephone Systems. Standard cellular coverage in Alaska is limited to populated areas 

primarily in Southcentral and Southeast Alaska, but coverage continues to expand rapidly within 

the state. The increasing availability of satellite-based cellular coverage is expected to make 

cellular telephone the communications system of choice. Battery-powered cellular telephones are 

preferred, to free the user from dependence on commercial power or vehicle batteries. 

 VHF-FM Marine Radio (156 to 158 MHz). On-water cleanup operations are expected to use 

marine VHF radio equipment for inter-vessel, ship-to-shore, or response personnel 

communications. Marine channel 16 is the international distress and hailing frequency. Marine 

VHF radios can also be used to warn other, non-response vessels about ongoing cleanup 

operations. Marine radios can be used for coordinating the cleanup operations, although UHF 

radios are also suitable for this purpose. 
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 VHF-AM Aircraft Radio (118 to 136 MHz). These VHF frequencies are used for ground-to-air 

communications, although most aircraft can also monitor VHF Marine and many UHF channels. 

Ground-to-air communications are very important for relaying surveillance information, as well as 

coordinating the transport of equipment and personnel. 

 UHF (454/459.000 MHz). UHF radio systems are typically used for land-based operations, 

although they are also acceptable for marine use. UHF radios are often limited to just a few 

frequencies or channels that are preset into the units. Most UHF radios are 3- or 6- (but can be 

up to 16) channel models with the actual frequencies dependent on the license of the particular 

facility or company. 

 High Frequency (HF) Single Sideband (SSB) Radio (2 to 20 MHz). For communication over 

long distance at sea and in undeveloped areas, operators may consider obtaining HF-SSB voice 

radio equipment. Radio propagation by this mode changes widely over daily and yearly cycles, 

and is strongly influenced by changes in solar activity. Communications may be excellent with a 

station 31 miles (mi) [50 kilometers (km)] away at a given time and barely audible a few hours 

later. 

 INMARSAT Satellite. INMARSAT systems can be installed on vessels or at remote locations 

and, where approved for voice and fax communications to standard telephone lines, almost 

anywhere in the world. The associated costs are high, but these systems can be invaluable in 

areas where other forms of communication are unavailable or inconsistent or fax transmissions 

are critical. 

 MSAT. MSAT is a satellite system based on the world’s most powerful commercial mobile 

satellite. Voice communications, including continent-wide group and private communications are 

available through use of the MSAT-G2 radio. The MSAT-G2 radio supports point-to-point and 

point-to-multi-point communications including push-to-talk, push-to-track and voice services. 

 Iridium Satellite. Iridium telephones use satellites to provide worldwide voice and data 

communications. The network is unique in that it provides whole-earth coverage, including polar 

regions, oceans, and airways. 

 Paging Systems. Pagers are one-way radio communication systems that enable persons within 

range of the paging system transmitter to be alerted or to receive a brief message. 

 700 MHz. Radio communication networks provide broadband wireless connectivity primarily in 

the Prudhoe Bay area westward to Alpine, including coverage offshore in short distances [less 

than 10 mi (16 km)]. 

Drillship Communication 

The communications equipment maintained on site at the drillship is listed below. Radio coverage on the 

drillship will be with VHF Marine and Land Mobile Radio. 

Shell’s OSR vessels will be equipped with radio subscriber units that are both handhelds and dash 

mounts, programmed with the frequencies of ACS- and Shell-licensed mobile, land VHF radio networks. 

For communications with spill response vessels in the area, base station radios will also be installed on 

the drillship. Standard marine VHF radio will be used to communicate with response vessels and drilling 

support vessels within a 30- to 50-mi radius of the drillship. The exact range is dependent on topography 

and, to some extent, on weather. For communication with response ships and other vessels beyond this 

radius, the satellite-based telephones will be used. 
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The drillship will have a Very Small Aperture Terminal (VSAT) voice and data service in excess of 512 

kilobits per second (kbps) to facilitate primary communications with shore resources. The VSAT service 

is composed of a Kurtz-under (Ku) Band satellite communication package and is supplied by Alaska 

Telecommunications Inc. The VSAT service on the drillship will have a back-up satellite communication 

system via Frontier Drilling. Telephone and facsimile lines will be provided over the satellite 

communication systems. 

Voice telephone calls are the primary means of direct communications with Anchorage, the on-scene 

command post, Shell staging areas, off-site resources, agencies, and other company contacts. The 

Shell-licensed radio frequencies may also be used where range permits. Voice telephone calls can be 

conducted across the VSAT system as well as using Iridium satellite telephones [or MSAT telephones]. 

There will be multiple telephone and facsimile lines available on the drillship for multiple simultaneous 

inbound and outbound calls. 

Intercom System 

Barkway intercom system units are located in mud utility, bulk, mechanical and electrical areas, drill floor, 

and manager’s office. The systems are equipped with priority override speed calling and two independent 

speech paths. The systems will be interrupted temporarily by a page or an alarm from a tone generator. 

Another system, Vingtor, links the drilling unit pump room, radio room, and control room to the drilling unit 

pump room, control room, and stairwell, and operates independently of all other systems. This is a handsfree, talk-back system. 

Page and Alarm System

This system consists of a camp page and alarm system. The camp page has high- and low- level 

volumes (low for sleeping areas); however, in the event of an alarm or emergency page, the volume is 

increased to high. Tone generators in the control unit of the page system will provide three distinct tones 

for: 

 General – Vibrato – percussive 816 hertz (Hz) tone 

 Combustible Gas – Yeow – 1260 to 600 Hz – downward sweep in 1.6 seconds, and 

 Hydrogen Sulfide (H2S) Gas – Hi-Lo – 780 to 600 Hz, alternately – 0.52 seconds each. 

A console in the radio room is interfaced to the control unit with push-button control of appropriate page, 

alarm, and cancel functions. This console is also interfaced to fire panel and remote sensors with lamps 

to indicate fault conditions, as well as an auto/manual switch to allow for automatic gas alarms if the radio 

room is not staffed. 

All alarm tones, standard pages, and emergency pages are transmitted to the drilling unit and camp via 

mixer-amplifiers installed in the equipment room in a rack with the page control unit. The drilling unit 

mixer/amplifiers are installed in the stores room. 

Communication and Navigation Equipment, Frontier Discoverer

The drillship has the following communication and navigation equipment installed: 

 Mitel SX-20 telephone exchange with seven outgoing trucks and associated locals 

 Four each, VHF, FM radio telephone, Raytheon Ray-55 

 VHF air-to-ground radio, WCS300 
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 Non-directional beacon, Wilcox 485 

 Two each, HF SSB – Motorola Triton 

 Radar transponder – Vega 367X 

 Rapifax machine 

 Satellite dish for TV, modulator, amplifier, intercamp wiring, VCR 

 Walkie-talkies (15) 

 2182 Marine Emergency Watch receiver 

 Class 1 and Class 2 Emergency Position Indicating Radio Beacon 

 Lifeboat radio and VHF crash boat radio 

 Weatherfax receiver – Furuno 

 Telecommunications currently supplied by Alaska Telecommunications, including a Ku band 

satellite system as the primary unit for telephones, data and fax, and a secondary VSAT system 

via Frontier Drilling. 

 Two each, 25 kilowatt (kW) Decca radars; one mounted on top of the camp, the other mounted 

on top of the derrick 

 Satellite navigator – Magnavox 4102 

 Three VHF radio-telephones – Raytheon Ray-78; one installed in each crane 

 One Sperry SR120 gyro compass 

 Pantenna/amplifier entertainment system 

 Three independent paging systems for all three cranes. 

Patch Number 1 and Patch Number 2 

HF radio can be patched to any worldwide telephone. When using these systems, the operator should 

explain to the other party that they have to wait for sender to stop transmitting before they try to talk or 

their conversation will be blocked. 

1.4.3 Equipment Maintenance 

Communication equipment will be tested and maintained according to the following schedule: 

 Periodically: 

- Rechargeable batteries will be tested and recharged. 

- Radio and electronic equipment will receive an operational test to ensure that the equipment is 

working. 

 After Use: 

- All communications equipment used in actual spill response operations will be inspected, 

cleaned, and tested before being returned to storage. 
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1.5 DEPLOYMENT STRATEGIES [18 AAC 75.425(e)(1)(E)] 

The OSRV will be stationed nearby the drillship during drilling operations into liquid hydrocarbon-bearing 

zones. The OSRV has trained personnel onboard who are provided with the necessary resources to 

implement containment, control, and recovery tactics. The OSRV will begin recovery operations and 

possess sufficient capacity (11,400 bbl at 95 percent capacity) to store all recovered fluids from a WCD 

during the first 24 hrs of skimming operations. The OST will be staged within 240 n mi of the Chukchi 

Sea drill site. The OSRV and OST are capable of transit speeds of 10 knots. Using 10 knots as a 

realistic average transit speed for planning purposes, the OSRV would be positioned to arrive at the spill 

site within one hr [(i.e., would be positioned within 10 n mi of the drill ship) see Section 1.6.13 Scenario], 

and the OST would be staged off the Chukchi Sea coast and arrive at the recovery site within 24 hrs of 

departure from the staging area. If necessary, a second vessel, the anchor handler or a similar vessel 

staged with the drillship, would be mobilized to act as a VOSS. The VOSS would possess sufficient 

skimming capability and liquid storage capacity (minimum of 3,200 bbl) to relieve the OSRV for 8 hr 

during which time it would lighter recovered fluids to the OST. The OSRV and VOSS would set up a 

rotation cycle with the OSRV skimming for 16 hr and the VOSS for another 8 hr while the OSRV lighters 

to the OST. The OST would possess a minimum liquid storage capacity of 287,100 bbl, sufficient 

capacity to store all recovered liquids (oil and emulsified oil/water) from a 30-day blowout. Additional 

personnel may also be transported via helicopter or vessel from a land- or vessel-based staging area. 

The oil spill personnel onboard the OSRV and VOSS are available to respond rapidly to an on-site 

emergency. During conditions that may limit helicopter operations, the OSRV crew would remain on the 

vessel and continue emergency operations. Personnel may also be transported via helicopter from the 

heli-decks located onboard either of the supporting vessels or may utilize other small vessels or work 

boats for transport.

A large, mobile Oil Spill Response Barge (OSRB) and tug, will be staged in the nearshore zone of the 

Chukchi Sea in order to best intercept and recover oil potentially threatening the coast, as water depth, 

weather, sea conditions and other circumstances allow. We anticipate the OSRB will generally loiter 

between Icy Cape and Peard Bay in order to ensure preparedness, and to facilitate support from the 

logistics base at Wainwright. It will carry response equipment that includes a 47-foot (ft) skimming vessel, 

34-ft work boats, mini-barges, boom and duplex skimming units for nearshore and shoreline protection 

and recovery. The OSRB will mobilize to implement nearshore recovery and support the shoreline 

protection task force. Additional equipment and personnel resources, supplies, billeting, and spike camp 

support facilities would be cascaded to support ongoing shoreline cleanup operations as necessary. 

The mobilization of additional staff and equipment to support the OSR effort (refer to Section 1.6.13), will 

be progressively mobilized as follows: 

 From existing call-out arrangements under ACS 

 Auxillary Contract Response Team (ACRT) personnel as well as equipment may be provided 

through ACS to supplement the offshore, nearshore, and shoreline response operations, as 

necessary; 

 Village Response Team (VRT) personnel may be provided through ACS to supplement the 

nearshore and shoreline response operations, as necessary; 

 North Slope Spill Response Team (NSSRT) personnel may be provided for shoreline response 

operations, as necessary; 

 ACS staff off-rotation outside the North Slope operating area (subject to 70 percent availability for 

planning purposes); 
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 Other Shell contractors; and 

 Other qualified staff mobilized from within the Royal/Dutch Shell Group in the U.S. and abroad. 

1.5.1 Transport Procedures [18 AAC 75.425(e)(1)(E)(i)] 

Actual response and mobilization times will vary depending on a variety of factors, such as weather, 

personnel safety, and wildlife considerations. During adverse weather conditions that prohibit the 

transport of equipment, personnel, and other resources to the spill site, spill response will be conducted 

solely by on-site personnel and equipment. Sufficient response personnel are stationed on the vessels to 

staff TF-1, TF-2 (VOSS), and TF-3 for two 12-hr shifts as listed in Table 1.6-9. 

Using 10 knots as a realistic average transit speed for planning purposes, the OSRV would be positioned 

to arrive at the spill site within one hr [(i.e., would be positioned within 10 n mi of the drill ship) see Section 

1.6.13 Scenario], and the OST would arrive at the recovery site within 24 hr of departure from the staging 

area. Shell has chosen a conservative 10 knot transit speed for response resources. Although service 

and maximum speeds for these vessels are significantly faster, the planning speed for response purposes 

has specifically been reduced to show robust response capability even in heavy sea conditions, reduced 

visibility, and due to the additional power requirements that may be necessary in the presence of ice. All 

major response assets are designed for and certified for operation in arctic conditions, including operation 

in high ice concentrations. Please refer to Appendix A for further information regarding general on-site 

vessel capabilities and, if applicable, class notations, as well as Table 1.6-9 for planned response staffing. 

Transportation options are listed in Table 1.5-1. 

The estimated response time from discovery of a spill at the drill site to the deployment of equipment 

varies depending on the incident causing the spill, the size of the spill, time of year, logistical support, and 

available information. 

TABLE 1.5-1 

TRANSPORTATION OPTIONS 

MODES OF 

TRANSPORTATION 

SEASON 

DRILLING BREAKUP/FREEZEUP WINTER 

Helicopters X1 X1 X1

Fixed-wing Aircraft X1 X1 X1 

Vessels X Conditional2 Conditional2

Vehicles/Heavy Equipment -- -- Conditional2

Heavy ATV -- -- Conditional2

1 Weather dependent 

2 Dependent upon ice conditions 

ATV = all terrain vehicle 

Pre-staged Equipment 

The drillship will have the OSRV on standby within its vicinity during drilling operations into liquid 

hydrocarbon-bearing zones. One of the support vessels assigned to the drillship will serve as the VOSS 

and will be on site. Additionally, the drillship will carry a limited amount of pre-staged equipment and 

supplies to handle minor operational spills. Pre-staged equipment will be inspected monthly. Inspections 

of response equipment would be performed by ACS as part of their periodic maintenance system, and the 

inspection records would be maintained through ACS. 
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Section 1.6.12 describes the equipment and personnel pre-staged at Wainwright that would be used to 

initiate and support shoreline response. Pre-staged equipment would be routinely inspected throughout 

the drilling season to ensure it is secure and ready for deployment in the event of an emergency. 

Equipment available through ACS has been scaled to fulfill specific shoreline protection strategies (refer 

to Section 1.6.13). Shoreline response personnel, described in Section 1.6.12, Shoreline Cleanup, and 

listed in Table 1.6-9, are pre-staged at Wainwright, and may be supported from mobile shore-based 

facilities during a response. Trajectory modeling shows that oil may reach shore in six days at the earliest 

possible time, allowing sufficient time to establish these support facilities in proximity to UC-designated 

priority protection sites. 

Air Access 

The drillship can accommodate helicopter operations. Air operations may be limited by weather 

conditions, as discussed in Section 3.4. 

Fixed-wing aircraft can transport personnel and equipment to airstrips located at Barrow, Wainwright, 

Point Lay, or Point Hope. These airstrips provide coastal access and can serve as logistical hubs for 

shoreline protection or cleanup efforts (Notification and Mobilization of Response Action Contractor 

[18 AAC 75.425(e)(1)(E)(ii)]). 

1.6 RESPONSE STRATEGIES [18 AAC 75.425(e)(1)(F)] 

The following subsections provide information about the strategies and tactics that would be used for 

response to potential oil spills and related incidents arising from Shell’s exploration drilling program. 

The narratives provided in these sections complement the information presented in Section 1.6.13, Spill 

Response Scenarios. Where practicable, project-specific details, including oil trajectories, have been 

incorporated based on the proposed drilling projects. 

1.6.1 Procedures to Stop Discharge [18 AAC 75.425(e)(1)(F)(i)] 

Procedures to stop the discharge are discussed in Section 1.6.3 Blowout Control/Relief Well Plan; 

Section 2.1.8, Blowout Prevention and Emergency Shutdown; Section 4.2, Source Control; Table 4.2-1, 

Best Available Technology (BAT) Analysis Well Blowout Source Control; and in the Spill Response 

Scenarios listed in Section 1.6.13. Shell certifies that we currently have and continually maintain a 

separate blowout contingency plan. 

1.6.2 Fire Prevention and Control [18 AAC 75.425(e)(1)(F)(ii)] 

In the event of a spill, all sources of ignition will be eliminated, if safe to do so. A standard Site Safety 

Plan will be used in the event of a major oil spill. This includes assessing and establishing exposure 

control zones into which appropriately trained and equipped personnel may enter. 

If a fire occurs, it will be controlled as much as possible with fire monitors on the drillship and supporting 

vessels. 

The drillship contains fire and lifeboat alarms, fire-fighting and wash-down systems: 
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 Alarm systems include vessel-mounted gas detectors located on the drilling unit floor, upper 

shale shaker, mud pit room and mud pump room, with a monitoring panel mounted in the radio 

room. 

 An emergency shutdown system for the ship is located on the drilling unit floor. The main engine 

emergency shutdowns are located on the bridge and in the Emergency Response Room. 

 Fire- and wash-down systems include two centrifugal, 300 gallon per minute (gpm) fire pumps, 

one centrifugal 300 gpm emergency fire pump, and fire hydrants located throughout the drillship. 

 The vessel is equipped with fixed carbon dioxide (CO2) fire-extinguishing systems to cover the 

propulsion room, generator room, control room, paint locker and emergency generator room. 

 Fire-fighting foam systems comprise two monitors, foam tank, and separate pump for heli-port 

protection. 

Ignition of the vapors surfacing at the blowout may be considered for safety reasons. By eliminating 

flammable vapors at the surface, any accidental ignition can be avoided thereby allowing response 

personnel to operate safely downwind. Ignition of this vapor source is not considered an initial response 

action and will only be attempted after: (1) the drill ship is relocated a safe distance from the surfacing 

vapor; (2) a complete site characterization and assessment is conducted; and (3) a full ignition plan has 

been developed and approved by the UC. Given that the volume and composition of surfacing gas is 

unknown, this safety precaution is not forwarded as a response strategy and no response planning 

standard credit is sought for oil elimination that may occur as a result of this mitigating safety measure. 

1.6.3 Blowout Control/Relief Well Plan 

Shell has taken significant precautions to minimize the potential for a loss of well control. Section 2.1.8 

describes the four layers of preventive and recovery measures used to minimize spill potential during 

drilling operations. Layer I consists of proper well pre-planning, risk identification, personnel training, and 

routine tests and drills on the drillship. Layer II includes early kick detection, implementation of kick 

response procedures and continuous monitoring of downhole conditions. Layer III involves the use of 

mechanical barriers, such as the blowout preventer (BOP), casing, and cement. Layer IV represents 

dynamic techniques to regain well control, including relief well drilling. 

In the unlikely event that well control is lost despite these precautions, Shell will immediately mobilize 

emergency response personnel and equipment. Shell will also consult a well control specialist such as 

Wild Well Control, Inc. (Wild Well Control) for the intervention and resolution of a well control emergency. 

Surface Control Options 

If well control is lost, every effort will be made to regain well control using dynamic surface control 

measures. Historically, these measures of regaining control have been rapid and effective. Refer to 

Section 2.1.8 for a more detailed discussion on well control options and methods. 

In the event of uncontrolled flow, safety procedures are employed to protect personnel, the environment, 

and equipment. A site assessment is conducted, safe access and work plans are created, and 

uncontrolled fluids are diverted for collection to create a safe working environment and to minimize 

pollution. 

Although the specific control methods used will depend on the situation, potential control methods include 

the following: 
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 Natural bridging; 

 Pumping mud, plugging material, and/or cement down the well to kill it; 

 Replacing the failed equipment if control was lost due to equipment failure; and 

 BOP. 

Relief Well 

As described in Section 2.1.8, Shell does not rely on relief well drilling as the primary method of surface 

well control, but rather applies a rigorous multi-layer well control management system that has proven 

successful in preventing escalation of a well control incident to a blowout situation. These layers include 

planning and risk identification, early kick detection and kick response procedures, and installing 

mechanical barriers. These measures result in an extremely low probability of an uncontrolled well 

release, but in the event this did occur, the drilling of a relief well is the final tool for regaining well control. 

In the scenario developed for this contingency plan, the drillship attempts to stop (or slow) the blowout by 

shutting in the BOP and/or pumping mud and/or cement downhole. Should these efforts fail, the drillship 

pulls away from the blowout location in order to support safe recovery operations from a relief well site. As 

a precautionary measure, relief well preparation operations are initiated in parallel with the 

implementation of surface control methods. 

The general strategy for drilling a relief well is to drill a well to intersect the blowout well. Then, drilling fluid 

or cement is circulated from the relief well to the original wellbore at sufficient rates and weight to stop 

formation fluid from flowing into the original wellbore, bringing the well under control. Finally, both wells 

are properly plugged and abandoned. 

A relief well in this situation would have the following general characteristics: 

 No mudline cellar (MLC). 

 No formation evaluation at the casing points. 

 Kill fluid as well as an additional wellhead and additional surface casing and other casing, 

drillpipe, mud materials, and cement would be in place onboard the Shell-operated drillship and 

supply vessels or available in time to deploy. 

 A detailed Relief Well Design is submitted to MMS as part of the Application for Permit to Drill 

(APD). 

Relief Well Locations 

The optimum location for a relief well depends on several factors, including the depth and direction of the 

wellbore, personnel safety, and weather conditions. The location of the relief well is selected so that it can 

be drilled in the most efficient manner practicable. 

Relief Well Drillship and Equipment 

Given Shell’s drilling assurance program in place to minimize any risks (See Section 2.1.8), Shell believes 

that a prudent operator can conduct a Chukchi Sea drilling program using a single drillship. In the event of 

a blowout, the drillship would immediately cease its then-current operations and relocate to a safe 

location to initiate a relief well and intersect the blowout well. It is important to note when considering 

potential relief well operations, that based on past seasonal ice conditions and active ice management 

experience, it is very likely that the drilling season could extend into December. 
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While the drillship will carry surface casing and wellhead equipment for a relief well, contingency plans 

have been established to augment existing drilling equipment (drillpipe, additional casing, cement, and 

mud materials) and services, which would be drawn from Shell’s operations Chukchi Sea support vessels 

or from onshore support facilities. 

Relief Well Timing 

The total duration from the start of a blowout to well killing by drilling a relief well would depend upon 

number of factors which include drilling depth, hole angle, formation properties, intersection and kill 

considerations, logistics, and environmental conditions. By example, it is estimated that the duration for 

an 8,000-ft true vertical depth (TVD) relief well is approximately 16 days and the duration for a 14,000-ft 

TVD relief well would be approximately 34 days. 

Blowout Well Ignition 

A decision to ignite the blowout well would be considered to control the vapors for personnel safety. The 

UC would base its decision on the consideration of potential safety hazards, pertinent environmental 

considerations, and necessary agency approvals. Through a risk/benefit analysis that places human 

safety as the highest priority, Shell will consider the feasibility and benefits of igniting the surfacing vapors 

after all personnel, equipment, and vessels have been located at a safe distance from the surfacing oil 

and gas. Ignition equipment and procedures such as heli-torch, handheld igniters, and flares, will be 

located in the vicinity and ready for use. The Shell risk/benefit analysis will facilitate a rapid assessment of 

the potential risks of exposure for personnel, equipment, and wildlife to the initial flash of combustible 

vapors, as well as the heat and combustion products from a sustained burn. Ignition and sustained 

combustion of vapors from the surfacing gas and oil could potentially result in a safer working 

environment for relief well operators and for responders attempting to contain and recover oil downstream 

of the blowout. A controlled burn would help eliminate dangerous vapors in the working vicinity. 

Permits 

In the event of a discharge due to the loss of well control, a series of federal, state, and local permits 

would be required to support the response effort. Permits will be needed to authorize construction of 

onshore support facilities if necessary (e.g., staging pads, temporary storage areas, and temporary water 

uses). 

Federal approval would be required in the form of a Section 404/10 permit from the U.S. Army Corps of 

Engineers (USACE) for placement of gravel in nearshore coastal waters and wetlands. The USACE has 

issued a Nationwide Permit No. 20, which authorizes placement of fill needed for cleanup of spilled oil. A 

request for this authorization would require approval from the Alaska Regional Response Team (ARRT), 

and would typically be approved very rapidly, assuming the team is in agreement with the overall cleanup 

strategy for the spill event. 

In addition to this federal permit, MMS, State of Alaska, and NSB permits would also be required. If all 

other surface control measures fail and it becomes necessary to drill a relief well, Shell will obtain APD 

from MMS prior to drilling. As part of the overall North Slope oil spill preparedness program, ACS holds a 

series of permits that facilitate agency authorizations for a variety of response and cleanup-related 

activities, including bird and mammal hazing and mammal stabilization. 

1.6.4 Discharge Tracking [18 AAC 75.425(e)(1)(F)(iv)] 

Discharge tracking is summarized in the response scenarios in Section 1.6.13. 
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Oil movement is tracked primarily through the combination of visual observations, aided where 

practicable by Global Positioning System (GPS) devices and spill tracking software, and commercially 

available remote sensing techniques. Based upon availability and weather conditions, a Sikorsky S-61 

helicopter with forward looking infrared radar (FLIR), vessel-mounted infrared radar (IR) systems onboard the OSRV or alternative commercially available aircraft with Synthetic Aperture Radar (SAR) would 

be deployed. 

Response vessels also deploy buoys with transmitters. Both systems are capable of real-time tracking of 

the leading edge of the oil. The tracking buoys are equipped with a transmitter that can be monitored by a 

receiver located either on a boat or aircraft. Oil location information is digitized and transferred to the IMT 

for response planning and trajectory modeling. 

In the event of a spill, trajectory models will be based on observed and modeled currents, wind speed, 

and direction. Vector addition and trajectory modeling are used to forecast oil movement. 

1.6.5 Protection of Sensitive Areas [18 AAC 75.425(e)(1)(F)(v)] 

The NOAA Environmental Sensitivity Index (ESI) Maps, ACS Technical Manual: Volume 2, Map Atlas

(ACS Map Atlas), and the North Slope Subarea Contingency Plan are used to identify areas of major 

concern. Using these map resources, as well as field observations, environmental conditions, spill 

trajectory and other data, a shoreline cleanup plan is prepared for approval by the UC. The ACS Map 

Atlas Sheet Index is included in Figure 1.6-1. 

Priority protection sites are identified by the Environmental Unit (EU) based upon oil tracking and 

trajectory predictions and in consultation with resource agencies and trustees. Priority sites are provided 

protection with exclusion or deflection booming when little or no ice is present. If drifting ice is present, 

and the use of booms is not practical, the oil that collects naturally among the ice will be monitored. 

Recovery efforts for these natural collection sites include the use of small skimming systems, using 

shallow-draft boats. Accumulations may also present an opportunity for limited burns at or near the shore. 

In the case where landfast ice conditions are present, sensitive shoreline resources may be afforded 

protection by the natural ice barrier. 

As OSR progresses, priorities for protection may change based on weather, sea state, oil condition, hours 

of daylight, and other factors. A new Shoreline Cleanup Plan will be developed and submitted to the UC. 

Oil and oiled ice will be monitored throughout the spill and for as long as oil is believed to be present. 

Should oil persist near the shoreline, after winter recovery operations are complete, these areas will be 

marked and monitored as the ice begins to melt during breakup. Cleanup teams, and shoreline and 

environmental specialists will use the monitoring data to plan and implement removal (and possibly, 

combustion) tactics within those regions with oil. 

1.6.6 Containment and Control Strategies [18 AAC 75.425(e)(1)(F)(vi)] 

Containment and control strategies are discussed in the scenarios, the ACS Technical Manual and Shell 

Beaufort and Chukchi Seas Regional Tactics Manual.

The OSRV will be staged within 10 n mi of the Shell drillship and is outfitted with sufficient work boats, 

boom, skimmers, and other necessary response equipment to respond to an uncontrolled well release. A 

second vessel, an anchor handler or similar vessel staged with the drillship and outfitted with skimming 

equipment, would be mobilized to serve as a VOSS for recovery operations. Specific tactics are 
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described in the scenario in Section 1.6.13. See Shell Beaufort and Chukchi Seas Regional Tactics 

Manual for details of the resources and deployment configuration for specific tactics.

In the unlikely event of a blowout, ACS will lead the containment and control efforts in the nearshore and 

shoreline environments and has the capability to mount an effective, timely response for oil containment 

and recovery operations. The OSRB would be mobilized as quickly as possible upon notification of a 

blowout and arrive into the Chukchi Sea nearshore zone within four days to provide nearshore 

containment and recovery operations. Based upon the blowout’s distance from shore and measured 

wind and current data, stochastic spill modeling predicts that oil would not contact the shoreline in less 

than six days, even if no containment and recovery operations were conducted. Nearshore and shoreline 

operations will utilize equipment and personnel on the OSRB and additional resources mobilized by ACS 

as identified in the Shell Beaufort and Chukchi Seas Regional Tactics Manual and the ACS Technical 

Manual.

The Shoreline Protection Task Forces would mobilize to deploy exclusion booms at protection sites if 

needed as identified through aerial surveillance activities and trajectory analyses. These sites are 

prioritized and boomed in order of proximity to the spill. Shoreline Protection Task Forces, involving free 

oil recovery, shoreline protection, and shoreline containment and recovery are mobilized well in advance 

of any oil that escapes the offshore operations. ACS would lead and provide ACRT and VRT personnel 

and equipment for the primary onshore response operations as needed. See the ACS Technical Manual 

and Shell Beaufort and Chukchi Seas Regional Tactics Manual for details of the resources and 

deployment configuration for specific shoreline tactics. 

Scenario 1, Subsea Well Blowout in Summer (August 7 to September 6) in Section 1.6.13 addresses 

Shell’s containment and control strategies to respond to a blowout during conditions likely to be 

encountered during the drilling season. An OSRV with 12,000 bbl (11,400 bbl at 95 percent capacity) of 

storage for recovered liquids staged near the Shell drillship would be used to initiate response operations. 

This OSRV is outfitted to deploy boom, high capacity skimmers, and work boats for encountering and 

recovering oil surfacing from an uncontrolled well blowout. The OSRV works to assist with containment, 

perform skimming operations, and lighter fluids to the OST. The VOSS would possess sufficient 

skimming capability and liquid storage capacity (minimum of 3,200 bbl) to maintain recovery operations 

during periods when the OSRV engages in lightering operations with the OST (up to eight hr). Specific 

tactics are described in Scenario 1 and the Shell Beaufort and Chukchi Seas Regional Tactics Manual 

and ACS Technical Manual. 

As described in Response Strategy 1, Subsea Blowout in Varying Ice Conditions, in Section 1.6.13, 

response strategies and specific tactics will be modified to accommodate the challenges of working with a 

variety of potential ice conditions. Ice incursions may occur during the drilling season and with the onset 

of fall when cold air temperatures result in the formation of new ice (typically grease ice and the formation 

of thin continuous layers of ice). Any continuous layers of ice, and even low concentrations of individual 

ice cakes or floes (such as 1/10 to 2/10 concentrations), can obstruct containment or deflection boom, 

prevent oil from accumulating in large pools, and block the flow of oil toward a recovery device. As these 

conditions develop, the efficiency of physical containment and recovery tactics will be reduced. If ice 

concentrations threaten the structural integrity of equipment or prevent oil from being deflected or 

effectively contained, the offshore response teams will use shorter outrigger/boom extensions in 

conjunction with skimmers in order to maneuver around large ice cakes while attempting to access 

smaller pockets of oil. As ice concentrations increase and mechanical recovery operations efficiencies 

are reduced, alternative response technologies including in situ burning and dispersant application will 

augment response operations when feasible and permitted. 
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As ice conditions persist, the ice-class vessels may use ice management techniques to create open leads 

until late in the season. The vessels would deploy rope mop skimmers and other over-the-side skimmers 

to access oil trapped next to or within heavier ice concentrations, until the conditions threaten the safety 

of personnel and/or the effective use of vessels. At this point, all physical removal tactics will cease, and 

cleanup operations will turn to the elimination of oil pockets through the use of controlled burning and 

dispersant application, as practical. Shell Tactics OR-7 through OR-9B and ACS Tactics B-3 through B-7 

would be considered for oil on water and solid surface burning or discrete application of dispersant. In 

situ burn tactics would be modified as appropriate for the controlled burning of oil herded against large ice 

floes, trapped within heavy concentrations of ice, accumulated in thick layers against shorelines or 

landfast ice. When the presence of ice precludes the use of a vessel for mechanical recovery operations, 

tactics for application of dispersant may be modified to extend the window for dispersant use and provide 

for additional mixing energy using the vessel’s drives to enhance the dispersion process. In some cases, 

the energy induced from moving ice floes may also provide the energy needed to stimulate dispersion of 

oil. Burning can be accomplished with the use of heli-torches. Visual monitoring of the effectiveness of 

these techniques will be conducted. 

At the blowout site, the potential for oil elimination using combustion may continue into periods of light to 

moderate ice concentrations (including new, solid ice layers) as the oil and gas released from the blowout 

lift and crack ice layers and leave oil exposed on or between ice cakes/floes. A heli-torch can be flown, 

day or night, and used to ignite the oil and vapors directly over the blowout. During early freezeup, icemanagement vessels upstream of the blowout can enhance the efficiency of this operation by keeping 

large ice floes from moving in over the surfacing oil and gas where they could potentially extinguish the 

flames. These vessels or barges may also be positioned at a safe distance upstream of the blowout to 

deflect ice and create a temporary, relatively ice-free path and potentially enhancing the combustion 

process. Oil that escapes the burn at the surfacing plume will likely be herded by wind to one side or the 

other of the cleared path, allowing oil to accumulate for additional burning downstream. 

Any oil that avoids containment, recovery, and/or combustion during freezeup conditions would soon be 

encapsulated under a stable ice cover as new ice forms around and beneath the oil. The encapsulation 

process prevents oil from coming into contact with wildlife. Depending on the concentration of the oil and 

the thickness of ice and snow, the monitoring of oiled ice could include the use of various commercially 

available options such as Shell Global Solutions Light Touch system (developed for methane detection 

from oil in or under ice), the use of Ground Penetrating Radar (showing great promise in recent tests by 

MMS, Statoil AS, and ACS), and the use of laser fluorosensors (showing considerable potential for 

detecting and mapping oil). 

Shell, its Alaska and International Response Teams and its contracted support from ACS, are prepared to 

conduct extensive monitoring and tracking of any oil that is released to the Chukchi Sea. Such tracking of 

oiled ice may involve the release of Metocean buoys and Arctic drift buoys with extended transmission 

capabilities, to be released at or near the spill source. Other markers may involve passive systems such 

as radar reflectors and brightly colored floats and flags. Together with daily weather recordings, satellite 

images and ice-movement modeling activities, the continued release and tracking of buoys will enable 

oceanographers and surveillance specialists to monitor changes in the location, speed and direction of 

oiled ice. While the nature and location of stable, landfast ice can vary substantially from year to year, the 

seasonal pack ice zone, although mobile, may experience periods of little or no ice motion. During these 

periods oiled ice would remain relatively close to the spill source and be easier to track. 

Proven techniques for the removal (or mining) of oil from within or below landfast ice may be feasible 

where it is safe to access and work on a stable ice layer. Under other ice conditions, particularly with new 
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ice and in moving broken ice, it will be impractical and unsafe to work from on the ice surface of the oiled 

zone because of its movement and extensive ridging and rafting of the ice. 

As longer periods of light occur and the ice begins to melt and weaken, the heavier deposits of oil 

contained beneath and within the ice will begin to move through brine channels and accumulate in melt 

pools at the surface. These pools will be easy to detect, they will contain oil that is nearly as fresh as 

when the pools were encapsulated, and they will likely remain concentrated enough to support 

combustion. Any oil released as fine droplets and widely dispersed will remain within the ice until the ice 

melts down to expose it. These droplets will eventually surface and be herded by wind into pockets of oil 

that can potentially be ignited. Aerial ignition will continue well into the breakup period, as conditions for 

combustion allow, until it is safe to operate small skimmers in and around ice cakes and floes. As the ice 

rots and breaks into smaller pieces, regions of open water will appear, allowing larger containment and 

recovery operations to begin. Every opportunity will be used to contain and recover oil and burn residue 

before it can reach shorelines and other sensitive habitats. 

1.6.7 Recovery Strategies [18 AAC 75.425(e)(1)(F)(vii)] 

Recovery strategies are discussed in the scenarios and Shell Beaufort and Chukchi Seas Regional 

Tactics Manual and the ACS Technical Manual.

Because of safety concerns, operations will be restricted or limited to appropriate distances from the 

blowout source. This statement does not indicate or imply a complete prohibition of activities such as 

containment and recovery close to the blowout. Personnel safety is Shell’s primary concern. The 

On-scene Safety Officer provides access zone information and determines personal protective equipment 

(PPE) requirements. Access to the blowout site is carefully controlled. Monitoring protocol is established 

by the On-scene Safety Officer to ensure personnel protection. Should a subsea blowout result in the 

release of large quantities of free gas and volatiles from the evaporation of surfacing oil, a rapid 

assessment will be made of deliberate ignition of those vapors. If authorized by the UC, such deliberate 

and controlled ignition will reduce the risks of an accidental ignition and the potential exposure of 

personnel and vessels downwind. 

Primary response is provided by equipment stationed in the vicinity of the drillship. This equipment 

includes a dedicated on-site OSRV with a 12,000 bbl storage capacity (11,400 bbl at 95 percent 

capacity), two (2) brush skimmers; one (1) Transrec skimmer, three (3) 34-ft work boats; and open-ocean 

containment boom and fire boom. The VOSS is equipped with sufficient equipment and storage capacity 

to relieve the OSRV for its transit and offload to the OST. Ten (10) knots is a realistic average transit 

speed for planning purposes for each of these response vessels, the OSRV, the VOSS, and the OST. 

Transiting at this speed, the OSRV would be positioned to arrive at the spill site within one hr (i.e., would 

be positioned within 10 n mi of the drillship). The VOSS will also be within 25 n mi of the drill ship and 

available to relieve the OSRV at hour 24. The OST would arrive at the recovery site within 24 hr of 

departure from its staging area off the Chukchi Sea coast. The tactics used for the positioning of oil 

recovery vessels at the blowout site are described in the scenarios. The on-scene OSRV recovers oil 

throughout Day 1. At hour 24, the OSRV suspends skimming operations and moves to the OST to lighter 

recovered oil. The OSRV is equipped with eight (8) positive displacement hydraulic screw pumps for 

lightering operations and each pump has a maximum discharge capacity of 723 bbl/hr. For planning 

purposes, it is conservatively assumed that the total transport and set-up time is about three to four hr 

before and after lightering and the offload time is approximately three to four hr. This allows the OSRV to 

complete its lightering and transit activities and return to skimming operations within eight hr. The VOSS 

and 34-ft workboats replace the OSRV to continue skimming operations and provide interim storage. 
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Following Day 1, the OSRV and VOSS would set up a consistent rotation cycle with the OSRV skimming 

for 16 hr and the VOSS for another 8 hr while the OSRV offloads. 

The time to fill the OSRV (nominal storage capacity of 11,400 bbl) is estimated by assuming that all of the 

oil released can be contained and recovered; that the oil is emulsified through the recovery and pumping 

process to 35 percent water-in-oil (using an emulsification factor of 1.54); and that an additional 20 

percent of the blowout flow rate is retained (after decanting) as free water. Based on the spill flow rate of 

5,500 bopd over 24 hrs, all fluids (emulsion and free water) will fill the OSRV at a rate of nearly 400 bbl / 

hr [64 cubic meters (cu m) / hr]. For planning purposes, the “Time-to-Fill” is based on the largest volume 

flow rate of oil/emulsion/water that could conceivably reach the skimming vessel. The anchor handler, 

Tor Viking or similar, acting as the VOSS, would be available for response operations at hour 24. 

The Arctic Class OST (minimum storage capacity of 287,100 bbl) will be located not more than 240 n mi 

from the drilling location and immediately mobilize in the event of a spill. The tanker would arrive at the 

blowout and be ready to accept recovered liquids within 24 hrs. 

For planning purposes, the scenario assumes that 10 percent of the 5,500-bopd discharge escapes the 

primary offshore recovery efforts at the blowout. This unrecovered 550 bopd is assumed to drift toward 

the mainland, driven by winds out of the west-northwest (WNW). This wind direction was used for 

planning purposes and does not correspond to the prevailing east (E), northeast (NE), and east-northeast 

(ENE) wind directions of summer months. The OSRB and tug are staged off the Chukchi Sea coast in 

the nearshore zone, as water depth, weather, sea conditions, and other circumstances allow. The OSRB 

will generally be positioned several miles offshore between Icy Cape and Peard Bay. From this location, 

it can be mobilized into the nearshore zone well ahead of the predicted timeframe that oil would reach 

shorelines for oil recovery and support of the shoreline protection task force. The OSRB would be 

dispatched as needed to intercept the oil as described in the scenario. It is assumed that half of the oil 

reaching the nearshore environment is recovered by the skimming systems dispatched from the OSRB. 

The remaining 275 bopd are assumed to migrate toward the shoreline where ACS would mobilize 

personnel and equipment to intercept the oil and deploy boom for shoreline protection. The OSRB 

possesses 18,636 bbl of fluid storage capacity for oil recovered from the nearshore operations for 30 

days. For planning purposes, 17,000 bbl is used as the nominal capacity of the OSRB for recovered 

fluids. 

Shoreline recovery operations are staffed by ACS personnel supplemented with NSSRT, ACRT, and VRT 

responders as needed. Shoreline protection and recovery task forces set up and maintain multiple teams 

along the shoreline to recover oil. For planning purposes, each task force maintains a minimum of six 

teams that deploy boom to intercept oil moving along the shoreline, a small skimmer, and Fast Tanks or 

bladders set up on the beach to hold the recovered liquids or oily waste and debris. The shoreline 

response teams have access to numerous storage containers (e.g., Fast Tanks) for oily waste storage 

along the shoreline. Additional temporary storage will be provided as needed using lined pits, drums, 

bladders and other storage containers flown in by helicopter or transported to the areas of need with 

landing craft. Authorization would be sought for the burning of oily solids (wood, vegetation and other 

combustible materials) at approved onshore burn sites after a careful assessment of the risks and 

benefits of various controlled burns. 
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1.6.8 Lightering, Transfer, and Storage of Oil from Tanks [18 AAC 75.425(e)(1)(F)(viii)] 

Lightering, transfer, and storage of oil from tanks are discussed in the Shell Beaufort and Chukchi Seas 

Regional Tactics Manual. 

Liquids from the nearshore skimmer vessels are stored in mini-barges. Liquids and oily waste and debris 

recovered by the shoreline recovery task forces are stored in Fast Tanks or bladder tanks. Decanting 

follows UC plan approval. Stored liquids on mini-barges are off-loaded to the OSRB for transfer to the 

OST. 

Heavy oil transfer pumps will be used to pump product from the mini-barges to the OSRB. These pumps 

are modified, positive displacement pumps that are hydraulically driven and have been specially 

developed for pumping extremely viscous product. The mini-barges are fitted with two suction lines (one 

each per tank) or the pumps can be submerged in the product via hold access hatches. 

Recovered liquids received by the OSRV/VOSS/OSRB will be retained onboard until transferred to the 

OST (refer to Section 1.6.9 below). 

1.6.9 Transfer and Storage Procedures [18 AAC 75.425(e)(1)(F)(ix)] 

Transfer and storage procedures are discussed in the Shell Beaufort and Chukchi Seas Regional Tactics 

Manual, Tactics OR-3A and OR-6.

Oil transfer from the OSRV/OSRB will be via permanently installed, hydraulically driven GT-A heavy oil 

transfer pumps. Each of the tanks on the OSRV is fitted with a discharge pump capable of a throughput 

rate of approximately 723 bbl/hr [115 cu m/hr]. The combined pumping capacity of the 8 pumps in each 

of the tanks onboard the OSRV is approximately 5,784 bbl/hr (920 cu m/hr). From the OSRV, recovered 

oil will be transferred from the manifold on the OSRV to the storage tanker. 

As the OSRV nears capacity, the recovered oily liquids are transferred to the OST. Stored liquids are 

gauged and manifested. 

1.6.10 Temporary Storage and Disposal [18 AAC 75.425(e)(1)(F)(x)] 

Temporary storage of oil, oily waste, and debris recovered during a spill clean up may be provided by 

tanks located on the OSRV/VOSS/OSRB. The spill location or other logistical concerns may also require 

storage of oil, oily waste, and debris in smaller, more portable containers that can be brought to the scene 

via helicopter, or small boats and mini-barges. 

Non-liquid oily wastes are classified and disposed of according to classification. Non-oily wastes are 

classified and disposed of accordingly.

At the time of the spill, the Operations Section Chief and Environment Unit Leader will jointly determine 

the reuse, recycling, or disposal method best suited to the state of the oil, the degree of contamination, 

and the logistics involved in these operations. Application for agency approvals are completed before the 

determined method of disposal is implemented. 

Disposal and processing of recovered fluids transported to Prudhoe Bay will be in accordance with ACS

Technical Manual disposal tactics D1 through D5. In the event they are taken to Prudhoe Bay, recovered 

fluids would be handled in accordance with Ballot Agreements. 
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Recovered fluids stored onboard the OST will be disposed of either at Shell Group refineries or other 

third-party processors, in accordance with Shell environmental policy, and relevant local laws and 

regulations. 

Shell’s waste management procedures are further described in Appendix D, Oil and Debris Disposal 

Procedures. 

1.6.11 Wildlife Protection [18 AAC 75.425(e)(1)(F)(xi)] 

Wildlife protection strategies are discussed in the ACS Technical Manual, Volume 1, and Tactics W-1 

through W-6. The primary objective is to protect wildlife by preventing birds and mammals from entering 

spill or containment areas. Containment areas will be monitored until USFWS and/or ADF&G determine 

that monitoring is no longer required. In general, wildlife protection strategies include, but are not limited 

to: 

 Containment and controls to limit the spread of oil, and the area influenced by the spill and 

response options; 

 Divert oil from most sensitive areas; 

 The drillship will have at least one on-duty marine mammal observer (MMO) onboard at all times, 

which is considered Best Available Technology (BAT) for wildlife monitoring; 

 Hazing of birds and mammals; 

 Capture and relocation of wildlife in direct threat; and 

 Aircraft monitoring. 

For more information, refer to Appendix E, “Wildlife Capture, Treatment and Release Programs, Chukchi 

Sea Oil Spill Response Planning.” 

Bear awareness training will be provided to all operations staff. Trained and certified bear guards will be 

deployed to support activities at risk of an encounter with polar bears. In the event of an accidental 

release that may impact shoreline resources, additional certified bear guards and security staff would be 

deployed to protect workers and polar bears. USFWS staff may also be deployed to provide additional 

oversight and consultation in the event of a major response. During a response, hazing of polar bear or 

other marine mammals is performed under the direct supervision of the USFWS or NMFS. 

1.6.12 Shoreline Cleanup [18 AAC 75.425(e)(1)(F)(xii)] 

Nearshore and Shoreline Response Plan 

Shell has developed a nearshore and shoreline response program that incorporates dedicated response 

equipment assets and trained personnel provided by ACS. The nearshore OSRB contains a capacity of 

18,636 bbl, a number of work boats, skimmers, mini-barges, and booms for nearshore recovery 

operations. In addition, work boats, and shoreline protection systems will be pre-staged in Wainwright for 

rapid deployment of resources to implement protection strategies and tactics. The response action time 

frame for pre-staged shoreline protection resources is estimated to be 12 hr, which includes mobilization 

(4 hr), transit (5 hr) and deployment (3 hr) times. Task Forces have been established to handle free oil 

recovery operations, shoreline protection booming, and shoreline recovery and cleanup activities. 

Personnel from ACS, supplemented with backup response teams from the NSSRT, ACRT, and VRTs, 

can be mobilized on short notice to deal with oil in the unlikely event that it could threaten any of the 

nearshore and shoreline environments along the Chukchi Sea. 
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Tactics in the shallow coastal and nearshore environments of the Chukchi Sea are best carried out using 

relatively small response boats. ACS can mobilize numerous small workboats and landing craft to 

support these operations providing for the transport of people and equipment to remote locations. These 

shallow-draft response boats are flexible platforms for conducting response activities in the changing 

conditions of the Chukchi Sea. The nearshore / shoreline response concept is to use smaller, more 

maneuverable vessels to conduct shoreline protection and cleanup operations, even in light 

concentrations of broken ice. The smaller vessels are better able to access pools of collected oil against 

an ice edge, move between ice cakes and floes, and respond more quickly to changing weather and ice 

conditions. 

Once mobilized to the Chukchi nearshore, the OSRB provides a safe haven for personnel and vessels in 

the event of bad weather. The OSRB is capable of storing recovered oil/emulsion and debris and serves 

as a mobile staging platform for nearshore and shoreline protection operations along the Chukchi Sea 

coast. The OSRB platform, the equipment staged onshore, and supplemented with cascading resources 

from ACS that includes equipment and responders (ACS and ACRT), provides a flexible yet rapid 

response capability should a spill occur in the Chukchi Sea. 

Experience has shown that small response boats, working with shallow-draft mini-barges (249-bbl 

capacity) are ideal for easy maneuvering in thin ice and around ice cakes. Another advantage of the minibarges is that on their return from lightering their contents at the OSRB, they can be used as cargo 

platforms to carry equipment and supplies for the ongoing nearshore and shoreline operations. 

Evaluations have been made of the likely spill trajectories that could result for a number of hypothetical 

spills from Shell’s offshore operations. The oil spread and transport calculations suggest that shoreline 

exposures are unlikely and, if occurring, would not normally involve more than a few high-priorityprotection sites at a time, and that even under infrequent, prolonged strong winds from the WNW and W, 

it would likely take several days for any oil to reach the mainland from the drill site located within the lease 

blocks. Using prevailing wind and sea conditions, including results from the MMS’ Final Environmental 

Impact Statement (FEIS) for Oil and Gas Lease Sale 193 and wind data collected by Shell during the 

years (1980, 1982, and 1983) of working in the Chukchi Sea, trajectory analyses suggest that it is highly 

unlikely that oil could impact the nearshore environment in less than six days. Even if oil did survive that 

long in the open ocean, there would be ample time to monitor its movement, prepare to intercept and 

recover it, and to position shoreline protection and cleanup crews at priority protection sites well before 

the oil may arrive. 

Potential shoreline cleanup tactics, employed in the unlikely event a spill reaches the Chukchi shoreline, 

are described in the ACS Technical Manual, Tactics SH-1 through SH-12. Additional tactics planned for 

nearshore and shoreline response (Tactics: SR-1 through SR-10) are described and illustrated in the 

Shell Beaufort and Chukchi Seas Regional Tactics Manual. Provided at the end of this section, Figures 

1.6-2 through 1.6-7 illustrate possible variations on these tactics because of the broad range of shoreline, 

weather, and ice conditions that could exist during the drilling season. 

Priority Protection Sites 

In addition to the consideration of appropriate shoreline tactics and equipment, an assessment has been 

conducted of the Chukchi Sea shoreline from Point Barrow to Cape Lisburne to identify priority protection 

sites. The assessment included identification of control sites where defensive measures such as 

exclusion or protection tactics would most effectively protect valuable resources. Maps identified in Table 

1.6-1, Figure 1.6-1, and the ACS Map Atlas, present the priority protection control sites. 
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The coastal area assessments consider the following factors: 

 The potential for oil impact, and the nature and magnitude of possible oil retention (substrate, 

grain size, beach slope, and wave and tidal energy); 

 The sensitivity of biological and human use/cultural resources at risk; 

 The type and amount of resources (personnel, boats, skimmers, and booms) required for 

shoreline protection and cleanup; and 

 The weather and environmental conditions (prevailing and extreme events) that would most 

influence the performance of personnel and equipment. 

An important step in this assessment process is the ranking of shoreline sensitivity. Ranking involves a 

careful evaluation of the relationships between physical processes, the nature and amount of oil that 

could reach a given shoreline, the shoreline type and substrate, oil fate and effects, and sedimenttransport patterns. The intensity of energy expended on a shoreline by wave action, tidal currents (though 

small in the Chukchi Sea), and river currents directly affects the persistence of stranded oil. The need for 

shoreline cleanup activities is determined, in part, by the speed with which natural processes might 

remove oil that is stranded on the shoreline, and the prioritization of areas where natural forces are 

relatively weak or absent (e.g., tidal flats and marshes). All of these processes and oil/shoreline 

interactions are used in the development and use of ESI values. 

One of the best sources of environmental sensitivity ranking for the region of interest is the Sensitivity of 

Coastal Environments and Wildlife to Spilled Oil, North Slope, Alaska, Atlas (North Slope Atlas), 

supported by NOAA, Oil Spill Recovery Institute in Cordova, Alaska, CHADUX Corporation, ACS, and the 

MMS. The ESI rankings reflect the fact that areas exposed to high levels of physical energy generally 

have low biological activity and rank low on a scale of 1 to 10. Sheltered areas, however, commonly have 

higher biological activity and rank the highest. The following list (extracted from the North Slope ESI) 

provides the ranking of shoreline habitats for the Chukchi Sea shoreline: 

1A Exposed Rocky Shores 

1B Exposed, Solid Man-Made Structures 

3A Fine- to Medium-Grained Sand Beaches 

3C Tundra Cliffs 

4 Coarse-Grained Sand Beaches 

5 Mixed Sand and Gravel Beaches 

6A Gravel Beaches 

6B Riprap 

7 Exposed Tidal Flats 

8A Sheltered Rocky Shores and Sheltered Scarps in Mud and Clay 

8E Peat Shorelines 

9A Sheltered Tidal Flats 

9B Sheltered, Vegetated Low Banks 

10A Salt- and Brackish-Water Marsh 

10E Inundated Low-Lying Tundra 

Wildlife at risk from exposure to spilled oil or the cleanup process is often, but not always, tied to 

shoreline sensitivities and is a critical element when considering priority protection sites. Biological 
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information about animal and plant species is also provided in the North Slope Atlas. The species are 

divided into the following groups and subgroups: 

 Birds (diving birds, gulls and terns, seabirds, shorebirds, and waterfowl); 

 Fish; 

 Marine Mammals (pinnipeds, polar bears, walruses, and whales); 

 Terrestrial Mammals (bears, caribou, and musk ox); and 

 Benthic Habitats (kelp). 

The environmental sensitivity rankings, together with information about biological resources, sea ice, and 

human-use resources provided in the North Slope Atlas, are important to the selection of areas identified 

as priority protection sites. The North Slope Sensitive Areas Work Group (NSSAWG), consisting of 

representatives from several federal, state, and local government agencies and industry organizations, 

has worked with a wide range of experts to evaluate the environmental sensitivity rankings, and identify 

specific areas along the Chukchi shoreline that should be recognized as priority protection sites. Table 

1.6-1 lists the priority protection control sites identified by the NSSAWG. 

Working closely with the NSSAWG, ACS has developed Volume 2 of their Technical Manual, the ACS 

Map Atlas, which includes a comprehensive set of shoreline maps where priority protection sites are 

identified (refer to ACS Map Atlas for priority protection control sites along the Chukchi Sea coastline). 

Shell has used the ESI rankings provided in the North Slope Atlas, along with the priority protection sites 

indicated in the ACS Map Atlas, to consider the nature and extent of resources (vessels, barges, booms, 

skimmers, response equipment, and personnel) to provide a timely and effective nearshore and shoreline 

response. 

Shell has also identified biological resources using an unpublished report by Woodward-Clyde 

Consultants (WCC), Walnut Creek, California, to NOAA Assessment Division, Anchorage, Alaska 

(Robilliard et.al. 1985, Chukchi Sea Coastal Studies: Coastal Geomorphology, Environmental Sensitivity, 

and Persistence of Spilled Oil). This report identifies key biological resources in the region of concern 

including: spotted seals, beluga whales, alcids (murres and puffins), sea birds (kittiwakes and gulls), 

waterfowl (eider, oldsquaw, and black brant) and shorebirds. Most of the shorelines of primary biological 

concern are in the Kasegaluk Lagoon portion of the coast, particularly the Icy Cape region. For example, 

black brant are key migratory birds in the Icy Cape and Peard Bay region that move north in the spring 

(June) migration, and return south in the late August to September migration. The northern portion of the 

shoreline is of lower primary concern as there are few wetlands and seabird colonies or waterfowl nesting 

areas. In the south, however, the Cape Lewis, Cape Lisburne, and Point Thompson bedrock cliffs 

support large seabird colonies. 

At this time, seven general locations have been identified as primary protection areas or coastal sites on 

the Chukchi Sea coast (refer to ACS Map Atlas Sheets 194, 195, 198, 223, 227, 228, 234 to 239, 243 −

245, 247 − 250, 253 – 255, and Table 1.6-1 for the protection control sites listed within these general 

locations). The identification of these recommended primary protection priorities is based on a 

combination of the biological resources at risk and existing human use activities. The seven areas 

include: 

 Barrow* 

 Peard Bay - Franklin Spit 

 Wainwright Inlet 
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 Icy Cape 

 Central Kasegaluk Lagoon (Kukpowruk Pass to Akunik Pass) 

 Cape Lisburne - Cape Lewis* 

 Marryat Inlet* 

Three of the seven areas listed above (shown with an asterisk *) are considered to have a low risk of oil 

impact because of the distance, time, and low likelihood for oil to make landfall and the lengthy response 

time window of opportunity. Five of these seven areas are characterized by a sheltered lagoon 

environment which is connected to the Chukchi Sea by a tidal inlet or inlets where protection tactics could 

be deployed to prevent oil entering the lagoon (Peard Bay-Franklin Spit; Wainwright Inlet; Icy Cape, 

Central Kasegaluk Lagoon; and Marryat Inlet). 

Two coastal locations (Barrow and Cape Lisburne-Cape Lewis) are open coast environments where the 

resources at risk are at sea in the adjacent nearshore environment, rather than in lagoon environments. 

In the case of Barrow, the community lives at the shoreline. A distinction is made between the five 

primary protection strategic coastal areas, which cover relatively large geographic area and for which a 

regional scale response strategy would be required, and two site specific primary protection shoreline 

locations (Wainwright Inlet and Marryat Inlet) for which a single inlet protection strategy would be 

appropriate. 

In addition, four recommended site-specific secondary areas have been identified. The identification of 

these recommended secondary protection priorities is also based on a combination of the biological 

resources at risk and human use activities. These are considered secondary priorities as the areas at risk 

are small in area compared to the recommended primary protection priorities. They include: 

 Will Rogers Memorial 

 Sinaruruk River 

 Pitemegea River * 

 Ayugatak Creek * 

The asterisk (*) indicates that two of these four locations are considered to have a low risk of oil impact 

because of the distance and time for oil to make landfall and the lengthy response time window of 

opportunity. All four areas have a single tidal inlet or river entrance where protection tactics could be 

deployed to prevent oil entering the river or estuary. 

Other potential protection locations exist including possible lagoon tidal inlets or open river mouths. 

Evolving marine mammal use is also an important consideration when selecting sites for protection. For 

example, the distribution and habitat use by Pacific walruses varies year by year, as it is closely 

associated with presence or absence of pack ice in the nearshore areas. Walruses tend to use pack ice 

for the haulouts, except for the cases when the pack ice retreats too far offshore, in which case they use 

beaches as haulout locations. Walruses may arrive at beach haulouts in late August and leave in the 

beginning of October. In 2007, large numbers of walruses were observed between Barrow and Point 

Hope with particularly dense concentrations on the beaches between Point Lay and Wainwright. In the 

event of a spill and the low likelihood of it reaching shore, a decision on which protection tactic would be 

necessary and appropriate would have to be evaluated in consultation with federal and state resource 

trustees and agencies. 
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TABLE 1.6-1 

SHORELINE PROTECTION ASSESSMENT FOR POINT BARROW TO CAPE LISBURNE 

PRIORITY 

PROTECTION 

SITES 

ACS MAP 

REFERENCE LATITUDE LONGITUDE TACTICS (SHELL / ACS) 

PPS-168 255 70o 49' 53.185" N 158o 1' 39.197" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-169 255 70o 49 13.442" N 158o 9' 37.538" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPA-6 254 70o 53' 42.218" N 158o 37' 30.199" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-170 254 70o 47' 8.256" N 158o 46' 27.046" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-171 254 70o 49' 0.019" N 159o 5' 18.898" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-172 253 70o 48' 37.548" N 159o 34’ 13.815" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-173 253 70o 47' 38.500" N 159o 38' 39.616" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-174 251 70o 41' 41.453" N 159o 54' 18.290" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-175 250 70o 36' 23.573" N 160o 6' 28.296" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-176 250 70o 33' 45.189" N 160o 12' 35.011" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-177 250 70° 32' 26.343" N 160° 15' 55.944" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-178 250 70° 32' 4.490" N 160° 16' 37.355" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-179 250 70° 30' 50.004" N 160° 20' 1.004" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-180 247 70° 26' 25.354" N 160° 33' 39.330" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-181 245 70o 22' 22.289" N 160o 48' 53.117" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-182 245 70o 19' 43.550" N 161o 4' 14.960" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-183 244 70o 17' 35.105" N 161o 17' 40.446" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-184 243 70o 18' 2.618" N 161o 57' 2.174" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-185 243 70o 15' 48.348" N 162o 5' 6.019" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-186 240 70o 5' 3.034" N 162o 30' 33.825" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-187 239 69o 53' 57.607" N 162o 49' 46.298" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-188 238 69o 45' 44.075" N 162o 57' 54.774" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-189 237 69o 44' 47.162" N 163o 3' 39.277" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-190 237 69o 40' 22.579" N 163o 6' 2.442" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 
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TABLE 1.6-1 

SHORELINE PROTECTION ASSESSMENT FOR POINT BARROW TO CAPE LISBURNE 

PRIORITY 

PROTECTION 

SITES 

ACS MAP 

REFERENCE LATITUDE LONGITUDE TACTICS (SHELL / ACS) 

PPS-191 235 69o 27' 23.872" N 163o 8' 26.842" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-192 235 69o 24' 53.101" N 163o 8' 23.636" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-193 233 69o 15' 17.732" N 163o 19' 39.914" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-194 233 69o 14' 8.612" N 163o 21' 28.840" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-195 233 69o 12' 3.518" N 163o 26' 15.885" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-196 232 69o 8' 22.200" N 163o 31' 47.420" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-197 230 68o 54' 51.072" N 164o 37' 17.810" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-198 229 68o 53' 29.219" N 164o 53' 44.537" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-199 228 68o 51' 38.879" N 165o 47' 27.582" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-200 223 68o 25' 10.566" N 166o 23' 36.592" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 

PPS-201 223 68o 20' 18.368" N 166o 50' 40.762" W SR-2, SR-3, or SR-4 / 

C-13 or C-14 
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FIGURE 1.6-1 

CHUKCHI SEA SHORELINE PROTECTION 

ACS MAP ATLAS SHEET INDEX 
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FIGURE 1.6-2 

SHORELINE CONTAINMENT AND PROTECTION 

FIGURE 1.6-3 

SHORELINE CONTAINMENT AND RECO

Concentration of oil at natural and/or man-made collection sites and diversion of oil away from priority protection sites. 

 Deflection of oil toward shore for recovery with 

storage of recovered oil in bladders or Fast Tanks, oil. 
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FIGURE 1.6-4 

SHORELINE CLEANUP AND BACKWATER PROTECTION 

Physical removal of oil and oiled debris from beaches. Temporary blockage of marshes and other wetland 

areas. 

FIGURE 1.6-5 

NEARSHORE DIVERSION AND RECOVERY OF OIL 

Protection of environmentally sensitive shoreline areas with recovery away from the shoreline. 
Oil Discharge Prevention and Contingency Plan Chukchi Se

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FIGURE 1.6-6 

NEARSHORE RECOVERY IN BROKEN ICE 

FIGURE 1.6-7 

NEARSHORE IGNITION OF OIL 

Recovery of oil that is wind-herded and trapped within ice cakes nearshore. Transfer of the recovered oil directly to a mini-barge. 

 Heli-torch ignition of oil that is wind-herded and tr

Burning with gelled fuel igniters released upstream the oil. 
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For planning purposes, Shell is using the priority protection sites described above between Point Barrow 

and Cape Lisburne (see Table 1.6-1 and the ACS Map Atlas) to ensure that the most environmentally 

sensitive shorelines are recognized and included in the current planning of nearshore and shoreline 

protection activities. This list was confirmed and expanded during aerial surveys conducted in 

cooperation with the NSSAWG in 2008. The ACS Technical Manual was updated accordingly. The goal is 

to designate official priority protection sites and establish tactics, equipment, and personnel requirements 

for each site. This listing will not be exclusive in the unlikely event of a spill and incident-specific 

conditions would be taken into account to maximize the use of protection strategies. 

While Shell’s highest priorities will remain the prevention of oil discharge and the safety of all personnel 

associated with the drilling program, the second highest priority will be the protection of the environment 

which will be achieved by containment, recovery, and/or elimination of as much oil as possible offshore 

before it can reach any of the sensitive resources and shorelines of the Chukchi Sea. In the unlikely event 

that a spill occurs and uncommon sustained winds direct it to shore, Shell will have planned and 

implemented protection strategies through their nearshore program and the shoreline protection program. 

1.6.13 Spill Response Scenarios 

Introduction 

The ADEC Response Scenario/MMS WCD Scenario contained herein was prepared to comply with both 

MMS regulations found in 30 CFR 254.26 for the discussion of the WCD scenario, and ADEC regulations 

found in 18 AAC 75.425(e)(1)(F) and (I) for the response scenario that demonstrates a plan holder's 

ability to respond to a discharge of the RPS volume. In order to address MMS and ADEC requirements, 

Shell is providing a scenario with a blowout duration of 30 days. 

A response strategy is provided in this plan following the Response Scenario/WCD Scenario to meet both 

the WCD scenario requirements of the MMS “in adverse weather conditions” with equipment that is 

“suitable, within the limits of current technology, for the range of environmental conditions” anticipated, 

and the ADEC requirements for a response strategy accounting for variations in receiving environments 

and seasonal conditions. The response strategy also illustrates additional spill response capabilities for 

employing an effective cleanup response using non-mechanical response options. 

This section contains the following: 

 Scenario 1, Response Scenario/WCD Scenario, Offshore Subsea Well Blowout During Summer 

Months (Tables 1.6-3 to 1.6-9) 

 Response Strategy 1, Offshore Subsea Well Blowout in Varying Ice Conditions (Table 1.6-10) 

 Response Strategy 2, Offshore Fuel Transfer Release During Summer Months (Table 1.6.11) 

The following scenarios and strategies were developed in accordance with MMS regulations in 30 CFR 

254.26; 18 AAC 75.425(e)(1)(F); and 18 AAC 75.445(d). The scenarios describe equipment, personnel, 

and strategies that could be used to respond to an oil spill. The scenarios are for illustration only and are 

not performance standards or guarantees of performance. The scenarios assume conditions of the spills 

and responses only to display general procedures, strategies, tactics, and selected operational 

capabilities. Also refer to the Shell Beaufort and Chukchi Seas Regional Tactics Manual and the ACS 

Technical Manual. 

Alternative countermeasures such as in situ burn or dispersant application could be used in a spill 

response to reduce oil impacts, regardless of whether a scenario hypothesizes that these measures help 

meet to the RPS. 
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Scenario 1 

ADEC Response Scenario 

Minerals Management Service 

Worst Case Discharge Scenario 

Subsea Well Blowout During 

Summer Months 
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SCENARIO 1 QUALIFICATION STATEMENT 

This WCD scenario was prepared to comply with both MMS regulations in 30 CFR 254.26 and ADEC 

regulations in 18 AAC 75.425. It is prepared as an illustration of the spill and response conditions that 

could be expected in the event of a WCD. The scenario makes certain assumptions about spill conditions 

and describes equipment, personnel, and strategies that would be used to respond to a WCD. 

The response timelines are provided for illustration only. Spill response decisions depend on safety 

considerations, weather, and other environmental conditions. It is the discretion of the IC and persons in 

charge of the spill response to select any sequence or take time as necessary to employ an effective 

response without jeopardizing personnel safety. In any incident, personnel safety is considered the 

highest priority. 

Depending on conditions, some equipment named in the scenario may be replaced by functionally similar 

equipment. The scenario assumes that agency permits are immediately granted by on-scene 

coordinators and other agency officials. 

Greater responses than illustrated in the scenario can be mounted with additional in-region resources and 

the mobilization of out-of-region resources if needed. 

How the Scenario Complies with the MMS Requirements 

The scenario provides a simulation of a WCD with the type of responses that could be employed, to the 

maximum extent practicable. 

Table 1.6-2 addresses how the scenario meets the MMS regulatory requirements (30 CFR 254.26) for a 

WCD. Many assumptions are made about environmental conditions, oil distribution, and response 

capabilities. References to documents that support these assumptions are provided in the table. These 

documents are publicly available at MMS and ADEC, along with the Shell Beaufort and Chukchi Seas 

Regional Tactics Manual, and ACS Technical Manual. 
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TABLE 1.6-2 

SUMMARY OF HOW THE WORST CASE DISCHARGE SCENARIO 

COMPLIES WITH MMS REGULATIONS 

MMS REGULATION SUMMARY REFERENCE 

30 CFR 254.26(a) and 254.47(b) 

WCD Volume for Exploration or 

Development Drilling Operations 

The WCD volume of oil for this regional 

exploration plan is based on the ADEC RPS 

daily volume for an exploration well blowout 

of 5,500 bopd. 

See the OPA 90 MMS cross-reference 

section at the front of this plan for a 

summary of the basis for the WCD 

estimate. The estimates follow 30 CFR 

254.47(b) regarding WCDs for 

exploration drilling operations. 

The total capacity of the oil storage tanks 

is the sum of permanent oil storage 

containers on the OST, OSRV, VOSS, 

and OSRB (Table 1.6-8). 

Because there is insufficient well test 

data to estimate the simulated blowout 

rate of the exploration well, the daily flow 

rate for a blowout is based on the ADEC 

response planning standard of 5,500 

bopd. 

30 CFR 254.26(b) 

Oil Trajectory 

The simulation of the oil plume on water is 

based on a well blowout at the sea floor (or 

mudline) in approximately 140 ft of water. 

The oil rises to the surface and spreads as a 

function of ocean currents and wind. The 

oil’s viscosity and emulsification tendency 

affects its distribution on the sea. 

The scenario simulates the oil footprint by 

trajectory modeling performed by estimating 

the prevailing winds and local ocean 

currents during a 30-day blowout. The 

modeling was performed by Applied Science 

Associates, Inc. (ASA). 

The speed and direction of wind and 

currents determine the oil trajectory on the 

sea. 

Oil is assumed to move with surface 

currents and at 3.5 percent of the wind 

speed. 

The prevailing summer winds tend to drive 

the oil trajectory offshore to the W-SW. 

Tactics TS-1, TS-2 and TS-3 from the Shell 

Beaufort and Chukchi Seas Regional 

Tactics Manual are used to track the oil 

plume on water throughout the spill 

response. 

Modeling of the oil plume migration was 

conducted by ASA using local wind data 

and ocean currents. 

Wind direction is simulated as prescribed 

by 18 AAC 75.425(e)(1). Wind direction 

and velocity data were derived from 

measurements collected by Shell in the 

Chukchi Sea from 1980, 1982, and 1983 

for the months of June through 

November. The average measured wind 

velocity in August is from the east at 

approximately 11 knots (12.6 miles per 

hour [mph]). This is consistent with 

NOAA wind data from Wainwright in 

recent years. 

30 CFR 254.26(c) 

Important Resources 

Resources of environmental or special 

economic importance that might be 

impacted are the marine bird and mammal 

populations that range in the sea offshore 

and to the shoreline and the shorelines of 

the barrier islands that lie in the oil 

trajectory. The trajectory is described in the 

body of the scenario. The resources are 

described more fully in the references. 

Resources of special economic or 

environmental importance that potentially 

could be impacted in the areas in the 

trajectory are described in Section 1.6.12, 

the ARRT’s “North Slope Subarea 

Contingency Plan,” Areas of Concern and 

from ESI maps published by NOAA. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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TABLE 1.6-2 (CONTINUED) 

SUMMARY OF HOW THE WORST CASE DISCHARGE SCENARIO 

COMPLIES WITH MMS REGULATIONS 

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MMS REGULATION SUMMARY REFERENCE 

30 CFR 254.26(d)(1) 

Response Equipment 

The scenario identifies the types, numbers, 

and usage of the equipment capable of 

containing and removing the oil. 

The equipment descriptions, locations, 

owners, inventory, quantity and 

capabilities are described in the Shell 

Beaufort and Chukchi Seas Regional 

Tactics Manual and ACS Technical 

Manual, Volume 1. 

30 CFR 254.44(a) 

Effective Daily Recovery 

Capacities 

The effective daily recovery capacities of the 

Transrec skimmers (2,516 bbl/hr or 400 cu 

m/hr) is derated to 20% of the 

manufacturer’s nameplate pump rate. 

Therefore, each Transrec skimmer would 

have an effective capacity of 0.20 X 2,516 

bbl/hr = 503 bbl/hr (80 cu m/hr). 

Lamor LSC-5 brush skimmers (1,289 bbl/hr 

or 205 cu m/hr) are determined using 20% 

of the manufacturer’s nameplate capacity. 

Each Lamor LSC-5 therefore is derated to 

258 bbl/hr (41 cu m/hr). Although each 

skimmer’s hopper is fitted with twin pumps 

rated at 723 bbl/hr (115 cu m/hr), the smaller 

value of 1,289 bbl/hr (205 cu m/hr) is used 

for planning purposes. 

Lamor LORS-2C brush skimmers (516 

bbl/hr or 82 cu m/hr) capacity is determined 

using 20% of the manufacturer’s nameplate 

capacity. Each brush skimmer is therefore 

derated to 103 bbl/hr (16 cu m/hr). 

Total daily recovery capacity is presented in 

Table 1.6-5. 

ADEC rates most skimmers at 20% of the 

manufacturer’s nameplate capacity 

unless ADEC approves another 

appropriate capacity based upon analysis 

or testing, and assumes an oil 

emulsification factor of 1.54. 

The MMS recovery capacity is based 

upon the manufacturer's rated throughput 

capacity over a 24-hr period multiplied by 

20%, corresponding to ADEC 

regulations. (See Table 1.6-5). 

Efficiency rates for offshore recovery 

equipment are listed in the Shell Beaufort 

and Chukchi Seas Regional Tactics 

Manual. 

30 CFR 254.44(b) 

Other Efficiency Factors 

A smaller skimmer, the duplex minibrush/disc, is derated to 10% of the effective 

nameplate capacity of the pumps. The 

resulting derated oil recovery rate is 10 

bbl/hr (1.6 cu m/hr) per skimmer. 

96 bbl/hr x 0.10 = 10 bbl/hr (per skimmer) 

The effective manufacturer’s nameplate 

pumping capacity of the other skimmers 

utilized are listed in the Shell Beaufort and 

Chukchi Seas Regional Tactics Manual and 

ACS Technical Manual. 

For other pump rates, see the Shell 

Beaufort and Chukchi Seas Regional 

Tactics Manual, Tactic LE-3, and ACS 

Technical Manual, Tactic L-6, for other 

pump rates. 
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TABLE 1.6-2 (CONTINUED) 

SUMMARY OF HOW THE WORST CASE DISCHARGE SCENARIO 

COMPLIES WITH MMS REGULATIONS 

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MMS REGULATION SUMMARY REFERENCE 

30 CFR 254.26(d)(2) 

Deployment and Operation 

The deployment of field personnel, vessels, 

and supplies needed to operate the oil 

removal and storage equipment are 

described in Tables 1.6-4 through 1.6-9 of 

the scenario. 

An OSRV is assigned to the drillship 

during critical drilling operations. A 

description of the OSRV, the VOSS, and 

the associated OSR equipment, vessels, 

and supplies contained on the vessel is 

described in Section 3.6. 

Equipment lists, locations, and owners of 

the equipment, as well as key OSR 

staffing, are described in the Shell 

Beaufort and Chukchi Seas Regional 

Tactics Manual and the ACS Technical 

Manual, Volume 1. 

30 CFR 254.26(d)(3) 

Oil Storage, Transfer, and 

Disposal 

The oil storage, transfer equipment, and 

disposal options, including barges, minibarges, and Fast Tanks, and transport to oil 

processing facilities, are described in the 

scenario. 

The types, locations, quantity, and 

capacity of the scenario’s equipment are 

described in the Shell Beaufort and 

Chukchi Seas Regional Tactics Manual, 

the ACS Technical Manual, Volume 1, 

and Section 1.6.10, Temporary Storage 

and Disposal. 

30 CFR 254.26(d)(4)(i) 

Time for Procurement of Oil 

Containment, Recovery, and 

Storage Equipment 

Time for procurement, mobilization, and 

transit time is reflected in the scenario. 

Mobilization and deployment time for 

offshore response equipment is specified 

in Tables 1.6-4 and 1.6-5. Nearshore and 

shoreline response equipment 

mobilization from ACS is specified in 

equipment tables in the Shell Beaufort 

and Chukchi Seas Regional Tactics 

Manual and ACS Technical Manual

tactics that the scenario incorporates by 

reference. In addition, Shell has the 

capability to mobilize out-of-area 

resources within 72 hrs if needed. See 

Shell Tactic LE-3 and ACS Tactics L-8, 

L-9, and L-10. 

30 CFR 254.26(d)(4)(iii) 

Time for Procurement of 

Personnel 

Procurement, mobilization, and transit time 

for personnel is reflected in the scenario. 

Mobilization time for staff operating 

vessels and other equipment contained 

on the OSRV and VOSS are reflected in 

the scenario. Mobilization time for other 

oil spill staff is specified in the Shell 

Beaufort and Chukchi Seas Regional 

Tactics Manual and the ACS Technical 

Manual. Equipment operators and crews 

mobilize with their equipment from North 

Slope of Alaska and outside Alaska 

through ACS contracts and Mutual Aid 

Agreements; see Shell Tactics LE-3 and 

ACS Tactics L-8, L-9, and L-10 for 

master agreements and other 

agreements for accessing equipment. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-2 (CONTINUED) 

SUMMARY OF HOW THE WORST CASE DISCHARGE SCENARIO 

COMPLIES WITH MMS REGULATIONS 

Shell 1-49 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

MMS REGULATION SUMMARY REFERENCE 

30 CFR 254.26(d)(4)(iv) 

Equipment Loadout Time 

Initial response vessels and equipment are 

contained on the OSRV. An OSRV and 

VOSS are assigned to a regional area in 

which the drillship is conducting drilling into 

liquid hydrocarbon-bearing zones and the 

loadout times are reflected in the scenario. 

The loadout times for nearshore and 

shoreline response equipment are included 

in the mobilization times listed in the Shell 

Beaufort and Chukchi Seas Regional 

Tactics Manual equipment tables and the 

ACS Technical Manual and are incorporated 

here by reference. 

Equipment loadout time is included in the 

mobilization times specified for 

equipment and vessels listed in the Shell 

Beaufort and Chukchi Seas Regional 

Tactics Manual tactics and the ACS 

Technical Manual tactics that the 

scenario incorporates by reference. 

30 CFR 254.26(d)(4)(v) 

Travel Time 

Times to travel to the deployment site for the 

offshore, nearshore, and shoreline tactical 

units (personnel and equipment) are 

described in the narrative of the scenario. 

Travel times to the deployment sites are 

included the WCD scenario tables (See 

Tables 1.6-4 and 1.6-5). 

30 CFR 254.26(d)(4)(vi) 

Deployment Time 

Times to deploy equipment are described in 

the scenario narrative and incorporated by 

reference to particular Shell Beaufort and 

Chukchi Seas Regional Tactics Manual and 

ACS Technical Manual tactics that list 

deployment times. 

Deployment times are specified in the 

WCD scenario tables (See Tables 1.6-4 

and 1.6-5). The Shell Beaufort and 

Chukchi Seas Regional Tactics Manual

and ACS Technical Manual contain 

tactics equipment tables that list 

equipment deployment times. 

The Shell prospects are approximately 

150 air mi from Barrow, 85 air mi from 

Wainwright and 350 air mi from 

Deadhorse. Assuming a helicopter travel 

speed of 100 mph, the estimated travel 

times would be 1.5 hr, 50 min, and 3.5 hr, 

respectively. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-2 (CONTINUED) 

SUMMARY OF HOW THE WORST CASE DISCHARGE SCENARIO 

COMPLIES WITH MMS REGULATIONS 

Shell 1-50 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

MMS REGULATION SUMMARY REFERENCE 

30 CFR 254.26(e)(1) 

Equipment and Strategies are 

Suitable for Conditions 

Response equipment illustrated in the 

scenario is designed to operate within the 

range of environmental conditions projected 

to be encountered at the exploration leases. 

The equipment available on the ice-class 

OSRV and VOSS and on the North Slope, 

and selected for the simulated deployments 

in this scenario, is the BAT for responding to 

oil well blowouts in the offshore and 

nearshore Chukchi Sea. Equipment in the 

scenario has been tested and selected as 

the most suitable for mechanical oil recovery 

in the environmental conditions associated 

with the Chukchi Sea regional exploration 

plan. 

Response strategies illustrated in the 

scenario are also suitable, within the limits of 

current technology, for the range of 

environmental conditions anticipated. The 

strategy of mechanical recovery illustrated in 

the scenario reflects best available 

technology for the environmental conditions. 

The strategy has been tested, exercised, 

and selected as most suitable for the 

conditions. 

See the following information and 

manuals that describe the equipment and 

strategies most suitable to this scenario: 

 Response plans, in Section 1.6 of 

this C-Plan, 

 Shell Beaufort and Chukchi Seas 

Regional Tactics Manual, and 

 ACS Technical Manual, Volumes 1 

and 2 

30 CFR 254.26(e)(2) 

Standard Terms for Conditions 

and Equipment Capabilities 

The scenario employs standardized, terms 

to define environmental conditions and 

response equipment. The terms in the 

scenarios are consistent with terms used in 

spill response planning in general and for 

North Slope responses in particular. 

For definitions of terms, see the following 

documents: 

 Shell Beaufort and Chukchi Seas 

Regional Tactics Manual, and 

 ACS Technical Manual, Volumes 1 

and 2 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-51 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

Simulated Weather and Sea Conditions at Spill Scene 

On August 7, the sea is ice-free at the drilling location with daylight lasting 24 hrs/day and decreasing to 

15 hrs/day by September 6. The average daily maximum and minimum air temperatures are 46°F and 

34°F. The average wind speed is 12 to 13 mph or 10 to 11 knots. 

Characteristics of the Simulated Discharged Oil [30 CFR 254.26(a)] 

Oil reaches the surface from the exploration well several hrs after a kick is detected. Oil flows at the rate 

of 5,500 bopd. Gas and oil reach the sea floor through a 6-inch inside diameter (ID) orifice at the mudline. 

Gas releases at an estimated rate ranging from 1.4 to 4.1 million standard cubic feet per day (mmscf/d). 

The blowout discharges a total of 165,000 bbl of crude oil over 30 days. 

For the purposes of the C-Plan, Alaska North Slope (ANS) crude oil is used because it is representative 

medium weight oil (25 to 30° American Petroleum Institute [API]). The following properties are derived 

from an ANS sample collected from the Trans-Alaska Pipeline System’s Pump Station 1: 

API gravity (15 degrees 

Centigrade [°C]): 

30.6 

Viscosity (15°C): 16 CentiStokes (cSt) 

Maximum water content in 

oil/water emulsion (weight %): 

70 

Asphaltene content (weight %): 5 

Pour point (°C): 

Flash point (°C): 

-55 

-19 

Aerial Deposition 

The well blowout occurs at the mudline and the crude oil migrates to the water surface. No aerial 

deposition occurs (other than vapor release.) 

Oil Spill Trajectory [30 CFR 254.26(b)] 

August 7 through September 6 

Oil on the water is assumed to move as the sum of vectors: surface currents plus 3.5 percent of the wind 

speed in the downwind direction. Oil plume migration is driven by ocean currents and prevailing winds for 

the 30-day duration of this scenario. The ocean current data used for trajectory modeling was based upon 

the MMS annual means analysis of Haidvogel, Hedstrom, and Francis (2001) coupled ice-ocean model. 

Wind data used for the trajectory modeling were collected by Shell from 22 locations in the Chukchi Sea 

during June through November for the years 1980, 1982, and 1983. Data from these three years were 

used for stochastic modeling. Wind data for the period of August 7 to September 6 were used for the 

trajectory modeling presented in Figure 1.6-8. 

Based upon the collected data, the offshore winds originated from the NE to southwest (SW) 54 percent 

of the time and the northwest (NW) to SW 23 percent of the time during the June through November 

period. Three predominant wind directions had a measured frequency of occurrence greater than 10 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-52 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

percent of the time originating from the NE, ENE and E based upon the 16 cardinal compass directions. 

These three wind directions on average occurred at the following frequencies for the June through 

November period: 

 ENE wind = 14.6% frequency 

 NE wind = 13.8% frequency 

 E wind = 13.0% frequency 

The ASA trajectory simulation uses a subsea blowout rising through the water column and surfacing 

above the well location. The trajectory simulation moves and spreads the oil under the influence of local 

winds measured at the closest station for the August 7 to September 6 time period and the MMS oceancurrent information. 

The trajectory shows the oil plume moving into open ocean away from shorelines in a southwesterly 

direction (Figure 1.6-8). From Day 1 through Day 3, the oil movement is directed by winds predominantly 

from the NE and the predicted current. Through Day 12, the oil movement is away from land into the 

open ocean. If not intercepted by containment and recovery operations, oil is predicted to begin drifting to 

the north-northeast (NNE) and toward shorelines by Day 14. The earliest oil is predicted to possibly 

contact shorelines is Day 25 in the area between Peard Bay and Kasegaluk Lagoon. Following Day 25, 

unrecovered oil would continue drifting to the NE, offshore and north of land. However, for planning 

response mobilization, the response scenario assumes oil could intercept the shoreline in no less than six 

days in the event sustained northwesterly winds develop, potentially affecting the shorelines from Peard 

Bay to Kasegaluk Lagoon, SW of Wainwright. Therefore, the response scenario plans to deploy 

resources to implement shoreline protection and recovery strategies as a defensive measure in the 

unlikely event oil reaches shorelines after six days. 

The FEIS for the Chukchi Sea Planning Area Oil and Gas Lease Sale 193 and Seismic Surveying 

Activities, prepared by the MMS (MMS 2007), includes an analysis of how and where offshore spills move 

using a computer trajectory simulation model. Simulations are performed using wind, ice, and oceancurrent information for winter and summer seasons and annual conditions. The wind, ice, and oceancurrents used for trajectories were derived from a variety of sources including field and satellite 

observations and calculated conditions. Thousands of trajectories were run for hypothetical spill launch 

locations distributed through the Lease Sale 193 area. The trajectory runs simulate the movement of oil 

without consideration of oil spill containment, control, or recovery actions. The trajectory model provides 

conditional probabilities that oil spilled from a hypothetical launch area will contact a specific land 

segment or environmental resource area within a given time frame. 

The MMS report reveals probabilities of oil contact from a large oil spill (≥1,000 bbl) during the drilling 

season to individual land segments to be typically 1 percent to 11 percent within the region between 

Peard Bay and Kasegaluk Lagoon (Land Segments 71 through 82). These probabilities are based on oil 

contacting the land segment with no cleanup response for the first 30 days from a spill in the vicinity of 

Shell’s Burger prospect drilled in 1990 (hypothetical results from launch areas LA 5, LA 11 and pipeline 

segment P09). Stochastic trajectories run by ASA using varied start dates, winds, and current data are 

consistent with the results presented in the MMS FEIS for Chukchi Sea Oil and Gas Lease Sale 193. 

While the trajectory modeling of hypothetical oil spills for the region of concern is valuable as an indication 

of probable shoreline impact, Shell recognizes the need to plan for those adverse wind and sea 

conditions that could conceivably drive oil directly toward shore and other sensitive resources. BAT has 

been used wherever possible, along with the expertise of ACS, to ensure that a timely and effective 

response is mobilized and protective measures are implemented before oil impacts priority sites (see 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-53 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

Table 1.6-1). Trajectory analyses suggest that it is highly unlikely that oil could impact the nearshore 

environment in less than six days at the earliest. 

Resources of Importance [30 CFR 254.26(c)] 

Resources of special economic or environmental importance could be impacted by spilled oil. These 

affected resources could include marine and coastal avian and mammalian populations, anadromous fish 

populations, and shoreline cultural resources occupying the path of the spilled oil. Many of these 

resources are important both ecologically and economically. Three principal sources contain reference 

information on the biological and cultural resources from Point Barrow south to Cape Lisburne: (1) the 

ACS Technical Manual, Volume 2, (2) the ARRT’s Sensitive Areas Section in the North Slope Subarea 

Contingency Plan, and (3) the NOAA ESI Maps contained in the North Slope Atlas. The ACS Technical 

Manual and the ESI Maps also describe the seasonal distribution of marine mammals and birds in the 

spill vicinity and simulated trajectory path. Endangered and threatened species are also identified with 

notes describing protection strategies. Shoreline habitats potentially exposed to oil are listed by level of 

concern and depicted on maps of the spill area. Known cultural resource sites are listed on the ACS

Technical Manual maps. 

Three primary strategies may be used to protect resources of importance. The primary strategy is to 

contain and recover oil as quickly as possible while it is encountered in a thick layer at the blowout site. 

Focusing on the release site will most effectively reduce the quantity of oil available to move away from 

the blowout into sensitive areas later. The second principal strategy is to contain and recover oil that has 

escaped the primary recovery operations. This secondary recovery would encounter oil using Shell’s 

OSRB and self-propelled skimming vessels and boom. The third strategy is for ACS to deploy exclusion 

and deflection boom at selected shoreline priority protection sites. All of these priority protection sites are 

identified in Table 1.6-1 and currently under review for the ACS Technical Manual, Volume 2. 

In order to protect shoreline priority sites from oil that escapes the offshore oil removal task forces, 

responders deploy equipment from the OSRB and onshore staging areas. The teams consist of ACS and 

ACRT personnel from the OSRB supplemented by NSRRT, ACRT and VRT mobilized by ACS as 

necessary for shoreline priority site protection. Teams work to deploy exclusion and deflection boom 

ahead of the arrival of oil into the nearshore environment ensuring protection of priority protection sites. 

Nearshore recovery, protection and shoreline efforts would be supported by equipment aboard the 

OSRB, including vessels, boom, skimmers, and mini-barges. Exclusion booming and deflection booming 

tactics, including equipment lists, personnel numbers, procedures, and mobilization and deployment 

times, are described in the ACS Technical Manual (Tactics SH-1 through SH-12) and Shell Beaufort and 

Chukchi Seas Regional Tactics Manual (Tactics SR-1 through SR-5). ACS may also mobilize by air 

NSSRT, ACRT, and VRT responders to shoreline staging areas, and then crews would travel by 

helicopter, landing craft, or work boats to protection sites along the affected shorelines. 

The main wildlife protection strategy is to remove oil from the environment as soon as possible. The 

secondary strategy for wildlife protection is hazing. Wildlife management plans and protective hazing 

permits would be coordinated and approved by resource trustees. Trained protective hazing specialists 

from ACS would be deployed to accompany equipment and crews working along shorelines. With the 

approval of resource agencies, oiled carcasses would be collected to remove them as sources of injury to 

predators. Oiled animals would be captured, stabilized, and treated by specialists using ACS equipment 

deployed to a staging location or transported to the wildlife stabilization facility at Prudhoe Bay. Animals 

requiring further treatment are transported to the Alaska Wildlife Response Center in Anchorage. See 

ACS Technical Manual Tactics W-1 to W-6 for decision-making and field procedures. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-54 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

Discussion of Equipment, Personnel, and Times [30 CFR 254(d)] 

The following discussion illustrates a response to the WCD scenario described above. Descriptions of 

conditions are provided in the Simulated Conditions section of the scenario. In addition, skimmer 

capacities are derated to reflect the effects of adverse weather, among other factors. Adverse weather 

conditions involving low temperatures and varying ice conditions are demonstrated in the ADEC 

Response Strategy following this Response Scenario/WCD Scenario. 

The locations, owner, and capacities of response equipment, personnel, materials, OSR support vessels, 

oil storage, transfer, and disposal equipment referenced in the scenario are listed in the Shell Beaufort 

and Chukchi Seas Regional Tactics Manual and the ACS Technical Manual. The Shell Beaufort and 

Chukchi Seas Regional Tactics Manual and ACS Technical Manual are incorporated into the scenario by 

reference. 

Mobilization and deployment times of the scenario’s containment, recovery, and storage equipment; 

equipment transportation vessels; and personnel to load and operate the equipment are listed in the Shell 

Beaufort and Chukchi Seas Regional Tactics Manual, the ACS Technical Manual tactics equipment 

tables, and Tables 1.6-5 through 1.6-9 of the scenario. Equipment loadout times to transfer equipment to 

vessels are incorporated into the mobilization times. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-55 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-3 

WELL BLOWOUT IN SUMMER 

SCENARIO CONDITIONS 

INITIAL CONDITIONS 

Spill Location Shell Exploration Well, drilled by the drillship Frontier Discoverer

Date August 7 

Duration 30 Days 

Type of Spill 25 to 30° API Crude Oil 

Source of Spill Uncontrolled well blowout at the mudline through an open orifice in 140 ft of water 

Quantity of Oil Spilled RPS Volume = 5,500 bopd x 30 days = 165,000 bbl 

No deductions were made to the RPS volume to account for burning or evaporation. 

Emulsification Factor and 

free water pickup 

1.54 x 165,000 bbl = 254,100 bbl. This is the oil emulsion volume created by skimming/pumping 

operations. Assuming that approximately 20% of the original oil volume recovered is added to this 

mix as free water (approximately 33,000 bbl), the total volume of fluids (emulsion + free water) 

could conceivably require approximately 287,100 bbl. 

Average Wind Speed 10 to 11 knots 

Wind Direction Prevalent winds are from the ENE. Wind direction and velocity data were derived from 

measurements collected by Shell in the Chukchi Sea from 1980, 1982, and 1983 during the period 

June 15 to November 15. The ocean current generally flows to the NNE. The trajectory depicted 

on Figure 1.6-8 was based upon the actual measured winds at the nearest station to the spill 

location from August 7 to September 6 of 1980. 

Based upon collected wind data, three primary wind directions emerge with a daily persistence 

greater than 10%: ENE, NE, and E. On average these wind directions occurred at the following 

measured frequencies for the June through November period: 

 14.6% ENE 

 13.8% NE 

 13.0% E

Air Temperature Average daily maximum and minimum temperatures were obtained from the Western Regional 

Climate Center website: http://www.wrcc.dri.edu/cgi-bin/cliMAIN.pl?ak0558 

The average daily maximum and minimum air temperatures for August are 46°F and 34°F, 

respectively. 

Surface Current The ocean current data used for trajectory modeling was based upon the MMS annual means 

analysis of Haidvogel, Hedstrom, and Francis (2001) coupled ice-ocean model. 

Visibility Variable 

Surface The prospect is located in federal waters in the Chukchi Sea. Wave heights are typically 1.5 to 2.5 

ft with no ice present. The Shell drillship located in the vicinity of an on-site OSRV and VOSS, and 

the OST is located 240 n mi (or less) from the drill site. The OSRB is located within 10 n mi of the 

drillship. Based upon a realistic average transit speed of 10 knots, the OST is located in the 

Chukchi Sea to ensure its arrival at the recovery site within 24 hr of mobilization. Similarly, the 

VOSS is positioned to arrive before the OSRV is filled to capacity. The OSRB is located on the 

Chukchi Sea Coast in the nearshore zone. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-3 (CONTINUED) 

WELL BLOWOUT IN SUMMER 

SCENARIO CONDITIONS 

Shell 1-56 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

INITIAL CONDITIONS 

Trajectory Modeling of the oil plume trajectory was conducted by ASA using historical wind data and the 

MMS hydrodynamic ocean-ice current model. 

The trajectory model uses OILMAP software developed by ASA. Based on environmental 

conditions including predominant winds and currents, the output from this model shows estimated 

oil concentrations and slick movement over time. Additionally, ASA’s SIMAP software provides 

probabilities and estimated contact timing if oil were to reach shorelines from a potential blowout. 

The ASA trajectory models include algorithms for spreading, evaporation, emulsification, and 

entrainment, all of which are input parameters based on the properties of the crude oil. The results 

provide graphical representation for instantaneous or continuous release spill volumes on water 

through time. 

Input parameters include a spill volume of 5,500 bopd using ANS crude oil with API gravity of 

30.6°. The ASA trajectory model was run using historical wind data collected by Shell for the initial 

blowout date and duration. The figure shows the model at 72 hrs into the spill and identifies the 

predicted surface oil concentrations from the blowout and slick direction. 

The simulated oil discharge of 5,500 bopd is ejected through a 6-inch ID well at the mudline, in 

water approximately 140 ft deep. Within minutes of the blowout, oil rises to the surface of the sea. 

The oil plume migrates to the southwest as a function of water currents and the direction of the 

prevailing wind. 

Within 72 hrs, if the oil remains uncontained and not recovered, the leading edge of the plume 

would extend roughly SW of the blowout for approximately 32 n mi. Refer to Figure 1.6-8. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-57 March 2010 

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TABLE 1.6-4 

WELL BLOWOUT IN SUMMER SCENARIO 

RESPONSE STRATEGY 

ADEC 

REQUIREMENT RESPONSE STRATEGY 

CROSS 

REFERENCE 

(i) Stopping 

Discharge at 

Source 

As soon as the well kicks, subsurface well control is initiated (increasing mud weight, 

followed by activation of the multiple rams on the BOP. Initial attempts fail and the 

exploration well is now classified as an “unobstructed” blowout well (T + 00 hrs). The 

well has a continuous flow rate that will deposit at the surface a total of 5,500 bopd. 

The On-Site Shell Drill Foreman notifies the On-Scene Incident Commander (OSC) 

who notifies response personnel on the OSRV accompanying the drillship. 

Notifications to appropriate state and federal agencies are performed. The NRC 

(1–800–424–8802) is notified, and the IMT is activated. 

The Shell OST (not more than 240 n mi from the drill site) and the OSRB (located at a 

maximum distance of 480 n mi from the Chukchi Sea nearshore zone) are notified and 

mobilized. 

The Shell OST is mobilized to within a safe distance within close proximity of the 

blowout. 

The drillship is undamaged by the subsea blowout and the drillship’s anchors are 

pulled and the vessel is moved to a safe location. Once the drillship is moved off 

location, the anchor handler, Tor Viking or similar, is reassigned as VOSS to Task 

Force 2 (TF-2) and mobilized to relieve the OSRV at hour 24 to perform recovery 

operations. 

Shell LE-2 

Tables 1.1-1 to 

1.1-3 and 

Tables 1.2-1 to 

1.2-2 

 in Section 1 of 

this plan 

Section 1.6.3 

of this plan 

(ii) Preventing or 

Controlling Fire 

Hazards 

The Site Safety Officer analyzes the situation and verifies that all sources of ignition 

are shut down or removed from the area. The Site Safety Officer provides access zone 

information and determines PPE requirements. Monitoring protocol is established for 

all work areas to ensure personnel protection. The monitoring protocol establishes 

safety zones according to applicable Occupational Safety and Health Administration 

(OSHA) and fire hazard standards. 

The OSC determines that ignition of the blowout warrants immediate consideration and 

initiates a request to the UC to ignite free gas surfacing at the well site The UC 

approves the ignition of the blowout for safety reasons. 

Shell 

S-1 

through 

S-4 

ACS 

S-1 

through 

S-6 

Well Control Plan Well control specialists are consulted to initiate safe blowout intervention and well 

control procedures. 

T + 12 Hours, The drillship, personnel and equipment are mobilized to a safe location 

to implement the relief well plan. 

T + 4 Days. Additional equipment and personnel required for well control arrive at the 

drillship. Potential subsurface control measures are evaluated. Damage to the drill site 

and the ability to access the subsurface well location are determined. All options are 

considered (see Section 1.6.3). 

T + 30 Days. Surface control of the blowout is achieved and relief well installation is 

suspended. 

Section 1.6.3 

of this plan 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-4 (CONTINUED) 

WELL BLOWOUT IN SUMMER SCENARIO 

RESPONSE STRATEGY 

Shell 1-58 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC 

REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE 

(iv) Surveillance 

and Tracking of Oil 

Oil movement is tracked using a combination of visual observations and remote 

sensing techniques. Fixed-wing aircraft and helicopters are used to provide 

surveillance and remote-sensing systems. Aerial overflights include spill tracking, 

vessel movements, wildlife monitoring, and operational system performance. 

Response vessels deploy buoys with transmitters. Both systems are capable of realtime tracking of the leading edge of the oil. Oil location information is digitized and 

transferred to the IMT and OSC for response planning and trajectory modeling. 

Satellite tracking of oil is initiated (RadarSat or EnviroSat) and coordinated with the use 

of tracking buoys. 

The NOAA and/or ASA OilMap trajectory models are used to provide initial trajectory 

predictions based on wind speed and direction observed in the field. The trajectory 

model forecasts would be updated as blowout progresses to monitor oil movement 

based upon field measurements. 

Shell 

TS-1, TS-2, 

TS-3 

ACS T-4, T-5 

(v) Exclusion 

Procedures; 

Protection of 

Sensitive 

Resources 

The initial oil trajectories have resulted in the primary spill recovery efforts being 

focused to the SW of the drill site. Based upon historical wind data and the MMS 

current model, the ASA trajectory predicts that without containment and recovery the 

earliest potential oil contact with shorelines would not occur until Day 25. However, in 

the unlikely event strong, sustained winds develop out of the WNW, trajectory modeling 

estimates that 6 days is the earliest possible time oil could reach shore. As a 

precaution, ACS mobilizes to implement protection strategies at priority resource sites. 

In addition to ACS, the OSRB is mobilized from its staging location to the Peard Bay 

vicinity to support nearshore protection and recovery if sustained WNW winds develop. 

Based on trajectory calculations and oil tracking, a 50-mi section of coastline consisting 

of barrier islands and exposed mainland is identified as the potential impact zone. 

Protection sites (PS-168, PS-169, PS-170, PS-171, PS-172, PS-173 and PS-174) are 

identified along the Chukchi Sea coastline for priority exclusion or deflection booming. 

Trajectory model runs are performed throughout the response using field-collected 

data to track oil and assess protection priorities. 

The NOAA ESI Maps, ACS Atlas Maps, and the North Slope Subarea Contingency 

Plan are used to identify areas of major concern. The EU Leader coordinates with 

resource agency representatives and local representatives to prioritize resource 

sensitivities and activate protection guidelines. The Cultural Resource Specialist and 

State Historic Preservation Officer (SHPO) coordinate to identify sites of concern and 

advise Operations of necessary site protection needs. 

The EU begins development of a shoreline protection plan, and Shoreline Cleanup 

Assessment Teams (SCAT) are placed on standby. 

T+4 Days. ACS Shoreline Protection Task Forces deploy exclusion booms at PS-174 

to protect the Sinaruruk River; PS-173 and PS-172 to protect lagoons at Point Belcher; 

PS-171 at the entrance of Kugrua Bay; PS-170 to protect an unnamed river on the 

south shore of Peard Bay; and PS-169 and PS-168 to protect unnamed rivers. The 

OSRB is mobilized to be centrally located to perform nearshore free oil recovery and 

support task forces and shoreline protection sites. 

ACS has the capability of mounting an effective shoreline response to supplement the 

primary response operation as necessary. 

NOAA ESI 

Maps ESI 14-

16 

ACS Map Atlas

Sheets 251-

255 

http://www.asg

dc.state.ak.us/

maps/cplans/s

ubareas.html#

northslope 

MESA 4 - 

Peard Bay / 

Franklin Spit 

ACS SH-1 

ACS C-13, 

C-14 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-4 (CONTINUED) 

WELL BLOWOUT IN SUMMER SCENARIO 

RESPONSE STRATEGY 

Shell 1-59 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC 

REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE 

(vi and vii) Spill 

Containment, 

Control, and 

Recovery 

Procedures 

Task Force (TF) Descriptions:

TF-1 provides the primary response OSRV and is stationed at or near the drillship. 

Response assets include an OSRV with 11,400 bbl of storage (95 percent capacity) 

with one (1) Transrec 150 skimmer; two (2) Lamor LSC-5 skimmers; one (1) vertical 

rope mop skimmer; three (3) 34-ft work boats; one (1) duplex mini-brush/disc skimmer; 

offshore containment boom; water-cooled fire boom and dispersant application 

capability. TF-1 arrives at the spill site within one hr. 

TF-2 consists of the anchor handler, Tor Viking or similar vessel, functioning as a 

VOSS with a minimum storage capacity of 3,200 bbl. Response assets aboard the 

VOSS include one (1) Transrec 150 skimmer. TF-2 assists the drillship to move off site 

and arrives to relieve the OSRV at hour 24. TF-2 works with the (3) 34-ft work boats 

from TF-1 to continue containment and recovery operations. 

TF-3 consists of the OST, providing a minimum of 287,100 bbl of oil storage capacity 

and staged within 240 n mi of the drill site. TF-3 arrives at the spill site within 24 hrs. 

Decanting (if necessary) within federal waters will be contingent upon FOSC approval. 

TF-4 consists of a C-130 aircraft equipped with 3,200 gal of dispersant and spray 

system. TF-4 is mobilized to the Barrow airport from the MSRC in Arizona and arrives 

in Barrow within 24 hrs. 

TF-5 consists of the OSRB with 18,636-bbl of onboard storage (17,000 bbl for planning 

purposes). The OSRB is mobilized from a staging area within 480 n mi of the Chukchi 

Sea nearshore zone, arriving on location within 96 hr. The OSRB provides a mobile onwater recovery system and staging platform. The OSRB is equipped with two (2) 

Lamor LSC-5 skimmers; one (1) 47-ft skimming vessel with built-in Lamor LORS-2C 

brush skimmers; three (3) 34-ft work boats; four (4) mini-barges; four (4) 656-ft (200-

meters [m]) ocean boom sections; one (1) vertical rope mop; one (1) duplex minibrush/disc skimmer; and one (1) 100-bbl storage bladder. 

TF-6 consists of ACS response equipment and personnel (ACS, ACRT, and VRTs) 

mobilized to deploy exclusion and deflection boom at priority protection sites. The 

primary objective of TF-6 is to prevent oil from impacting sensitive resources. TF-6 is 

also supported by the OSRB. TF-6 consists of two (2) landing craft; two (2) work 

boats; 10,000-ft conventional boom; 10,000-ft coastal boom; and 4,000-ft shore seal 

boom. 

TF-7 consists of ACS response equipment and personnel (ACS, NSSRT, ACRT, and 

VRTs) mobilized to perform shoreline cleanup. Based upon shoreline type and oiling 

conditions, cleanup is performed by 6 or 7 strike teams. Containment and recovery 

tactics are used to remove oil from the shoreline. The recovered oil is stored in 

temporary holding containers (portable folding tanks, bladders, and lined pits). TF-7 

would access shorelines using the two (2) landing craft and two (2) work boats (shared 

with TF-6). Additional small boats, boom, portable tanks and bladders are mobilized to 

the area during the first 6 days (the earliest time oil is predicted to impact shorelines). 

Recovery Timeline:

T + 1 Hour. TF-1 deploys immediately at a safe distance downstream of the blowout, 

ahead of the leading edge of the oil plume. The objective of TF-1 is to recover oil and 

store oil aboard the vessel for subsequent lightering to the OST. 

The burning of free gas from the blowout may eliminate some of the surfacing oil. 

However, for planning purposes the full WCD of 5,500 bopd (229 bbl/hr) will be used 

for mechanical recovery calculations. 

TF-1 deploys two (2) 34-ft work boats with an open apex U-boom configuration down 

current the blowout. The OSRV and one (1) 34-ft work boat deploy behind the open 

apex in a J-boom configuration to recover oil. The OSRV operates one (1) Transrec 

150 skimmer with a derated recovery of 503 bbl/hr or two (2) Lamor LSC-5 skimmers 

with a combined derated recovery of 516 bbl/hr (2 X 258 bbl/hr).

Shell 

OR-2B, OR-10, 

OR-8 

ACS R-20 

(modified) 

Shell 

OR-10 

ACS R-20 

(modified) 

Shell 

OR-3A 

Shell 

OR-9A 

Shell 

OR-1A, 

OR-1B, OR4A, 

OR-4B, 

OR 5B, OR-5B 

ACS C-13, 

C-14 

Shell 

SR-3, SR-4, 

SR-5 

ACS SH-3, 

SH-5 through 

SH-12 

Shell 

OR-2B, OR-10 

Shell 

OR-2B, OR-10 

(Table 1.6-5) 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-4 (CONTINUED) 

WELL BLOWOUT IN SUMMER SCENARIO 

RESPONSE STRATEGY 

Shell 1-60 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC 

REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE 

T + 24 Hours. The drillship is relocated a safe distance from any surfacing oil and gas. 

The VOSS (TF-2), equipped with one (1) Transrec 150 skimming system, relieves the 

OSRV (TF-1) to lighter its recovered fluids to the OST. TF-2 has enough storage 

capacity to store recovered fluids for eight hr of skimming during which time lightering 

operations from the OSRV to the OST are completed. The VOSS works with the three 

(3) 34-ft workboats from TF-1. The VOSS and one (1) 34-ft workboat operate in a Jboom configuration behind the two (2) 34-ft workboats towing an open apex U-boom. 

TF-2 works downstream of the blowout to contain, collect, and recover surfacing oil. 

TF-3 has arrived from its standby location not farther than 240 n mi from the drill site. 

The primary objective of TF-3 is to provide offshore interim storage capacity for 

recovered fluids. Upon TF-3 arrival, TF-2 relieves the OSRV (TF-1) to lighter its 

recovered fluids to the OST. 

During OSRV lightering operations to the OST, TF-2 maintains two (2) 34-ft workboats 

with open apex U-boom configuration downstream of the blowout to contain and collect 

surfacing oil for recovery by the VOSS with one (1) Transrec skimmer in J-boom 

configuration. During the 8-hr timeframe to complete lightering from the OSRV to the 

OST and resume skimming, the VOSS encounters approximately 1,833 bbl (229 bbl/hr) 

of surfacing oil and possesses the capacity to store the 3,200 bbl of recovered liquids 

(400 bbl/hr x 8 hr). The TF-2 VOSS initiates lightering operations to the OST following 

the resumption of recovery by the TF-1 OSRV. The derated recovery capacities of TF-1 

and TF-2 exceed the 229 bbl/hr oil rate released from the blowout. 

A strategic plan is provided to the UC to use dispersants when conditions arise that limit 

or preclude the effectiveness of mechanical recovery techniques, or if surface oil 

presents a significant threat to sensitive environmental resources. To augment 

mechanical response operations, a request and application to authorize dispersant use 

is submitted to the UC. 

TF-4, consisting of one (1) C-130, is mobilized to Barrow where 25,000 gal of Corexit 

9500 also have been mobilized and staged. TF-1 would apply dispersants via spray 

arms. 

T + 96 Hours. Should oil escape offshore recovery operations, and in the unlikely event 

moves toward the Chukchi shoreline, nearshore assets would be mobilized to 

implement nearshore response, shoreline protection and cleanup. At the very earliest, 

oil may reach shore on Day 6 if sustained northwesterly winds develop. ACS is 

mobilized to the projected area of impact with response equipment and personnel 

(ACS, ACRT and VRTs) to deploy exclusion and deflection boom at priority protection 

sites. 

TF-5, consisting of the OSRB, arrives within 4 days to provide support (e.g., platform, 

safe haven for personnel and vessels, response equipment, recovered fluid storage) for 

the nearshore recovery and shoreline response operations. 

TF-5 targets free oil in windrows and linear slicks. In addition to the OSRB with LSC-5 

skimmers, TF-5 includes one (1) 47-ft skimming vessel configured with two (2) side 

booms and two (2) built-in Lamor LORS-2C skimmers. Two (2) 34-ft work boats are 

deployed to tow boom for the concentration of oil and recovery by the 47-ft skimming 

vessel. The remaining 34-ft work boat shuttles personnel, supplies, and four (4) minibarges. 

TF-6 is mobilized by ACS from Prudhoe Bay to implement shoreline protection 

strategies within the area of potential impact. TF-6 deploys equipment pre-staged 

along the Chukchi Sea coast consisting of (2) landing craft; two (2) work boats; 10,000-

ft conventional boom; 10,000-ft coastal boom (6,000-ft from OSRB and 4,000-ft prestaged); and 3,000-ft shore seal boom. TF-6 is also supported by the OSRB and its 

personnel and equipment. ACS cascades additional crews, boom and workboats to 

priority protection sites selected by the UC. Exclusion and deflection boom is deployed 

within 6 days (the predicted earliest time oil may reach shorelines if sustained 

northwesterly winds develop). 

TF-7 is mobilized by ACS from Prudhoe Bay to stage equipment and personnel for 

Shell 

OR-10 

ACS 

R-20 

(modified) 

Shell 

OR-3A 

Shell 

OR-10 

ACS R-20 

Shell 

OR-9A, 

OR-8 

ACS C-13,

C-14 

Shell 

OR-1A, OR-1B 

OR-4A,OR-4B, 

Or-5A, Or 5B 

ACS C-13, 

C-14 

Shell 

SR-2, SR-3, 

SR-4 

ACS SH-1 

through SH-12 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-4 (CONTINUED) 

WELL BLOWOUT IN SUMMER SCENARIO 

RESPONSE STRATEGY 

Shell 1-61 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC 

REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE 

shoreline cleanup operations in the unlikely event a sustained WNW wind results in 

impacts. The shorelines predicted at risk lie between the Sinaruruk River and Peard 

Bay. In the event recovery operations are necessary, ACS shoreline recovery teams 

anchor boom to the shore in a hook configuration and recover oil with a skimmer into 

Fast Tanks or bladders. One team works 10 locations within a five-mi area. Consistent 

with the UC-approved Shoreline Cleanup Plan, ACS crews would begin shoreline 

cleanup operations using passive, manual, deflection booming, and/or deluge 

techniques. 

T + 15 Days. Through Day 14, the oil trajectory moves in a southwesterly direction 

away from shorelines. After Day 14, trajectory modeling predicts oil to begin drifting to 

the NNE. Oil recovery vessels adjust their location to maintain containment and 

recovery operations. 

T + Day 25. A low probability exists for oil to reach shorelines. As predicted by 

trajectory modeling using historical wind data collected by Shell for the initial blowout 

date and duration, the earliest that oil could contact shorelines is Day 25. Nearshore 

recovery operations would be conducted using the OSRB with Lamor LSC-5 skimmers, 

one (1) 47-ft skimming vessel and one (1) 34-ft workboat with duplex skimmer and two 

(2) 249-bbl mini-barges to recover bands of oil approaching shore. The OSRB’s 

storage capacity is sufficient to store all nearshore recovered liquids. 

In the unlikely event oil contacts shoreline, TF-7 teams would be mobilized to 

implement shoreline recovery and cleanup strategies. One team works 10 locations in 

a five-mi area. Two teams manage shoreline operations for 10 mi. 

T + Day 30. Offshore and nearshore recovery operations are completed. The 

shoreline cleanup plan (approved by UC) is implemented by shoreline teams [see (xii) 

Shoreline Cleanup Plan]. 

Shell 

SR-1, SR-5, 

SR-6, SR-7, 

SR-8, SR-9, 

SR-10 

ACS R-16 

Shell 

OR-2B, OR-10 

Shell 

OR-3A, 

Shell 

OR-1A, 

OR 1-B 

OR 4A, OR 4B, 

OR-5A, OR-5B 

ACS SH-1 

through SH-12 

(viii) Lightering 

Procedures 

Decanting (if required) follows FOSC plan approval within the OCS. Within state 

waters, decanting is subject to approval of the State On-Scene Coordinator (SOSC). 

Stored liquids are offloaded from the OSRV, VOSS, and OSRB to the OST. 

Based on a maximum WCD of 5,500 bbl/day (or 229 bbl/hr), a 1.54 emulsification factor 

and free water retained in storage (20% of the WCD), each skimming vessel could be 

filled at a rate of approximately 400 bbl/hr. 

TF-1 OSRV has 11,400 bbl of storage volume (95 percent capacity). The 11,400 bbl 

storage capacity is more than sufficient to store recovered fluids until the OST arrives 

on-scene from a staging location no farther than 240 n mi from the drill site. 

At hour 24, the VOSS replaces the OSRV as it disengages from skimming operations, 

transits to the OST, and commences offloading recovered fluids. The VOSS and 34-ft 

workboats replace the OSRV to continue skimming operations and provide interim 

storage. The 34-ft workboats maintain the open apex U-boom configuration safely 

downstream of the blowout to direct surfacing liquids for collection by the VOSS. The 

VOSS initiates lightering operations to the OST following the resumption of recovery by 

the OSRV. Skimming and lightering operations are scheduled on a 24-hr rotation basis. 

For the duration of the response, the OSRV and VOSS would set up a rotation cycle 

with the OSRV skimming for 16 hr and the VOSS for another 8 hr. At the end of the 

rotation, each vessel is relieved to offload recovered fluids to the OST. 

The OSRV is equipped with eight (8) positive displacement hydraulic screw pumps for 

lightering operations. Each pump has a maximum discharge capacity of 723 bbl/hr. It is 

conservatively assumed that the total transit and set up time for lightering is three to 

four hr. The estimate offload time of three to four hr is based upon the transfer rate of 

four (4) pumps working together (4 X 723 bbl/hr) to offload approximately 9,570 bbl of 

recovered liquids (5,500 bbl at a 1.54 emulsification factor plus 20% retained free 

water). For planning purposes the OSRV completes lightering operations to the OST 

within 8 hr. 

Shell 

OR-3A 

Shell 

OR-3A 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-4 (CONTINUED) 

WELL BLOWOUT IN SUMMER SCENARIO 

RESPONSE STRATEGY 

Shell 1-62 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC 

REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE 

The OST is maintained in close proximity, typically a mile or two, from the recovery 

operations so that transit times to and from the OST are kept to a minimum. The 

transfer of recovered fluids (after decanting forward of the skimmers) is accomplished 

using BAT; that is, annulus injection of water at a suction head to produce a low-friction 

transfer of viscous fluids between the skimmer’s onboard storage and the OST. With 

high-volume transfer pumps and annulus injection, each transfer from the OSRV to the 

OST should require only 3 to 4 hr with an additional 3 to 4 hr factored in for setup and 

transit to and from the OST. The VOSS lighters to the OST when the OSRV resumes 

recovery operations. Using high-volume transfer pumps, the VOSS offloading requires 

less than the 16 hr available to complete transfer operations and transit to and from the 

OST. 

(ix) Transfer and 

Storage of 

Recovered 

Oil/Water; Volume 

Estimating 

Procedure 

Stored liquids are offloaded from the OSRV and VOSS to the OST. Liquids from the 

nearshore skimmer vessels are stored in mini-barges and transferred to the TF-6 

OSRB. 

Liquids recovered by the shoreline recovery task forces are stored in Fast Tanks, 

bladders, mini-barges, or mobile tanks. Fluids may be transferred to secondary storage 

containers. See Section 1.6.10. 

Stored oil emulsion and free water are gauged and recorded for volume estimation. 

Shell 

OR-3A, OR-6 

ACS R-22, 

R-24 

ACS T-7 

(x) Plans, 

Procedures, and 

Locations for 

Temporary Storage 

and Disposal 

A Waste Management Plan is developed and submitted to the UC for approval to 

address: (1) documentation and tracking; (2) measure liquid and other waste; and (3) 

final disposal. 

Recovered fluids stored onboard the OST and from nearshore and shoreline recovery 

operations will be disposed of outside the U.S., either at Shell Group refineries or other 

third-party processors, in accordance with Shell environmental policy, and relevant 

local laws and regulations (see Section 1.6.10). 

Non-liquid oily wastes are classified and disposed of according to classification. 

Non-oily wastes are classified and disposed of accordingly. 

ACS D-1 

through D-5 

Shell DP-1 

(xi) Wildlife 

Protection Plan 

Wildlife monitoring and deterrents to protect animals are put in place at the spill scene 

and impacted areas during recovery operations. The International Bird Rescue 

Research Center is put on standby in the event the wildlife treatment facility is required. 

Temporary facilities are established as necessary and made available to agency 

biologists and veterinarians standing by to respond to potential reports of oiled wildlife.

MMOs are stationed aboard the primary drilling and support vessels. The EU 

coordinates with resource trustee agency representatives to develop and implement 

plans for wildlife hazing and/or rehabilitation of marine mammals. 

Aerial overflights include wildlife monitoring. 

ACS W-1, 

ACS W-2 

ACS W-2B, 

L-6, 

W-3, 

W-4, 

W-5 

(xii) Shoreline 

Cleanup Plan 

Based upon prevailing winds and currents in the lease areas, there exists a very low 

probability that oil will reach the Chukchi Sea coastline. However, for planning 

purposes, the contingency plan addresses nearshore free oil recovery, priority 

protection sites, and shoreline cleanup techniques. 

It is anticipated to take at least six days for oil to travel from the drill site in the unlikely 

event a sustained wind from the WNW were to develop and for shoreline impacts. 

Prevailing winds in the Chukchi Sea are normally from the ENE. 

A shoreline assessment is conducted to understand the nature and extent of oiling. 

Based on the shoreline assessment, priorities are established for cleanup. Cleanup 

techniques chosen are based on shoreline type and degree of oiling. Shoreline 

operations will be performed consistent with the UC-approved cleanup plans. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-4 (CONTINUED) 

WELL BLOWOUT IN SUMMER SCENARIO 

RESPONSE STRATEGY 

Shell 1-63 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC 

REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE 

Shoreline response would consist of ACS mobilized personnel (ACS, NSSRT, ACRT, 

and VRT), equipment from Chukchi shore-based staging areas, Prudhoe Bay, and the 

OSRB. Shorelines will be approached primarily by workboat or barge. Primary 

shoreline cleanup techniques would include: 

 Passive recovery of oil using snare boom. 

 Manual removal of oil and oily debris. 

 Deflection booming with skimming or trenching to contain and recover floating 

oil/emulsion. 

 Deluge of minor to moderately oiled shoreline. 

 Burning of oiled debris and vegetation, 

 Natural recovery for those areas where residual staining may remain, but further 

recovery would cause more harm than good. 

The EU will supervise access of response teams to environmentally sensitive areas. 

ACS 

SH-1 

Shell 

SR-1 

ACS SH-2 

through SH-12 

Shell 

SR-5, SR-6, 

SR-7, SR-8, 

SR-9, SR-10 
Oil Discharge Prevention and Contingency Plan Chuk

Part 1 – Response Action Plan 

Shell 1-64 95-2000.01-25.201-001/09-018 

TABLE 1.6-5 

WELL BLOWOUT IN SUMMER 

DERATED POTENTIAL RECOVERY CAPABILITY 

A B C D E F G H I J 

SHELL / 

ACS SPILL 

RECOVERY 

TACTIC 

NUMBER OF 

SYSTEMS 

(SKIMMERS 

PER 

VESSEL) 

RECOVERY SYSTEM 

DERATED 

RECOVERY 

CAPACITY 

PER 

SKIMMER1, 2

(BBL/HR) 

SCENARIO 

RECOVERY 

RATE3, 4 

(BBL/HR)

MOBILIZATION 

AND TRANSIT 

TIME TO SITE 

(TIME) 

OPERATING 

TIME ON 

DAY 1 

(HR/DAY) 

RECOVERY 

RATE ON 

DAY 1 

[BBL/DAY] 

(E X G) 

OPERATING 

TIME AFTER 

DAY 2 

(HR/DAY) 

RECOVE

RATE 

AFTER 

DAY 2

[BBL/DA

(E X I) 

OFFSHORE RECOVERY 

Alternative 1: TF-1: Shell 

OR-2B, OR-10 

1 

Transrec 150 − 400 cu 

m/hr (2,516 bbl/hr) derated to 20% nameplate pump rate (20% x 2,516 bbl/hr = 503 bbl/hr) 

503 400 <1 hr 23 9,600 16 6,400 

(or) 

Alternative 2: TF -1: Shell 

OR-2B, OR-10 

2 

Lamor LSC-5 205 cu m/hr (1,289 bbl/hr) derated to 20% nameplate pump rate (20% x 1,289 bbl/hr = 258 bbl/hr 

258 400 <1 hr 23 9,600 16 6,400 

TF-2: Shell OR-10 

1 

Transrec 150 – 400 cu m/hr (2,516 bbl/hr) derated to 20% nameplate pump rate (20% x 2,516 bbl/hr = 503 bbl/hr) 

503 400 24 hrs 0 0 8 3,200 

NEAR SHORE / SHORELINE RECOVERY 

TF-5 Shell OR-1A, OR-1B 

2 

Lamor LSC-5 205 cu m/hr (1,289 bb/hr) derated to 20% nameplate pump rate (20% x 1,289 bbl/hr = 258 bbl/hr 

258 40 96 hrs 0 0 0 0 

TF-5: Shell OR-4A, OR-4B 

2 

Lamor LORS-2C 82 cu m/hr brush 

skimmers (47-ft work boat) Derated to 20% nameplate pump rate (20% x 516 bbl/hr = 103 bbl/hr) 

103 40 96 hrs 0 0 0 0 

TF-6: ACS R-16 10 

Hook boom configuration with oleophilic skimmer 

10 40 96 hrs 0 0 0 0 

TOTAL BBLS OF RECOVERED LIQUIDS/DAY 9,6006 9,6006 
Oil Discharge Prevention and Contingency Plan Chuk

Part 1 – Response Action Plan 

TABLE 1.6-5 (CONTINUED) 

WELL BLOWOUT IN SUMMER 

DERATED POTENTIAL RECOVERY CAPABILITY 

Shell Offshore Inc. 1-65 

95-2000.01-25.201-001/09-018 

1. Pumps are derated to 20% per 30 CFR 254.44 (a) and (b) and 18 AAC 75.445(g)(5). 2 Pump performance calculations assume one (1) cu m equals 6.29 bbl (U.S. oil).3.The offshore scenario recovery rate of 400 bbl/hr is the estimated quantity of oil / water emulsion and free water available for recovery per hour based upon t

(or 229 bbl/hr), a 1.54 emulsification factor and free water retained in storage (20% of the WCD). The derated recovery capacity of the listed skimmers excewater emulsion and free water available for recovery within a 24 hr period. 

4. The nearshore recovery rate is based upon the planning assumption that a 10% fraction of the daily release volume (23 bbl/hr) may escape the primary offs

toward the nearshore and shorelines. Based upon trajectory modeling, oil would reach the nearshore at the earliest after Day 6 and only in the unlikely even

or WNW. The scenario trajectory developed using historical winds and the MMS Chukchi current model shows that oil has a low probability of shoreline con

5 After Day 1, recovery calculations assume that operations go into a 24-hr rotation with the OSRV and VOSS alternating as skimming platforms to maintain r

skims for 16 hr at a time using the Transrec 150 or Lamor side collector skimmers and the VOSS skims for 8 hr using the Transrec 150 while the OSRV ligh

lightering operation is based upon an 8 hr period including transits to and from the OST and offloading. Once the OSRV resumes skimming, the VOSS lighte

For the purposes of calculating total recovery, 24 hrs of recovery per day is used for the skimming systems. 

6. Alternative 1 is based upon use of the free floating Transrec 150 weir skimmer for total recovery capacity and Alternative 2 uses the Lamor LSC-5 brush ski
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-66 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-6 

MAJOR EQUIPMENT FOR OFFSHORE RESPONSE DURING THE DRILLING SEASON 

ITEM EQUIPMENT INFORMATION QUANTITY 

TASK FORCE 1 

 Vessels 

 OSRV 300-ft Response Vessel with 12,000 bbl Storage 1 

 Work boats 34-ft Work Boats (Shared with TF-2) 3 

 Oil Recovery Equipment 

 Transrec 150 Skimmer Umbilical Weir Skimming Package 1 

Lamor LSC-5 Skimmer Brush Skimmer Packages 2 

 Vertical Rope Mop Portable Skimming Package 1 

 Ocean Boom 200-m Containment Boom Sections (Shared with TF-2) 4 

Duplex Mini-Brush/Disc Skimmer Portable Skimming Package 1 

Storage Bladder 100-bbl Bladder 1 

 Non-Mechanical Response 

Fire Boom System In Situ Burning Containment 1 

Dispersant Application Systems Spray Arms 2 

TASK FORCE 2 

Vessels 

VOSS Vessel of Opportunity with 3,200 bbl Storage 1 

Oil Recovery Equipment 

Transrec 150 Skimmer Umbilical Weir Skimming Package 1 

TASK FORCE 3 

 Vessels 

 OST OST (287,100 bbl Minimum Capacity) 1 

TASK FORCE 4 

Non-Mechanical Response 

C-130 aircraft Aircraft with Integrated Dispersant Tank and Spray Arms 1 

Corexit 9500 Dispersant 1 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-67 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-7 

MAJOR EQUIPMENT FOR NEARSHORE AND OPERATIONS 

TASK FORCE EQUIPMENT QUANTITY 

TF-5, Nearshore Recovery 

18,636 bbl OSRB with Support Tug 1 

Lamor LSC-5 Brush Skimming Packages 2 

47-ft Response Vessel 1 

Lamor LORS Brush Skimming Package 2 

34-ft Workboats 3 

Vertical Rope Mop 1 

Duplex Mini-Brush/Disc Skimmer 1 

100-bbl Flexible Containment System 1 

249-bbl Interim Storage 4 

200-m Containment Boom Section 4 

Fire Boom System (5 X 30-m) 1 

Coastal Boom (Shared with TF-6 and TF-7) 6,000-ft 

TF-6, Shoreline Protection 

Landing Craft 26-32 ft (Shared with TF-7) 2 

24-ft Workboat (Shared with TF-7) 2 

Workboats ─ ACS Type A & B (Shared with TF-7)* 4 

Workboats ─ ACS Type C (Shared with TF-7)* 2 

Conventional Boom (Shared with TF-7) 10,000-ft 

Coastal Boom (Shared with TF-7) 4,000-ft 

Shore Guardian Boom 4,000-ft 

TF-7, Shoreline Recovery 

Oleophilic Skimmers* 20 

Bladders (500 to 2,640 gal)* 36 

Portable Folding Tank (2,500 gal)* 50 

International Maritime Organization (IMO) Tanks (6,000 

gal)* 1 

* Equipment denoted with an asterisk is deployed from Deadhorse. All other TF-6 and TF-7 equipment is pre-staged at Wainwright. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-68 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-8 

STORAGE EQUIPMENT FOR RECOVERY OPERATIONS 

SUM OF CAPACITY OF OIL STORAGE TANKS 

ELEMENT PLANNING CAPACITY (BBL) REFERENCE 

OFFSHORE STORAGE 

OSRV 11,400 Shell Charter, available to ACS 

VOSS 3,200 Shell Charter, available to ACS 

OST 287,100 Shell Charter, available to ACS 

NEARSHORE STORAGE 

OSRB 17,000 Shell Charter, available to ACS 

ACS Mini-barges Response Dependent ACS Technical Manual

AES-RO Mini-barges 946 (4 x 236) Shell Beaufort and Chukchi Seas Regional Tactics 

Manual 

SHORELINE STORAGE 

Fast Tanks Response Dependent Shell Beaufort and Chukchi Seas Regional Tactics 

Manual or ACS Technical Manual
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-69 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-9 

STAFF TO OPERATE OIL RECOVERY AND TRANSFER EQUIPMENT 

FOR OFFSHORE, NEARSHORE AND SHORELINE OPERATIONS 

LABOR 

CATEGORY 

TASK 

FORCE UNIT DESCRIPTION NO. UNITS STAFF PER UNIT 

STAFF PER 

SHIFT6 

DAY 1

STAFF PER 

SHIFT6 

AFTER DAY 4 

Team 

Leader/Field 

Supervisors1, 2, 5 

TF-1 OSRV Supervisor 1 2 2 2 

TF-2 VOSS Supervisor3 1 1 

TF-3 Tanker Deck PIC 1 1 1 1 

TF-4 Aerial Dispersant Supervisor 1 1 1 

TF-5 OSRB Supervisor 1 2 1 1 

Nearshore Recovery Supervisor 1 1 1 1 

TF-6 Shoreline Protection 1 1 2 

TF-7 Shoreline Recovery 1 1 2 

Large Vessel 

Operators, >30 

feet4, 5 

TF-1 OSRV Operator 1 1 1 1 

34-ft Work Boat Operator (Shared with TF-2) 3 1 3 3 

TF-3 Tanker Operator 1 1 1 1 

TF-5 47-ft Skimmer Boat Operator 1 1 1 

34-ft Work Boat Operator 3 1 3 

Small Vessel 

Operator, <30 

feet4, 5 

TF-6 / 7 

24-ft Work Boat Operator 2 1 2 

Landing Craft (26-32 ft) 2 1 2 

Workboats 18-26 ft (ACS Type A & B) 4 1 4 

Workboats 29 ft (ACS Type B) 2 1 2 

Skilled 

Technicians4, 5 

TF-1 OSRV Deck Crew 1 7 7 7 

34-ft Work Boat Crew 3 1 3 3 

TF-2 VOSS Deck Crew 1 2 2 2 

TF-3 Tanker Deck Crew 1 3 1 3 

TF-5 

OSRB 1 4 4 

34-ft Work Boat Crew 3 1 3 

47-ft Skimmer Crew 1 2 2 

General 

Laborer5 

TF-6 / 7 

24-ft Work Boat Crew 2 1 2 

Landing Craft Crew 2 1 2 

Workboats 18-22 ft (ACS Type A & B) 4 1 4 

Workboats 29 ft (ACS Type C) 2 1 2 

TF-6 Shoreline Protection Labor 2 4 8 

TF-7 Shoreline Recovery Labor 2 4 8 

TOTAL 23 79 

Table notes: 

1. For ACS personnel, the Total is the sum of vessel operators, technicians, and general laborers. For ACS personnel, the 

Team Leader is a separate person. 

2. All TF-3 tasks, including PIC = Person-in-Charge, will be performed by the tanker crew with no additional response staff 

from Shell or ACS. 

3. Beginning Day 2, the TF-2 Team Leader / Field Supervisor is accounted for in TF-1. 

4. Boats and landing craft are shared between TF-6 and TF-7. 

5. TF-5, TF-6, and TF-7 operate one 12-hr shift per day. 

6. One (1) shift is (=) twelve (12) hr. 
AES-RTS: 08-098E-002.mxd, 09/15/08, R00

SCALE: FIGURE:

1.6-8

PREDICTED SUBSEA BLOWOUT TRAJECTORY

(WITHOUT CONTAINMENT AND RECOVERY)

Chukchi Sea Regional Exploration

Oil Discharge Prevention and Contingency

SHELL

Amount of Oil Spilled:

 5,500 bbl/day

Type of Oil Spilled:

 Alaskan North Slope Crude

Release Duration (hrs):

 72

Spill Location:

 Longitude (deg., min.):

 163 19.8001 (W)

 Latitude (deg., min.):

 71 16.6200 (N)

Spill Starts (Mo, Day, Hr:min):

 Aug. 7 0:00Hrs

Initial Release Within Depth Range of:

 42.0 - 44.0m

Wainwright
Offshore 

Response

Nearshore 

Response

Task Force 5

OSRB

Function: Response Equipment Platform, Supplies, 

Staging, Decon, Interim Waste Storage, 

Nearshore Recovery

Task Force 7

Function: Shoreline Cleanup

Task Force 6

Function: Protect Priority Resource Sites

Task Force 1

OSRV

Function: Open Water Recovery

Task Force 3

Oil Storage Tanker (OST)

Function: Interim Storage of Recovered 

Fluids

Task Force 4

C-130 

Function: Aerial Dispersant

Application

TACTICAL 

OPERATIONS

SHELL

OFFSHORE BLOWOUT TACTICAL 

OPERATIONS ORGANIZATION

Chukchi Sea Regional Exploration 

Oil Discharge Prevention and Contingency Plan

FIGURE:

1.6-9

Task Force 2

VOSS

Function: Open Water Recovery
Relief Well Drillship

Blowout

Safe Zone

Frontier Discoverer

Vapor Ignition

NEARSHORE Operations:

• (1) OSRB

• (1) 47’ Skimming Boat

• (4) Mini Barges

• (3) 34’ Workboats OSRV/VOSS

Skimmers

OSRV/VOSS

OST

Relocated for 

Relief Well

Safety Zone

RECOVERY & LIGHTERING 

Operations

SHELL

PRIMARY RESPONSE TO AN 

OFFSHORE BLOWOUT

FIGURE:

1.6-10

• (1) TransRec
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-73 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

RESPONSE STRATEGY 1 

SUBSEA BLOWOUT IN VARYING ICE CONDITIONS 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-74 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

THIS PAGE INTENTIONALLY LEFT BLANK 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-75 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

RESPONSE STRATEGY PARAMETERS 

The following response strategy describes methods and equipment that could be used in response to a 

hypothetical oil spill from a subsea well blowout at one of Shell’s exploration drilling locations during 

varying ice conditions. 

For the purposes of the strategy, an exploration well on the Shell prospect blows out at subsea nine days 

before freezeup. While the drilling season at the exploration well location can extend well into 

November/December, the formation of new ice by Day 9 provides ample time for the description of 

response techniques during freezeup. In this simulation, oil and gas travels from the subsea release at 

the mudline to an open region at the water surface. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-76 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-10 

RESPONSE STRATEGY 

SUBSEA WELL BLOWOUT IN VARYING ICE CONDITIONS 

ADEC REQUIREMENT RESPONSE STRATEGY 

CROSS 

REFERENCE 

(i) Stopping Discharge 

at Source 

The On-site Shell Drill Foreman initiates Shell’s internal emergency notification 

process for all on-site personnel as to the nature and severity of the blowout. 

Notifications are also made to appropriate state and federal agencies, including 

the NRC (1-800-424-8802). Shell’s IMT is activated. Response personnel are 

notified and all offshore and off-duty response personnel are put on alert. All 

vessels are moved to a safe location upwind of the blowout pending the results 

of site characterization assessments and relocation (if necessary) of the 

drillship. 

The drillship prepares for a relief well if necessary. The OSRV mobilizes to the 

blowout location and provides assistance (as needed.) Once the anchor 

handler, Tor Viking or similar, assists the drillship move to a safe location, it is 

re-assigned as a VOSS to Task Force (TF-2) and mobilized to relieve the 

OSRV at hour 24 to perform recovery operations. 

The OST on standby (within 240 n mi of the drilling location) and the OSRB 

(located at a maximum distance of 480 n mi from the Chukchi Sea nearshore 

zone) are notified and mobilized immediately to support spill control efforts at 

the blowout location. 

Shell LE-2 

Tables 1.1-1 to 

1.1-3 and Tables 

1.2-1 to 1.2-2 

 in Section 1 of 

this plan 

Section 1.6.3 of 

this plan 

(ii) Preventing or 

Controlling Fire 

Hazards 

The Site Safety Officer analyzes the situation and verifies that all sources of 

ignition are shut down or removed from the area. The Site Safety Officer 

provides access zone information and determines PPE requirements. 

Monitoring protocol is established for all work areas to ensure personnel 

protection. The monitoring protocol establishes safety zones according to 

applicable Occupational Safety and Health Administration (OSHA) and fire 

hazard standards. 

The OSC determines that ignition of the blowout warrants immediate 

consideration and initiates a request to the UC to ignite free gas surfacing at 

the well site The UC approves the ignition of the blowout for safety reasons. 

Shell 

S-1 

through 

S-4 

ACS 

S-1 

through 

S-6 

Well Control Plan Refer to Well Control Plan discussed in Section 1.6.3 of this C-Plan. Refer to 

the well control actions in Table 1.6-4. 

Section 1.6.3 of 

this C-Plan 

(iv) Surveillance and 

Tracking of Oil; 

Forecasting Shoreline 

Contact Points 

Oil movement is tracked using a combination of visual observations, remote 

sensing systems from fixed-wing aircraft and helicopters, and from satellites 

already in place for the tracking of ice conditions throughout the region 

(RadarSat & EnviroSat) 

Visual observation provides the greatest potential for monitoring oil and/or ice 

movement on location because aircraft (fixed-wing and helicopter) play a vital 

role for the ongoing assessment of weather conditions, oil transport, and 

conditions at/near the blowout, smoke plume (if free-gas ignition is 

implemented), and the positioning (or “spotting”) of spill control systems 

downstream. In addition, remote sensing systems (e.g., FLIR) and tracking 

buoys and beacons are used to track oil or oiled ice during periods of reduced 

visibility (day or night). Tracking buoys, capable of transmitting signals to 

aircraft and/or satellites, play an important role in tracking the leading edge of 

any oil that escapes recovery or elimination onsite and moves toward sensitive 

resources offshore, nearshore, or onshore. 

All tracking of oil and oiled ice is coordinated with NOAA and ASA to provide 

predicted trajectories, based upon best available weather/ice predictions and 

actual field observations and measurements. Spill trajectories are used to 

ensure that tactics and strategies are implemented to protect identified priority 

protection sites well ahead of any oil that could impact those regions. 

Additional sources of data could also include: NASA moderate-resolution 

imaging spectroradiometer (MODIS) imagery (Aqua & Tera satellites) and the 

U.S. National Ice Center. 

Shell 

TS-1, TS-2, TS-3 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-10 (CONTINUED) 

RESPONSE STRATEGY 

SUBSEA WELL BLOWOUT IN VARYING ICE CONDITIONS 

Shell 1-77 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC REQUIREMENT RESPONSE STRATEGY 

CROSS 

REFERENCE 

(v) Protection of 

Environmentally 

Sensitive Areas and 

Areas of Public 

Concern 

The development of landfast ice along the Chukchi Sea coast is highly variable 

with first new ice appearing in early October to as late as the end of November. 

Such landfast ice can provide an effective natural barrier against oil reaching 

Environmentally Sensitive Areas along the shoreline, and is therefore 

monitored carefully should any oil manage to survive the long transit from a 

blowout to the nearshore environment. Should oil enter and be captured within 

the landfast ice, any oiled ice that may break free of the shoreline would be 

tracked (as discussed earlier). Frequent “break-away” events can occur at 

almost any time throughout the freezeup and winter seasons. 

Prior to the formation of landfast ice, any oil that manages to survive and enter 

the nearshore environment will have been tracked and used to focus response 

resources (personnel and equipment) within the regions of highest potential 

impact. During this period, the UC’s, in cooperation with the State Historic 

Preservation Officer, NOAA, and resource trustees would monitor oil trajectory 

reports, identify resources at risk and issue appropriate restrictions and 

advisories to response personnel in the field. Environmental specialists 

together with resource trustee representatives will identify priority protection 

sites and develop a Shoreline Cleanup Plan, including appropriate cleanup 

techniques and endpoints using the NOAA ESI Maps, ACS Atlas Maps, and 

North Slope, Alaska Subarea Contingency. ACS, including NSSRTs, ACRTs, 

and VRTs, together with the OSRB, would establish protective booms at key 

locations to prevent or minimize the movement of oil into the most sensitive 

areas. It is assumed that strong northwesterly winds could result in the 

movement of oil to the nearshore environment between Peard Bay and 

Wainwright. This stretch generally consists of low energy beaches and the 

inlets to the Sinaruruk River and Wainwright Lagoon between Peard Bay and 

Wainwright. The shoreline south of Wainwright to Kasegaluk Lagoon consists 

of low-energy beaches, washover fans, protected tundra cliffs and lagoons. 

In the days to weeks before ice begins to form in this region, nearshore 

skimming operations are used to intercept oil and divert it into temporary quietwater holding areas and/or exclude it from entering sensitive inland or 

backwater wetlands. The OSRB (TF-5), having been relocated from its 

standby location, moves to a central location about a mile offshore. The barge 

provides additional boats, booms, and recovery equipment, decontamination 

facilities, communications, and a “safe haven” for boats and personnel in the 

event weather and/or ice concentrations force a cessation of nearshore 

operations. TF-5 consists of the OSRB with Lamor LSC-5 skimmers, one (1) 

47-ft skimming vessel with built-in Lamor LORS-2C brush skimmers, two (2) 

34-ft workboats with duplex skimmers and four (4) 249-bbl mini-barges. TF-5 

intercepts as much oil as possible before potential contact with shorelines and 

protection sites. 

Trajectory modeling predicts that oil escaping the offshore and nearshore “onwater” recovery operations could arrive at the shoreline at the earliest 

approximately 6 days following the blowout, if sustained winds from the WNW 

occur. The areas of immediate concern include the Wainwright Inlet and 

Sinaruruk River to Peard Bay. As a precaution in the event the wind shifts from 

the ENE to the WNW, response resources are mobilized to perform nearshore 

and shoreline containment and recovery operations (TF-5, TF-6, & TF-7). 

These operations would be initiated prior to Day 6 and continue until mid-day 

on Day 9 when the formation of new ice along the shoreline and in protected 

calm-water areas begins to block the movement of free oil toward the shore. 

Free oil recovery continues just offshore for another 24 hrs until ice formation in 

those deeper waters begins to degrade the collection of oil with the 47-ft 

skimming vessels with built-in Lamor LORS-2C brush skimmers. 

As freezeup along the shoreline continues, all nearshore response activities 

cease, the OSRB relocates to Peard Bay to continue nearshore recovery, and 

ACS crews focus upon the removal of oil and oiled debris that has been 

concentrated at (or stranded on) the beaches. 

A shoreline cleanup plan is approved by the UC; however, it is recognized that 

shoreline access will be limited as landfast ice begins to form throughout the 

NOAA ESI Maps 

ESI 14-16 

ACS Map Atlas

Sheets 251 to 255 

http://www.asgdc.

state.ak.us/maps/c

plans/subareas.ht

ml#northslope 

MESA 4 - Peard 

Bay/Franklin Spit 

MESA 5 - 

Kasegaluk Lagoon 

MESA 6 - Cape 

Lisburne/Cape 

Lewis 

Shell 

SR-2, SR-3, 

SR-4 

Shell 

OR-1A, 

OR-1B, 

OR-4A,OR-4B 

Shell 

OR-1A, OR-1B, 

OR-4A, OR-4B, 

OR-5A, OR-5B 

ACS 

C-13, C-14, 

R16 

ACS 

SH-2 through 

SH-12 

ACS SH-1 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-10 (CONTINUED) 

RESPONSE STRATEGY 

SUBSEA WELL BLOWOUT IN VARYING ICE CONDITIONS 

Shell 1-78 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC REQUIREMENT RESPONSE STRATEGY 

CROSS 

REFERENCE 

region. Should oil move into these nearshore waters and become entrained 

within the growing ice, the locations of the oiled regions will be recorded and 

monitored for ice movement. As ice thickness increases at these sites, stakes 

will be positioned to identify areas for on/in-ice recovery techniques. 

(vi and vii) Spill 

Containment, Control 

and Recovery 

Procedures 

Offshore: OSR operations offshore are initiated immediately upon notification. 

Once site characterization efforts are completed and safe operating zones are 

established, TF-1 (OSRV) moves into position a safe distance downstream of 

the blowout along with its boom handling 34-ft work boats and open-ocean 

booms. At the time of the blowout ice-free waters allow oil to flow toward the 

open swath of the U-boom after it surfaces. Approval to ignite free gas has 

reduced the high-risk red-zone to less than 1⁄2 n mi from the surfacing oil and 

gas. 

TF-1 consists of two (2) 34-ft workboats towing an open apex U-boom 

downstream of the oil surfacing from the blowout. The OSRV and one (1) 34-ft 

workboat operate in J-boom configuration with one (1) Transrec 150 skimmer 

or with two (2) Lamor LSC-5 skimmers and outriggers positioned behind the 

open apex U-boom. Oil moves into the U-boom and is concentrated and 

directed to the following skimming system. Frequent monitoring of vapor 

loadings at, and just forward of, the recovery operations is carried out to ensure 

that boom-tending work boats and the OSRV remain at a safe distance 

downstream of the blowout. 

While TF-1 (OSRV) and its recovery operations get underway, TF-3 (OST) and 

TF-5 (OSRB) are already underway toward the blowout from their staging 

locations. With 11,400 bbl of recovered oil storage capacity aboard the OSRV, 

the OST arrives on scene within 24 hr (several hours before the OSRV 

approaches holding capacity). Once the OST is on location, the OSRV is 

relieved by the VOSS (TF-2) equipped with one (1) Transrec 150 skimmer. 

The OSRV with its Transrec 150 skimmer pulled onboard, transits to the OST 

and lighters its contents. While the OSRV engages in lightering operations, the 

VOSS and one (1) 34-ft workboat in J-boom configuration continue recovery 

operations following the two (2) 34-ft workboats towing an open apex U-boom. 

OSRV is able to resume skimming operations in less than 8 hr, because 

lightering can be performed in less than 4 hrs and transit each way can be 

completed in 2-3 hr. After the first day, the OSRV operates on a rotation cycle 

with the VOSS. Each day following Day 1, the OSRV skims for 16 hr and the 

VOSS skims for the remaining 8 hr while the OSRV engages in 8 hr of 

lightering activities. The Transrec 150 skimmers have more than adequate 

capacity to recover the daily oil volume released from the blowout. 

The positioning of work boats and OSRV during darkness and other periods of 

low visibility is facilitated by the bright light associated with the burning of free 

gas over the blowout. In the event that surfacing gas is not ignited, infra-red 

imaging and lights mounted on the OSRV and workboats would be used to 

position response assets to intercept surfacing oil. Winds and currents are 

monitored frequently to ensure that the containment and recovery operations 

remain centered on the heaviest concentrations of oil downstream of the 

blowout. 

During the first few hours following the blowout, authorization had also been 

sought from UC for the use of chemical dispersants. The potential for 

dispersant application was needed for oil that would escape mechanical 

recovery operations downstream of the spill source when environmental 

conditions reduce the effectiveness of mechanical recovery methods. 

Dispersant application would also provide an important backup response option 

should wind/sea conditions or ice preclude the use of booms for mechanical 

recovery, and/or burning, or when important environmental resources are 

threatened by surface oil. 

On Day 2, the UC, working closely with the ARRT, grants authorization for the 

limited application of dispersants from a C-130 for oil that escapes mechanical 

operations (TF-1). While the request for dispersant use was initiated and under 

review, TF-4, consisting of a C-130, was mobilized to Barrow from MSRC in 

Shell 

OR-2A, OR-2B 

Shell 

OR-2B,OR-10 

ACS R-20 

Shell 

OR-2B, OR-10 

ACS R-20 

Shell 

OR-3A 

Shell 

TS-1, TS-2, TS-3 

Shell 

OR-8, 

OR-9A 

Shell 

OR-9A 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-10 (CONTINUED) 

RESPONSE STRATEGY 

SUBSEA WELL BLOWOUT IN VARYING ICE CONDITIONS 

Shell 1-79 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC REQUIREMENT RESPONSE STRATEGY 

CROSS 

REFERENCE 

Arizona. Approvals are initially limited to day-time operations only, and in water 

depths of 30 ft (10 m) or more, outside state territorial waters. Authorization is 

issued for dispersant use downstream of booming and recovery operations and 

as the primary response option when conditions preclude the use of booms for 

the concentration and containment of oil. 

TF-1, TF-2, and TF-3 offshore response operations continue well into the 

second week. Minor amounts of oil escape at times when work boats and 

booms are repositioned, and when they are subjected to brief periods of strong 

wind and sea conditions (winds >20 knots and waves of 4 to 6 ft). Because of 

the blowout location so far offshore, oil that escapes these operations 

weathers, degrades, and disperses naturally. In the unlikely event oil travels to 

shore, dispersant use and controlled burning are ruled out for the emulsions 

that may survive the long transit. The nearshore and onshore response 

activities focus on mechanical options for the physical recovery of oil/emulsion 

and the protection of environmentally sensitive areas. 

By Day 12, reductions in hours of daylight combined with dropping 

temperatures make it necessary to focus on oil surveillance and tracking 

methods suitable for lower light such as infrared radar. With the formation of 

grease ice and nilas (i.e., thin elastic layers of ice up to 10 cm thick that bend 

easily under pressure), TF-1 remains on location changing to work with short 

lengths of boom attached to outriggers. 

Beyond Day 14, the on-scene drilling support vessels with ice-breaking 

capabilities begin to break through the formation of pancake ice and large 

continuous layers of new ice. The ice management vessels patrol the area and 

move ice that can hamper normal drilling operations. They are able to manage 

large ice floes from interfering with relief well drilling, and they are able to 

minimize large ice floe interference with the ongoing oil recovery operations. 

By maintaining broken ice upstream of the blowout, the gas-lift from the 

blowout produces currents creating a relatively ice free radius around the 

surfacing oil and gas. Continued combustion of the free gas is therefore 

enhanced, minimizing any chances of flame extinguishment by heavy 

continuous ice layers. Oil surfacing at the blowout experiences less spreading 

(due to the presence of ice) and coalesces into pockets of oil. Some of these 

accumulations near the burning free gas ignite thereby increasing the 

elimination of oil at the source. 

TT-1 and TF-2 continue to alternate in recovery operations to work immediately 

downstream and at a safe distance from the blowout. Operating with only 

outriggers and/or short lengths of boom, the OSRV maneuvers at very slow 

speeds through the pockets of heaviest oil concentration. Because oil 

encounter rates are reduced, TF-1 is able to stay on location without reaching 

its holding capacity several days. 

When ice concentrations preclude even the limited use of short boom lengths 

and outriggers, TF-1 and TF-2 move into pocket recovery techniques involving 

onboard, over-the-side skimmers. The vertical rope mop skimmer (TF-1) is 

suspended from a crane out over pools of concentrated oil layers, and the 

umbilical Transrec 150 weir skimmers (TF-1 and TF-2) are deployed into 

pockets of oil confined by ice to gather oil. Such skimmers provide a means of 

recovering a range of oil viscosities, even in the presence of broken ice and/or 

slush. 

As ice concentrations continue to increase, the controlled burning of oil in fire 

boom ceases. The build-up of ice within the fire U-Boom configurations limits 

the amount of oil that can be contained, and heavy ice loadings can threaten 

the structural integrity of the booms. However, the burning of spilled oil within 

pockets created by ice remains a viable technique. The 34-ft workboats, 

previously used for towing boom, are used to deploy handheld igniters into 

such pockets of oil; and, the heli-torch (deployed from a helicopter) is used to 

ignite oil that has been concentrated and kept from spreading by ice. Even the 

34-ft work boats are used in relatively light ice concentrations for the recovery 

and temporary storage of oil. Small over-the-side skimmers (brush and/or disc) 

are positioned from these boats into pockets of oil while the recovered fluids 

are stored in drums, totes, mini-barges, and/or bladders. 

Shell 

OR-2B, OR-10 

OR 3A 

ACS 

R-20B (modified) 

Shell 

TS-1, TS-2, 

TS-3 

Shell 

OR-2C, OR-2D, 

OR-2E 

Shell 

OR-2C, OR-2D, 

OR-2E 

Shell 

OR-2C, OR-2D 

OR-2E 

Shell 

OR-7, 

ACS B-3 

Shell 

OR-2C, OR-2D, 

OR-2E 

OR 5A, OR-5B 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-10 (CONTINUED) 

RESPONSE STRATEGY 

SUBSEA WELL BLOWOUT IN VARYING ICE CONDITIONS 

Shell 1-80 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC REQUIREMENT RESPONSE STRATEGY 

CROSS 

REFERENCE 

As freezeup continues and blowing snow begins to accumulate on young ice, 

the pockets of oil become more difficult to find and access. By Day 21 it is no 

longer possible to conduct containment and recovery operations safely and 

effectively downstream of the blowout. All work boats, booms, mini-barges, 

etc. are loaded back aboard the OSRV (TF-1) and prepared for transit back to 

the mainland. The drillship (for relief well), anchor-handler (VOSS), and icebreakers remain on location making every effort to sustain the burning of 

surfacing oil and gas at the blowout. A heli-torch and/or handheld igniters are 

used to reignite vapors if flames are extinguished by the ice. Downstream of 

the burning oil/gas there is an accumulation of unburned oil and burn residue. 

The deposition of oil and burn residue within the field of broken ice is confined 

to a relatively narrow swath created by the natural containment of the 

surrounding ice. Wherever oil accumulations are evident at the surface, aerial 

ignition techniques are used to burn that oil in place. When accessible, TF-1 

recovers burn residue from aerial ignition operations. 

During the last week (prior to Day 30 and control of the blowout) efforts to burn 

oil in place include the monitoring and marking of oiled ice and burn residue. 

Using the same techniques implemented throughout the response (with 

tracking buoys, satellite monitoring of ice movement, etc.), the swath, speed, 

and direction of potentially oiled ice is documented and updated on charts. The 

delineation of any ice that could contain oil or unburned oily residue is used 

throughout the winter to ensure that over-flights in the spring are directed to 

those locations as soon as surface melt and breakup conditions begin. The 

dynamic nature of the continually moving and ridging offshore ice fields make it 

difficult to mount any significant mid-winter on-ice recovery operations; to the 

extent that it is safe to land on the ice during the winter, efforts can be made to 

confirm the nature and extent of any oiled ice/snow, to mark and rank the 

severity of any oiling, and to remove or burn any oil that can be handled quickly 

and safely. 

Nearshore and Shoreline: TF-5, TF-6, and TF-7 are put on alert shortly after 

notification of the blowout. Oil surveillance and tracking efforts are used to 

monitor the nature and extent of oil released from the blowout, and to give 

advanced warning of whether, when, and where oil is projected to impact 

environmentally sensitive areas. 

Although it is unlikely, if it is determined that oil from the blowout could impact 

the mainland, TF-5 (OSRB staged within 480 n mi of the Chukchi Sea 

nearshore zone) would be mobilized and relocated to a temporary mooring 

about a mile off the shoreline of the projected impact zone. Trajectory 

modeling predicts 6 days as the earliest possible time oil could contact 

shorelines between Wainwright and Peard Bay, and only in the unlikely event 

sustained winds from the WNW occurs. ACS mobilizes crews and equipment 

from Prudhoe Bay to implement shoreline protection (TF-6) and recovery 

operations (TF-7). TF-5, TF-6 and TF-7 arrive on scene within 96 hr. 

ACS mobilizes response personnel to be on location at their respective staging 

areas awaiting updates on locations and times for potential shoreline landfall by 

oil. TF-5 stages the OSRB to perform nearshore free-oil recovery. TF-6 

deploys to initiate priority protection booming and TF-7 positions crews and 

equipment for shoreline cleanup operations. Sufficient numbers of trained 

personnel are brought in to support 12-hr shifts until darkness and/or other 

conditions preclude the effectiveness or need for around-the-clock operations. 

ACS crews, as well as the OSRB, are prepared to fulfill all “decontamination” 

needs for personnel, boats, and equipment. 

A secondary objective for TF-5 (OSRB) is to provide logistical support for the 

shoreline protection and recovery activities of TF-6 and TF-7. The OSRB 

serves as a large, shallow-draft platform that can help sustain nearshore 

operations by providing a safe haven for personnel, small vessels and minibarges; communications; deck space to store boats; equipment and supplies; 

refueling capabilities; decontamination facilities; and storage for recovered oil 

and oily debris. 

Shell 

OR-7 

ACS B-3 

Shell 

OR-7 

ACS B-3, 

B-6 

Shell 

TS-1

ACS T-4A 

Shell 

TS-1, TS-2, TS-3 

ACS T-4, T-4A, 

T-5 

ACS LE-3 

Shell 

L-3 

ACS S-4 

Shell S-4 

Shell 

OR-1A, OR-1B 

OR-4A to OR-4D, 

OR-5A, OR-5B 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-10 (CONTINUED) 

RESPONSE STRATEGY 

SUBSEA WELL BLOWOUT IN VARYING ICE CONDITIONS 

Shell 1-81 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC REQUIREMENT RESPONSE STRATEGY 

CROSS 

REFERENCE 

Key equipment aboard the OSRB (TF-5) includes: two (2) Lamor LSC-5 

oleophilic skimmers; one (1) 47-ft vessel with two (2) Lamor LORS-2C 

skimmers; three (3) 34-ft work boats; four (4) mini-barges; pedestal crane; 

ocean boom; and hydro-fireboom. TF-5 intercepts oil approaching the 

mainland. These operations remain within a few miles of shore, involve 

temporary storage in mini-barges, and transit to the OSRB for lightering of 

recovered oil from the mini-barges. 

TF-6 consists of ACS-mobilized personnel and response equipment mobilized 

by ACS from Prudhoe Bay for the setting of deflection and exclusion booms at 

key locations to keep oil from entering previously identified priority protection 

sites. As necessary, TF-6 also utilizes the OSRB for support, fuel, 

decontamination, etc. TF-6 pre-staged equipment includes: two (2) landing 

craft; two (2) 24-ft work boats; 10,000-ft conventional boom; 10,000-ft coastal 

boom (6,000-ft from OSRB and 4,000-ft pre-staged); and 4,000-ft shore seal 

boom. 

TF-7 primarily operates from and along the shoreline, involves booming and 

skimming operations along the mainland, beach cleaning operations, and 

temporary storage/disposal of recovered oil and oily debris. TF-7 consists of 

personnel and vessels mobilized by ACS. Available equipment includes: twenty 

(20) oleophilic skimmers; fifty (50) 2,500 gal folding tanks; eight (8) ATVs; 

twelve (12) 5,000-gal folding tanks; one (1) IMO tank; and twelve (12) rope mop 

skimmers. As needed, ACS mobilizes four (4) Type A and B workboats and 

two (2) Type C workboats to support TF-6 and TF-7. 

TF-5, TF-6 and TF-7 are utilized in this late-season blowout scenario from the 

time oil first enters the nearshore/shoreline environment (about Day 6) until 

freezeup and the formation of landfast ice which then keeps oil from impacting 

the barrier islands and mainland. TF-7 (Shoreline Cleanup), however, 

continues to collect and recover oil and oily debris until such oil is no longer 

recognizable or recoverable on the beaches or back-water areas. 

ACS C-13, C-14, 

C-15 

ACS R-16, 

SH-2 through 

SH-12 

Shell 

OR-1A, OR-1B 

OR-4A to OR-4D, 

OR-5A, OR-5B 

ACS 

SH-2 to SR-12 

(viii) Lightering 

Procedures 

Offshore: The lightering of recovered fluids from the TF-1 OSRV and TF-2 

VOSS offshore to the TF-3 OST is accomplished with rotation cycles beginning 

after Day 1 that are completed within a 24-hr period for each full cycle. The 

OSRV skims for 16 hr and lighters for the other 8 hr while the VOSS with the 

34-ft workboats maintain recovery operations with containment systems 

downstream of the surfacing oil. The OST is maintained in close proximity, 

typically a mile or two, from the recovery operations so that transit times to and 

from the OST are kept to a minimum. The transfer of recovered fluids (after 

decanting forward of the skimmers) is accomplished using BAT; that is, annulus 

injection of water at a suction head to produce a low-friction transfer of viscous 

fluids between the skimmer’s onboard storage and the OST. With high-volume 

transfer pumps and annulus injection, each transfer from the OSRV to the OST 

should require only 3 to 4 hr with an additional 3 to 4 hr factored in for set up 

and transit to and from the OST. The VOSS lighters to the OST when the 

OSRV resumes recovery operations. Using high-volume transfer pumps, the 

VOSS offloading requires less than the 16 hr available to complete transfer 

operations and transit to and from the OST. 

Nearshore: Recovered fluids from TF-5’s skimming boats are actively 

transferred to mini-barges during the skimming operations. The 249-bbl minibarges are lightered in approximately one hour using Lamor GTA 50 pumps to 

transfer viscous fluids to the OSRB. Other recovery operations at and on the 

shoreline will likely involve relatively small volumes of oil. These fluids and/or 

oily solids can be transferred as time and vessel- or helicopter-availability allow. 

Some of these recovered materials could be stored onshore, if necessary, in 

durable containers until they can be retrieved during the winter or following 

summer. 

For planning purposes, the OSRB has a storage capacity of 17,000 bbl. This 

volume is significantly greater than the amount of oil that would likely escape 

offshore operations, survive the long journey to shore, and be recovered.

Shell 

OR-3A and OR-6 

Shell OR-3A 

Shell 

OR-6 

ACS D-2 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-10 (CONTINUED) 

RESPONSE STRATEGY 

SUBSEA WELL BLOWOUT IN VARYING ICE CONDITIONS 

Shell 1-82 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC REQUIREMENT RESPONSE STRATEGY 

CROSS 

REFERENCE 

(ix) Transfer and 

Storage of Recovered 

Oil/Water; Volume 

Estimating Procedure 

TF-1 OSRV and TF-2 VOSS are equipped with sensors to indicate liquid levels 

in its holding tanks; transfer pumps are calibrated; decanting is monitored 

closely and volumes of discharged water accounted for. Careful records are 

kept on the volumes of fluids transferred to the OST. The OST transfers are 

also manifested and logged with the assistance of the Waste Management 

Team. 

Storage and transfer procedures are maintained aboard the OSRB, and 

accurate records are maintained involving liquid and/or solid waste transferred 

from the mini-barges or other small vessels involved with the 

nearshore/shoreline cleanup operations. 

Shell 

DP-1, OR-3A 

OR-6 

(x) Plans, Procedures, 

and Locations for 

Temporary Storage 

and Disposal 

A Waste Management Plan is developed in order to: (1) fill out and sign 

manifests, (2) measure liquid and other waste, and (3) show 

procedures/documentation that meets regulatory requirements. 

Non-liquid oily wastes are classified and disposed of according to classification. 

Non-oily wastes are classified and disposed of accordingly. 

Recovered fluids stored onboard the OST are disposed of outside the U.S., 

either at Shell Group refineries or other third-party processors. Such disposal 

is carried in accordance with Shell environmental policy and relevant local laws 

and regulations (see Section 1.6.10). 

Shell 

DP-1 

ACS D-1, 

D-3, D-4 

(xi) Wildlife Protection 

Plan 

Containment and exclusion booming are deployed by ACS (NSSRT, VRTs and 

ACRTs) to protect priority areas. Landfast ice, if present, also provides 

protection, keeping oil from impacting barrier islands, sensitive waters behind 

those islands, and the mainland. This protection of sensitive habitats by a 

natural ice barrier, however, is not stable along most of the Chukchi Sea 

shoreline. Prevailing winds with a strong component out of the east can cause 

the landfast ice to break free of the shoreline and drift out to sea or toward the 

NE running parallel to the shoreline. Should oil pass from the offshore 

environment toward shore during this period, every effort will be made to work 

within the narrow nearshore ice free to moderate ice concentration period to 

limit the spread of oil and recover it as quickly as possible. 

Should oil be encapsulated within the landfast ice and then “break-away”, 

tracking buoys and satellite monitoring of the oiled ice will be used to prepare 

appropriate recovery/burning techniques should that oil be exposed near 

sensitive environments later on. Encapsulation of oil in ice reduces the 

potential that wildlife will be exposed to the spill. 

A wildlife protection plan, permits, and strategies would be developed, 

implemented, and coordinated with the ACS to manage birds and mammals 

that become oiled at sea or in the nearshore/onshore environments. 

ACS C-13, C-14, 

C-15 

Shell 

TR-1 

ACS T-4A 

ACS W-1 

W-2A, W-2B 

W-5, W-6 

(xii) Shoreline Cleanup 

Equipment 

A shoreline protection and cleanup plan is developed as soon as possible 

reflecting the nature and amount of oil that could enter the nearshore 

environment. Depending upon the location and timing of that threat, a 

shoreline assessment is conducted to understand all potential exposures to oil. 

A plan, with and without the formation/presence of landfast ice, is drawn up and 

submitted to the UC. 

Depending upon the nature and amount of oil coming ashore, the least 

damaging response options are used to keep oil away from sensitive habitats, 

plants and animals, and to minimize any damage to those resources. While the 

distances that oil would need to travel to impact land are quite great in the 

Chukchi Sea and weathering of that oil would occur, the potential for controlled 

burning of oil and oiled debris would be given serious consideration. As long 

as burns are conducted at least 3 mi from any populated area, and satisfy all of 

the constraints imposed by the UC and the In Situ Burning Guidelines for 

Alaska, it may be possible to eliminate beached oil/debris with overall minimal 

impact to the environment. 

ACS 

SH-1 

Shell 

SR-1 

ACS 

SH-10 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-10 (CONTINUED) 

RESPONSE STRATEGY 

SUBSEA WELL BLOWOUT IN VARYING ICE CONDITIONS 

Shell 1-83 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC REQUIREMENT RESPONSE STRATEGY 

CROSS 

REFERENCE 

During the winter months, a shoreline cleanup plan is developed and submitted 

to the UC in the event that oil shows up during and/or following breakup. As 

soon as practicable, SCATs monitor the shorelines and adjacent tundra and 

then establish clear objectives and procedures to minimize impacts. Priorities 

are established, and cleanup techniques are chosen based on shoreline type, 

degree of oiling, and resources at risk. 

Representative shoreline cleanup tactics include: 

 Passive recovery of oil using snare boom. 

 Manual removal of oil and oily debris. 

 Deflection booming with skimming or trenching to contain and recover 

floating oil/emulsion. 

 Deluge of minor to moderately oiled shoreline. 

 Burning or removal of oiled debris and vegetation, 

 Natural recovery for those areas where residual staining may remain, but 

further recovery would cause more harm than good. 

ACS SH-1, 

SH-2 through 

SH-12 

Shell 

SR-5, SR-6, SR-7, 

SR-8, SR-9, SR10 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

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Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

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95-2000.01-25.201-001/09-018 Rev. 0

RESPONSE STRATEGY 2 

FUEL TRANSFER RELEASE DURING SUMMER MONTHS 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-86 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

THIS PAGE INTENTIONALLY LEFT BLANK 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-87 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

RESPONSE STRATEGY PARAMETERS 

The following response strategy describes methods and equipment that could be used in response to a 

hypothetical diesel spill during a fuel transfer from a fuel barge to one of Shell’s exploration drilling 

locations during summer months. 

For the purposes of the strategy, the release occurs during a fuel transfer from a barge or supply boat to 

the drillship. Assumptions for the discharge are based on 33 CFR 154.1029(b). The diesel release is 

assumed to occur because of transfer hose failure. The spill duration is assumed to be 5.5 minutes, 

resulting in the release of 2,000 gal (48 bbl) of diesel. Approximately 10 percent of the spill is contained 

on the deck of the drillship, and 90 percent of the spilled diesel enters the water. The maximum targeted 

recovery volume is 3,132 gal (75 bbl). 

The direction of the wind and ocean current will have limited effect on the recovery of diesel because 

containment boom will be pre-deployed prior to the fuel transfer. The current is assumed to be 0.75 knots 

to the NE. The sea conditions are assumed to be typical 1.5 to 2.0 ft wave height. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-88 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-11 

FUEL TRANSFER RELEASE DURING SUMMER 

RESPONSE STRATEGY 

ADEC 

REQUIREMENT RESPONSE STRATEGY 

CROSS 

REFERENCE 

(i) Stopping 

Discharge at 

Source 

The fuel barge is positioned adjacent to the drillship to conduct a fuel transfer. The 

fuel transfer is monitored by a dedicated response team equipped with an OSRV 

and three (3) 34-ft work boats. 

A pre-transfer conference is conducted between the fuel vessel, the drillship, and 

response team personnel. During the transfer, the fuel vessel operator, an officer in 

the wheelhouse of the fuel barge tug, and the hosewatch from the drillship remain in 

both visual and radio contact. Additionally, the response team pre-deploys 

containment boom down current of the fueling operation. 

During the fuel transfer, the fuel hose close to the deck rail of the drillship fails. The 

failure is assumed to be a complete rupture of the hose. 

For the purposes of the strategy, the hosewatch discovers the hose failure after 5 

minutes. The hosewatch activates the emergency shutdown, stopping the pump on 

the fuel barge. At T + 5.5 minutes, fuel transfer has stopped. 

The On-Site Shell Drill Foreman assumes role of IC. He activates the drillship 

response team. The response team from the drillship lifts a section of hose onto the 

deck, attempting to prevent any further draining of fuel. The end of the hose is 

sealed. 

The On-Site IC ensures notifications to appropriate state and federal agencies are 

performed. ACS (in Prudhoe Bay) is put on standby. 

Appendix C of this 

C-Plan 

Table 1.1-1, 

Section 1 of this 

C-Plan 

Tables 1.1-2, 

Table 1.2-1 and 

Table 1.2-2 

(ii) Preventing or 

Controlling Fire 

Hazards 

Throughout the first few minutes of the spill, the Site Safety Officer verifies that all 

sources of ignition are shut down or removed from the area. The Site Safety Officer 

also reminds personnel that the vessel diagram has the location of all fire 

suppression equipment. 

The Site Safety Officer then provides access zone information and determines PPE 

requirements. Monitoring protocol is established for all work areas to ensure 

personnel protection. The monitoring protocol establishes safety zones according to 

applicable OSHA and fire hazard standards. 

Shell 

S-1 

through 

S-4 

Well Control Plan Not applicable. 

(iv) Surveillance 

and Tracking of Oil 

To ensure that the entire spill is recovered, diesel movement is tracked using visual 

observations from the drillship, fuel barge, and support vessels. 

After recovery operations, one of the three 34-ft work boats performs 

reconnaissance of the area down-current of the release using visual methods and a 

handheld FLIR unit to monitor the spill’s movement. 

Shell 

TS-1, TS-2 

(v) Protection of 

Environmentally 

Sensitive Areas 

and Areas of Public 

Concern 

Diesel is recovered in open water in compliance with the Site Safety Plan, and a 

shoreline assessment/recovery plan is not activated. This is validated through 

overflights and surveillance. 

If necessary, NOAA ESI Maps, ACS Atlas Maps, and the North Slope Subarea 

Contingency Plan are used to identify areas of major concern. Nearby priority 

protection sites are identified. ACS is put on standby to deploy exclusion booms if 

necessary at the nearest shoreline. 

NOAA ESI Index 

Maps ESI 14-16 

ACS Map Atlas

Sheets 223 -256 

http://www.asgdc.

state.ak.us/maps/

cplans/subareas.h

tml#northslope 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

TABLE 1.6-11 (CONTINUED) 

FUEL TRANSFER RELEASE DURING SUMMER 

RESPONSE STRATEGY 

Shell 1-89 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

ADEC REQUIREMENT RESPONSE STRATEGY Cross Reference 

(vi and vii) Spill 

Containment, Control, 

and Recovery 

Procedures 

TF Descriptions:

TF-1: Primary response is provided by personnel and equipment stationed with 

the drillship. This equipment includes an OSRV; personnel and equipment 

stationed with the drillship; 11,400 bbl capacity; one (1) Transrec 150 skimmer; 

two (2) Lamor LSC-5 skimmers; one (1) duplex mini-brush/disc skimmer; one 

(1) vertical rope mop skimmer; three (3) 34-ft work boats; and containment and 

fire boom. The OST is not mobilized because there is sufficient storage 

capacity for the recovered fluids on the OSRV. 

TF-2: ACS Shoreline Protection Task Forces are put on standby to deploy 

exclusion booms at priority sites. The IC, OSRV Captain, and Site Safety 

Officer communicate throughout the recovery operations. 

Recovery Timeline:

T = 0 Minutes. Transfer hose ruptures. TF-1 has previously deployed two (2) 

work boats towing boom in a U-shape formation down-current of the fuel 

transfer operations. 

T + 5.5 Minutes. Fuel transfer operations have stopped. Site Safety Officer 

assesses access and PPE requirements. The drillship and fuel barge detach 

and separate. Recovery operations begin. Sorbents are used to clean the deck 

of the drillship. 

T + 20 Minutes. The work boats position the U-boom to contain the spilled fuel, 

and then proceed to the OSRV for recovery. The OSRV utilizes either a minibrush skimmer or rope mop to collect the contained diesel. Recovered 

fuel/water mixture is stored in the OSRV. 

End of Day 1. Recovery operations have stopped. Approximately 75 bbl of 

liquid (fuel/water) is collected and stored in the OSRV. 

Shell 

OR-2A, OR-2B 

OR-5A, OR 5B 

ACS C-13, C-14, 

C-15 

Shell 

OR-5A (modified 

for OSRV) 

Shell 

S-2, S-3 

Shell 

OR-5A (modified 

for OSRV) 

(viii) Lightering 

Procedures 

On a non-emergency basis the recovered diesel is lightered from the OSRV to 

the OST tanker located within 240 n mi. 

Shell 

OR-3A 

(ix) Transfer and Storage 

of Recovered Oil/Water; 

Volume Estimating 

Procedure 

The volumes of stored oil emulsion and free water are gauged with ullage tape 

and recorded on waste manifests 

Shell 

TS-2 

(x) Plans, Procedures, 

and Locations for 

Temporary Storage and 

Disposal 

A Waste Management Plan is developed in order to: (1) fill out and sign 

manifests; (2) measure liquid and other waste; and (3) submit a plan to the UC 

for waste management. 

Non-liquid oily wastes are classified and disposed of according to classification. 

Non-oily wastes are classified and disposed of accordingly. 

Recovered fluids potentially transferred to West Dock would be disposed of 

either using available injection wells or by reprocessing in available production 

facilities as discussed in Section 1.6.10. 

Recovered fluids stored onboard the OST would be disposed of outside the 

U.S., either at Shell Group refineries or other third-party processors, in 

accordance with Shell environmental policy, and relevant local laws and 

regulations. 

Shell 

DP-1 

ACS D-1 

ACS D-2, 

ACS D-3 

Section 1.6.10 of 

this C-Plan 

(xi) Wildlife Protection 

Plan 

ACS is mobilized, if necessary, to conduct wildlife monitoring immediately. If 

necessary, deterrents to protect animals are put in place at the spill scene 

during recovery operations. 

The International Bird Research and Rescue Center is put on standby in the 

event the wildlife treatment facility is required. 

ACS W-1 

ACS W-2, W-2B, 

ACS L-6 

(xii) Shoreline Cleanup 

Plan 

Fuel is recovered or dissipates prior to encountering any shoreline. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-90 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

RESPONSE SCENARIO 2 

ADEC SPECIFIC SCENARIO 

WORST-CASE DISCHARGE – Chukchi Sea 

UNCONTROLLED SUB-SEA WELL RELEASE 

DURING SUMMER MONTHS 

RESPONSE SCENARIO PARAMETERS 

This WCD scenario was developed to specifically describe a response that addresses each of the ADECcompliant regulations of 18 AAC 75.425. Although Section 1.6.13, Spill Response Scenarios, Scenario 1,

Response Scenario / WCD Scenario, Offshore Subsea Well Blowout During Summer Months of this plan 

provides a state-compliant WCD scenario, the following is provided at the specific request of ADEC. This 

scenario is not a guarantee of performance. Rather, it is an illustration of the spill and response 

conditions that could be expected in the event of a loss of primary well control. The scenario makes 

certain assumptions about spill conditions and describes equipment, personnel and strategies that would 

be used to respond to a WCD. 

In the unlikely event primary well control was lost, the well would be secured and physically shut-in in less 

than three minutes. This scenario and response timeline are presented for the purposes of 

demonstrating Shell’s response capabilities and meeting contingency planning requirements only. In a 

real event, spill response decisions depend on a host of considerations including: safety, weather and 

other environmental conditions. It is the discretion of the IC and persons in charge of the spill response to 

select any sequence or take as much time as necessary to employ an effective response without 

jeopardizing personnel safety. As in any incident, personnel safety is the highest priority. 

Simulated weather and sea conditions, oil characteristics, aerial deposition, oil trajectory modeling and 

resources of importance are as described in Scenario 1 (pages 1-51 thru 1-54). The difference between 

this response scenario and Scenario 1 is that the well location has been changed to Burger F and the 

scenario duration is 15 days instead of 30 days. All other parameters are as describe in Scenario 1 (see 

Table 1.6-3). 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-91 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-12 

ADEC SPECIFIC SCENARIO 

UNCONTROLLED SUB-SEA WELL RELEASE DURING SUMMER MONTHS 

INITIAL CONDITIONS 

Spill Location Shell Exploration Well, drilled by the drillship Frontier Discoverer at the Burger F wellsite 

(71o 20’ 14” N, 163o 12’ 22” W) 

Date August 7 

Duration 15 Days 

Type of Spill 25 to 30° API Crude Oil 

Source of Spill Loss of well control at the mudline in 140 ft of water 

Quantity of Oil Spilled RPS Volume = 5,500 bopd x 15 days = 82,500 bbl 

No deductions were made to the RPS volume to account for burning or evaporation. 

Emulsification Factor and 

free water pickup 

1.54 x 82,500 bbl = 127,050 bbl. This is the oil emulsion volume created by skimming/pumping 

operations. Assuming that approximately 20% of the original oil volume recovered is added to this 

mix as free water (approximately 16,500 bbl), the total volume of fluids (emulsion + free water) 

could conceivably require approximately 143,550 bbl. 

Average Wind Speed 10 to 11 knots 

Wind Direction Prevalent winds are from the ENE. Wind direction and velocity data were derived from 

measurements collected by Shell in the Chukchi Sea from 1980, 1982, and 1983 during the period 

June 15 to November 15. The ocean current generally flows to the NNE. The trajectory depicted 

on Figure 1.6-8 was based upon the actual measured winds at the nearest station to the spill 

location from August 7 to September 6 of 1980. 

Based upon collected wind data, three primary wind directions emerge with a daily persistence 

greater than 10%: ENE, NE, and E. On average these wind directions occurred at the following 

measured frequencies for the June through November period: 

 14.6% ENE 

 13.8% NE 

 13.0% E 

Air Temperature Average daily maximum and minimum temperatures were obtained from the Western Regional 

Climate Center website: http://www.wrcc.dri.edu/cgi-bin/cliMAIN.pl?ak0558 

The average daily maximum and minimum air temperatures for August are 46°F and 34°F, 

respectively. 

Surface Current The ocean current data used for trajectory modeling was based upon the MMS annual means 

analysis of Haidvogel, Hedstrom, and Francis (2001) coupled ice-ocean model. 

Visibility Variable 

Surface The prospect is located in federal waters of the Chukchi Sea. Wave heights are typically 1.5 to 

2.5 ft with no ice present. The OSRV and VOSS are located within 10 n mi of the drillship. Based 

upon a realistic average transit speed of 10 knots, the OST is located in the Chukchi Sea to 

ensure its arrival at the recovery site within 24 hr of mobilization. The OSRB is located on the 

Chukchi Sea Coast in the nearshore zone. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-92 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-12 (CONTINUED) 

ADEC SPECIFIC SCENARIO 

UNCONTROLLED SUB-SEA WELL RELEASE DURING SUMMER MONTHS 

INITIAL CONDITIONS 

Trajectory Modeling of the oil plume trajectory was conducted by ASA using historical wind data and the MMS 

hydrodynamic ocean-ice current model. 

The trajectory model uses OILMAP software developed by ASA. Based on environmental conditions 

including predominant winds and currents, the output from this model shows estimated oil concentrations 

and slick movement over time. Additionally, ASA’s SIMAP software provides probabilities and estimated 

contact timing if oil were to reach shorelines from a potential blowout. The ASA trajectory models include 

algorithms for spreading, evaporation, emulsification, and entrainment, all of which are input parameters 

based on the properties of the crude oil. The results provide graphical representation for instantaneous or 

continuous release spill volumes on water through time. 

Input parameters include a spill volume of 5,500 bopd using ANS crude oil with API gravity of 30.6°. The 

ASA trajectory model was run using historical wind data collected by Shell for the initial blowout date and 

duration. The figure shows the model at 72 hrs into the spill and identifies the predicted surface oil 

concentrations from the blowout and slick direction. 

The simulated oil discharge of 5,500 bopd is ejected through a 6-inch ID well at the mudline, in water 

approximately 140 ft deep. Within minutes of the well release, oil rises to the surface of the sea. The oil 

plume migrates to the southwest as a function of water currents and the direction of the prevailing wind. 

Within 72 hrs, if the oil remains uncontained and not recovered, the leading edge of the plume would 

extend roughly SW of the spill site for approximately 32 n mi. Refer to Figure 1.6-8. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-93 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-13 

ADEC SPECIFIC SCENARIO 

UNCONTROLLED SUB-SEA WELL RELEASE DURING SUMMER MONTHS 

ADEC 

REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE 

(i) Stopping 

Discharge at 

Source 

As soon as the well kicks, subsurface well control, such as increasing the drilling 

mud weight, is initiated. Initial actions, including the attempted closing of the BOP 

rams fail. Other well control attempts are unsuccessful, and the Burger F 

exploration well is now classified as an “unobstructed” well release (T= 00 hours). 

The well has a continuous flow rate that will deposit at the surface a total of 5,500 

bopd. 

ACS Volume 3 

ICS 

Shell 

LE-2 

The On-site Shell Drilling Foreman notifies the On-Scene Incident Commander 

(OSC) who notifies response personnel on the OSRV accompanying the drilling 

ship and activates ACS. Notifications to appropriate state and federal agencies, 

including MMS, are performed. The NRC is notified and the IMT is activated. 

Table 1.1-2, 

Section 1 of this 

Plan. 

The Shell OST and the Nearshore OSRB are also notified and immediately 

mobilized. The Shell OST is positioned within a safe distance and within close 

proximity to the well release.

ACS 

A-1, A-2 

Well control is discussed in Section 1.6.3 of this plan. The drillship is undamaged 

and, after Safety analyzes the situation, a decision is made to move the drillship 

away from the area of the surfacing well release. 

(ii) Preventing or 

Controlling Fire 

Hazards 

Throughout the first few hours of the spill, the Site Safety Officer verifies that all 

sources of ignition are shut down or removed from the area. The Site Safety Officer 

provides access zone information and determines PPE requirements. Monitoring 

protocol is established for all work areas to ensure personnel protection. The 

monitoring protocol establishes safety zones according to applicable OSHA and 

fire hazard standards. 

Shell S-1 

through S-4 

Consideration is given to pull anchors and move the drillship from the well release. 

Once the drillship has been moved, the FOSC approves the ignition of the 

surfacing plume for safety reasons.

ACS S-1 

through S-6 

Well Control Plan Well control is consistent with that described in Scenario 1 with the exception that 

well site is Burger F. The Blowout Contingency Plan is initiated, of which relief well 

drilling is one sub-component. 

T + 4 Days. Although available on-site, for planning purposes, specialty equipment 

and personnel required for secondary well control arrive at the drillship. Plans are 

to close the blind shear rams, located on the BOP stack, remotely using an ROV to 

activate the sub-sea control panel. Hypothetically, on arrival, it is discovered the 

ROV was damaged in shipping. Repair parts for the ROV are ordered, but the 

estimated time of arrival (ETA) is several days. Other options are considered, 

including a diver and diver support requirements. 

T + 5 Days. The diver option is rejected due to safety concerns. 

T + 7 Days. ROV repair parts arrive in Barrow, but due to inclement weather (poor 

visibility), it is not transferred to an awaiting vessel at Wainwright. 

T + 13 Days. ROV repair parts arrive at the drillship and the remotely operated 

vehicle (ROV) is repaired. 

T + 15 Days. ROV successfully activates the sub-sea BOP control panel and 

activates the blind shear rams on the BOP stack. The well bore is secured and the 

discharge is stopped. 

Section 1.6.3 of this 

plan 

(iv) Surveillance 

and tracking of Oil Oil movement is tracked using a combination of visual observations and remote

sensing techniques. Within the first hours of initial notification of the well release, a 

FLIR equipped aircraft is deployed. Response vessels also deploy buoys with 

transmitters. Both systems are capable of real-time tracking of the leading edge of 

the oil. Oil location information is digitized and transferred to the IMT and OnScene Commander for response planning and trajectory modeling. 

Satellite tracking of oil is initiated (RadarSat or EnviroSat) and coordinated with the 

use of tracking buoys. 

Shell 

TS-1, TS-2, TS-3 

ACS 

T-4, T-5 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-94 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-13 (CONTINUED) 

ADEC SPECIFIC SCENARIO 

UNCONTROLLED SUB-SEA WELL RELEASE DURING SUMMER MONTHS 

ADEC 

REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE 

The NOAA and/or ASA OilMap are requested to provide trajectories based on wind 

speed and direction. Vector addition and trajectory modeling are used to forecast 

oil and movement based upon field measurements. 

(v) Exclusion 

Procedures; 

Protection of 

Sensitive 

Resources 

The EU's Cultural Resource Specialist and State Historic Preservation Officer issue 

an advisory. The NOAA ESI maps, ACS Map Atlas, and the North Slope Sub-Area 

Contingency Plan are used to identify areas of major concern. 

The initial oil trajectories have resulted in the primary spill recovery efforts being 

focused to the SW of the drill site. Based upon historical wind data and the MMS 

current model, the ASA trajectory predicts that without containment and recovery 

the earliest potential oil contact with shorelines would not occur until Day 25. 

However, in the unlikely event strong, sustained winds develop out of the WNW, 

trajectory modeling estimates that six (6) days is the earliest possible time oil could 

reach shore. As a precaution, ACS mobilizes to implement protection strategies at 

priority resource sites. In addition to ACS, the OSRB is mobilized from its staging 

location to the Peard Bay vicinity to support nearshore protection and recovery if 

sustained WNW winds develop. 

Based on trajectory calculations and oil tracking, a 50-mi section of coastline 

consisting of barrier islands and exposed mainland is identified as the potential 

impact zone. Protection sites (PS-168, PS-169, PS-170, PS-171, PS-172, PS-173 

and PS-174) are identified along the Chukchi Sea coastline for priority exclusion or 

deflection booming. Trajectory model runs are performed throughout the response 

using field-collected data to track oil and assess protection priorities. 

The NOAA ESI Maps, ACS Atlas Maps, and the North Slope Subarea Contingency 

Plan are used to identify areas of major concern. The EU Leader coordinates with 

resource agency representatives and local representatives to prioritize resource 

sensitivities and activate protection guidelines. The Cultural Resource Specialist 

and SHPO coordinate to identify sites of concern and advise Operations of 

necessary site protection needs. 

The EU begins development of a shoreline protection plan, and SCAT are placed 

on standby. 

T + 4 Days. ACS Shoreline Protection Task Forces deploy deflection or exclusion 

booms at PS-174 to protect the Sinaruruk River; PS-173 and PS-172 to protect 

lagoons at Point Belcher; PS-171 at the entrance of Kugrua Bay; PS-170 to protect 

an unnamed river on the south shore of Peard Bay; and PS-169 and PS-168 to 

protect unnamed rivers. The OSRB is mobilized and positioned to be centrally 

located to perform nearshore free oil recovery and support task forces and 

shoreline protection sites. 

ACS has the capability of mounting an effective shoreline response to supplement 

the primary response operation as necessary. 

NOAA 

ESI Maps 

ESI 14-16 

ACS 

Map Atlas 

Sheets 251 - 255 

http://www.asgdc

.state.ak.us/maps/cpl

ans/subareas.html#n

orthslope

MESA 4 – 

Peard Bay/Franklin 

Spit 

Shell 

SR-1 

ACS 

SH-1 

Shell 

SR-2 through SR-5 

ACS 

C-13, C-14 

Shell 

OR-1A, OR-1B 

OR-4A, OR-4B 

(vi and vii) Spill 

Contain, Control 

and Recovery 

Procedures 

Task Force (TF) Descriptions:

TF-1 Primary response is provided by equipment stationed near the drillship This 

equipment includes: an OSRV (11,400 bbl storage) with one Transrec 150 

skimmer, two (2) Lamor brush skimmers, three (3) 34-foot workboats, and 

containment and fire boom. 

TF-2 Operating in relief of TF-1, a VOSS, one of the on-site drillship support 

vessels, equipped with a Transrec 150 skimmer performs oil recovery operations 

while TF-1 is off-loading recovered oil to TF-3. 

TF-3 An approximately 513,000 bbl tanker located in close proximity to the drilling 

location is deployed immediately. It arrives within 24 hr. Decanting (if required) 

follows FOSC plan and USCG approval. TF-3 provides oil storage capacity for 

TF-1 and TF-2. 

Shell 

OR-2A, OR-2B 

ACS 

R-20, R-17 

Shell 

OR-3A 

ACS 

R-28 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-95 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-13 (CONTINUED) 

ADEC SPECIFIC SCENARIO 

UNCONTROLLED SUB-SEA WELL RELEASE DURING SUMMER MONTHS 

ADEC 

REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE 

TF-4 consists of a C-130 aircraft equipped with 3,200 gal of dispersant and Spray 

System. TF-4 is mobilized to the Barrow airport from the MSRC in Arizona and 

arrives in Barrow within 24 hrs. 

TF-5 consists of the OSRB with 17,000 bbl of onboard storage. The OSRB is 

mobilized from a staging area within the Chukchi Sea nearshore zone, arriving on 

location within 96 hr. The OSRB provides a mobile on-water recovery system and 

staging platform. It is equipped with two (2) Lamor LSC-5 skimmers; one (1) 47-ft 

skimming vessel with built-in Lamor LORS-2C brush skimmers; three (3) 34-ft 

work boats; four (4) mini-barges; 2,500 ft ocean boom; one (1) vertical rope mop; 

one (1) duplex mini-brush/disc skimmer; and one (1) 100-bbl storage bladder. 

TF-6 consists of pre-staged response equipment and personnel at Wainwright and 

mobilized to deploy exclusion and deflection boom at priority protection sites. The 

primary objective of TF-6 is to prevent oil from impacting sensitive resources. 

TF-6 is also supported by the OSRB. TF-6 consists of two (2) landing craft; two 

(2) work boats; 10,000-ft conventional boom; 10,000-ft coastal boom; and 4,000-ft 

shore seal boom. 

TF-7 consists of ACS response equipment and personnel (ACS, NSSRT, ACRT, 

and VRTs) mobilized to perform shoreline cleanup. Based upon shoreline type and 

oiling conditions, cleanup is performed by 6 or 7 strike teams. Containment and 

recovery tactics are used to remove oil from the shoreline. The recovered oil is 

stored in temporary holding containers (portable folding tanks, bladders, and lined 

pits). TF-7 would access shorelines using the two (2) landing craft and two (2) work 

boats (shared with TF-6). Additional small boats, boom, portable tanks and 

bladders are mobilized to the area during the first 6 days (the earliest time oil is 

predicted to impact shorelines). 

Recovery Timeline: 

T + 1 Hour. TF-1 is deployed immediately and locates to a safe distance from the 

well release. A vessel-based boom-skimmer system deploys downwind/downcurrent of the blowout, ahead of the leading edge of the oil plume. The objective of 

TF-1 is to recover oil shortly after it surfaces and begins to move from the location. 

While the burning of the well would likely eliminate some of the surfacing oil, it is 

assumed here (for planning purposes) that the full WCD of 5,500 bopd (229 bbl/hr) 

continues to flow from the well. 

TF-1 deploys two (2) 34-ft work boats with an open apex U-boom configuration 

down current. The OSRV and one (1) 34-ft work boat deploy behind the open apex 

in a J-boom configuration to recover oil. The OSRV operates one (1) Transrec 150 

skimmer with a derated recovery of 503 bbl/hr or two (2) Lamor LSC-5 skimmers 

with a combined derated recovery of 516 bbl/hr (2 X 258 bbl/hr). 

T + 4 Hours. The volume of recovered liquids exceeds the volume of discharged 

oil (with emulsification). 

T + 24 Hours. The drillship is relocated a safe distance from any surfacing oil and 

gas. The VOSS (TF-2), equipped with one (1) Transrec 150 skimming system, 

relieves the OSRV (TF-1) to lighter its recovered fluids to the OST. TF-2 has 

enough storage capacity to store recovered fluids for eight hr of skimming during 

which time lightering operations from the OSRV to the OST are completed. The 

VOSS works with the three (3) 34-ft workboats from TF-1. The VOSS and one (1) 

34-ft workboat operate in a J-boom configuration behind the two (2) 34-ft 

workboats towing an open apex U-boom. TF-2 works downstream of the drill site 

to contain, collect, and recover surfacing oil. 

TF-3 has arrived from its standby location not far from the drill site. The primary 

objective of TF-3 is to provide offshore interim storage capacity for recovered 

fluids. Upon TF-3 arrival, TF-2 relieves the OSRV (TF-1) to lighter its recovered 

fluids to the OST. 

Shell 

OR-9A 

Shell 

OR-1A, OR-1B, 

OR-4A, OR-4B, 

OR 5A 

ACS 

R-32A, 

R-32B 

ACS 

C-13, C-14 

Shell 

SR-2 through SR-5 

ACS 

SH-3 and 

SH-5 through 

SH-12 

Shell 

OR-2A, 

OR-2B, 

OR-10 

ACS 

R-20, R-17 

(Table 1.6-5) 

Shell 

OR-2A, 

OR-2B 

ACS R-20, R-17 

Shell 

OR-2A, 

OR-2B, 

ACS 

R-20, R-17 

Shell 

OR-3A 

ACS R-28 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-96 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-13 (CONTINUED) 

ADEC SPECIFIC SCENARIO 

UNCONTROLLED SUB-SEA WELL RELEASE DURING SUMMER MONTHS 

ADEC 

REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE 

During OSRV lightering operations to the OST, TF-2 encounters approximately 

1,833 bbl (229 bbl/hr) of surfacing oil and possesses the capacity to store the 3,200 

bbl of recovered liquids (400 bbl/hr x 8 hr). The TF-2 VOSS initiates lightering 

operations to the OST following the resumption of recovery by the TF-1 OSRV. 

From this time forward, TF-1 and TF-2 alternate recovery operations so that one 

task force is always skimming. Two workboats continuously tow boom in a Ushape, open-apex formation that allows oil to filter through at the apex of the boom 

to either the OSRV or the VOSS. 

J-Boom skimmer deployment is considered by TF-1 and TF-2 if sea conditions 

prevent U-Boom deployment. 

Recovery rates of TF-1 and TF-2 are detailed in Table 1.6-5. The recovery capacity 

rate exceeds the rate that oil is released from the well. 

T + 96 Hours. Should oil escape offshore recovery operations, and in the unlikely 

event it moves toward the Chukchi shoreline, nearshore assets would be mobilized 

to implement nearshore response, shoreline protection and cleanup. At the very 

earliest, oil may reach shore on Day 6 if sustained northwesterly winds develop. 

TF-5, consisting of the OSRB, arrives to provide support (e.g., platform, safe 

haven for personnel and vessels, response equipment, recovered fluid storage) for 

the nearshore recovery and shoreline response operations. 

TF-5 targets free oil in windrows and linear slicks. In addition to the OSRB with 

LSC-5 skimmers, TF-5 includes one (1) 47-ft skimming vessel configured with two 

(2) side booms and two (2) built-in Lamor LORS-2C skimmers. Two (2) 34-ft work 

boats are deployed to tow boom for the concentration of oil and recovery by the 47-

ft skimming vessel. The remaining 34-ft work boat shuttles personnel, supplies, 

and four (4) mini-barges. 

TF-6 is mobilized from Wainwright to implement shoreline protection strategies 

within the area of potential impact. TF-6 deploys pre-staged equipment consisting 

of (2) landing craft; two (2) work boats; 10,000-ft conventional boom; 10,000-ft 

coastal boom (6,000-ft from OSRB and 4,000-ft pre-staged); and 4,000-ft shore 

seal boom. TF-6 is also supported by the OSRB and its personnel and equipment. 

ACS cascades additional crews, boom and workboats to priority protection sites 

selected by the UC. 

TF-7 is mobilized by ACS from Prudhoe Bay for shoreline cleanup operations in the 

unlikely event a sustained WNW wind results in impacts. The shorelines predicted 

at risk lie between the Sinaruruk River and Peard Bay. In the event recovery 

operations are necessary, ACS shoreline recovery teams anchor boom to the 

shore in a hook configuration and recover oil with a skimmer into Fast Tanks or 

bladders. 

T + 5 days. Oil trajectory modeling predicts WNW movement of oil. Oil recovery 

vessels adjust positioning accordingly. 

T + 15 days. The ROV successfully activates the sub-sea BOP control panel, the 

well bore secured, and the discharge stopped. The volume of released oil is 

recovered. 

Shell 

OR-2A, 

OR-2B, OR-3A 

ACS 

R-20, R-17 

Shell 

OR-1A, OR-1B 

OR-4A, OR-4B, 

OR-5A 

Shell 

SR-2 through 

SR-5 

ACS 

C-13, C-14 

Shell 

SR-5 through 

SR-10 

ACS 

SH-2 through 

SH-12 

(viii) Lightering 

Procedures Decanting (if required) follows FOSC plan approval within the OCS. Within state 

waters, decanting is subject to approval of the State On-Scene Coordinator 

(SOSC). Stored liquids are offloaded from the OSRV and VOSS (TFs 1 & 2 

respectively) to the OST. 

Based on a maximum WCD of 5,500 bbl/day (or 229 bbl/hr), a 1.54 emulsification 

factor and free water retained in storage (20% of the WCD), each skimming vessel 

could be filled at a rate of approximately 400 bbl/hr. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-97 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-13 (CONTINUED) 

ADEC SPECIFIC SCENARIO 

UNCONTROLLED SUB-SEA WELL RELEASE DURING SUMMER MONTHS 

ADEC 

REQUIREMENT 

RESPONSE STRATEGY CROSS 

REFERENCE 

TF-1 OSRV has 11,400 bbl of storage volume (95 percent capacity). The 11,400 

bbl storage capacity is more than sufficient to store recovered fluids until the OST 

arrives on-scene. 

At hour 24, the VOSS replaces the OSRV as it disengages from skimming 

operations, transits to the OST, and commences offloading recovered fluids. The 

VOSS and 34-ft workboats replace the OSRV to continue skimming operations 

and provide interim storage. The VOSS initiates lightering operations to the OST 

following the resumption of recovery by the OSRV. Skimming and lightering 

operations are scheduled on a 24-hr rotation basis. For the duration of the 

response, the OSRV and VOSS would set up a rotation cycle with the OSRV 

skimming for 16 hr and the VOSS for another 8 hr. At the end of the rotation, each 

vessel is relieved to offload recovered fluids to the OST. 

The OSRV is equipped with eight (8) positive displacement hydraulic screw pumps 

for lightering operations. Each pump has a maximum discharge capacity of 723 

bbl/hr. It is conservatively assumed that the total transit and set up time for 

lightering is three to four hr. The estimate offload time of three to four hr is based 

upon the transfer rate of four (4) pumps working together (4 X 723 bbl/hr) to 

offload approximately 9,570 bbl of recovered liquids (5,500 bbl at a 1.54 

emulsification factor plus 20% retained free water). For planning purposes the 

OSRV completes lightering operations to the OST within 8 hr. 

The OST is maintained in close proximity, typically a mile or two, from the recovery 

operations so that transit times to and from the OST are kept to a minimum. The 

transfer of recovered fluids (after decanting forward of the skimmers) is 

accomplished using BAT; that is, annulus injection of water at a suction head to 

produce a low-friction transfer of viscous fluids between the skimmer’s onboard 

storage and the OST. With high-volume transfer pumps and annulus injection, 

each transfer from the OSRV to the OST should require only 3 to 4 hr with an 

additional 3 to 4 hr factored in for setup and transit to and from the OST. The 

VOSS lighters to the OST when the OSRV resumes recovery operations. Using 

high-volume transfer pumps, the VOSS offloading requires less than the 16 hr 

available to complete transfer operations and transit to and from the OST. 

ACS R-28 

Shell 

OR-3A 

(ix) Transfer and 

storage of 

Recovered 

Oil/Water; Volume 

Estimating 

Procedure 

Stored liquids are offloaded from the OSRV and VOSS to the OST. Liquids from 

the nearshore skimmer vessels are stored in mini-barges and transferred to the 

TF-6 OSRB. 

Liquids recovered by the shoreline recovery task forces are stored in Fast Tanks, 

bladders, mini-barges, or mobile tanks. Fluids may be transferred to secondary 

storage containers. See Section 1.6.10. 

The volumes of stored oil emulsion and free water are gauged with ullage tape and 

recorded on waste manifests. 

ACS R-28 

Shell 

OR-3A , OR-6 

(x) Plans, 

Procedures and 

Locations for 

Temporary Storage 

and Disposal 

A Waste Management Plan is developed in order to (1) fill out and sign manifests;

(2) measure liquid and other wastes and (3) submit a plan to ADEC for waste 

management. 

Non-liquid oily wastes are classified and disposed of according to classification. 

Non-oily wastes are classified and disposed of accordingly. 

Recovered fluids stored onboard the OST and from nearshore and onshore 

recovery operations will be disposed of outside the U.S., either at Shell Group 

refineries or other third-party processors, in accordance with Shell environmental 

policy, and relevant local laws and regulations (see Section 1.6.10). 

Shell 

DP-1 

ACS 

D-1 through D-3 

Appendix D 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-98 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

TABLE 1.6-13 (CONTINUED) 

ADEC SPECIFIC SCENARIO 

UNCONTROLLED SUB-SEA WELL RELEASE DURING SUMMER MONTHS 

ADEC 

REQUIREMENT 

RESPONSE STRATEGY CROSS 

REFERENCE 

Temporary facilities are established as necessary and made available to agency 

biologists and veterinarians standing by to respond to potential reports of oiled 

wildlife.

MMOs are stationed aboard the primary drilling and support vessels. The EU 

coordinates with resource trustee agency representatives to develop and 

implement plans for wildlife hazing and/or rehabilitation of marine mammals. 

Aerial overflights include wildlife monitoring. 

ACS 

W-3, 

W-4, W-5 

(xii) Shoreline 

Cleanup Plan Shoreline impact is not expected with the current trajectory; however, for planning 

purposes a percentage of the oil is projected to reach the nearshore environment 

as detailed in Section 1.6.7. 

Shoreline cleanup operations are based on a plan approved by the UC. A 

shoreline assessment is conducted to understand the nature and extent of oiling. 

Based on the shoreline assessment, priorities are established for cleanup. Cleanup 

techniques chosen are based on shoreline type and degree of oiling. 

Primary delta and shoreline cleanup techniques include: 

Burning of oily vegetation, 

Deluge of minor to moderately oiled shoreline in the river, including those areas 

where heavier concentrations were manually removed, and 

Natural recovery for those areas where residual staining may remain, but further 

recovery would cause more harm than good. 

Shell 

SR-1 

ACS SH-1 

Shell 

SR-1, SR-5, SR-6, 

SR-7, SR-8, SR-9, 

SR-10 

ACS 

B-2 

ACS SH-2, SH-3 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-99 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

1.7 NON-MECHANICAL RESPONSE OPTIONS [18 AAC 75.425(e)(1)(G)] 

Shell has incorporated the flexibility to implement multiple strategies and tactics into their response 

preparedness and planning. Mechanical recovery and removal of oil from the environment is the primary 

method of response that Shell intends to employ for OSR. Use of in situ burn and dispersants will be 

considered as options to augment mechanical response methods. In situ burn and dispersant would be 

used with the consent of the FOSC or UC to augment mechanical response. 

1.7.1 Obtaining Permits and Approvals 

Application for approval of the use of non-mechanical countermeasures will be made to the UC. The 

ARRT, comprised of federal, state, and local governmental agencies, will act as an advisory board to the 

FOSC. 

The need for the use of non-mechanical response methods to augment mechanical recovery is 

determined and approved by the FOSCs and SOSCs within the UC. Input and considerations from local 

stakeholders and regulatory authorities shall be vetted through the On-Scene Coordinators and IC. 

Application for the use of in situ burn will be coordinated with resource agencies within the IMT EU. 

Requests for approval shall be made consistent with procedures In Situ Burning Guidelines for Alaska, 

Revision 1, dated August 2008. 

For dispersant use, the application will be made consistent with the guidance procedures outlined Annex 

F “Chemical Countermeasures: Dispersants, Chemical Agents, And Other Spill Mitigating Substances, 

Devices or Technology” of the Alaska Federal and State Preparedness Plan for Response to Oil and 

Hazardous Substance Discharges and Releases (Unified Plan). 

1.7.2 Decision Criteria for Use 

There are several situations in which non-mechanical response techniques shall be considered. 

Dispersant use and in situ burn are used as supplemental techniques to augment mechanical response 

methods (e.g., to treat slicks that escape containment and not readily accessible to mechanical response 

equipment, or slicks that are of imminent threat to sensitive resources). Additionally, when environmental 

conditions exceed the limitations of mechanical equipment or preclude its use, non-mechanical response 

methods are viable options. 

In either case, the decision to use dispersants or in situ burn will be based upon the following: 

• Safety of Personnel. 

• Incident-specific strategies to ensure mechanical recovery operations are not impeded through 

the implementation of alternative methods. 

• Use of the technique results in a net benefit by reducing oil spill impacts to sensitive resources 

and shoreline. 

• Method of efficacy monitoring shall be implemented as agreed upon by the FOSC or, as 

appropriate, the UC. 

As covered in Shell Tactic OR-7 and ACS Tactics B-1 through B-7, burning may be used as a spill control 

measure once regulatory approval has been obtained. When mechanical recovery is not practicable or 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-100 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

less effective, removing oil from the water through the use of in situ burning may provide significant 

protection for fish, wildlife, and sensitive environments, as well as commercial, subsistence, historic, 

archaeological, and recreational resources. 

In situ burning may: 

 Prevent the resources from coming into contact with spilled oil; 

 Reduce the size of the spill and thus the amount of spilled oil affecting natural resources; 

 Allow the environment to recover more quickly to the pre-spill state; and 

 Provide the most effective means to remove oil from water prior to shoreline impacts in broken ice 

conditions, in remote or inaccessible areas, or when containment and storage facilities are 

overwhelmed. 

The option to apply dispersants to a spill within the Chukchi Sea will most likely be evaluated by the 

FOSC and UC when environmental conditions reduce the efficacy of mechanical recovery or when the 

spill volume and duration warrant consideration of its use. 

There are several reasons to consider dispersants as a viable treatment option. Aerial application 

provides an increased vantage point to locate and target oil slicks for treatment, increased mobility 

compared to on-water assets, and an increased oil encounter rate. Vessel-based platforms using spray 

arms provide the ability to apply dispersants in discrete areas and at times when aerial assets may not be 

available. Mixing of the dispersants into oil using the OSRV’s propulsion system facilitates the 

effectiveness of oil dispersion in ice. Dispersants also provide the ability to treat a significantly larger 

volume of oil than can be mechanically recovered in a similar time. The resulting potential to mitigate 

sensitive resource and shoreline impacts warrants the consideration of dispersant use. 

1.7.3 Implementation Procedures 

Upon approval, incident-specific conditions associated with the approval shall be met. Both alternative 

response techniques shall require a test to determine if its use is feasible given environmental and oil 

conditions. If the event warrants the consideration of alternative measures, assets will be immediately 

mobilized to support operations. The efficient use of both techniques decreases as the oil weathers, 

presenting a relatively narrow window of opportunity for its use. In addition, dissipation of a dispersed oil 

plume into deeper waters (more than 10 m [30 ft]) is preferable and relies upon timely deployment of an 

application platform. On-site assets shall be deployed upon approval by the UC. 

In Situ Burn 

If the Shell IC or the UC decides to use in situ burn and obtains the necessary authorization, ACS will 

carry out the response (see Shell Tactic OR-7 and ACS B-1 through B-7). 

Once approved, in situ burning will normally involve the following steps: 

1. Collect and concentrate the oil using a fire-resistant boom, ice cakes/floes, ice pits, or other 

natural features as gathering places for the burn. 

2. Ignite the oil using the heli-torch or handheld igniters, making sure to avoid flashback and 

ignition of the spill source. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 1 – Response Action Plan 

Shell 1-101 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0

3. Monitor the burn using Special Monitoring of Applied Response Technologies (SMART) 

maintain constant watch on the fire and smoke plume, condition of containment boom, speed 

and position of boom-towing vessels, and other safety hazards and issues. 

4. To the extent possible, recover and dispose of the burn residue.

Dispersants 

Dispersants may be applied from either on-water assets or an aerial platform. Shell’s OSRV is equipped 

with dispersant application spray arms system. 

Initiation of dispersant application will normally involve the following steps: 

1. Activation and mobilization of on-water and aerial monitoring resources as required. 

2. Mobilization of aerial application platforms and dispersant supply with staging out of a coastal 

Chukchi community. 

3. Deployment of vessel-mounted dispersant platforms. 

4. On-going monitoring of the dispersant effectiveness using SMART protocols. 

Additional information on the use of non-mechanical response techniques are detailed within the Shell 

Beaufort and Chukchi Seas Regional Tactics Manual (Tactics OR-7, OR-8, OR-9A, and OR-9B) and 

Section 3.7. 

1.8 FACILITY DIAGRAMS [18 AAC 75.425(e)(1)(H)] 

Diagrams for the drillship are presented in Figures 1.8-1 through 1.8-5. 
AES-RTS: 08-098E-004.mxd, 09/15/08, R00

SCALE: FIGURE:

1.8-1

 FRONTIER DISCOVERER DRILLSHIP

OUTBOARD PROFILE SCHEMATIC

Chukchi Sea Regional Exploration

Oil Discharge Prevention and Contingency Plan

SHELL
AES-RTS: 08-098E-005.mxd, 09/15/08, R00

SCALE: FIGURE:

1.8-2

 FRONTIER DISCOVERER DRILLSHIP

MAIN DECK AND ABOVE SCHEMATIC

Chukchi Sea Regional Exploration

Oil Discharge Prevention and Contingency Plan

SHELL
AES-RTS: 08-098E-006.mxd, 09/15/08, R00

SCALE: FIGURE:

1.8-3

 FRONTIER DISCOVERER DRILLSHIP

MAIN DECK VIEW

Chukchi Sea Regional Exploration

Oil Discharge Prevention and Contingency Plan

SHELL
AES-RTS: 08-098E-007.mxd, 09/15/08, R00

SCALE: FIGURE:

1.8-4

 FRONTIER DISCOVERER DRILLSHIP

LOWER DECK SCHEMATIC

Chukchi Sea Regional Exploration

Oil Discharge Prevention and Contingency Plan

SHELL
AES-RTS: 08-098E-008.mxd, 09/15/08, R00

SCALE: FIGURE:

1.8-5

 FRONTIER DISCOVERER DRILLSHIP

LOWER DECK VIEW 2

Chukchi Sea Regional Exploration

Oil Discharge Prevention and Contingency Plan

SHELL
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 2 – Prevention Plan 

Shell 2-i March 2010 

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PART 2 PREVENTION PLAN [18 AAC 75.425(e)(2)] ........................................................................... 2-1

2.1 PREVENTION, INSPECTION, AND MAINTENANCE PROGRAMS 

[18 AAC 75.425(e)(2)(A)] ................................................................................................. 2-1

2.1.1 Prevention Training Programs [18 AAC 75.020] ................................................. 2-1

2.1.2 Substance Abuse Programs [18 AAC 75.007(e)] ............................................... 2-1

2.1.3 Medical Monitoring [18 AAC 75.007(e)] .............................................................. 2-2

2.1.4 Security Program [18 AAC 75.007(f)] ................................................................. 2-2

2.1.5 Fuel Transfer Procedures [18 AAC 75.025] ........................................................ 2-3

2.1.6 Maintenance Programs ....................................................................................... 2-5

2.1.7 Operating Requirements for Exploration [18 AAC 75.045] ................................. 2-5

2.1.8 Blowout Prevention and Emergency Shutdown [18 AAC 75.425(e)(1)(I)] .......... 2-6

2.1.9 Oil Storage Tanks [18 AAC 75.065] .................................................................. 2-13

2.1.10 Emergency Tow and Escort Vessels Program ................................................. 2-14

2.2 DISCHARGE HISTORY (>55 GAL) [18 AAC 75.425(e)(2)(B)] ...................................... 2-14

2.3 ANALYSIS OF POTENTIAL DISCHARGES [18 AAC 75.425(e)(2)(C)] ........................ 2-14

2.3.1 Potential Areas for Discharge ........................................................................... 2-14

2.4 OPERATIONAL CONDITIONS INCREASING RISK OF DISCHARGE 

[18 AAC 75.425(e)(2)(D)] ............................................................................................... 2-17

2.4.1 Severe Weather ................................................................................................ 2-17

2.4.2 Ice Conditions ................................................................................................... 2-18

2.4.3 Structural Icing .................................................................................................. 2-19

2.4.4 Critical Operations and Curtailment Plan .......................................................... 2-19

2.4.5 Hours of Light at 71°N ....................................................................................... 2-20

2.5 DISCHARGE DETECTION [18 AAC 75.425(e)(2)(E)] ................................................... 2-21

2.5.1 Drilling Operations ............................................................................................ 2-21

2.5.2 Automated Methods .......................................................................................... 2-21

2.6 RATIONALE FOR CLAIMED PREVENTION CREDITS [18 AAC 75.425(e)(2)(F)] ...... 2-21

2.7 COMPLIANCE SCHEDULE [18 AAC 75.425(e)(2)(G)] ................................................. 2-21

LIST OF TABLES 

Table 2.3-1 Summary of Potential Discharges .................................................................................. 2-15

Table 2.3-2 Potential Discharge for Alaska Offshore Drilling (1997 to 2003) ................................... 2-16

LIST OF FIGURES 

Figure 2.1-1 Models for Site-Specific Well Control ............................................................................... 2-8

Figure 2.1-2 Real Time Operations Center ........................................................................................ 2-10

Figure 2.1-3 Example of a BOP .......................................................................................................... 2-11

Figure 2.1-4 Frontier Discoverer Drillship Blowout Prevention Equipment System ........................... 2-12
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PART 2 PREVENTION PLAN [18 AAC 75.425(e)(2)] 

2.1 PREVENTION, INSPECTION, AND MAINTENANCE PROGRAMS 

[18 AAC 75.425(e)(2)(A)] 

2.1.1 Prevention Training Programs [18 AAC 75.020] 

Personnel involved in spill response or cleanup activities are thoroughly trained and are expected to be 

knowledgeable of safety, health, and environmental requirements, so they fully understand the safety and 

health risks associated with their job, and the practices and procedures required to control their exposure 

to potential safety and health hazards. The level of training is based upon the duties and functions of 

each responder in the emergency response, and complies with the regulatory requirements for employee 

training. See Section 3.9 for additional training information. 

Site personnel who are expected to participate in OSR activities will require training in a number of other 

subjects, including: 

 HAZWOPER 24-hour 

 Shell C-Plan Overview 

 Oil Spill Response Equipment Overview and Oil Spill Response System Performance 

 Specialized training as needed for oil spill response boat operations, lightering, spill containment 

and recovery, and ISB operations 

In addition, selected site personnel shall be fully aware of waste issues involving on-site generation, 

storage, segregation, manifesting, and transportation. They must be knowledgeable of exempt vs. nonexempt, and hazardous vs. non-hazardous materials, and the associated practices in managing the 

material in accordance with standard operating procedures. 

Shell Drill Foreman and Contractor Toolpushers, Drillers, and Assistant Drillers are required to have 

formal well control training in accordance with 30 CFR 250 Subpart O requirements for well control and 

production safety training. In addition, MMS requires weekly pit- and trip-drill exercises designed to keep 

drill crew personnel alert to well control contingencies. The BOP is regularly pressure- and functiontested, again under MMS requirements, and flow-chart response plans are kept visible on the drill floor as 

decision aids to the driller should a well flow event occur. 

2.1.2 Substance Abuse Programs [18 AAC 75.007(e)] 

The Shell drug policy was established to ensure a safe working environment at all operations. Shell’s 

company-wide policy covers all employees. All contractors and non-employees who work at Shell facilities 

must also obey this policy. Shell requires joint venture partners under its operational control to apply this 

policy and uses its influence to promote it in other ventures. 

The use, possession, distribution, or being under the influence of illegal drugs or alcohol is strictly 

prohibited on Shell-controlled premises. Entry onto Shell-controlled premises constitutes consent to and 

recognition of the right of the Company to conduct random drug testing, as well as drug testing for cause. 

Beyond these requirements, operators of designated critical equipment (such as company drivers, crane 

operators, and work boat operators) are subject to daily alcohol testing. 
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Failure to cooperate, or repeated positive test results will result in termination for Shell personnel, and 

removal from Company premises for all others. 

2.1.3 Medical Monitoring [18 AAC 75.007(e)] 

Shell has a systematic approach to medical monitoring designed to pursue Shell’s international goal of 

safe working conditions and continuous performance improvement. Shell employees and contractor 

employees are required to have medical evaluations for fitness to work (FTW), based on job classification 

and responsibilities, as outlined in the Shell Exploration and Production Company’s FTW policy. 

Shell employees receive medical evaluations at the onset of employment and periodically as specified in 

the FTW policy. Contract employees who perform drilling, navigational towline, security, maintenance, 

fuel transfer or response duties are required to have a medical evaluation of FTW based upon their job 

responsibilities. Where a Shell protocol exists for a specific job or task, at a minimum the protocol shall be 

included in the contractor's medical evaluation for FTW. In addition, employees shall be included in 

applicable medical surveillance programs. 

2.1.4 Security Program [18 AAC 75.007(f)] 

The primary safety and security concern relates to the transportation of Shell and contractor personnel via 

the Shell Logistical Support Base facility or other company-established logistical base. Security services 

may be provided through coded badges or a professional security company for Shell’s Logistical Support 

Base and other support facilities. 

Access to the drillship is either by helicopter or by vessel. Personnel will be primarily transferred to the 

platform by helicopter, which is strictly controlled at Shell’s Logistical Support Base facility and airstrip. 

Shell anticipates helicopter operations will be conducted from Barrow, and vessel operations will be 

conducted from Wainwright; each facility will have security controls in place. 

Supplies will be loaded onto the drillship and support vessels prior to mobilization, and all OSR equipment 

will be mobilized directly to the Chukchi Sea onboard the OSRV. Transport of any remaining supplies 

during the drilling season is expected to be minimal, mainly related to transfers of spare parts, drilling 

tools, and other unforeseen items which can be transported from Shell’s Logistical Support Base to the 

drilling location by helicopter (or vessel, if weather conditions preclude helicopter operations). 

In the event of an actual spill, vessels and aircraft may be used for supplemental transportation of 

equipment, personnel, and supplies in support of the ACS shoreline recovery effort and, in all likelihood, 

temporary camps would be mobilized to suitable areas and communities adjacent to the shoreline 

recovery effort. 

Access to the drilling sites themselves will be very limited, given that they are in remote, offshore 

locations and subject to authorization by the on-site Drill Foreman who strictly controls transit and access 

to the drilling site. For safety reasons, access to the drillship will be limited to authorized personnel only. 

For further information regarding on-site security and regulations, see the Security Plan for the respective 

drillship. 
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2.1.5 Fuel Transfer Procedures [18 AAC 75.025] 

At exploration sites, the following types of fuel transfers will be conducted: 

 Fuel transfers to or from the drillship, including transfers from the drillship to other supporting 

vessels (e.g., anchor handler) or helicopters. 

 Fuel transfers to or from the OSRV, including transfers from these vessels to other supporting 

vessels such as work boats. 

Fuel Transfer Procedures for the OSRV and for the Frontier Discoverer are in Appendix C. 

The drillship Frontier Discoverer incorporates fuel transfer facilities for helicopter support, fuel barge, and 

other support vessels. 

Fuel transfers will be performed in accordance with: 

 Lease-specific requirements including the pre-deployment of booming; 

 USCG regulations [33 CFR 154.1035(b)(2)(i)] and vessel response plans; and 

 ADEC regulations 18 AAC 75.025. 

Drillship specific procedures governing fuel transfers, including emergency shutdown, will be strictly 

followed by marine personnel. The procedure manuals will be onboard the drillship. If a spill of any size 

is detected, immediate action will be taken to stop the source, prevent any spill going overboard, and 

initiate containment and recovery actions. The drillship has shipboard oil pollution emergency plans that 

personnel adhere to, including immediate contact of the supervisor and reporting to the appropriate 

authorities. 

Drillship Internal Fuel Transfers 

Internal fuel transfers include flow of fuel from the onboard storage tanks to settling tanks, or to loading 

stations on deck. Onboard storage tanks will include: 

 cold-start compressor, 

 emergency generator day tank, 

 incinerator day tank, 

 deck cranes, 

 crude oil tank, and 

 mud pits. 

The emergency generator day tank and the incinerator day tank are fitted with overflow pipes that return 

excess fuel back to the inner hull storage tanks. These transfers generally will occur twice daily, once per 

shift, and are performed by marine personnel. Safety procedures include adherence to an internal fuel 

transfer checklist, direct communication among personnel, and visual inspection of the transfers. No 

internal fuel transfers will be conducted during high-risk situations such as bad weather or alarm status. 

If an alarm occurs, an emergency shutdown system at the pumps will close any valve in use and stop the 

transfer to avoid spill overflow. 
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Helicopter Fuel Transfer 

Helicopter fuel transfers include storage, filtering, and transfer of fuel from the fuel pods located on the 

drillship deck through pumps and filters to the delivery skid on the heli-deck. Emergency shutdown 

controls are located at the heli-deck and the forward port exit ladder from the heli-deck. Preventive 

measures for fuel transfer to the helicopters include: 

 Ensuring no helicopters are inbound/outbound; 

 Discontinuing hot work on the heli-deck and starboard decks; 

 Verifying operative firefighting system including extinguisher on the heli-pad; 

 Proper alignment of fueling facilities (including valves, motor, pump, and coalescing filter); and 

 Electrical bonding or grounding of the helicopter to the vessel. 

Only authorized personnel (either the Helicopter Landing Officer or one of three heli-deck crew members) 

will activate this system. 

Drillship Fuel Transfers 

No fuel transfers will occur during emergency weather conditions or alarms without the direct approval of 

the Offshore Installation Manager (OIM). Safety of diesel fuel transfer to the drillship will rely on direct 

communication between drillship and fuel supply vessel personnel responsible for the transfer 

procedures. Preventive measures for ensuring safe transfer will rely on pre-transfer procedures. Prior to 

transfer, the fuel-handling personnel will identify: 

 Product, rate of transfer, and sequence of operations; 

 Critical stages of the transfer operation; 

 Applicable federal, state, and local regulations; and 

 Emergency procedures including shutdown operations. 

Refer to Appendix C for the fuel transfer procedures for the drillship. 

Fuel transfers will include the use of pre-deployed boom, visual inspection, and open communication 

between the personnel of the fueling facility and the drillship personnel. Continuous communication is the 

best preventive measure for avoiding an emergency situation. If radios are used for communication, they 

will be tested and ensured to be intrinsically safe as required by 46 CFR 110.15 through 46 CFR 110.100 

and 46 CFR 11.80. 

Once a fuel transfer is complete, fill valves will be closed and visual inspection of valves, flanges, pumps, 

and connection facilities will be conducted to ensure there is no discharge. 

OSRV Fuel Transfer 

In normal operation, the OSRV will receive diesel fuel delivered from a drilling support vessel or thirdparty fuel barge. The OSRV may also serve as a fuel lightering vessel transporting fuel from a drilling 

support vessel or third-party barge to the drillship. In both cases, the fuel transfer procedures will be 

based on the more stringent of either the vessel’s own procedures (as part of the USCG-approved Vessel 

Response Plan submitted by each vessel owner) or the similar procedures in place at the drillship. 

Refer to Appendix C for the fuel transfer procedures for the OSRV. 
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The OSRV may also at times be used to provide diesel bunkering for OSR-related work boats (34-foot 

work boats), in which case the transfer would always be conducted under the fuel transfer procedure of 

the OSRV. 

In the event that any oil spill response-related work boats or support vessels have fuel delivered to them 

by a third-party fuel barge, the transfer would be conducted in accordance with the fueling procedure 

established by Shell. 

Where required as part of an approved Vessel Response Plan, or as required under the lease 

stipulations, fuel transfers will include the use of pre-deployed boom, visual inspection, and 

communication among the vessel personnel as the best preventative measures. 

2.1.6 Maintenance Programs 

Operations of the Frontier Discoverer drillship include routine internal inspections and maintenance. 

Maintenance is an important tool for spill prevention because it monitors mechanical integrity and is 

documented daily by written reports. During the refurbishment phase, maintenance records are kept in 

log books. Under the operating phase, maintenance is performed according to a computerized 

maintenance program with records kept in the electronic maintenance database. The mechanical integrity 

of the drillship is upheld through the planned maintenance program initiated following drilling unit 

refurbishment. 

For malfunctioning or corroded materials, the maintenance department is notified and personnel are 

assigned the repair task by either the Chief Engineer or the Maintenance Supervisor. Equipment is 

inspected based on frequency intervals indicated in the maintenance program and in accordance with 

manufacturer and industry recommendations. For example, cranes are inspected daily per regulatory 

requirement, while the BOP gantry crane hydraulic system, which receives only sporadic use, is inspected 

weekly. 

2.1.7 Operating Requirements for Exploration [18 AAC 75.045] 

Drillship Integrity Inspections 

During drilling, a visual inspection of major tanks and lines will be conducted daily. Shift inspections are 

conducted by personnel to detect leakage, damage, or serious deterioration of the storage tanks, fuel 

lines, piping, and associated facilities. Potential leaks will be properly reported in the daily tour report and 

the Toolpusher will be notified. 

Piping between the storage tanks and boilers or engines is attached to the structure with brackets or 

double plates that protect the piping from damage. These brackets are visible for regular inspections. 

Much of the piping is routed by design to be out of the way and protected from impact or the environment. 

Preventive measures include floor drains around the drilling deck to stop minor spills from flowing off the 

deck. Supplemental one-inch drain lips at individual doorways are provided to contain potential spills to a 

single room. The Frontier Discoverer floor drains flow to a holding tank. From the holding tank, the spilled 

liquid is sent through the oil-water separator. After separation, water is routed overboard and 

contaminants are stored until shipped ashore for proper disposal. 
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2.1.8 Blowout Prevention and Emergency Shutdown [18 AAC 75.425(e)(1)(I)] 

Drilling Assurance 

Well control is the process of maintaining positive pressures in the drilled wellbore so that pressures in 

the geologic formations do not cause gas or fluids from the formations to escape in an uncontrolled 

manner. This section provides information on the measures taken to maintain well control and prevent a 

blowout during drilling operations. Recovery measures used to regain well control in the event of lost 

control are discussed in Section 1.6.3. The potential for discharge is discussed in Section 2.3. 

No failure of a single barrier or a barrier element, whether caused by operational error or equipment 

failure, should lead to loss of well control. Therefore, Shell applies the following series of layers of 

prevention and response to well control issues: 

 Layer I includes proper well planning, risk identification, training, routine tests and practice drills 

on the drillship which build a strong prevention and response foundation. Examples of Layer I 

would include BOP tests, pit drills, and trip drills. 

 Layer II includes early kick detection and timely implementation of kick response procedures. 

Continuous monitoring including the use of Shell’s Real Time Operations Center (see subsections 

below on Well Control During Drilling) provides early kick detection. When a kick is detected, the 

general response is to immediately shut down the pumps, perform a flow check, shut in the well, 

and kill the well. 

 Layer III involves the use of mechanical barriers, including, but not limited to, BOP, casing, and 

cement. Testing and inspections are performed to ensure integrity is maintained at all times. 

 Layer IV represents relief well drilling, which would be implemented if a blowout were to occur, 

despite the first three layers of protection. Contingency plans include dynamic surface control 

measures and the methods for drilling a relief well. 

Well Control During Planning and Preparation 

The primary methods of well control are properly designed casing/cementing programs to isolate and 

structurally support downhole formations, and maintenance of drilling fluids of sufficient volume and 

density in the wellbore to counteract any experienced geologic pressures. Data from previous wells in the 

area have been used to anticipate formation pressures that might be experienced when drilling the 

planned wells and the wells have been designed to handle the expected pressures. See Figure 2.1-1 for 

an example of this process. 

The primary causes of loss of well control are insufficient fluid density, fluid losses to the formation, 

swabbing, not keeping the wellbore full of drilling mud, charged formations, rapidly drilling a gas sand, 

and dissolution of shallow gas hydrates. Loss of well control, an uncontrolled influx of formation fluids into 

the wellbore, is primarily prevented by properly designed casing strings and drilling fluid systems. 
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Shell’s approach to reducing the risk of a well control incident includes proactive measures to maintain 

well control. This starts with the following key safeguards during well planning and preparation: 

 Training key drillship site personnel; 

 Risk identification and mitigation, including writing Shell’s “Drill-the-Well-on-Paper” (DWOP) 

exercise; 

 Contingency planning, including operation-specific plans to mitigate all of the potential causes of 

loss of well control; and 

 Flexible well design to accommodate a range of uncertainty in subsurface data. 

The following training and drills support the proactive approach to well control in the well preparation 

phase. 

 On-site Shell and contractor supervisors maintain current well control certification. 

 Prospect-specific well control scenarios and kill techniques are modeled and simulated using 

Shell’s proprietary software and well control simulators at the Robert Training and Conference 

Center. 

 Shell foreman, Shell engineers, contractor supervisors, and contracted drillship skilled positions 

(e.g., drillers and assistant drillers) are trained for prospect-specific well control situations. 

 Weekly pit drills and trip drills. 

 Secure well drills performed when applicable. 

 Training on the COCP and the associated daily status reporting conducted for appropriate 

personnel. 

 Blowout prevention drills performed on a frequent basis ensure the well can be shut in properly 

and quickly. BOP service and inspection are performed throughout the drilling and off seasons. 

Available data from seismic operations and neighboring exploration wells, such as rock types and 

subsurface pressure profiles, are interpreted to ensure a design that permits effective control of the well. 

Drilling engineers predict downhole pressures and interpret existing datasets to design a safe and 

productive drilling program. 

Shell performs a site-specific hazardous operations analysis for each prospect (Figure 2.1-1). In addition, 

Shell conducts a DWOP exercise for each prospect which involves a collaborative effort of drilling 

engineers, operations and HSSE personnel, as wells as service providers, to analyze all phases of the 

planned drilling program. DWOP is a systematic method to: 1) identify and prioritize a set of actions to 

optimize the drilling program, considering all areas of activity; 2) identify and prioritize key operational and 

HSSE risks and associated mitigation opportunities; and then 3) use this information to develop the 

optimum drilling program. Shallow hazards surveys have also been conducted to assess the shallow 

areas of the planned wellbore for potential pockets of shallow gas that could result in loss of control. 
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FIGURE 2.1-1 

MODELS FOR SITE-SPECIFIC WELL CONTROL 
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In addition to site-specific hazardous operations analyses and the DWOP exercise for each prospect, the 

following additional risk identification and mitigation measures would be taken: 

 Site-specific well control modeling for anticipated hydrocarbon intervals; 

 Site-specific dynamic well control modeling for any prospects with possible shallow gas or 

hydrate accumulations 

 Virtual ice management using shipboard marine radar combined with satellite RADARSAT ice 

imagery to permit advanced and accurate warning of ice hazards. 

Well Control During Drilling 

General 

The primary means of controlling well pressure utilizes hydrostatic pressure exerted by drilling fluid of 

sufficient density to prevent flow from the formation into the wellbore. The condition of the drilling fluid is 

continuously monitored using both manual and automated means, and adjusted as necessary to meet the 

actual wellbore requirements. Monitored parameters include mud weight into and out of the well, mud 

flow rate into and out of the well, and presence and analysis of any gases in the return mud flow. The 

majority of those monitoring duties are performed by the staff of the drilling crew. A mud-logging unit, 

staffed by experienced personnel, will be in continuous use during drilling operations. 

Should a kick occur, kick identification and detection, and timely kick management are the primary tools 

used to prevent a blowout. Latest generation Measurement-While-Drilling (MWD) and Pressure-WhileDrilling (PWD) tools are used, allowing real-time monitoring of downhole pressures and drilling 

parameters. This allows rapid identification of the onset of abnormal pore pressures, swabbing, or the 

influx of hydrocarbons near the drilling bit. 

The drilling operations are supported by Shell’s Real Time Operations Center (RTOC), where technical 

experts in Houston or New Orleans can assist by monitoring on-going operations, analyzing penetrated 

formations, and analyzing pressure trends. Data can be transferred from the drillship to the RTOC in realtime. See Figure 2.1-2. This service augments the mud logging capabilities at the drillship and allows 

Shell to easily make the people with the right skills available to support the drilling operation. 
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FIGURE 2.1-2 

REAL TIME OPERATIONS CENTER 

Early kick detection is critical to maintaining well control. The drillers, drill crews, mud engineers, mud 

loggers, and logging engineers are all trained on kick detection and rapid response procedures. In 

addition, all drilling breaks are treated as potential kick situations, taking all necessary precautions until 

the situation has been determined to be stable. 

Well Control While Drilling at the Mudline 

There is risk for a shallow gas blowout while drilling a hole at the mudline, before the subsea BOP or 

surface casing have been installed. Large volumes of high-pressure gas can escape from shallow 

formations, into the wellbore, and then into the water. It should be noted that shallow gas blowouts do not 

contain oil; therefore, no spill of oil would be expected at the surface. However, such an incident would be 

critical from a worker safety standpoint. In order to minimize this risk, Shell would conduct a site 

clearance and shallow hazards survey prior to conducting drilling operations using high resolution 

profiling systems. This survey would evaluate conditions at and below the seafloor, which could affect the 

safety of operations including the presence of shallow gas. 

If a shallow gas blowout would occur, no attempt would be made to shut-in the well to contain the gas 

because the shallow formations exposed at these depths generally would not have enough strength to 

control the gas. Instead, the gas would be directed away from the drilling unit floor using a diverter valve 

and diverter line. 

Free gas accumulations in shallow permafrost have been encountered in the course of drilling permafrost 

intervals. To avoid release of this gas and the potential loss of structural integrity of the wellbore, the 

drilling fluid is cooled to ensure that the wellbore remains frozen, with the gas trapped, and the integrity of 

the hole is intact. 

Well Control While Drilling Below the Conductor Casing 

Each well is drilled according to a detailed location-specific well plan, based on expected downhole 

conditions at that location. Such plans are part of the first layer of protection, proper planning, and risk 
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identification. Isolating formations with casing and appropriately maintaining the drilling fluid properties, 

including density, are critical to preventing loss of well control during drilling. 

Once the conductor casing has been set across the shallowest formations, the BOP provides a 

mechanical barrier to loss of well control, key to the third layer of protection. See Figure 2.1-3 for an 

example of a BOP and Figure 2.1-4 for a diagram of the BOP to be used with the Frontier Discoverer

drillship. Although rarely needed, this equipment is available as a back-up means (secondary to the mud 

system) to secure well pressure. In the unlikely event that primary well control is lost; the BOP can be 

used to safely halt an uncontrolled flow from the wellbore. 

FIGURE 2.1-3 

EXAMPLE OF A BOP 

In the event the well kicks, the BOP will be used immediately to shut-in the well and confine the pressure 

within a closed system. The casing program will be designed so that any anticipated formation pressure 

can be shut-in at the subsea BOP without rupturing the casing. Shell representatives assigned to the 

drilling unit have MMS-approved blowout prevention training and actual experience in controlling and 

killing kicks. Training of this nature is a continual program with Shell. Drilling crews will be trained to a 

standard sufficient to satisfy both MMS and Shell. 

The BOP for the Frontier Discoverer consists of: 

 Four 18 3⁄4-inch 10,000 pounds per square inch (psi) working pressure (WP), ram-type preventers 

(Cameron). 

 Two 18 3⁄4-inch 5,000 psi annular preventers (Hydril). 

 2 3⁄4-inch (ID) 10,000 psi choke and kill lines. 

For a diagram of the BOP for the Frontier Discoverer, refer to Figure 2.1-4. 
AES-RTS: 08-098E-010.mxd, 09/15/08, R00

FIGURE:

2.1-4

 FRONTIER DISCOVERER DRILLSHIP

BLOWOUT PREVENTION SCHEMATIC

Chukchi Sea Regional Exploration

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After installation, the BOP will be tested in accordance with MMS and Shell specifications. Tests will be 

conducted at least weekly and prior to drilling out casing. 

Well Suspension or Abandonment 

Upon completion of drilling operations, the well will be properly plugged and abandoned following MMS 

requirements. Procedures include setting cement across hydrocarbon intervals. All plug and 

abandonment operations will be conducted per 30 CFR 250 Subpart D and with prior approval from MMS. 

Spill Prevention Practices and Training 

Blowout prevention drills are performed on a frequent basis to ensure the well is shut-in properly and 

quickly. Blowout prevention testing intervals are within the standard of MMS regulations. Blowout 

preventers will be pressure-tested every 14 days and function-tested every 7 days. In addition, drilling 

personnel are MMS-certified in well control, and weekly pit/trip drills will be conducted. 

2.1.9 Oil Storage Tanks [18 AAC 75.065] 

Section 3.1 contains information about the major tank facilities on the drillship. During drilling, a visual 

inspection and soundings of the major tanks will be conducted at least once daily for leakage or damage 

detection, and to identify any questionable mechanical integrity of the storage tanks and their associated 

fuel lines, piping, and valves. Leak detection will be recorded in a daily tour report and the OIM in charge 

of the drillship will be notified in order to ensure that repairs are completed safely and in a timely manner. 

Inspections of Elevated and Portable Tanks [18 AAC 75.065(a)] 

The storage tanks to be used in Shell exploration are integral parts of the Frontier Discoverer which will 

undertake the drilling program. The Frontier Discoverer will not carry any non-integral bulk storage oil 

tanks equal to or greater than 10,000 gal, which are regulated under 18 AAC 75.065. 

Inspection Records [18 AAC 75.065(d)] 

Inspection records are maintained by the drillship contractor. 

Repair or Alteration [18 AAC 75.065(e)] 

Shell will notify MMS of any major repair or alteration. 

Leak Detection [18 AAC 75.065(h)(1)] 

See Section 2.5. 

Overfill Prevention [18 AAC 75.065(j), (k)] 

Overfill protection is primarily through visual observation and mechanical and remote soundings during 

transfer operations. Containment save-all is in place around the fuel tank vent outlet. 

The Frontier Discoverer fuel tanks are integral to the vessel’s hull. Therefore, all loading stations and 

vents are provided with save-alls or high coamings as per the requirements of SOLAS (International 

Convention for the Safety of Life at Sea), MARPOL (International Convention for the Prevention of 

Pollution from Ships), and Det Norske Veritas (DNV) requirements. 

Bulk oil storage tanks located on the drillship will be lined with appropriate impermeable liners. Tanks will 

be visually inspected daily for the presence of oil leaks or spills. 
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Debris Removal [18 AAC 75.075 (c)] 

The tank areas will be maintained free of debris and other material that might interfere with the 

effectiveness of the system. 

Drainage [18 AAC 75.075(d)] 

Drill floor drainage will be routed to an oil-water separation tank. The Frontier Discoverer is equipped with 

two oil-water separators for handling bilge and waste oil. The separation process will be inspected to 

ensure that separated oily water may safely be disposed. The deck is furnished with scuppers that can 

be plugged to manage deck drainage. 

2.1.10 Emergency Tow and Escort Vessels Program 

The drillship will have two dedicated ice-class vessels assigned to support them for the purpose of anchor 

handling and ice management (see Appendix A). These two dedicated vessels are the primary escort and 

emergency vessels for the drillship. 

2.2 DISCHARGE HISTORY (>55 GAL) [18 AAC 75.425(e)(2)(B)] 

Not applicable. 

2.3 ANALYSIS OF POTENTIAL DISCHARGES [18 AAC 75.425(e)(2)(C)] 

This section contains a summary of potential discharges and their impact. The spill history of previous 

exploration drilling in the Chukchi Sea demonstrates the low probability of an event causing oil to enter 

into an open water environment. Table 2.3-1 summarizes maximum discharges of liquid hydrocarbons 

that potentially could occur from various sources. 

A response scenario addresses the potential immediate release of crude oil to the environment by a loss 

of well control during drilling operations in conditions typically encountered during the drilling season. The 

probability of a major oil spill occurring during drilling operations is extremely low. Comprehensive flow 

histories are generally not available for exploration areas. For planning purposes, the flow rate from a 

blowout is 5,500 bopd for the duration of the event. 

2.3.1 Potential Areas for Discharge 

Fuel Transfers 

A potential source of discharge occurs during fuel transfers of any kind. This discharge is minimized by 

the weather restrictions of transfer procedures, which prevent transfers during unfavorable wind or sea 

conditions. Transfers are announced in advance and verbal communication, in combination with visual 

inspection, is the best method of discharge detection. 

If discharge is detected, the fuel would most likely be contained immediately on deck. If fuel overflow of 

the containment dikes occurs, edge coaming would prevent flow of fuel off the vessel into open water. 
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TABLE 2.3-1 

SUMMARY OF POTENTIAL DISCHARGES 

TYPE CAUSE PRODUCT SIZE DURATION 

ACTIONS TAKEN TO 

PREVENT POTENTIAL 

DISCHARGE 

Transfer from 

fuel barge to 

drillship 

Hose rupture Diesel Approximately 

48 bbl (2,000 gal) 

(Section 1.6) 

5.5 min 

(Section 1.6) 

Transfer procedures in place; 

Note: This scenario will be 

addressed as part of USCG 

approval of Vessel Response 

Plans by individual vessel 

owners. 

Diesel Tank rupture Diesel 1,555 bbl Minutes to 

hours 

 Note: The diesel tanks are 

internal to the drillship rather 

than deck-mounted, where 

the potential for marine spills 

is much greater. As a result, 

a scenario involving tank 

rupture has not been 

included in the oil spill 

response plan, but will be 

monitored as part of an 

ongoing tank inspection 

program. 

Blowout Uncontrolled 

flow at the 

mudline 

Crude oil 287,100 bbl 

including emulsion 

and free water 

30 days 

(Section 1.0) 

BOP and related procedures 

for well control. 

Blowouts 

Since 1940, oil and gas exploration and production have been conducted in U.S. federal waters. Given 

the use of modern prevention and control techniques, actual blowouts are extremely rare and of relatively 

short duration. Often used interchangeably, the term “blowout” is also known as a “loss of well control”, 

and often does not result in a release to water. As currently defined by MMS, loss of well control 

includes: 

 Uncontrolled flow of formation or other fluids. The flow may be to an exposed formation (an 

underground blowout) or at the surface (a surface blowout). 

 Flow through a diverter. 

 Uncontrolled flow resulting from a failure of surface equipment or procedures. 

From 1971 to 2005, 276 exploration and development blowouts occurred on the OCS while drilling 

approximately 34,000 wells. Thirty-three of those 276 blowouts resulted in oil spills of crude or 

condensate with the amount of oil spilled ranging from <1 bbl to 350 bbl. The total volume spilled from 

those 33 blowouts is approximately 1,600 bbl. 

Table 2.3-2 provides a summary of the potential discharge volumes associated with exploration and 

production plans that were proposed in Alaska’s OCS and state waters since 1997. This summary 

includes the maximum potential spill volumes for either well blowouts or other WCDs. Although unlikely 

to occur, Shell has developed strategies to respond to a WCD of an uncontrolled release of oil during a 

blowout or any other spill. These strategies are discussed in Section 1.6. 
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TABLE 2.3-2 

POTENTIAL DISCHARGE FOR ALASKA OFFSHORE DRILLING (1997 TO 2003) 

PLAN NAME 

PRODUCTION OR 

EXPLORATION OPERATOR 

18 AAC 75.425(e)(1)(f) 

SCENARIO WELL 

BLOWOUT WORST CASE 

DISCHARGE VOLUME 

(bbl/day) 

18 AAC 75.425(e)(2)(C) 

POTENTIAL DISCHARGE 

ANALYSIS BLOWOUT 

VOLUME (bbl/day) 

McCovey Exploration Exploration AEC Oil & Gas, Inc. 5,500 (March 2002) 5,500 (March 2002) Warthog #1 Exploration ARCO 5,500 (August 1997) 5,500 (August 1997) Northstar Operations Production BPXA BP Exploration 

(Alaska) Inc. (BPXA) 

7,220 (May 2003) 10,000 (July 2005) 

Milne Point Unit (F Pad) Production BPXA 2,000 (June 2002) 142,800 gpd = 3,400 

bbl/day (March 2003) 

Greater Prudhoe Bay Exploration BPXA 3,000 (September 2006) 6,005 (September 2003) Endicott Production BPXA 2,000 (December 2003) 2,250 (December 2003) Badami Production BXAP 1,100 (May 2005) 1,045 (May 2005) Alpine Dev. Participating Area 

Production ConocoPhillips Alaska, 

Inc. (CPAI) 

7,500 (January 2004) 7,500 (August 2004) 

Thomson Gas Cycling Exploration ExxonMobil 517 (May 2003) 517 bbl/day (May 2003) Kuparuk Field Production Phillips 66 1,000 (March 2003) N/A Cook Inlet Area Exploration Program 

Exploration Phillips 66 1,500 (July 2001) 5,500 (February 2001) 

Tyonek Platform Exploration Phillips 66 5,500 (September 1998) 5,500 (September 1998) North Slope Exploration Program 

Exploration Pioneer Natural 

Resources 

5,500 (September 2005) 5,500 (September 2005) 

Kitchen Prospect Exploration Escopeta Oil 4,675 (June 2006) 4,353 (June 2006) Cook Inlet Production Facilities 

Production/Exploration Unocal 76 300 (December 2006) 1,200 (December 2006) 

Oil & Gas Production Operations 

Production Kerr-McGee 1,000 (September 2005) N/A 

Northwest Milne Point Exploration Operations 

Exploration Kerr-McGee 5,500 (January 2004) 5,500 (January 2004) 

Oooguruk Development Project 

Exploration Pioneer Natural 

Resources Alaska Inc. 

2,500 (April 2006) 2,500 (April 2006) 

Cook Inlet Area Production Operations 

Production/Exploration Forest Oil Corporation 1,500 (February 2002) 1,500 (August 2004) 
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2.4 OPERATIONAL CONDITIONS INCREASING RISK OF DISCHARGE 

[18 AAC 75.425(E)(2)(D)] 

Severe weather and ice conditions are the primary factors most likely to curtail operations and increase 

the potential for accidental discharge. Drilling operations will be conducted utilizing key precautionary 

measures documented in the COCP to minimize both the likelihood and consequence of an oil spill 

incident from offshore drilling in the Chukchi Sea. Conditions specific to Shell's Chukchi Sea operations 

that potentially elevate the risk of discharge, and actions taken to eliminate or minimize identified risks, 

are summarized below: 

 Temperature: Cold temperatures pose a threat to personnel and equipment. Excessive heat may 

cause gases to expand and increase the likelihood of discharge. Drilling operations conducted in 

the Arctic are exposed to arctic air masses with relatively harsh temperatures throughout the 

year. 

 Weather Conditions: The operation most likely to be affected by adverse weather conditions is 

the drilling support operation, such as transportation activities between the drill site and staging 

areas. Strict adherence to air safety will be enforced. 

 Sabotage or Vandalism: Potential for any sabotage or vandalism is minimal. Security and specialinterest training by Shell and its contractors should deter any damage from these acts at any of 

the drill sites. Air safety is essential. 

These characteristics can affect the movement of discharge as well as deployment of equipment and 

efforts to contain and recover the oil. 

2.4.1 Severe Weather 

In general, meteorological and oceanographic conditions at the project location are moderate during the 

summer months. Winds are predominately from the ENE June through November with occasional lowpressure systems moving into the area from the western Pacific through the Bering Strait bringing warm 

air and moisture. Wet conditions producing fog and rain can result in periods of low visibility on the open 

ocean. Storms are more common during the winter months than the summer. The frequency of storms 

and associated high winds increase with the transition of open water season into the fall freezeup time 

frame. Severe storms generally originate from the southwest, progress swiftly into the area, and last a 

relatively short time, although rough weather will on occasion persist for many days. 

Environmental parameters such as wind speed and wave height do not directly influence drilling 

operations. Rather it is the drilling unit’s response to environmental conditions, coupled with the drill 

crew’s ability to handle equipment safely, that affects curtailment of critical operations. Conditions of 

curtailment due to heavy weather are therefore determined in accordance with the drillship’s responses to 

heave, pitch, roll, horizontal displacement, and anchor tension as a function of the corresponding 

environmental parameters. 

Because heavy weather will clearly influence vessel response, environmental conditions will be regularly 

monitored at the drillship and regional wind and wave forecasts will be received on each drilling unit two 

times a day with two updates between each forecast. Meteorologists with the weather forecasting service 

will provide weather consultation services on a 24-hr/day basis. 

Shell has developed a COCP, which has procedures to aid operations personnel in determining the 

correct procedures to follow when storm conditions are anticipated. Implementing the procedures will 
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ensure the safety of any personnel onboard, minimize the risk of damage to equipment, and minimize the 

chance of a discharge attributable to the severe weather conditions (see Section 2.4.4 below for more 

information on this document). 

Once on location, the drillship and key personnel monitor weather conditions continually using a variety of 

data including aerial ice reconnaissance, third-party forecasts from weather services, and onboard 

weather surveillance and motion monitoring. Critical operations will be managed in accordance with the 

COCP, which prescribes allowable operating parameters based upon the “T-time” value. T-time is defined 

as the estimated (total) time to secure the well and leave the location. The T-time value is updated at 

least daily by operations and marine personnel. The value is based upon the time required to trip or 

recover the drillpipe and associated equipment and complete the operations required to leave the well in 

a secured state. In heavy weather conditions, when vessel heave and horizontal displacement exceed 

pre-set levels, drilling operations cease, the drill string is pulled into the protective casing of the well, the 

drillpipe is hung off the blowout prevention stack, and the drilling unit crew prepares to recover anchoring 

equipment. If weather and sea conditions continue to deteriorate, the lower marine riser package is 

disconnected and anchoring equipment is recovered (or released if necessary). If weather severity 

reaches specified levels, the drillship moves off location and is positioned to ride out the storm. 

2.4.2 Ice Conditions 

On-site project activities will begin after July 1. The retreat of the ice typically occurs in most years from 

early June to late July. The duration of open water (≤1/10 ice concentration) in the central Chukchi Sea 

has lengthened by up to four weeks over the past 30 years to a summer average of 17 weeks. However, 

the range of open water is variable from year to year and ice could be present at the drill site. An Ice 

Management Plan (IMP) is in place to ensure safe operations at all times. Exploration drilling will not be 

conducted after October 31. Other project activities may continue until the onset of freezeup, which 

historically varies from late October to late November. 

Shell’s ice management system combines ice monitoring and forecasting techniques, along with 

icebreaking operations. Ice monitoring techniques include satellite-based SAR, airborne and icebreaker 

reconnaissance, ice forecasting, and weather forecasting. Forecasting incorporates data from the federal 

services of Canadian Ice Service and NOAA. Shell also intends to use specialized software to integrate 

ice speed and direction data from vessel radar, aerial reconnaissance, and satellite imagery to predict 

individual ice floe movement; therefore, allowing modification of icebreaking operations on a real-time 

basis. Shell’s ice management team at Shell's Bellaire Technical Center will be fully engaged to support 

the collection and use of ice-related information. 

Two ice management vessels will accompany the drilling unit. Typically, one ice management vessel 

may deflect or break up large ice floes farther away by circling updrift or upwind (“upstream”) in the 

flowing sea ice, while the other protects the drillship by further breaking closer ice floes into smaller 

pieces so that the drillship is able to maintain position. 

Shell has developed two sets of protocols for responding to potentially hazardous ice conditions: one set 

of protocols for typical summer drilling when ice driven by wind and currents can move into the area; and 

another set of protocols to address winter freezeup conditions. These two sets of procedures utilize Ttime estimates for establishing alert stages and associated operational and communication protocols. 

In general, drilling operations will cease and preparations will be made to disconnect drillpipe when 

hazardous ice conditions are anticipated within the T-time plus four hours. If the ice management strategy 

is not capable of preventing a large ice floe from impacting the drillship or reducing ice buildup, then the 
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drillship begins preparing in stages to secure the well and disconnect from the lower marine riser 

package, recover anchoring equipment, and vacate the drilling location. 

The Ice Alert Procedures spell out specific responsibilities for personnel onboard the drillship and 

onboard support vessels. The conditions necessary to achieve a given alert level are described, along 

with the corresponding tasks for each of the key individuals assigned to Drilling Operations, Marine 

Operations, and Helicopter Support Base Operations. The conditions for each alert level relates to a time 

value “T” which is defined as “the time required for safely and efficiently stopping current operations so 

that the riser can be disconnected and the anchors retrieved or disconnected to move off location.” All 

estimates of operational closure time include safety margins that guarantee that the well will be 

completely secured in the best possible way by the end of the period, “T.” 

2.4.3 Structural Icing 

Meteorological data for the project area indicate that structural icing may occur as early as September. 

The severity of icing conditions is a function of surface water temperature, air temperature, and wind 

speed. The occurrence of atmospheric icing due to freezing fogs and snow may also increase the 

possibility or extent of structural icing. Accumulations of ice on the drillship superstructure will be thickest 

on windward surfaces between 33 to 164 ft (10 to 50 m) above the water surface. Heavy structural icing 

will raise the vessel's vertical center of gravity and affect its heeling and righting moments. 

The Frontier Discoverer has been arctic-strengthened and has pre-established ice load limits. If icing for 

the drillship approaches the allowable amount, raising the allowed vertical center of gravity, critical 

operations will be curtailed until sufficient ice has been removed and the loading is acceptable. The 

Frontier Discoverer incorporates features to minimize the accumulation of spray ice, such as enclosed 

work spaces and enclosed or heat-traced piping. 

When icing conditions exist, crew vigilance will be essential to preventive accumulation. At the start of 

each tour, crewmembers will inspect their work areas for icing. Roustabouts will remove ice, snow, and 

standing water from decks, equipment, railings, and the superstructure to prevent ice accumulation in any 

of these areas. If ice builds up on the derrick it will be removed. Removal onboard the vessel will be 

accomplished by means of portable heaters, steam hoses, steam lances, wooden ice bats, and picks. 

2.4.4 Critical Operations and Curtailment Plan 

MMS requires that offshore operators in the Alaska OCS Region develop procedures and maintain an 

MMS-approved COCP. The plan deals largely with potential problems associated with severe weather 

and unexpected levels of ice. The procedures identify ice conditions, weather, and other constraints 

under which the exploration activities will be either curtailed or stopped. Shell’s COCP provides a series 

of procedures for monitoring and responding to various ice conditions and weather/wave conditions at the 

drill sites. The focus of the COCP is to prevent personnel injury, equipment damage, and any accidental 

discharges to the environment. The main objective is to secure the well in an orderly manner when facing 

adverse environmental conditions. 

A prerequisite to safe and efficient arctic offshore operations is an environmental monitoring and 

forecasting system. A comprehensive system has been established to support Shell’s drilling activities in 

the Chukchi Sea. Components of the monitoring and forecasting system include meteorological 

observations, on-site weather forecasts, oceanographic observations, sea state forecasts, ice monitoring, 

and ice forecasting. In addition to the environmental monitoring and forecasting system, real-time 
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measurements of drillship performance in ambient conditions is obtained from a performance-monitoring 

system installed onboard. An alert status system has been established onboard the drillship to anticipate 

hazardous ice and weather events and to assign pre-determined responses for all responsible personnel. 

The COCP describes the comprehensive effort that Shell and the drillship contractors provide to ensure 

that drilling operations are conducted in a safe and prudent manner in the unique environment of the 

Chukchi Sea. The COCP is a component of the Applications for Permit to Drill submitted for approval to 

the MMS. The COCP is also readily available onboard the drillship and in Shell’s offices. 

The COCP defines standards and guidelines for the conduct of operations on the drillship to minimize any 

hazard to personnel or the environment. In the Alaskan Chukchi Sea, the two primary factors that can 

cause curtailment of critical operations and that potentially increase the risk of discharge while drilling are: 

sea ice and heavy weather. The objective of the COCP is to detail the critical drilling operations and the 

conditions under which such operations will be curtailed. 

The COCP will be strictly followed to mitigate ice potentially forcing the drillship off location in an 

uncontrolled fashion. 

2.4.5 Hours of Light at 71°N 

In addition to severe weather and ice conditions described above, reduced hours of daylight occurring at 

the end of the drilling operations could increase the risk of a discharge during some activities. Daylight 

hours on the first day of each month for the Chukchi Sea at 71°N are as follows: 

 January 0.0 

 February 4.1 

 March 9.5 

 April 14.3 

 May 19.9 

 June 24.0 

 July 24.0 

 August 24.0 

 September 14.6 

 October 10.9 

 November 5.7 

 December 0.0 

Drilling operations will be aided by drillship lights and portable lighting as necessary. 
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2.5 DISCHARGE DETECTION [18 AAC 75.425(e)(2)(E)] 

2.5.1 Drilling Operations 

Visual surveillance is used for discharge detection. Visual inspections are an important component of 

leak and spill detection because automated systems may not detect small leaks and spills. The drillship 

and fuel-transfer operations will be closely monitored at all times (see Section 2.1.6). Operations will be 

staffed 24 hr/day by drilling personnel. Once per day facility personnel will visually inspect tankage, 

sumps, and drains for indications of oil leaks. Piping, valves, pumps, and other machinery will also be 

visually inspected as part of the daily routine. Any oil leaks or spills will be noted, the source of the spill 

will be located and corrected, and the oil spill will be cleaned up. During drilling, drillers continually 

monitor the drilling equipment and will stop drilling if unsafe conditions are observed. 

2.5.2 Automated Methods 

The drillship has a system of controls, monitors, and procedures to assist in the early detection of 

potential discharges. For both downhole and surface operations, these detection systems include 

standard operating procedures governing the monitoring, handling, and containment of fluids. Specifically, 

visual and manual detection in combination with drilling policies and procedures allow for ample 

discharge detection. 

Several independent Emergency Shutdown (ESD) Systems limit the scope of any single failure. An ESD 

can be initiated by process conditions outside pre-set limits or manually initiated by operators at the 

instrument/control panels. Manually-actuated ESDs (punch-button panels) are also strategically placed 

throughout the facility. ESDs are specifically provided for the primary systems of ship operations, drilling 

operations, and fuel transfers. Drill operation shutdowns are located on the drilling unit floor. Fuel 

transfer ESDs are located on the lower and upper deck of the helideck. Ship-to-ship fuel transfer ESD 

and drilling operation shut downs, including associated hydraulic systems, are located on the drill floor. 

ESDs to shut down all ship operations are located in the emergency response room and in the semiconductor room. Rounds are documented daily. Incidents are recorded using an approved incident 

reporting and investigation process. 

Further discharge detection is allowed by the continuous monitoring of the drillship’s bilge systems. 

Potential discharge collects in system where it eventually travels to the pump room. Visual surveillance of 

this bilge system’s piping, valves, and pumps allows for early detection of a spill. 

2.6 RATIONALE FOR CLAIMED PREVENTION CREDITS [18 AAC 75.425(e)(2)(F)] 

Although Shell considers its well prevention and control measures “best in class,” it will not be claiming 

any prevention credits to offset oil spill response planning requirements, based on exploration well 

operations as specified in 18 AAC 75.430 through 18 AAC 75.434. 

The recovery equipment provided in support of this plan (see Tables 1.6-6, 1.6-7, and 1.6-8) substantially 

exceeds the mechanical recovery capability needed to contain the WCD (see Section 1). 

2.7 COMPLIANCE SCHEDULE [18 AAC 75.425(e)(2)(G)] 

Compliance schedule and waivers have not been requested at this time. 
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PART 3 SUPPLEMENTAL INFORMATION [18 AAC 75.425(e)(3), 30 CFR 254.22(a), 

30 CFR 254.23(e), AND 30 CFR 254.26] ................................................................................. 3-1

3.1 FACILITY DESCRIPTION AND OPERATIONAL OVERVIEW 

[18 AAC 75.425(e)(3)(A)] ............................................................................................ 3-1

3.1.1 Facility Description ......................................................................................... 3-1

3.1.2 Bulk Storage Containers ................................................................................ 3-3

3.1.3 Transfer Procedures ...................................................................................... 3-3

3.1.4 Vessel Plans and Diagrams ........................................................................... 3-3

3.2 RECEIVING ENVIRONMENT [18 AAC 75.425(e)(3)(B)] ........................................... 3-3

3.3 COMMAND SYSTEM [18 AAC 75.425(e)(3)(C)] ........................................................ 3-7

3.3.1 Incident Management Team .......................................................................... 3-8

3.3.2 Unified Command .......................................................................................... 3-8

3.4 REALISTIC MAXIMUM RESPONSE OPERATING LIMITATIONS 

[18 AAC 75.425(e)(3)(D)] [30 CFR 254.26(D)] ......................................................... 3-15

3.4.1 Adverse Weather Conditions ....................................................................... 3-18

3.4.2 Sea States, Tides and Currents ................................................................... 3-20

3.4.3 Hours of Daylight and Visibility .................................................................... 3-28

3.5 LOGISTICAL SUPPORT [18 AAC 75.425(e)(3)(E)] ................................................. 3-29

3.6 RESPONSE EQUIPMENT [18 AAC 75.425(e)(3)(F)] .............................................. 3-31

3.6.1 Equipment Lists ........................................................................................... 3-31

3.6.2 Maintenance and Inspection of Response Equipment ................................ 3-32

3.7 NON-MECHANICAL RESPONSE INFORMATION [18 AAC 75.425(e)(3)(G)] ........ 3-32

3.7.1 Assessment of Environmental Consequences and Monitoring ................... 3-40

3.7.2 Non-mechanical Response Equipment ....................................................... 3-41

3.7.3 Identification of Necessary Approvals and Application for Non-mechanical 

Response Options. ...................................................................................... 3-42

3.7.4 Identification of Permits, Approvals or Authorizations ................................. 3-42

3.7.5 Plan for Protection Environmentally Sensitive Areas and Areas of Public 

Concern ....................................................................................................... 3-42

3.8 RESPONSE CONTRACTOR INFORMATION [18 AAC 75.425(e)(3)(H)] ................ 3-43

3.8.1 Statement of Contractual Terms .................................................................. 3-43

3.9 TRAINING PROGRAM [18 AAC 75.425(e)(3)(I)] ..................................................... 3-43

3.9.1 Incident Management Team Member Training ............................................ 3-44

3.9.2 Other Training .............................................................................................. 3-45

3.9.3 Record Keeping ........................................................................................... 3-45

3.9.4 Spill Response Exercises ............................................................................ 3-45

3.10 PROTECTION OF ENVIRONMENTALLY SENSITIVE AREAS AND AREAS OF 

PUBLIC CONCERN [18 AAC 75.425(e)(3)(J)] ......................................................... 3-46

3.10.1 Sensitive Wildlife Areas ............................................................................... 3-46

3.11 ADDITIONAL INFORMATION [18 AAC 75.425(e)(3)(K)] ......................................... 3-47

3.12 BIBLIOGRAPHY [18 AAC 75.425(e)(3)(L)] .............................................................. 3-47

LIST OF TABLES 

Table 3.1-1 Frontier Discoverer Service Facilities .............................................................................. 3-2

Table 3.3-1 Command Staff Contact Information .............................................................................. 3-10

Table 3.3-2 IMT Checklist ................................................................................................................. 3-12

Table 3.4-1 Ice Alert Levels ............................................................................................................... 3-16

Table 3.4-2 Ice Alert Roles and Responsibilities ............................................................................... 3-17

Table 3.4-3 Average and Maximum Wind Speeds ............................................................................ 3-19

Table 3.4-4 Percentages of Days per Month that Temperature Could Reduce Response 

Effectiveness For Worker Threshold Limit Values ........................................................ 3-20
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Table 3.4-5 Beaufort Wind Force and Sea State Relationship Between Wind and Wave 

Conditions in Fully Developed Seas .............................................................................. 3-21

Table 3.5-1 Logistical Support Contractors ....................................................................................... 3-30

Table 3.7-1 Minimum Ignitable Oil Thickness on Water (Adapted from Buist et al. 2003) ............... 3-34

Table 3.7-2 Burn Removal Rates for Large Fires on Water (Adapted from Buist et al. 2003) ......... 3-34

Table 3.7-3 Fire Extinguishing Slick Thickness (Adapted From Buist et al. 2003) ........................... 3-35

Table 3.7-4 Inventory of In situ Burning Equipment (Shell and ACS) ............................................... 3-36

Table 3.7-5 Safe Working Distances From the Fire .......................................................................... 3-38

LIST OF FIGURES 

Figure 3.1-1 Oil Spill Response Vessel Nanuq Deck and Profile View ................................................ 3-5

Figure 3.1-2 Oil Spill Response Barge Endeavor Deck View .............................................................. 3-6

Figure 3.3-1 Incident Command System .............................................................................................. 3-9

Figure 3.4-1 Comparison of Regional Ice Conditions......................................................................... 3-23
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PART 3 SUPPLEMENTAL INFORMATION [18 AAC 75.425(E)(3), 

 30 CFR 254.22(A), 30 CFR 254.23(E), AND 30 CFR 254.26] 

3.1 FACILITY DESCRIPTION AND OPERATIONAL OVERVIEW 

[18 AAC 75.425(e)(3)(A)] 

3.1.1 Facility Description 

Shell proposes to conduct a multiyear exploration drilling program in the Chukchi Sea OCS on current 

and future lease holdings. 

Shell intends to utilize the drillship Frontier Discover, or similar, to drill multiple wells to total depth. 

Exploration wells would be drilled, evaluated, and plugged and abandoned. Operations would be initiated 

each year following seasonal ice clearing and continue into freezeup. 

The Frontier Discoverer Drillship 

The Frontier Discoverer is a 514 ft (156 m) moored drillship with drilling equipment on a turret amidships 

and classified by DNV as a 1A1 Ship-shaped Drilling Unit, winterized for service in the arctic offshore 

environment. It is designed for water depths ranging from 125 to 1,000 ft (38 to 305 m). An eight-point 

mooring system is attached to the bottom of the turret. The drillship is equipped with thrusters, which are 

used to rotate around the turret, keeping the drillship bow into the weather or ice floe. The Frontier 

Discoverer drilling depth can reach a maximum of 20,000 ft (6,096 m). It can house up to 124 people. A 

facility diagram and schematics are provided in Section 1.8, Figures 1.8-1 through 1.8-5. 

Table 3.1-1 describes the service facilities on the Frontier Discoverer. 
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TABLE 3.1-1 

FRONTIER DISCOVERER SERVICE FACILITIES 

SERVICE FACILITY DESCRIPTION 

Length 514 ft (156 m) 

Capacities

Bulk Mud and Cement 1,132 bbl (180 cu m) 

Sack Storage 5,845 bbl (934 cu m) 

Total Liquid Mud 2,400 bbl (282 cu m) 

Drilling Water 5,798 bbl (922 cu m) 

Potable Water 1,670 bbl (266 cu m) 

Fuel Oil 6,497 bbl (1,033 cu m) 

Drilling Equipment 

Draw Works EMSCO E-2,100, 1,600 hp 

Pumps Two (2) Continental EMSCO FB 1,800 

Triple Mud Pumps 

Rotary National C-495 

Derrick IDECO 175 ft with 1,300,000 lbs nominal 

capacity 

Blowout Prevention Equipment 

WP RAM-Type Preventers Four 18 3⁄4 -inch 10,000 psi 

Annular Preventers Two 18 3⁄4 -inch 5,000 psi 

Choke and Kill Lines YES 

Hydraulic Control Systems with 

Accumulator Back-up Closing YES 

 hp = horsepower 

Drilling Support Vessels 

The drillship would be accompanied by support vessels as necessary for anchor handling, ice 

management, and general logistical support for the movement of supplies and personnel. Vessels for the 

2010 season are identified in Appendix A. It is Shell’s intent to update information regarding specific 

vessels in the event that changes occur prior to each drilling season. 

Oil Spill Response Support Vessels 

In the event of an oil spill, Shell’s primary response for the purposes of the C-Plan would be conducted by 

the following vessels (refer to Appendix A for general specifications): 

 OSRV Nanuq, stationed nearby the drillship while drilling into liquid hydrocarbon-bearing zones in 

the Chukchi Sea; 

 VOSS, consisting of the anchor handler, Tor Viking or similar, stationed in proximity of the 

drillship while drilling into liquid hydrocarbon-bearing zones; 

 Three 34-ft OSR work boats; 

 Endeavor OSRB, stationed in along the Chukchi Sea coast or in an area not more than 480 n mi 

from the Chukchi Sea nearshore zone while the drillship is drilling into liquid hydrocarbon-bearing 

zones; and 
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 OST stationed in an area not more than 240 n mi from the Chukchi Sea drillsite while drilling into 

liquid hydrocarbon-bearing zones. The OST would be the Arctic tanker Affinity or similar (70,000 

gross metric tons, with a storage capacity of at least 287,100 bbl). 

Fuel Systems 

The fuel system of the Frontier Discoverer has a holding capacity of 6,500 bbl, including main bunker, 

emergency generator and helicopter fuel systems. There are two fuel tanks for the helicopter; both with 

17 bbl holding capacity. 

Bilge Systems 

The Frontier Discoverer bilge system consists of a network of piping and mud boxes which are connected 

to locations where water is likely to collect from environmental or natural leakage from equipment and 

other systems under normal operations. The bilge system is connected to two electrically driven bilge 

pumps located in the ship’s service pump room. 

The oil-water separator on the Frontier Discoverer is located in the propulsion room to treat effluent 

propulsion and forward generator room bilges. 

3.1.2 Bulk Storage Containers 

The Frontier Discoverer contains integral bulk storage tanks. Non-integral bulk oil storage tanks equal to 

or greater than 10,000 gal will not be located onboard any of the vessels. 

An OST with a minimum capacity of 287,100 bbl will be located not more than 240 n mi away from the 

drillship while drilling in liquid hydrocarbon-bearing zones, and will be used for emergency oil spill 

response. 

3.1.3 Transfer Procedures 

Fuel transfer procedures are discussed in detail in Section 2.1.5 and Appendix C. 

3.1.4 Vessel Plans and Diagrams 

See Figures 1.8-1 through 1.8-5, 3.1-1 and 3.1-2 for diagrams of the vessels. 

3.2 RECEIVING ENVIRONMENT [18 AAC 75.425(e)(3)(B)] 

Operations in the Chukchi Sea would begin with the drillship traveling to the Chukchi Sea accompanied 

by support vessels, including the OSRV and VOSS. The vessels may arrive at the project location after 

July 1. The movement and positioning of the fleet is dependent on the timing and extent of breakup of the 

arctic sea ice. 

The winter offshore ice in the Chukchi Sea is more dynamic than in the Beaufort Sea. Prevailing easterly 

winds across the northern Chukchi Sea frequently create an open water lead or polynya up to 30 mi (50 

km) across from shore paralleling the coast between Cape Lisburne and Point Lay. Breakup along the 

coast typically proceeds rapidly, changing from high ice concentration to open water in a few days. The 

timing of breakup is variable, ranging from early June to late July. Breakup tends to occur on the central 

coast one to three weeks earlier than at Point Barrow. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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Project activities will commence after July 1 and continue into freezeup. When drilling in water depths of 

130 ft (40 m) or more, the environment will be dominated by open water throughout the drilling season. 

In midsummer, the Chukchi Sea pack ice is typically composed of a mixture of broken, eroded blocks and 

small floes. The edge of the ice pack is irregular and usually remains well north of the proposed 

operational area in the summer months. Storm events can rapidly drive multiyear floes south at rates 

exceeding 7.5 mi/day (12 kilometers per day [km/day]). The fleet, consisting of the drillship and support 

vessels, would exit the exploration sites through the open water pathway before winter ensues and the 

pack ice encroaches on the shoreline. 

Shell’s lease area lies on the federal OCS within the Chukchi Sea approximately 52 n mi or more off the 

north coast of Alaska in the Arctic Ocean. The waters of the Chukchi Sea begin just north of the Bering 

Strait and extend northward to the Arctic Ocean. The predominant current in the Chukchi flows northward 

and slightly eastward at 0.15 to 0.2 meters per second (m/sec) (0.3 to 0.4 knots). 

The ice free or broken ice season typically persists nearly twice as long as that of the Beaufort Sea coast, 

extending June through November/December. However, some portions of the Chukchi Sea are affected 

by sea ice all year, containing both seasonal first year ice and thicker multiyear arctic pack ice. Several 

smaller fresh water rivers including the Kobuk and Noatak Rivers empty into the Chukchi Sea. Annually, 

the waters of the Arctic go through variations in salinity. In the summer, waters are less saline than in the 

winter because of river inflow and ice melt. In winter, salinity increases result from reduced fresh water 

inflow from river freezeup and brine rejection during ice formation [reaching as high as 34.5 parts per 

thousand (ppt)]. In the eastern Chukchi Sea, Alaska coastal waters also flow along the coast 

incorporating cooler fresh water at speeds of 0.24 to 0.30 m/sec (0.5 to 0.6 knots) past Point Hope, Cape 

Lisburne, and Icy Cape (MMS 2007). 

Tides in the Chukchi Sea are mixed semidiurnal and increase in range from 0.4 ft (0.1 m) at Barrow to up 

to 3 ft (1.0 m) in Kotzebue Sound. Fetch distances are significantly greater than the Beaufort Sea and 

wave energy levels are consequently greater. The possibility of cross-boundary impacts on Siberian 

waters does exist. 

Predominately, the Chukchi coastal character is composed of cliffs that make up about 249 mi (400 km) 

of the approximately 385 mi (620 km) of total shoreline between Barrow and Point Hope. Ice-poor tundra 

cliffs dominate the north with bedrock cliffs exposed south of Kasegaluk Lagoon. The lowland coasts are 

characterized by low, sand barrier beaches and spits. 

Wildlife expected in the Chukchi Sea offshore exploration area includes polar bears, bowhead whales, 

gray whales, minke whales, fin whales, walrus, bearded seal, ringed seal, spotted seal, and marine birds. 
AES-RTS: 08-098E-009.mxd, 02/20/09, R00

FIGURE:

3.1-1

OIL SPILL RESPONSE VESSEL NANUQ

DECK AND PROFILE VIEW

Chukchi Sea Regional Exploration

Oil Discharge Prevention and Contingency Plan

SHELL
SHELL

Oil Spill Response Barge Endeavor

DECK VIEW

Chukchi Sea Regional Exploration 

Oil Discharge Prevention and Contingency Plan

FIGURE:

3.1-2

Bow of Pushing Tug

Fire Boom 

Connex

Pedestal 

Crane

Mini-Barges 

(double stacked)

Utility 

 Connex “A” 

“

Parts 

 Connex 

Tools 

 Connex 

“

Utility 

 Connex “B” 

“

Mini-Barges 

(double stacked)

47’ Skimming 

Vessel

34’ Work Boat

34’ Work Boat

Sea Slug Bladders

34’ Work Boat

R-Max Boom

Brush Skimmer

R-Max Boom

Small Skim 

System Kit

Sorbent Decon 

Connex

Contingency 

Connex

Rubber Max 

Boom Support

Rigging 

Connex
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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3.3 COMMAND SYSTEM [18 AAC 75.425(e)(3)(C)] 

Shell’s oil spill response command system is compatible with the responsibilities established and detailed 

by the Alaska Federal and State Preparedness Plan for Response to Oil and Hazardous Substance 

Discharges and Releases (Unified Plan) and the structure is easily adapted to that described within the 

Alaska Incident Management System (AIMS) Guide. As with AIMS, Shell’s emergency management 

organization structure is based on the National Incident Management System. This system provides a 

clear definition of roles, chain-of-command, and has the flexibility for expansion or reduction of the 

organization as needed to address incident-specific conditions. Shell’s Incident Management Handbook is 

followed for the process, organization, and language for incident response management. 

All emergency response situations would use the ICS. The ICS defines roles and lines of command, 

together with the flexibility for expansion of the organization as necessary. The first person discovering or 

responding to any emergency situation becomes the On-scene IC until that individual relinquishes 

authority to another person better able to assess the situation. 

In most Tier I incidents, the on-site spill technicians possess the capabilities to effectively control the 

incident. The On-site Shell Company Representative may fulfill the role of IC. Personnel would be 

activated to stand by until an assessment is performed. Once the assessment is complete, response 

personnel are either released or mobilized to the incident location. 

For Tier I incidents, drillship personnel would report to a designated secure area until completion of an 

incident assessment by the on-site representative. Following that assessment, the drillship personnel 

would be assigned cleanup duties based on their level of training. A spill response technician would be 

mobilized to assist in this effort as necessary. 

Tier II/III responses are initiated by the Drilling Foreman who activates the appropriate IMTs. Once the 

response level is ascertained, the appropriate IMT begins to provide support to the field responders 

(Operations Section) and to coordinate the collection and distribution of information. Shell and their 

response contractor provide personnel and equipment resources from the on-site OSRV, VOSS, and 

North Slope resources. 

For Tier II/III incidents, the Drilling Foreman is the initial On-scene IC. The drillship personnel may be 

directed to a secure area to await the arrival of emergency response personnel. Depending on the 

incident, drillship personnel may be incorporated into the IMT, when applicable. 

The QI would be notified during callout of the IMT (Tier II or III response). During Tier II events, the 

response contractor provides personnel and equipment. During Tier III events, the QI acts as the 

company representative for commitment of additional resources. The QI can be either the IC or the 

Deputy IC (DIC). As described in Section 1.1, Tier II or III incidents will normally be managed from the 

Incident Command Center located at Shell’s 3601 C Street, Suite 1000, Anchorage, Alaska offices. 

Forward command posts could be established on the drillship, at Wainwright and/or at Barrow, as 

necessary. 

For significant oil spills of Tier II and III magnitude, there may be FOSC, SOSC, and Local On-Scene 

Coordinator (LOSC) participation alongside Shell’s IC. These individuals may become part of the UC, 

representing their organization. Each contributes to the process of: 

 Determining and establishing overall incident objectives and priorities, 
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 Selecting strategies, 

 Planning for tactical activities, 

 Conducting integrated tactical operations, and 

 Using resources effectively and efficiently. 

The Responsible Party (RP) would fill the role of IC in the UC structure unless the FOSC determines the 

RP’s response is inadequate. In such a circumstance, the FOSC would assume the role of IC. 

Response personnel would be available to respond to a Tier II or Tier III incident at a drill site through 

Shell’s primary response action contractors. If necessary, Shell would arrange for additional resources by 

activating contracts maintained by their response contractors for specialized equipment and trained 

response personnel. 

3.3.1 Incident Management Team 

The UC determines and prioritizes strategic objectives to respond to an emergency incident. Shell’s IMT 

would define the spill response tactics and provide overall support to the Operation’s field spill response 

technicians to meet the incident-specific objectives. The level of “ramp-up” and activation of IMT staffing 

is scaled depending on the severity of the incident. Shell intends to integrate IMT staff with federal, state 

and local representatives. 

An organization chart showing the ICS structure is presented in Figure 3.3-1. Command Staff contact 

information is presented in Table 3.3-1, and an IMT checklist is presented in Table 3.3-2. 

3.3.2 Unified Command 

An ICS is a management structure implemented at the time of an incident to bring together the ICs of 

major organizations involved in response operations. The result is unified approach and response to 

emergency situations. In Alaska, the UC representatives may include the FOSC, the SOSC, and the RP. 

A representative from a neighboring area or the NSB may act as the LOSC. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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FIGURE 3.3-1 

INCIDENT COMMAND SYSTEM 

 

Logistics 

Section

Support Branch

Service Branch

Operations 

Section

Staging Area 

Manager

Recovery and

Protection Br/ Grps

Emergency 

Response Br/ Grps

Air Operations

Branch/ Groups

Wildlife Branch/

Groups

Finance/

Admin Section

Time Cost

Unit

Time 

Unit

Procurement 

Unit

Compensation/ 

Claims Unit

Planning

Section

Situation 

Unit

Resources 

Unit

Documentation

Unit

Demobilization

Unit

Environmental 

Unit

Technical 

Specialists

Legal 

Officer

Liaison

Officer

Public Affairs 

Officer

Safety 

Officer

Incident 

Commander/ QI

Deputy IC/ QI

FOSC / SOSC / LOSC

Corporate CMT

Source Control Group

(Senior Exec. Liaison)

Supply Unit

Facilities Unit

Transport Unit

(Vessel/ Ground)

Food Unit

Medical Unit

Communication

Unit
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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TABLE 3.3-1 

COMMAND STAFF CONTACT INFORMATION 

NAME OFFICE # PAGER # CELL # 

COMMAND STAFF 

IC/QI 

Rick Fox 907- 770-3700 907-360-4813 

Susan Childs 907-646-7112 907-301-5792 

Deputy IC /QI 

Susan Moore 907-646-7119 907-382-5474 

Jon Edmondson 907-646-7110 907-952-7769 

Public Affairs/Information Officer 

Jennifer Taylor 907-646-7178 907-382-5974 

Phil Dyer 907-646-7181 907-382-1410 

Liaison Officer 

Susan Childs 907-646-7112 907-301-5792 

Nicole St. Armand 907-646-7152 907-382-6852 

Safety Officer 

Brad Boschetto 907-770-3700 907-854-0073 

Grantt Bedford 907-771-7201 907-382-2808 

Legal Officer 

Marc Stone 281-544-2596 713-269-8054 

Company Security Officer (IC Support) 

Phil Smith 504-728-4252 888-265- 8113 504-606-4252 

Tommy Hutto 504-728-4369 888-264-0024 504-884-1665 

Senior Executive (IC Support) 

Frank Glaviano 504-728-6711 281-857-1888 

Pete Slaiby 907-771-7210 907-382-7247 

Source Control Executive Liaison (IC Support) 

Paul Goodfellow 281-544-2151 281-857-4014 

Chandler Wilhelm 713 546 6157 713-444-3811 

GENERAL STAFF 

Operations Section Chief 

Geoff Merrell 907- 771-7221 907-306-8016 

ACS Staff 907-659-2405 

O’Brien’s Oil Pollution Services (OOPS) Staff 800-910-3778 

Staging Area Manager 

ACS Staff 907-659-2405 

Operations Section Branch Directors 

Shell Staff 907-770-3700 

ACS Staff 907-659-2405 
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TABLE 3.3-1 (CONTINUED) 

COMMAND STAFF CONTACT INFORMATION 

NAME OFFICE # PAGER # CELL # 

Planning Section Chief 

Jon Edmondson 907-646-7110 907-952-7769 

Brad Boschetto 907-646-7121 907-382-5050 

Technical Specialists 

Michael Macrander 907-646-7123 713-907-8136 

Al Allen (Spiltec) 425-869-0988 

Ian Voparil 281-544-6906 281-222-8472 

David Dickins (contractor) 858-453-8688 

ACS Planning and Development Manager (IMT 

coach/facilitator) 907-659-3220 

Logistics Section Chief 

Kate Marstall 907-646-7111 907-382-2755 

Jack Wallis 907-646-7168 907-980-2934 

Support Branch Director 

John Maketa 907-646-7172 907-980-5146 

Finance Section Chief 

JoAnn Spears 907-646-7191 907-229-5501 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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TABLE 3.3-2 

IMT CHECKLIST 

POSITION RESPONSIBILITIES COMMENTS 

INITIAL 

RESPONSE 

INCIDENT 

COMMANDER 

 Fill in Spill Report Form 

 Assist field personnel (medivac) 

 Assemble Spill Response Team 

 Brief team 

 Assign duties (org. chart) 

 Remind team to keep logs 

 Establish objectives (chart) 

 Name Incident 

 Determine response strategies 

 Conduct air surveillance 

 Establish meeting times (chart) 

 Notify agencies (chart) 

QUALIFIED 

INDIVIDUAL 

(IC or DIC) 

 Status of incident, facility, and personnel 

 Evaluate level of response required and activate SMT support 

as required 

 Conduct internal / external notifications as required 

 Authorize the use of response resources 

 Participate in Incident Command briefings 

LIAISON 

OFFICER 

 NRC 

 Notify appropriate state agencies 

 Notify federal agencies 

 Request safety zones air/ water (USCG) 

 Request Notice to Mariners (USCG) 

 Submit In situ Burn request to USCG 

 Obtain approval to decant (USCG) 

 Prepare written reports to agencies 

HUMAN 

RESOURCES 

 Notify family of injured (if company employee) 

 Follow up on injured 

 Coordinate volunteer activities 

 Notify corporate executives 

PUBLIC 

AFFAIRS 

OFFICER 

 Notify partners 

 Notify company personnel 

 Prepare for media interest 

 Keep the public informed 

 Coordinate media efforts through the Joint Information Center 

 Coordinate efforts with USCG 

 Identify community concerns 

 Evaluate/ monitor hazards 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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TABLE 3.3-2 (CONTINUED) 

IMT CHECKLIST 

POSITION RESPONSIBILITIES COMMENTS 

SAFETY 

OFFICER 

 Notify offset operators 

 Obtain MSDS / Prepare Site Safety Plan 

 Establish first aid posts 

 Coordinate search and rescue operations 

 Coordinate post-incident debriefing 

 Conduct air monitoring as may be needed 

 Establish initial site safety plan 

 Ensure HAZWOPER compliance 

 Investigate safety related accidents and report to Incident 

Commander 

 Conduct safety inspections 

 Commence source control operations 

SOURCE 

CONTROL 

 Verify amount spilled 

 Calculate total potential 

 Mobilize source control specialist 

 Develop / Obtain approval for repair plan 

 Direct surveillance operations 

OPERATIONS 

 Mobilize Response Contractors as needed and other available 

equipment that is deemed necessary to response efforts by the 

UC. 

 Equipment / operators / supervisors 

 Take air monitoring equipment 

 Obtain samples of spilled material 

 Prepare shoreline for impact (pre-clean) 

 Contact Airborne Support, Inc. (ASI) 

 Spray / Spotter aircraft and personnel 

 Vessel for USCG SMART Team 

 For assistance contact OOPS 

See Appendix B for equipment (potential services not 

under contract). 

WILDLIFE 

BRANCH/GRO

UPS 

 Send company representative to site/ staging 

 Consider night time spill tracking – Real Time Tracking 

Information (RTTI) 

 Consider pre-cleaning the shoreline prior to impact 

 Assist in SCAT process to determine shoreline response 

 Contact wildlife specialist/ refuge mgrs. for info. 

 Consider scare cannons 

 Call Wildlife Rehab 

 Prepare Air Operations Plan 

 Develop waste disposal plans 

 Set up decontamination stations 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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TABLE 3.3-2 (CONTINUED) 

IMT CHECKLIST 

POSITION RESPONSIBILITIES COMMENTS 

LOGISTICS 

 Locate utility / crew boats, helicopters 

 Identify/ set up staging areas 

 Ensure temporary storage-recovered oil capacity 

 Request mechanics / parts trailers 

 Prepare medical plan, source emergency medical technicians (EMTs) 

 Prepare communications plan (ICS 205) 

 Obtain security at Incident Command Post (ICP) / staging areas 

 Establish services 

 Housing 

 Catering 

 Parts trailers/ mechanics 

 Fueling facilities 

PLANNING 

 Call Response Group 

 Request trajectories 

 Show dispersant timeline 

 Shoreline impact? Request sensitive areas 

 Update with weather forecasts / surveillance 

 Prepare dispersants / in situ burning request form 

 Post / Update charts in ICP 

 Commence Natural Resources Damage Assessment (NRDA) 

operations (sampling) 

 Determine Sensitive Areas as Identified in the Area Contingency Plan 

(ACP) 

 Call out technical specialists as needed 

 Prepare ICS 201 and IAP 

 Set up secured filing system 

 Obtain USCG approval for decanting 

FINANCE 

 Issue Web-based System (WBS) Element 

 Prepare for claims 

 Review contracts with Logistics/ vendors 

A fully integrated UC provides for open communication between the RP and government representatives, 

expedites permitting and plan approvals, ensures that response and resource protection priorities are 

established based upon the best information available, and provides for the sharing of response assets. 

The use of a IC structure provides for optimal management and efficient use of available response 

resources to implement approved tactics and strategies. State, local, and federal government 

participation, as UC representatives and within the IMT, provides a venue for addressing concerns and 

regulatory issues as objectives, strategies, and tactics are being developed. UC representatives review 

and approve the IAP that is presented for each defined operational period. 

For state, federal, and local representatives, a coordinated approach to managing a response provides an 

opportunity to determine the appropriate role(s) for agency personnel and to position them optimally 

within the IMT structure. For the RP, it ensures members of the IMT have access to valuable expertise 

without diluting their ability to manage response operations. 
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3.4 REALISTIC MAXIMUM RESPONSE OPERATING LIMITATIONS 

[18 AAC 75.425(e)(3)(D)] [30 CFR 254.26(D)] 

Certain environmental conditions can sometimes limit the options for response and their overall 

effectiveness. Some limitations are based on safety and health, and others concern equipment 

effectiveness or access. The environmental and safety factors potentially impacting a spill response in 

the Chukchi Sea are primarily weather-related and include: 

 reduced visibility and available daylight; 

 wind and sea conditions; 

 sea ice and structural icing; and, 

 cold temperatures. 

Generally, response effectiveness is not determined by any one single environmental factor or threshold. 

Environmental factors interact to compound response operating challenges. Operational efficiency also 

may be affected from these combined environmental factors. This complicates the task of setting distinct 

operational limits for each potential environmental factor. To achieve the most effective response, an 

assessment of on-site environmental conditions by trained response personnel is necessary to determine 

the operational strategy and tactics appropriate for the actual conditions encountered in the field. 

Personnel safety would always receive top priority during any spill response. 

Environmental conditions that challenge the effectiveness of response operations may also impact drilling 

operations. Shell’s Chukchi Sea COCP and IMP identify drilling restrictions during adverse weather that 

serve as prevention measures. The plans describe procedures for continuous weather surveillance and 

heavy-weather policies that aid drilling personnel in determining the correct procedures to follow when 

storm conditions are expected. Shell, consistent with the COCP, would evaluate the need to suspend 

operations during periods of adverse ice, weather, or sea states that significantly increase the likelihood 

of a release or severely hamper the ability to contain or control a release. Should it become necessary to 

cease critical operations, methods will be followed for securing the well and the drillship, ceasing drilling 

operations and hanging off the drillpipe. Critical operations will not recommence until it is deemed safe by 

the appropriate personnel. As part of that decision, the Shell Drilling Foreman will assess the risks 

associated with drilling, including: 

 evaluating the forecast for weather conditions; 

 fuel and water sustainability; 

 safety of operations: type of operation needed, hazards, and the risks involved; and 

 availability of emergency equipment. 

The procedures for ice management include identifying the alert status and conditions of ice movement 

and the site-specific procedures for the support vessels. See Table 3.4-1 (Ice Alert Levels) and Table 

3.4-2 (Ice Alert Roles and Responsibilities). 
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For discussion and details on response equipment operating in varying ice conditions refer to Section 

1.6.13, Tables 1.6-10 and 1.6-20, the Shell Beaufort and Chukchi Seas Regional Tactics Manual (Tactics 

OR-2C, OR-2D, OR-4A, OR-4B, OR-5A, OR-5B, OR-7), and the ACS Technical Manual (Tactic L-7). 

Timing and characteristics of the environmental conditions at Shell’s Chukchi drill sites differ in a number 

of respects from the descriptions and dates under which many of the North Slope Operators function (as 

detailed in ACS Tactic L-7.) For example, this would include weather, sea conditions, ice, daylight hrs, 

and other environmental conditions. Additional information on seasonal ice conditions in both nearshore 

and offshore areas is provided in Section 3.4.2. 

Under certain conditions, the use of in situ burning or dispersants would also be considered in conjunction 

with, or to augment mechanical recovery operations. See Section 1.7.3 for additional information on the 

considerations to augment mechanical response with non-mechanical strategies and tactics and Section 

3.7 for a discussion of in situ burning and dispersant response measures in the Chukchi Sea. 

TABLE 3.4-1 

ICE ALERT LEVELS 

ALERT 

LEVEL TIME CALCULATION ACTION 

Green (HT – T-Time) is greater than 24 hrs Normal operations 

Yellow (HT – T-Time) is greater than 12 hrs but less 

than 24 hrs Heightened awareness 

Orange (HT – T-Time) is greater than 6 hrs but less 

than 12 hrs 

Limited well operations in line with COCP, possibly 

commence securing well 

Red (HT – MT) is less than 6 hrs Secure well, disconnect riser and commence mooring 

recovery operations 

Black HT is less than 1 hr Move drillship to a safe location 

Definitions: 

Ice Alert Level: The Ice Alert Level is a color-coded hazard category that depends on the time necessary to secure the well and to 

prepare the drillship to move to a place of safety in event of a confirmed hazardous ice incursion. 

Hazard Time (HT): HT is the estimated arrival time, in hours, of hazardous ice at the drill site. 

Secure Time (ST): ST is the time, in hours, required to cease drilling operations and temporarily abandon the well in a way that 

prevents leakage and make ready for departure of the drillship from location. 

Move Off Time (MT): MT is the time, in hours, to disconnect from the subsea BOP, recover the riser, lower the marine riser package, 

safely store all items aboard the vessel, recover the moorings, and make the vessel ready to evacuate the site. The move off time 

varies depending on the method of anchor recovery, which in turn depends on changing environmental conditions. A very short MT

can be achieved in an emergency by actuating the rig anchor releases (RARs) or by simply running the anchor lines off the winches, 

dropping the entire mooring system on the seafloor for later recovery. 

Total Time (T-Time): T-Time is the sum of MT and ST, and represents the total time required to terminate drilling operations, safely 

secure the well and move the drillship off the drill site. 

Hazardous Ice: Hazardous ice is any ice feature that is considered to be a threat to the continued safe operation of the drillship. 
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TABLE 3.4-2 

ICE ALERT ROLES AND RESPONSIBILITIES 

Alert Condition Shell Drilling Foreman Frontier OIM 

Marine 

Superintendent Ice Advisor 

Green 

Hazardous ice is not expected to arrive at location within T-Time plus >24 hrs 

Establishes potential well ST in conjunction with the VMT. Advises OIM and Frontier Drilling Supt. regarding any critical operations and curtailment plans. Approves Ice Alert Level. 

Monitors ice reports and forecasts, directs ice management operations. Determines Ice Alert Level in conjunction with VMT 

Establishes potential MT 

Monitors ice conditions and predictions, reportHT to the OIM and VMprovides link to Ice Pilofor ice management vessel deployment and recon. 

Yellow 

Hazardous ice is not expected to arrive at location within T-Time plus >12 but <24 hrs 

Monitors well operations relative to ice forecast. Establishes potential well ST in conjunction with the VMT. Advises OIM and Frontier Drilling Superintendent regarding any critical operations and curtailment plans. Approves Ice Alert Level. 

Monitors ice reports and forecasts, directs ice management operations. Determines Ice Alert Level in conjunction with VMT 

Establishes MT Monitors ice conditions 

and predictions, reportHT to the OIM and VMprovides link to Ice Pilofor ice management vessel deployment, recand ice management operations. 

Orange 

Hazardous ice is not expected to arrive at location within T-Time plus >6 to <12 hrs 

Approves Ice Alert Level. Establishes potential well ST and, if required, initiates well secure operations. 

Determines Ice Alert Level with VMT. Monitors and controls ice operations. 

Continuously updates all the potential MT. Ensures anchor handling and RAR capability. 

Monitors ice conditions and predictions, reportHT to the OIM and VMprovides link to Ice Pilofor ice management operations. 

Red 

Hazardous ice is expected to arrive at location within MT plus < 6 hrs 

Approves Ice Alert Level. Manages well secure operations and updates OIM on well status. Establishes availability of additional support for site departure operations. 

Monitors ice conditions and directs ice management operations for return to drill site. Confers with the Drilling Foreman on course of action to be taken 

Manages mooring recovery operations 

Monitors ice conditions and predictions, reportHT to the OIM and VMprovides link to Ice Pilofor ice management operations. 

Black 

Hazardous ice is expected to arrive at location within 1 hour 

Approves Ice Alert Level. Confers with OIM and monitors ice conditions for return to drilling location. Prepares well reentry prognosis with Drilling Engineers, and reviews with MMS Field Representative. 

Monitors conditions for return. Confers with Drilling Foreman on the return Ice Alert Level and tentative timing. 

Safely clears drilling location with the drillship. Prepares for return 

Continues to monitor icconditions, prepares nestimates of HT for anhazardous ice featuresassist in establishing tito return to drill site. 

IA = Ice Advisor RAR = Rig Anchor Release MT = Move Off Time IWC = Ice and Weather Information Center ST = Secure Time OIM = Offshore Installation Manager VMT = Vessel Management Team 
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3.4.1 Adverse Weather Conditions 

MMS regulations (30 CFR 254.23 and 30 CFR 254.26(d)) for a Facility Response Plan require 

consideration of how a spill response would be managed during adverse weather conditions. The 

effectiveness of mechanical containment and response equipment and tactics may be impacted by 

extreme weather conditions. Activities at the drill site may be curtailed due to safety considerations. 

Temperatures below -35o F may cause failures in hydraulic equipment. Winds above 15 knots with 30-

knot gusts are strong enough to make hoists and lifts unsafe, 10 to 20 ft (3 to 6 m) above ground, with 

whiteouts restricting visibility to a few feet. Drill site activity may also be curtailed if crucial materials or 

supplies cannot be delivered. If conditions should arise that effectively prohibit the recovery or 

containment of an oil spill as per the USCG Marine Safety Manual and 30 CFR 254.23, the Shell Drilling 

Foreman will lead a risk assessment with the participation of the Toolpusher, location personnel and Shell 

Management. A joint decision is made by the VMT as to the level of risk in accordance with Shell’s 

Chukchi Sea Ice Management Plan. 

In general, meteorological and oceanographic conditions at the project location are moderate during the 

summer months of June through August. Winds are predominately from the ENE June through 

November with occasional low-pressure systems moving into the area from the western Pacific through 

the Bering Strait bringing warm air and moisture. Wet conditions producing fog and rain can result in 

periods of low visibility on the open ocean. Storms are more common during the winter months than the 

summer. The frequency of storms and associated high winds increase with the transition of open water 

season into the fall freezeup time frame. Severe storms generally originate from the SW, progress swiftly 

into the area, and last a relatively short time, although rough weather may on occasion persist for many 

days. 

Weather and ice conditions that may be present during the drilling season are also represented in the 

Sections 1.6.13, Response Strategies. Additional information may be found in Section 2.4.2 and 2.4.3, 

and below in Section 3.4.2 and 3.4.3. 

High Winds 

Deployment of oil spill response equipment in the Chukchi Sea would not normally be limited soley by 

high winds. Chukchi winds on the whole are moderate (5 to 7 m/sec or 10 to 13 knots). Winds exceeding 

10 m/sec or 20 knots are less common and tend to occur predominately from October through March and 

near the coast. Extreme winds, recorded at the Barrow weather station for all months, may be directly 

attributed to the large fetch of the Arctic Ocean to the north, east, and west, as well as the lack of physical 

barriers and level tundra stretching 200 mi (322 km) to the south. 

Shell leases are situated approximately 52 n mi or more west of the Chukchi coast. Table 3.4-3 presents 

average and maximum wind speed values for the months June through November that were gathered by 

Shell within the lease vicinity. This data represents measurements for the period June to November of 

1980, 1982, and 1983. Based upon these measurements, the aggregate and predominant offshore winds 

during the June through November season were NE to SE 54 percent of the time and NW to SW 23 

percent of the time. Winds equal to or exceeding 15 knots occurred approximately 22 percent of the time 

and winds exceeding 30 knots were considerably less than 1 percent for the data collected. 
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TABLE 3.4-3 

AVERAGE AND MAXIMUM WIND SPEEDS 

Month Maximum Speed 

(knots) 

Average Speed 

(knots) 

June 21 9.6 

July 25 9.9 

August 25 11.5 

September 36 13.3 

October 32 13.1 

November 34 15 

Wind can impact mechanical response operations by hampering the ability of vessels to maintain 

position, limiting the ability of the crews to work on deck, impeding equipment and work boat deployment 

and retrieval, and may limit containment of oil within the boom. 

Mechanical spill response equipment for the Chukchi Sea was selected for the variable conditions that 

may be encountered. The offshore/coastal boom and the skimmer systems may be deployed and 

operated in sea states associated with up to Beaufort Wind Force 6. The corresponding wind speeds for 

these sea states are up to 22 knots. Alternative countermeasures would be considered to extend 

response operations beyond these wind speeds. 

Response efficiencies may also be dependent upon other compounding variables (e.g., temperature, sea 

state, or visibility) that may make the specific wind speed problematic. The Wind Chill Factor addresses 

safety concerns for personnel. Heavy clothing, while being the primary means of protecting personnel 

from the effects of wind chill, may also hinder the ability of personnel to work quickly and efficiently in cold 

weather. 

Temperature 

Lower temperatures affecting response efficiencies are compounded by several factors including: 

sustained (long-term) cold temperatures and wind-chill factor; icing on vessels and barge decks 

(structural icing); safety and efficiency of personnel; effectiveness of iced response equipment; and oil 

viscosity. Personnel safety is priority. Response operations will provide for personnel safety based upon 

the Threshold Limit Values, Chemical Substances and Physical Agents and Biological Exposure Indices. 

Considering temperature alone and based upon the number of average monthly temperatures below 

-20°F, response capabilities begin to be affected in November through April. Workers in temperatures 

below -25°F must take more breaks with time indoors. At temperatures below -45°F, all non-emergency 

work will stop. Table 3.4-4 lists the percentage of days per month when the average monthly temperature 

falls below -20°F and response effectiveness may be reduced solely due to temperature. 
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TABLE 3.4-4 

PERCENTAGES OF DAYS PER MONTH THAT 

TEMPERATURE COULD REDUCE RESPONSE EFFECTIVENESS 

FOR WORKER THRESHOLD LIMIT VALUES 

Jan Feb Mar April May June July Aug Sept Oct Nov Dec 

50% 64% 58% 17% 0% 0% 0% 0% 0% 0% 17% 42% 

Based upon the averaged monthly minimum temperature data for Barrow, AK from http://climate.gi.alaska.edu/climate/ 

Temperature also affects the viscosity of oil, complicating recovery efforts. Shell is fully aware of the 

challenges of responding to spills during freezing temperatures and has selected equipment that 

addresses a wide range of variable operating conditions. This equipment is capable of recovering oil of 

typical viscosities as well as highly viscous, waxy, or emulsified oils. 

3.4.2 Sea States, Tides and Currents 

Sea State 

Rough seas may affect the ability to deploy equipment, boom and skimmer efficiencies, the ability of 

vessels to maintain position, the ability of crews to work on a vessel, and the ability to tract and encounter 

oil. 

Consideration must be given to both wave height and wave period when evaluating sea state and the 

effectiveness of spill response options. Short-period waves or chop has a greater effect than long-period 

swells. While personnel safety is the primary consideration, a response that is ongoing and working may 

continue to be effective in long-period swells up to a Sea State 5 up to about 10 ft (3 m) in height 

correlated to a Beaufort Wind Force 6 (22 to 27 knots). Based upon measurements collected by Shell for 

the years 1980, 1982, and 1983, winds exceeding 22 knots occurred approximately 17 percent of the 

time. The effects wind speed and open water fetch on sea state are dampened with the onset of ice in 

November. Table 3.4-5 summarizes the relationship between the Beaufort Wind Force, sea state, and 

wind and wave conditions. 

The compounding influence of other environmental factors together with sea state can only be evaluated 

on a case-by-case basis. Alternative response methods, from both aerial and vessel-based platforms, 

may continue to be used beyond this sea state. 
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TABLE 3.4-5 

BEAUFORT WIND FORCE AND SEA STATE 

RELATIONSHIP BETWEEN WIND AND WAVE CONDITIONS IN FULLY DEVELOPED SEAS 

Beaufort 

Number 

Wind Speed 

Knots mph kph Wind Force Sea Surface Sea State 

Height 

(m) 

0 < 1 < 1 < 1 Calm Calm 0 0 

1 1-3 1-3 1-5 Light air Ripples with the appearance of 

scales; no foam crests. 0 0 

2 4-6 4-7 6-11 Light Breeze Small wavelets; crests of glassy 

appearance, not breaking. 1 0-0.1 

3 7-10 8-12 12-19 Gentle Breeze Large wavelets; crests begin to 

break; scattered whitecaps. 2 0.1-0.5 

4 11-16 13-18 20-28 Moderate Breeze Small waves, becoming longer; 

numerous whitecaps. 3 0.5-1.25

5 17-21 19-24 29-38 Fresh Breeze Moderate waves, taking longer form; 

many whitecaps; some spray. 4 1.25-2.5

6 22-27 25-31 39-49 Strong Breeze Larger waves forming; whitecaps 

everywhere; more spray. 5 2.5-4 

7 28-33 32-38 50-61 Near Gale 

Sea heaps up; white foam from 

breaking waves begins to blow in 

streaks. 

6 4-6 

Adapted: (http://www.psych.usyd.edu.au/vbb/woronora/maritime/beaufort.html ) 

kph = kilometers per hour 

Storm surges are coastal phenomena and can depend not only upon the storm characteristics, but also 

on the topography onshore and bathymetry offshore. The characteristics of a storm that affect the surge 

height include atmospheric pressure, wind speed and direction, as well as the storm’s direction and 

speed. Storm surges are greater when air temperature is colder than the water and the sea has little ice 

cover, providing a long fetch to generate waves and swells. The area from Point Lay to northwest of 

Barrow is generally of low relief and the offshore ocean floor is gently sloping. When the waters of the 

Chukchi are ice-free (July to October/November), storms from the W or SW may result in surges up to 10 

ft (3 m) along this section of the coast. Surges of 6 to 10 ft (2 to 3 m) are projected to be 10-year events 

(Brower et. al., 1988). 

The Shell lease area is approximately 52 n mi or more from the Chukchi coast. Storm surges in 

themselves are not expected to affect offshore drilling or response operations. However, the high winds 

and sea states associated with these storms may hamper offshore response operations. Shell, 

consistent with the COCP, will evaluate the need to suspend operations during these conditions. 

Tides and Currents

The tides in the Chukchi Sea are semidiurnal ranging from 0.3 ft to 2.5 ft (0.1 to 0.8 m) and generally 

would have negligible influence on offshore response efforts. However, strong coastal currents may 

affect shoreline protection strategies or cleanup efforts through the impact to boom effectiveness and the 

ability of vessels to maintain station. 

Currents in the Chukchi Sea typically range from 10 to 30 centimeter (cm)/sec (0.2 to 0.6 knot). Because 

open water currents occur over a broad area, the entire response system would be relatively affected as 

a whole; therefore, the system would not be impacted unless localized eddies or tidal rips occur. 
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Schematics of the Chukchi Sea currents may be found on the Unified Plan, Subarea Plan Web site at 

http://www.asgdc.state.ak.us/maps/cplans/base/AK-Circ.pdf. 

Seasonal Ice Conditions 

Sea ice can present a significant challenge for encountering oil with mechanical recovery equipment; 

however, ice also can provide natural containment of oil, and cold water temperatures can inhibit 

evaporation and weathering, thus extending the window of opportunity for mechanical recovery and in situ

burning when the oil becomes accessible as the ice concentration or cover lessens. 

The start of on-site project activities will begin after July 1 which coincides with the retreat of the ice in 

most years (early June to late July). The duration of open water (≤1/10 ice concentration) in the central 

Chukchi Sea has lengthened by up to four weeks over the past 30 years to a summer average of 17 

weeks. However, the range of open water is variable from year to year and ice could be present at the 

drill site. An Ice Management Plan will be implemented to ensure safe operations at all times. Exploration 

drilling will conclude by October 31. Other project activities will conclude with freezeup, which historically 

varies from late October to mid December. 

Landfast ice along the Chukchi coast is much less stable and expansive than in the Beaufort. Frequent 

“break-away” events can substantially alter the extent of the nearshore solid ice in a matter of hours. 

Freezeup at the shoreline in this region is highly variable with first new ice appearing as early as the first 

week in October and as late as the end of November. The inter-annual variability at a given coastal 

location is greater than the average north-south difference in timing of first ice (for example, comparing 

Wainwright and Barrow). Historically, the average freezeup dates at these two locations have differed by 

less than a week. 

The Chukchi Sea ice environment differs significantly from the Beaufort Sea. Important ice characteristics 

in this area (first-year ice thickness, multiyear ice occurrence, and open water season duration) are 

related strongly to latitude. The winter offshore ice cover is highly dynamic in response to wind and 

current driving forces and the nearshore fast ice tends to be unpredictable in extent and stability. 

Prevailing easterly winds across the northern Chukchi Sea often create an open water/thin ice “flaw” lead 

or polynya paralleling the fast ice edge. The broadest extent of this zone [up to 30 mi (50 km) out from 

the coast] occurs between Cape Lisburne and Point Lay an average of 65 percent of the time in the 

winter. The lead increases in frequency and extent after April. However, in extreme cases, sustained 

westerly winds can prevent the lead from opening in late winter and maintain the pack ice along the coast 

until mid or late summer. Figure 3.4-1 provides an overview of general regional ice conditions in the 

Chukchi Sea. 

Breakup 

Breakup along the central coast (vicinity of Wainwright) tends to be short-lived with ice concentrations 

dropping from close to complete cover at the shore to open water within a 5 to 10 day window. The 

timing of breakup at the coast is highly variable with historic dates over the past decade ranging from 

early June to late July. Breakup in the Wainwright area tends to occur between one and three weeks 

earlier than at Point Barrow. 

Breakup offshore (defined as first date with less than 9/10 ice coverage) spanned a two-month period of 

variability over the past 12 years, from mid-May to mid-August in the extremes. In most years (10 out of 
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12) the range in timing of initial breakup fell between early June and late July. The period of intermediate 

concentrations (2/10 to 8/10) tends to be very short with the transition from close to complete ice cover to 

open water occurring within one week in every year examined. 

FIGURE 3.4-1 

COMPARISON OF REGIONAL ICE CONDITIONS 

There is extreme variability in the timing of breakup and freezeup in the Chukchi Sea. Summer ice 

conditions are highly variable from year to year. For example, the duration of the summer open water 

period ranged from 8 to 24 weeks, reflecting the variability in breakup and freezeup dates. A record year 

of ice retreat in 2005 was followed by a late developing summer in 2006 and then a dramatic new record 

for minimum ice cover in the Chukchi region in 2007. 

Over the past 12 years (1996 to 2007) the onset of freezeup (first appearance new ice) in the vicinity of 

the previously drilled Burger prospect occurred between early October and the third week of November. 

The offshore transition period from very open drift ice to 9/10 or more ice concentrations is highly 

unpredictable, taking anywhere from one week to a month. Nearly complete ice cover has covered the 

area offshore of Wainwright as early as October 22 and as late as December 11 (1996 to 2007). 

Response in Broken Ice 

Ice may serve to reduce oil spreading and concentrate oil into thicker pools for more effective recovery or 

use of in situ burning or dispersant countermeasures. Recovery techniques in broken ice conditions 

would be similar to those employed during an open water response, such as locating pockets of oil 

contained by ice for skimming or burning. As freezeup begins and ice concentrations beyond 10 percent 

develop, various techniques and equipment that can be used to respond include managing drift ice by 

deflection to sustain or create open water pockets for skimming, releasing ice accumulations within 

containment boom, strategically recovering oil that concentrates in pockets between ice floes, and the 

potential to use alternative countermeasures such as in situ burning to augment mechanical response 

techniques when ice concentrations limit or preclude recovery options. 

As offshore ice becomes too concentrated or dynamic to mount any significant mid-winter on-ice recovery 

operations, mechanical response options become more targeted. The response scenario (Table 1.6-10) 

illustrates the recovery and treatment methods that can be used when conditions preclude the use of 

conventional boom for capturing oil and directing it to a skimming devise. Tracking buoys and satellite 

monitoring are employed to track the movement of potentially oiled ice. As ice encapsulates oil, the 

location can be marked and tracked for removal when the ice is safe to work on, or the oil could be 

tracked until spring. During breakup the following spring, response efforts continue. 
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Effectiveness of In Situ Burning in Open Water and in Ice 

The consensus of research regarding in situ burning of oil on open water and with ice is that burning is an 

effective technique with removal rates of 85 to 95 percent in most situations (Shell et al. 1983; SL Ross 

1983; SL Ross and DF Dickins 1987; Allen 1990; Allen 1991; Allen and Ferek 1993; Singsaas et al. 

1994). Results of considerable research have demonstrated the success of in situ burning in broken ice. 

The research includes several smaller-scale field and tank tests (SL Ross et al. 2003; Shell et al. 1983; 

Brown and Goodman 1986; Buist and Dickins 1987; Smith and Diaz 1987; Bech et al. 1993; Guénette 

and Wighus 1996) and one large-field test (Singsaas et al. 1994). Most of the tests involved large 

volumes of oil placed in a static test field of broken ice resulting in substantial slick thicknesses for 

ignition. Tests in unrestricted ice fields or in moving ice have indicated that the efficacy of in situ burning 

is sensitive to ice concentration and dynamics and thus the tendency for the ice floes to naturally contain 

the oil, the thickness (or coverage) of oil in leads between floes, and the presence or absence of brash or 

frazil ice which can absorb the oil. 

The following information addresses the practicality of burning in open water and with varying 

concentrations of ice while recognizing the effect that current (primarily wind-driven) could have upon the 

distribution of oil and, therefore, the feasibility of collecting and igniting the oil. 

Open Water with Current 

The initial distribution of the surfacing oil droplets in open water could involve a surface area with a 

diameter of several hundred meters. The outer reaches of this area would involve a relatively small 

percentage of the total blowout release as the largest droplets would surface more quickly near the center 

and the smallest droplets would rise more slowly, riding with the induced currents to the outer regions of 

the slick. Authorization for ignition of the gas cloud directly over the blowout would normally be requested 

as early as possible to avoid any risk of exposure to personnel on location and any accidental ignition that 

could expose personnel and equipment to fire.

Burning of the oil in this situation would require containment or deflection with boom to concentrate and 

thicken the oil while it is relatively fresh without emulsification. Towed open-apex boom configurations 

could be used downstream of the blowout to thicken and release concentrated bands of oil into fire boom 

being towed in a U-configuration. Once such fire booms reach their holding capacity, they could be 

moved a safe distance from the open-apex, where ignition and sustained combustion could be quite 

successful. While burning the contained oil, a second fire boom could be positioned downstream of the 

open-apex to collect oil for a second burn. The elimination of oil at the first boom could easily be 

completed in time to relieve the second collection effort before the fire boom reaches its holding capacity.

Open Water with Little or No Current 

Should oil and gas be released from the seabed with little or no current, it is likely that authorization would 

have been secured (as in the previous scenario) to ignite the free gas directly over the blowout to avoid 

harmful exposures to personnel and any accidental ignition of the gas plume. Without current to carry 

surfaced oil away from the blowout, there would be an accumulation of oil droplets at the surface allowing 

for the build-up and recoalescence of those droplets into a layer that could support combustion. In this 

case, it is likely that the heat generated by the burning of free gas would be sufficient to ignite vapors from 

the surfacing oil, thereby enlarging the burn area and removing a substantial portion of the blowout.
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The efficiency of removal by burning, however, could be improved if it was safe to deploy fire boom in a 

U-configuration at and immediately downstream of the surfacing oil and gas. The positioning of fire boom 

in this mode could be carried out safely if there was at least a light wind and/or a slight current that could 

carry the burning oil back into the apex of the U-configuration. Two boom-towing boats could be 

positioned well upstream of the surfacing oil and gas (using longer than normal tow lines) at a distance 

that would preclude any unsafe exposure to heat and smoke from the fire. Effective burning could be 

conducted without personnel, boats and boom when the surfacing oil is held naturally at and near the spill 

source. In fact, the heated air rising above the blowout would produce a thermally induced wind along the 

surface working radially inward toward the fire. Even a very light breeze of this kind could help reduce 

spreading of the oil and maintain oil thickness for improved combustion. If currents less than 1 knot 

and/or light winds were available to move the burning oil away from the source, boom-tending boats could 

work at a safe distance from the burning source, and substantially improve the efficiency of burn. 

Low to Moderate Ice Concentrations (with and without current) 

Even at relatively low ice concentrations (≤ 2/10), the effectiveness of conventional or fire booms may be 

reduced (depending upon the size and distribution of the ice pieces) for the collection of oil. If the 

distribution of ice is such that ice could not be avoided or deflected away from the opening of a boom 

configuration, then ice could accumulate in high concentrations within the boom. However, low ice 

concentrations are often present as discontinuous wind-consolidated strips separated by broad open 

water areas that limit use of boom to capture oil. In more scattered ice concentrations, responders could 

access oil at low speeds and encounter rates between ice floes. At such low ice concentrations, there are 

times when burning could be conducted with fire boom. 

Should broken ice (from as little as 2/10 to 3/10 to as high as 7/10 to 8/10 concentrations) move into and 

over the blowout, the ice could actually help in a number of ways. The ice would tend to dampen waves, 

reduce surface spreading radially over the blowout, and promote recoalescence of the surfacing oil 

droplets in the reduced water surface between ice cakes or floes. Under these conditions there would be 

an increased potential for the accumulation of oil on water at thicknesses that could support sustained 

combustion. 

As long as the ice concentrations do not become excessive (greater than 8/10 to 9/10) and/or the ice 

comes under pressure, there should remain sufficient oil-on-water area to support combustion. Also, as in 

the previous open water scenarios, if water movement over the blowout drops to little or no current, the 

increased accumulation of oil between ice floes would only enhance the overall efficiency of burning. 

Induced radial currents over, and adjacent to the blowout may prevent much of the oil from sticking to the 

underside of ice cakes and small floes. Therefore, most oil would be exposed for combustion while it is 

fresh and relatively free of emulsification. Should the natural floes be large enough to entrap some of the 

oil beneath them and keep the oil from surfacing, efforts could be initiated with ice management vessels 

at a safe distance upstream of the blowout to break such ice into smaller pieces or deflect large floes 

away from the blowout. 

Ice management is a proven technique that can completely modify the composition of the ice moving over 

a drilling location. For example, a 2004 coring program at 88°N saw two ice management vessels 

successfully work to maintain a drillship on location in high concentrations of 7 to 9 ft (2.1 to 2.7 m) ice 

thickness. Floes drifting towards the drill site were over 3,000 ft (914 m) in diameter. By the time they 

arrived the ice management vessels had reduced the average ice piece size to between 35 and 43 ft 

(10.6 to 13.1 m) (Keinonen et al. 2006). In addition to managing the floe sizes, oil could be dislodged from 

the underside of ice (before it becomes encapsulated within the ice) using prop-wash from vessels on 

location. 
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Another approach that could enhance combustion of oil with moving ice concentrations involves the use 

of large ice-deflection barriers such as a barge with tug assist or a vessel with dynamic positioning. Shell 

has conducted extensive mathematical and ice-tank modeling efforts to show that such large-scale 

deflection of ice appears safe and feasible for the creation of a relatively ice-free surface downstream of 

the deflection operation. Pending the results of full-scale trials with ice, it is likely that moving broken ice 

and early freezeup ice (new ice, nilas) could be deflected with a barge or vessel positioned sideways to 

the current/ice flow. Temporary paths of relatively open water several hundred feet wide could be created 

downstream of the deflection system to facilitate the use of conventional containment and recovery tactics 

and/or the use of fire boom in a conventional burn mode. 

High Ice Concentrations and Continuous Layers of New Ice in Early Winter 

The movement of a continuous layer of new ice or very high ice concentrations over a subsea blowout 

could reduce the effective use of in situ burning. There could be a reduction in the air/water surface area 

to accumulate oil and allow for efficient sustained combustion. This could be remedied in two ways: one 

involving the natural processes, and the other involving ice management. Experience has shown that 

large gas accumulations beneath ice will accumulate and rupture continuous ice layers (Dickins and Buist 

1981) during early freezeup. The ice would likely break up, move out and away from the blowout, rafting 

and accumulating to create a natural barrier within which burning of the oil and free gas could take place. 

The other remedy involves the use of large ice-deflection systems upstream of the blowout as described 

above. Such deflection would provide an opening for burning on ice until prevented by excessive ice 

thickness. If the ice was continuous [even at relatively thin layers such as 3 to 6 inches (7.2 to 15 cm)] 

tank-test results suggest that it would be necessary to use ice management vessels forward of the 

deflection system. As long as the ice could be broken, and not too thick or pressured, it is possible that a 

relatively ice-free path could be opened just forward (or upstream) of the blowout. Oil (even widely 

scattered particles) surfacing within the cleared path downstream of the deflection system would soon be 

trapped within the downstream opening bounded on each side by ice. Even if bounded by broken ice and 

slush, these “walls of ice” would help contain and limit the spread of oil. The ice boundaries would provide 

considerable natural containment for the oil and enhance the potential and efficiency of elimination by 

burning. 

As the ice boundaries continue to collapse inward on the cleared path of nearly open water, any 

contained oil would build in thickness, improving its condition for sustained and efficient combustion. 

Burning could occur in that ice-contained pocket as it moves away from the blowout. If the blowout was 

sufficient in flow rate and/or the currents were low, the buildup of oil at and immediately downstream of 

the blowout could be thick enough to support an ongoing efficient elimination of oil. 

If conditions made it impossible or impractical to use the ice-deflection system, oil could surface beneath 

the continuous or solidly packed ice field where it would quickly become immobilized at the ice/water 

interface. If left undisturbed, new ice growth would soon provide a “lip” around the oil (typically within 

hours to a day, depending upon air temperature and ice thickness) further ensuring that the oil would not 

migrate out over a larger area. Typically within a day or two, new ice would completely surround the oil, 

encapsulating, immobilizing and preserving the condition of the oil. The ice-encapsulated oil can be 

marked and tracked for removal when the ice is safe to work on, or the oil could be tracked until spring. At 

that time the oil would become exposed at the surface through brine-channel migration or through surface 

melt down to the small entrapped oil droplets. The location and “mining” of oil from solid ice continues to 

be tested and enhanced; and, as long as it is safe to access the oiled ice by helicopter, these tactics 

could be implemented throughout most of the winter months. Of equal importance is the success with 

which oil has been burned after surfacing into melt pools in the spring. The elimination of evaporation, 
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emulsification and other weathering phenomena while the oil is frozen within the ice, makes it possible to 

burn the exposed oil safely and efficiently using well-established aerial ignition techniques. 

Still another tactic during this early freezeup phase involves the use of vessels to break the newly formed 

ice with oil under it, or about to be encapsulated within it. By breaking the ice and using the vessel’s propwash to dislodge oil from below the ice, oil can be flushed to the surface and trapped on or between 

pieces of ice. If there is sufficient oil present, the oil could be ignited and burned. 

Very Close Winter Pack Ice (greater than 9/10 concentration) 

There is the possibility that an incursion of older, multiyear ice could move in over a subsea blowout, and 

that a blowout could continue into the winter months exposing it to mix of growing first-year and multiyear 

ice. While highly unlikely, this scenario could involve the deposition of oil and gas beneath the closely 

packed ice floes. Depending upon the ice thickness and the volume of gas released with the blowout, the 

ice cover could fracture, thereby exposing both oil and gas at the surface. Depending upon the current 

and the rate of ice transport over the blowout, the rupturing of the ice could provide sufficient oil/gas 

exposure to support combustion. Previous studies of the possible effects of gas bubbles under the ice 

concluded that ice rupturing and gas/oil venting was likely with ice sheets up to three feet thick (Dickins 

and Buist 1981). 

In this situation, it might be possible to keep some of the larger ice management vessels on location until 

it is no longer feasible to physically break the ice forward and/or downstream of the blowout. Between 

natural rupturing of the ice (gas lift) and deliberate breakup with ice management vessels, every effort 

would be made to entrap oil at or near the surface for immediate combustion or for enhanced combustion 

later during breakup. 

As in the previous scenario with high ice concentrations, mid-winter response could (if it is safe to access 

the oiled ice) involve the location and recovery of oil using on-ice “mining” techniques. Promising results 

of tests with Ground Penetrating Radar and other remote-sensing systems could lead to the development 

and refinement of detection and tracking techniques for oil that is trapped deep within a thick ice layer 

(Dickins et al. 2006). Should the location and removal of oil be impractical during the winter months, oil 

deposited beneath and trapped within the ice in this way could be dealt with (as described above) when it 

becomes naturally exposed in the spring/summer period. 

Structural Icing 

The primary concern for structural icing in the Chukchi Sea is from sea spray. Structural icing of ships or 

drilling facilities is a concern in open water and coastal areas. Icing may cause hazards to personnel 

(e.g., slippery work surfaces such as decks or railings, moveable parts become inoperable because of 

icing). Environmental conditions that may cause significant spray icing are water temperatures less than 

46°F, winds of 25 knots or more, and air temperatures less than 28°F. From December to June in the 

Shell lease area, structural icing has a very unlikely possibility of impacting response operations because 

of a fairly complete sea ice cover. Structural icing becomes a concern as breakup occurs in June. By 

July, the air temperature has warmed enough that only light to moderate superstructure icing is a 

concern. By August the temperatures begin to cool and the possibility of icing increases in the northern 

part of the Chukchi Sea. Structures from the pack ice edge to Cape Lisburne are most likely to be at risk 

in September (Brower et al. 1988). 

Based upon Shell’s accumulated wind data for the months of June through November, winds recorded 

over 25 knots or more occurred just under 3 percent of the time. This same value may be extrapolated to 
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the possibility of structural ice occurrence for the months of June through November. However, this value 

does not reflect the amount of time that structural icing will result in unsafe ice accumulations that could 

affect both drilling or response operations. Vessels may take evasive action to avoid the accumulation of 

an excessive amount of ice by either heading directly into the wind or heading downwind (Brower et al. 

1988). Ice accumulations may also be mitigated by mechanical removal. Drilling operations shall be 

managed under the provisions of the COCP.

3.4.3 Hours of Daylight and Visibility 

Hours of Daylight 

Visibility can be hampered by several environmental factors including darkness, fog, snow, heavy 

precipitation, or low clouds. If wind, sea state, temperature, visibility and/or precipitation result in the 

reduction of response efficiencies, the additional factor of darkness may further complicate efforts to track 

and encounter oil and may limit flight operations. 

In Barrow, the sun does not set between May 10 and August 2 in summer, and does not rise between 

November 18 and January 24 in winter. From January 24 to May 10, daylight increases each day by not 

less than 9 minutes. By May 10 daylight has increased to 24 hrs/day. The sun remains visible from that 

time to August 2, when it again sets for 1 hour and 25 minutes. By September 1 there is just over 15 

hours of daylight and by October 7 there is just 10 hours of daylight. Daylight hours decrease at the 

same rate as the increase (http://climate.gi.alaska.edu/Stations/Arctic/Barrow.html). 

As the daylight hours diminish, visual aids shall be employed to continue open water response. 

Operations will continue by using lighting on booms, skimmers, and vessels. Buoy tracking systems, 

strobe lights, and infrared systems will be used to track oil in open water recovery efforts. On land, the 

use of portable lighting or infrared will be used to locate oil and assist recovery operations during periods 

of darkness. 

Visibility 

The increase of daylight also parallels the occurrence of cloudiness, precipitation, and heavy fog. All three 

build up to a maximum concurrent with the increased hours of daylight. Annual precipitation is light, 

averaging 5 inches (12 cm) (http://climate.gi.alaska.edu/Stations/Arctic/Barrow.html), and summer season 

pressure patterns are variable. June through August, the occurrence of reduced visibility on the open sea 

ranges from 25 to 30 percent. This is primarily from a high frequency of fog generated from WesternPacific low-pressure systems that move northeasterly through the Bering into the Chukchi and along the 

Alaskan coastline. 

For booming and skimming vessels, the visibility limitation varies between 0.125 and 0.5 n mi (200 to 800 

m), depending upon temperature, sea state, wind, and precipitation. The operational limitation for visibility 

depends upon whether response vessels are already recovering oil. For vessels actively booming and 

skimming oil, the operating limits would be set by the master of the vessel based on safety and 

operational efficiency. When vessels require aircraft assistance to locate recoverable slicks, the 

limitations would likely be for the aircraft. A realistic maximum response operation, based solely on hours 

of daylight, could only be determined on a case-by-case basis. Depending on other environmental 

factors, the visibility of less than 0.5 n mi (800 m) presents challenges for vessels tracking oil. Response 

efforts would continue below this level using the same tools that are employed for nighttime operations 

(e.g., lighting on booms, skimmers, and vessels) as long as it is safe to do so. Buoy tracking systems, 

strobe lights, and infrared systems will be also used to track oil in open water recovery efforts. 
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In the event of adverse weather, flight limitations caused by adverse ceiling and visibility combinations 

may restrict offshore operations and response. Customary North Slope standards for flight surveillance 

operations, based on Visual Flight Rules (VFR) for rotary- and fixed-wing aircraft are: 

 500-ft (152-m) ceiling and 1 mi (1.6 km) visibility if in sight of land, or 

 500-ft (152-m) ceiling and 3 mi (4.8 km) visibility if over open water and land is not in sight. 

3.5 LOGISTICAL SUPPORT [18 AAC 75.425(e)(3)(E)] 

The Logistics Section Chief is responsible for providing facilities, transportation, communications, 

services, and material in support of the incident. The Logistics Services Branch may include 

communications, information technology, medical, and food units. The Support Branch may include 

transportation, personnel, equipment, facilities, and supplies. 

Logistical support for spill response is provided through response contractors. Table 3.5-1 contains a list 

of vendors in Alaska that may be called upon to support Shell’s spill response operations. During a Tier II 

or III incident air operations will primarily be conducted from the Barrow airport. The air strips at 

Wainwright, Point Hope, and Point Lay (to a limited extent) would be utilized as back-up landing sites, or 

to position response equipment, as needed, along the coast. 

On a day-to-day basis, Shell provides the immediate spill response equipment within the Chukchi Sea. In 

addition, ACS can mobilize the OSRB to provide personnel and equipment for nearshore response 

operations (see Shell Beaufort and Chukchi Seas Regional Tactics Manual, Tactics LE-1 through LE-4, 

and ACS Technical Manual, Tactics L-1 through L-12) and ACS can mobilize personnel and equipment 

for shoreline protection and response along the Chukchi Sea coast (see ACS Technical Manual, Tactics 

L-1 through L-12). 

Depending on the severity of a situation, federal and state logistics may also support the response. 

Examples of these functions include ordering, tracking and servicing government resources, arranging for 

transportation and lodging for government response staff, providing communications to government 

oversight staff, and performing other logistical functions specifically in support of the government 

oversight role. These governmental functions may become an integral part of the overall Logistics 

Section. 
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TABLE 3.5-1 

LOGISTICAL SUPPORT CONTRACTORS 

COMPANY SERVICES CONTACT 

TRANSPORTATION 

Era Helicopters 

6160 Carl Brady Drive 

Anchorage, AK 99502 

Rotary-wing Passenger Transport, 

Medivac, Small Cargo, Aerial Ignition (907) 248-4422 

(907) 550-8600 

Peninsula Airways, Inc. 

6100 Boeing Avenue 

Anchorage, AK 99502 

Fixed-wing Passenger Transport, Cargo 

Transport, Medivac (907) 243-2485 

Frontier Flying Service 

5245 Airport Industrial Road 

Fairbanks, AK 99709 

Fixed-wing Passenger Transport, Cargo 

Transport, Medivac (907) 450-7250 

800-478-6779 

Carlile Transportation Systems 

1800 East 1st Avenue 

Anchorage AK 99501 

Ground Transportation (907) 276-7797 

800-478-1853 

Lynden Transport 

3027 Rampart Drive 

Anchorage, AK 99501 

Ground Transportation (907) 276-4800 

800-326-5702 

COMMUNICATIONS 

Alaska Telecom 

6623 Brayton Drive 

Anchorage, AK 999507 

Remote Site Systems, 

Microwave/Satellite Radio Systems, 

VHF/UHF handheld radios, satellite and 

cellular telephones 

(907) 344-1223 

Wire-Com - UIC 

6700 Arctic Spur Road 

Anchorage, AK 99518 

Communications, 

Data & Electrical (907) 563-2240 

ProComm/Motorola 

4831 Old Seward Hwy Suite 111 

Anchorage, AK 

Radio Communications 

Motorola Service 

Wireless 

(907) 563-1176 

North Slope Telecom 

2020 E Dowling #3 

Anchorage, AK 

Telecommunications Services 

Feasibility Studies & System Design 

Operations and Maintenance Services 

Aviation, Marine, & Power Systems 

(907) 562-4693 

GCI 

2550 Denali Street Suite 1000 

Anchorage, AK 99503 

Cellular Services, Local and Longdistance telephone service, wide area 

network (WAN) connectivity within AK 

and lower 48 states. Internet service 

(dial, DSL, T1) 

(907) 265-5600 

ASTAC 

4300 B Street Suite 500 

Anchorage, AK 99503 

Local & long-distance telephone service, 

Internet service (DSL, dial, wireless) 

cellular service 

(907) 563-3989 

AT&T Alascom 

505 E. Bluff Drive 

Anchorage, AK 99501 

Long-distance telephone service, 

Internet service, and WAN connectivity 

within AK and lower 48. 

800-620-6520 
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TABLE 3.5-1 (CONTINUED) 

LOGISTICAL SUPPORT CONTRACTORS 

COMPANY SERVICES CONTACT 

FACILITIES 

Marsh Creek LLC 

2000 E. 88th Avenue, Suite 100 

Anchorage, AK 99507 

Housekeeping and Catering 

907-258-0050 

Arctic Structures 

9312 Vanguard Dr 

Anchorage, AK 99507 

Planning, Design, and Construction of 

Remote Camps 

Metal and Modular buildings. 

(907) 522-2425 

Taiga Ventures 

2700 S Cushman St 

Fairbanks, AK 99701 

Remote Camps 

Camp Services 

Drilling Supplies 

(907) 452-6631 

PacificRim Logistics 

737 W. 5th Ave Suite 209 

Anchorage, AK 99501 

Remote Logistics 

Transportation Services (907) 277-5191 

Bering Marine 

6441 S. Airpark Place 

Anchorage, AK 99502 

Barge Camps 

(907) 248-7646 

Doyon Universal Services, LLC 

701 W Eighth Ave Suite 500 

Anchorage, AK 99501 

Camps and Catering 

(907) 522-1300 

ACS Technical Manual Tactic L-7 provides additional technical information on aircraft. 

Please refer to Appendix A for additional technical information regarding the vessels and aircraft to be 

used for offshore operations. 

3.6 RESPONSE EQUIPMENT [18 AAC 75.425(e)(3)(F)] 

This section is intended to provide additional information and lists of equipment to be used to conduct 

mechanical recovery of oil spill fluids and other response activities as discussed in Section 1.6. 

Information on mechanical response equipment is also provided in the Shell Beaufort and Chukchi Seas 

Regional Tactics Manual and in the ACS Technical Manual. 

3.6.1 Equipment Lists 

Spill response equipment is available through Shell for offshore and nearshore operations, as in Tables 

1.6-6, 1.6-7 and 1.6-8 of this Plan. ACS equipment is available to support shoreline protection and 

recovery activities. A list of the primary response assets that are available on the OSRV and VOSS 

staged in the Chukchi Sea may be found in the Shell Beaufort and Chukchi Seas Regional Tactics 

Manual, Tactic LE-3. 

On-site equipment and supplies may be contained in heated storage units to ensure their operability 

during cold temperatures, as necessary. There are a number of conexes included in the vessel fleet 

which include a supply of contingency materials, tools, PPE, and spare parts. 
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3.6.2 Maintenance and Inspection of Response Equipment 

ACS performs routine inspection and maintenance of all ACS response and prestaged land-based 

equipment. ACS holds the following USCG Oil Spill Removal Organization (OSRO) classifications:

 River/canal environments: Classes MMPD, WCD1, WCD2, and WCD3; 

 Inland environments: Classes MMPD, WCD1, WCD2, and WCD3; 

 Nearshore environments: Classes MMPD, WCD1, WCD2, and WCD3; 

 Offshore: Classes MMPD, WCD1, WCD2, and WCD3; and 

 Open ocean environments: Classes MMPD, WCD1, WCD2, and WCD3. 

ACS has fulfilled the equipment maintenance and testing criteria that these classifications require. 

Response equipment will be stored so that it can be rapidly deployed and in response-ready condition. 

Monthly inspections will be performed on all the offshore oil spill response equipment listed in Tactic LE3. The equipment will be maintained in response-ready condition. 

3.7 NON-MECHANICAL RESPONSE INFORMATION [18 AAC 75.425(e)(3)(G)] 

In situ burning and dispersant application will be considered as secondary response techniques. 

Additional information and considerations for when these options are to be considered are provided in 

Section 1.7 of this C-Plan. 

In Situ Burn 

One of the most important factors that influence drilling activities is the movement and amount of ice. Ice 

can pose a significant challenge for spill response; however, experience has shown that low temperatures 

and ice can often enhance spill response and reduce environmental impacts. For example: 

 Low air and water temperatures often result in greater oil equilibrium thicknesses thereby 

reducing spreading rates and areas of coverage. These reductions greatly reduce the potential 

for impact with natural resources while providing the potential for much higher oil encounter rates 

for mechanical recovery and burning operations. 

 Evaporation rates are reduced, leaving the lighter and more volatile components in the oil longer, 

thereby enhancing the ease with which the oil could be ignited. 

 Ice may actually dampen wave action and limit the fetch over which winds might otherwise create 

large waves. 

 While ice, even in low concentrations, can preclude the effective use of oil containment boom, 

responders may still operate with short boom extensions and skimmers to maneuver among ice 

pieces and intercept oil. 

 When ice concentrations preclude the use of any boom, the ice will often serve as a natural 

barrier to the spread of oil and help concentrate the oil for pocket-recovery operations with 

stationary skimmers. The natural containment of oil against ice will often result in thicknesses that 

could significantly enhance the efficient removal of oil with burning. 

 When high ice concentrations (very close pack) and/or continuous stable ice conditions prevail, 

any spilled oil (especially from a subsea blowout) will likely become immobilized and 

encapsulated within the ice and therefore isolated from any contact with airborne or waterborne 

resources. 
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 Oil encapsulated within the ice will be preserved physically and chemically so that its 

unweathered state upon release (deliberately exposed, or naturally released during breakup) will 

support combustion. 

In addition to the environmental factors described above, there are other spill source considerations that 

should be recognized as they influence the full potential for elimination of spilled oil with burning: 

 The spill scenarios associated with Shell’s operations in the Chukchi Sea involve the release of 

oil and gas from a subsea blowout (in contrast to an above-water release such as from a fixed 

drilling structure). Oil would therefore be released to a relatively small area on the water with 

initial slicks with widths of typically a few hundred meters or less. Even with the gas-induced flow 

of oil and water toward the surface and the resulting radial spread of oil outward from the source, 

the initial area of involvement will be localized and relatively easy to contain and/or deflect with 

booms. 

 Because of the likely release of large quantities of natural gas and vapors from the surfacing oil, it 

is likely that early ignition of that gas would be desirable as soon as the drillship is moved off 

location. The vapor cloud could be readily ignited using standard ignition procedures, thereby 

eliminating the accidental ignition of the source when vessels are in close proximity. The early 

ignition of the source would not only be prudent for safety reasons, it is possible that significant 

quantities of oil could be eliminated through combustion at/near the source. As discussed in 

Section 1.6.3, the potential ignition is intended to improve on-site safety conditions for 

responders; potential oil elimination is an ancillary benefit. As such, no response planning 

standard reduction is taken. Additionally, because this potential ignition is not posed as a 

response tactic, we anticipate the decision to ignite surfacing gas would be made by the UC as a 

part of a fully developed, and agreed upon, portion of an Incident Action Plan, and independent of 

the in situ burn guideline process described in Section 1.7.1. 

 With or without ignition of the blowout, prevailing atmospheric conditions in the Chukchi Sea will 

support safe operating conditions at or beyond a few hundred meters downwind of the source. 

To summarize key points: the nature of oil released to the surface; the oil’s limited spread due to reduced 

temperatures (and possible ice); and the potential for responders to access the oil before it moves far 

from the source and begins to weather, all enhance the potential for successful recovery and/or burning 

operations. 

Key Combustion Processes 

The following discussion summarizes the current state of understanding of the scientific principles and 

physical processes involved with in situ burning of oil on water and ice. 

For an oil slick on water or ice to become ignited, the oil must be thick enough to insulate itself from the 

water beneath it. The igniter can heat the surface of thickened oil to the flash point temperature at which 

the oil produces sufficient vapors to ignite. The rules of thumb for minimum ignition thickness are listed in 

Table 3.7-1. 
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TABLE 3.7-1 

MINIMUM IGNITABLE OIL THICKNESS ON WATER 

(ADAPTED FROM BUIST ET AL. 2003) 

OIL TYPE MINIMUM THICKNESS 

Light Crude and Gasoline 1 mm* (0.04 inches) 

Weathered Crude and Middle-Distillate Fuel Oils (Diesel and Kerosene) 2 to 3 mm (0.08 to 0.12 inches) 

Residual Fuel Oils and Emulsified Crude Oils 10 mm (0.4 inches). 

*mm = millimeters 

The oil removal rate for in situ oil fires is a function of fire size (or diameter), slick thickness, oil type and 

ambient environmental conditions. For most large [greater than about 10 ft (3 m) diameter] fires of 

unemulsified crude oil on water, the “rule- of-thumb” is that the burning consumption rate is 3.5 

millimeter/minute (min). Lighter fuels burn faster while heavier oils and emulsions burn slower, as shown 

in Table 3.7-2. 

TABLE 3.7-2 

BURN REMOVAL RATES FOR LARGE FIRES ON WATER 

(ADAPTED FROM BUIST ET AL. 2003) 

OIL TYPE/CONDITION BURN/REMOVAL RATE 

Gasoline >10 mm (0.4 inches) thick 4.5 mm/min (0.18 inches/min) 

Distillate Fuels (diesel and kerosene) >10 mm (0.4 inches) thick 4.0 mm/min (0.16 inches/min) 

Crude Oil >10 mm (0.4 inches) thick 3.5 mm/min (0.14 inches/min) 

Heavy Residual Fuels >10 mm (0.4 inches) thick 2.0 mm/min (0.08 inches/min) 

Slick 5 mm (0.2 inches) thick1 90% of rate stated above 

Slick 2 mm (0.1 inches) thick1 50% of rate stated above 

Emulsified oil (percent of water content)2 Slower than above rates by a factor equal to the 

water content percent 

Estimates of burn/removal rate based on experimental burns and should be accurate to within ±20 percent. 

1. Thin slicks will naturally extinguish, so this reduction in burn rate only applies at the end of a burn. 2. If ignited, emulsions will burn at a slower rate almost proportional to their water content (a 25% water-in-crude-oil emulsion

burns about 25% slower than the unemulsified crude). 

Burn rate is also a function of the size of the fire. Crude oil burn rates increase from 1 mm/min (.04 

inches/min) with 3-ft (0.9-m) diameter fires to 3.5 mm/min (0.14 inches/min) for 15-ft (4.6-m) diameter 

fires and greater. In situ burns on melt pools typically consume oil at 1 mm/min (.04 inches/min). For very 

large fires, on the order of 50 ft (15.2 m) in diameter and larger, burn rates may decrease slightly because 

there is insufficient air in the middle of the fire to support combustion at 3.5 mm/min (0.14 inches/min). As 

fire size grows to the 50-ft (15.2-m) range, oil type ceases to affect burn rate for the same reason. 

An in situ oil fire extinguishes naturally when the slick burns down to a thickness that allows enough heat 

to pass through the slick to the water to cool the surface of the oil, below the temperature required for 

sustained combustion. The thickness at which an oil fire on water extinguishes is related to the type of oil 

and initial slick thickness. The rules of thumb are presented in Table 3.7-3. Other, secondary factors 

include environmental effects such as wind (winds greater than 20 knots preclude in situ burning in most 

cases) current herding of slicks against barriers, and oil weathering. 
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TABLE 3.7-3 

FIRE EXTINGUISHING SLICK THICKNESS 

(ADAPTED FROM BUIST ET AL. 2003) 

OIL TYPE/INITIAL SLICK THICKNESS EXTINGUISHING THICKNESS 

Crude Oil up to 20 mm (0.8 inches) thick 1 mm (0.04 inches) 

Crude Oil 50 mm (2 inches) thick 2 to 3 mm (0.08 to 0.12 inches) 

Distillate Fuels any thickness 1 mm (0.04 inches) 

With an estimate of the initial thickness of a fully contained slick, or a measure of the burn time, it is 

relatively easy to estimate oil removal efficiency by burning. If not all of the slick area is on fire; the 

calculations need to account for this. 

Oil removal efficiency through burning may be summarized as a function of the following key factors: 

 Initial thickness of the slick, 

 Thickness of the residue remaining, and 

 Amount of the slick’s surface that was on fire. 

The water current maintains the oil thickness in the open-apex configuration of a fire-resistant boom 

under tow, or against an ice edge in wind. When burning in a current, the fire slowly decreases in area 

until it reaches a size that can no longer support combustion. This herding effect can increase overall 

burn efficiencies, but it extends the time required to complete each burn. 

The residue from a typical, efficient (greater than 85 percent removal) burning of crude oil 10 to 20 mm 

(0.4 to 0.8 inches) thick is a semi-solid, tar-like layer that has an appearance similar to the skin on an old 

can of latex paint that has gelled. For thicker slicks, typical of what might be expected in a towed fire 

boom [about 150 to 300 mm (6 to 12 inches)], the residue can be a solid. Burn residue is usually denser 

than the original pre-burn oil, and usually does not spread because of its increased viscosity or solid 

nature. 

Most unburned oil or burn residue following combustion would be transported from the vicinity of the 

blowout by wind or currents; should any residue remain on the surface in the immediate area, it could be 

recovered by various means, including the use of booms in open water conditions downstream of the 

burn area, or by response personnel using nets, poles or other simple equipment over-the-side of small 

work boats, subject to safe working conditions, weather, and available time. 

Compared with unemulsified slicks, emulsions are much more difficult to ignite and, once ignited, display 

reduced flame spreading and more sensitivity to wind and wave action. Stable emulsion water contents 

are typically in the 60 percent to 80 percent range with some up to 90 percent. The oil in the emulsion 

cannot reach a temperature higher than 100°C until the water is either boiled off or removed. The heat 

from the igniter or from the adjacent burning oil is used first, mostly to boil the water rather than heat the 

oil. 

While formation of stable water-in-oil emulsion may decrease burn efficiency, emulsion formation is 

slowed dramatically by high ice concentrations and may not be a significant operational factor in planning 

in situ burning of oil on solid ice or naturally contained in higher concentrations of broken ice. 

In summary, in situ burning of oil is efficient and rapid in broken ice conditions under the following 

conditions: 
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 The spilled oil is thicker than the minimum required for ignition [a thickness of 2 to 3 mm (0.08 to 

0.1 inches)] results in 50 to 66 percent removal efficiency: 10 mm (0.4 inches) thickness, a typical 

thickness for wind-herded slicks on melt ponds on ice, gives 90 percent removal efficiency; 

 Larger areas can be ignited a 9.3 sq m (100 sq ft) slick on a melt pool will burn at 3.5 barrels of oil 

per hour (boph), a 50 ft (15.2 m) diameter, 10 mm (0.4 inches) thick slick will burn at 300 boph 

and a 9.3 m (100 ft) diameter slick will burn at 1,200 boph; 

 The oil is not more than 25 percent emulsified; and 

 Herding in a current and enlarging fire diameters can increase burning rates. 

The potential for efficient oil spill response (with or without burning) is strongly tied to the nature and 

amount of ice present. The following section addresses the seasonal ice conditions in Shell’s area of 

interest in the Chukchi Sea during the proposed drilling season. 

Operational Preparedness 

Shell and its contractors maintain a comprehensive inventory of equipment to initiate and sustain burning 

operations throughout the proposed drilling season. The Shell Beaufort and Chukchi Seas Regional 

Tactics Manual and ACS Technical Manual contain specific tactical guidelines for the offshore operations 

with and without ice. Many of these tactics (e.g., Shell Tactics OR-1B, OR-2B and OR-4B and ACS Tactic 

R-20) illustrate ways to intercept oil with an open-apex U-boom configuration so that thin or scattered oil 

slicks can be concentrated for recovery or captured downstream of the open-apex for burning within a fire 

boom. 

Some of the tactics within each manual are specific with guidelines for implementing and sustaining 

burning on open water and in the presence of ice (e.g., Shell Tactic OR-7 and ACS Tactics B-3, B-4, B-5, 

B-6 and B-7). These tactics are incorporated in this C-Plan by reference, along with shoreline concepts 

for burning nearshore in Section 1.6.12 (Shoreline Cleanup). 

ACS conducts in situ burn training and competencies several times a year at different North Slope 

locations. Typical courses involve at least an hour of classroom instruction and an hour of field exercises 

involving basic combustion theory, guidelines for safe operating procedures, and gelled fuel mixing and 

heli-torch deployment. Table 3.7-4 summarizes the Shell and ACS inventory of specialized major 

response equipment to support a large-scale burn operation. 

TABLE 3.7-4 

INVENTORY OF IN SITU BURNING EQUIPMENT (SHELL AND ACS) 

EQUIPMENT QUANTITY 

Shell

HydoFire Boom [152 m (500 ft) per system] 2 

Cooling Water Pumps and Hoses 2 

ACS

Fire Boom [50-, 76- and 102-cm 

(20-, 30- and 40-inch) skirts] 

5,791 m (19,000 ft) 

Heli-torch (55 gal.) 6 

Heli-torch (300 gal.) 2 

Heli-torch SureFire gel 544 kilograms (1,200 pounds) 

Air Deployable Igniters > 1,400 

Heli-torch Batch Mixers (gelled fuel) 2 
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In addition, Shell and ACS maintain all appropriate logistical support for controlled burning, including 

boom-tending vessels, helicopters and vessels to transport and deploy equipment and ignition systems, 

and fire extinguishers. 

Regulatory approval must first be obtained before using in situ burning depending on whether the burning 

operations will be conducted in federal or state waters. The “In situ Burning Guidelines for Alaska” 

(ADEC, EPA, and USCG August 2008) Application for in situ burning will be submitted to the UC. An 

incident-specific burn plan is contained within the application. 

Once relevant state and federal approval has been obtained, the following steps are normally taken to 

implement the response: 

 Use towed open-apex boom configuration(s) as necessary to concentrate and release oil directly 

into fire-resistant booms. Conventional boom may be used for this operation. 

 Collect and contain the oil using fire-resistant booms. Relocate the contained oil a safe distance 

from the open-apex configuration and other vessels. 

 In light ice cover (with ice-deflection/management support), collect and contain oil using fireresistant booms. 

 In higher ice concentrations, locate naturally occurring pools of thick oil. 

 As appropriate, use fire monitors and/or wash propulsion to gently direct oil into heavier 

concentrations against ice floes or densely packed ice cakes. Wind may provide such desired 

herding of oil naturally. 

 Ignite the oil using the heli-torch or handheld igniters, following established safety procedures to 

avoid flashback or ignition of any ongoing spill source. 

 Monitor the burn, maintaining constant watch on the fire and smoke plume. Maintain a careful 

assessment of fire boom condition (if used) and other safety hazards and issues as appropriate. 

 Make every effort to recover and dispose of the burn residue. 

Safety procedures and planning in accordance with established guidelines are emphasized throughout 

the training, preparation, and conduct of in situ burn operations. 

In situ burns are monitored to ensure that fire does not spread to any uncontained oil nearby and that 

burns are conducted at safe operating distances from all vessels and personnel on location. Personnel 

and equipment used in conducting the operation are kept at safe distances from the spill source (ongoing 

natural gas normally already ignited). The safe working distances from an in situ fire on water depend on 

the size of the fire and the exposure time, and are summarized in Table 3.7-5. Safety procedures and 

planning in accordance with established guidelines are employed throughout the training, preparation and 

conduct of in situ burning operations. Although the planning and conduct of operations are the same, 

distinction is made between the elimination of oil as a response technique, and the ignition of surfacing 

gas as a safety measure, as described in Section 1.6.3, Section 3.7, and elsewhere in this Plan. When 

ignition of oil in situ as a response action is proposed, the permitting process on the In Situ Burning 

Guidelines for Alaska will be followed. The elimination of gas as a safety measure, not related to oil 

elimination, is a UC decision that may follow the same planning process, but does not seek the permit 

necessary in the In Situ Burning Guidelines and issued by the ARRT. 
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TABLE 3.7-5 

SAFE WORKING DISTANCES FROM THE FIRE 

PERSONNEL EXPOSURE TIME 

PERSONNEL MINIMUM DISTANCE FROM FIRE 

(FIRE DIAMETERS) 

Indefinite 1.2 m (4 ft) 

30 min 0.9 m (3 ft) 

5 min 0.6 m (2 ft) 

Aerial ignition with gelled fuel from a heli-torch or with other ignition devices is coordinated, taking into 

account prevailing weather conditions, oil pool size and distribution, and the need for strict adherence to 

established safety practices. 

ACS personnel practice the techniques involved with controlled burning operations at sea that could 

involve several vessels and aircraft working in close proximity. 

Dispersants 

Dispersant use is a rational approach to mitigate environmental impacts from spills when sea states or 

other factors limit or negate conventional countermeasures. While the primary response method to be 

employed by Shell in the Chukchi Sea is mechanical recovery, Shell also recognizes the limitations of 

mechanical response equipment in various sea states and environmental conditions as well as the need 

for strategic flexibility to maximize oil spill response in the Chukchi Sea. The capability of applying 

dispersants extends response operations beyond the limitations of mechanical equipment. 

Dispersants are chemical formulations containing surfactants that, when applied to a slick, lower the 

surface tension between oil and water, facilitating the formation of oil droplets under wave action and 

preventing them from coalescing and resurfacing, therefore enhancing oil dispersion and biodegradation 

into the water column. Dispersants may be strategically applied to reduce oil impacts to sensitive 

shoreline or to remove oil concentrations from the water surface reducing marine bird and mammal 

contact with oil slicks. 

The decision to use dispersants is dependent upon the several factors including: the effectiveness of 

mechanical response; whether dispersant application strategies can be employed to augment and not 

impede mechanical recovery; and whether environmental conditions are right for dispersant use. 

A critical window of opportunity exists in which both dispersants and in situ burning are best used. 

Generally, dispersants are most effective on fresh crude oil as the dispersant reacts with the more volatile 

hydrocarbons. Overtime, spilled oil in the marine environment will weather losing volatile hydrocarbons 

and forming water-in-oil emulsion. For the Chukchi Sea blowout scenario, the decision to use dispersants 

may be considered daily until several days after well control is achieved. 

Dispersants shall be recommended to augment mechanical response operations when mechanical 

recovery is not feasible and/or has reduced efficiencies, or the slick threatens sensitive resources, coastal 

areas and state waters. Effective dispersion of oil is affected by multiple factors include the following: 

 oil properties; 

 oil weathering or emulsification; 

 sea state or mixing energy; 

 oil and water temperature; 

 seawater salinity; 
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 type of dispersant; and 

 application systems and strategies. 

Shell recognizes that when proposing the use of dispersants on spills from exploration operations there 

may be critical unknowns (e.g., oil properties and whether the oil is chemically dispersible). When 

proposing the use of dispersants in open water, the following should be considered. 

 The oil properties will be unknown until Shell’s exploration operations and flow tests are 

complete. SMART protocols also recommend a field test application for any proposed treatment 

of spilled oil with dispersants. Because the oil properties in this prospect are currently unknown, 

there is an expectation that an on-site test for dispersant use in the Chukchi would be a UC 

condition of approval. 

 Wind waves [greater than 3 to 4 ft (0.9 to 1.2 m)] (Beaufort Scale 4) reduce or impede the 

containment of oil with booms. Dispersant effectiveness requires some wave energy (or 

deliberate mixing) and is not normally applied to oil on calm waters. Having the option of using 

dispersants as a response strategy could extend response operations beyond mechanical 

recovery and in situ burning possibilities. Dispersants can be applied effectively with only light 

wind chop (Beaufort Scale 1); however, they are much more effective with breaking waves as 

seas approach a Beaufort Scale 3. The upper limit for dispersant use is typically around a 

Beaufort Scale 6 to 7 [waves at 10 to 14 ft (3.0 to 4.3 m)]; however, the limitation is not because 

of wave conditions, but because of the effects of strong winds on droplet size and distribution. 

Natural dispersion under these conditions will also play a major role in removing oil from the 

surface. 

 As required by Subpart J of the National Contingency Plan (NCP), the dispersant proposed and 

available for use in Alaska (Corexit® EC9500 and Corexit® EC9527) are on the NCP Product 

Schedule and approved for use by EPA. Tests have shown that both 9500 and 9527 are effective 

dispersants on Alaskan oils in cold water (SL Ross 2003). 

 As water temperature decreases, oil viscosity increases. Dispersants are most effective for oil 

viscosities less than 2,000 cSt and almost no dispersion occurs for viscosities exceeding 10,000 

cSt. A general rule of thumb is that all crude oils are initially amenable to dispersion except those 

crude oils with high initial viscosities or that would be solid at seawater temperatures. If the water 

temperature is below the pour point of the oil, dispersant will simply roll off of the oil layer. (NRC 

1989) Sea water freezes at around 28°F (-2°C). Water temperatures in the Chukchi Sea appear 

to be undergoing a warming trend (MMS 2007). 

 Salinity in the Chukchi ranges between 31 to 35 ppt (http://www.ims.uaf.edu/chukchi/#seas). 

Values below this range are not expected offshore in the sale lease area. Increased salinity 

generally decreases the solubility of dispersants in the water enhancing oil/dispersant interaction. 

(Chandrasekar et al. 2006). 

 Oil slick thicknesses should be about .004 inches (0.1 mm) or greater for the effective use of 

dispersants. Oil at this thickness of .004 inches (0.1 mm) would require a dosage of about 5 gal 

of dispersant per acre for a commonly accepted dispersant-to-oil (DOR) ratio of 1:20. 

 Although near shore [<33 ft (10 m) water depth] dispersant application may in some cases be 

considered to protect sensitive resources, operations in the Chukchi will more likely be offshore 

(approximately 52 n mi or more) near the sale area. Consistent with the guidelines established 
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by the Unified Plan, the optimal water depth to disperse oil is ≥33 ft (10 m). The water depths in 

the lease sale area range from 98 to 9,843 ft (30 m to 3,000 m). 

 Studies have shown that chemically dispersed oil does not adhere to some organisms or habitats 

to the extent of untreated oil (NRC 1989). 

 The encounter rate to treat a spill using aerial and on-water application platforms is significantly 

higher than on-water recovery operations. 

The use of dispersants in broken ice also offers its own challenges, but certain broken ice conditions may 

present the potential for improved efficiency. When proposing the use of dispersants in broken ice 

conditions, the following should be considered. 

 Low air and water temperatures often result in greater oil equilibrium thicknesses, thereby 

reducing spreading rates and areas of coverage. These reductions limit the potential for impact 

with natural resources while providing the potential for much higher oil encounter rates for 

dispersant application. For maximum effectiveness, dispersant should be applied “neat” or 

undiluted. Shell has chosen Corexit 9500 for use, undiluted, in the Chukchi. 

 Evaporation rates are reduced, leaving the lighter and more volatile components in the oil longer, 

thereby extending the time in which the oil could be dispersed. 

 The presence of ice can dampen wave action and limit the fetch over which winds might 

otherwise create large waves. While this would enhance burning opportunities, oil is more readily 

dispersed with induced agitation and/or wave energy. Tests have shown that moving broken ice 

can actually stimulate dispersant action. Dispersant efficiencies increase with the amount of 

mixing energy even more so than with increases in salinity (Chandrasekar et al. 2006). The 

OSRV propulsion system may be used to create surface turbulence, thereby enhancing mixing 

energy for dispersants in areas where wave action is diminished by the presence of ice. 

 Sea-ice formation results in increased salinity. Brine rejection during sea-ice growth strongly 

affects salinity of upper ocean water. This may result in improved oil dispersion as tests have 

shown an increase in the dispersability of some oils with an increase in salinity (Chandrasekar et 

al. 2006). The salinity of sea water normally ranges between 32 to 35 parts per thousand (ppt). 

 Emulsion formation may be slowed dramatically by high ice concentrations. Fresh unemulsified 

crude is more efficiently dispersed. 

3.7.1 Assessment of Environmental Consequences and Monitoring 

In situ Burning

Shell is taking a number of steps to safeguard the area for in situ burning consistent with the In Situ 

Burning Guidelines referenced in Section 1.7.1. In situ burning would be conducted only under 

authorization by the UC, in consultation with the ARRT, during emergency situations where in situ burning 

of oil augments mechanical recovery operations, burning is feasible, and the burn is a safe distance from 

populated areas. 

The source location of a spill associated with Shell’s exploration activities would be at a great distance 

from shore (over 52 n mi), which far exceeds the minimum safe distance (>1 mile) to protect populated 

areas from the use of in situ burning. At these distances from population centers, Shell will perform 
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continuous visual monitoring of the burn and resulting smoke plume. At any time during an authorized 

burn that there is potential of impacting a populated area, Shell will activate resources to implement air 

quality monitoring consistent with NOAA’s SMART protocols. As detailed in the In Situ Burning 

Guidelines, the UC would consult and coordinate with resource trustee agencies anytime threatened or 

endangered species or their critical habitats are, or could be, present in the area of the burn. These 

agencies provide recommendations to mitigate impacts of the resource from the burn operation or 

possible oil spill impacts. 

Although the burn residue itself is low volume (typically less than 2 to 3 percent) and low toxicity; batch 

samples of the floating residue would be analyzed to confirm composition and toxicity. Every effort would 

be made to recover burn residue as time and conditions allow. 

Dispersants 

When dispersants are considered for use as a response option, the UC may require that monitoring of the 

dispersed oil is performed consistent with one of the three tiers defined within NOAA’s dispersant use 

SMART protocol. Accepted by the response community as a standardized approach to monitoring 

dispersant applications, the protocol tiers provide escalating levels of monitoring effort. The UC approves 

the monitoring requirements appropriate for the response and the incident-specific environmental 

conditions. 

Shell would mobilize aerial and on-water monitoring contractors to the spill location located over 52 n mi 

offshore. Tier I SMART protocols would be implemented for approved dispersant application. Subject to 

UC and ARRT approvals for dispersant use, implementation of Tier II or Tier III SMART protocols provide 

for real-time fluorometry data collection, supplemented with water sample collection for later chemical 

analyses. The fluorometry readings provide data on the dispersant efficacy and the dispersed oil plume. 

Tier III also provides for the collection of data on physical parameters such as water temperature, 

conductivity, and turbidity that, when correlated with Tier I visual observations and Tier II / Tier III 

fluorometry readings, may be used to evaluate dispersant efficacy. Current drogues or buoys also may 

be deployed to track the dispersed oil plume. 

3.7.2 Non-mechanical Response Equipment 

Non-mechanical response equipment and supplies are included in the Shell Beaufort and Chukchi Seas 

Regional Tactics Manual, Tactics OR-7, OR-8, OR-9A, and OR-9B. 

The NCP requires that dispersants proposed for use are listed in the NCP Product schedule. Products 

currently stockpiled for use by industry in Alaska include COREXIT® EC9500A (9500) and COREXIT® 

EC9527A (9527). Shell would have 25,000 gal of 9500 available for use in Alaska, with approximately 

23,700 gal available for mobilization from Anchorage and 1,300 gal pre-staged with ACS on the North 

Slope. Both of these products are solvent-based “concentrate” dispersants that may be applied in their 

undiluted (neat) or diluted form. Toxicity information for each product is available online at 

http://www.epa.gov/oem/content/ncp/tox_tables.htm. 

Although 9500 has been considered to be more effective on viscous, weathered spills, recent small wave 

tank test results during effectiveness testing on Alaskan oils in cold water, suggest that both dispersants 

generate similar results (SL Ross et al. 2003). A standard DOR application rate of 1 to 20 would be used; 

however, this may be modified based upon incident specific needs and UC approval. Multiple passes or 

applications may also provide an added level of control. 
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Aerial application of dispersants would likely involve fixed-wing aircraft as helicopters have more limited 

payload-range capabilities. Shell has access to large fixed-wing aircraft through service agreements, and 

additional aircraft can be mobilized as needed. As an established member of the MSRC, Shell has 

access to a C-130 with integrated dispersant tanks that would be staged, maintained, and mobilized out 

of Coolidge Arizona. The C-130 would arrive in Barrow with a qualified crew and operator within 24 hrs of 

initial notification. The integrated dispersant tanks on the MSRC C-130 Hercules have a 3,200 gal 

capacity. As a member of MSRC and ACS, Shell also has access to additional dispersant stockpiles and 

aircraft. Reference Shell Beaufort and Chukchi Seas Regional Tactics Manual, Tactics OR-9A and OR9B for information on aerial dispersant application equipment staging, mobilization, and capacities. 

Compared to aircraft delivery systems, vessels may be slower with limited transit speeds, limited swath 

widths, and are subject to the variability of sea state. However, vessel application systems can be of 

great value when conditions preclude the use of that vessel for other mechanical recovery operations. 

Should it become too rough to deploy booms for the recovery and/or burning of oil, vessels might be used 

to apply dispersants at or near the spill site. Even in the presence of broken ice, dispersants could be 

applied and then agitated with drives that may be used to enhance the dispersion process. Any 

application of dispersants, whether from vessels or aircraft in open water or in broken ice, would always 

involve a thorough assessment of the benefits and risks, and involve appropriate authorization for use. 

Shell has equipped the OSRV in the Chukchi with a conventional spray-arm application system. This 

application system provides flexibility of use under a broad range of operational and environmental 

conditions. Reference Shell Beaufort and Chukchi Seas Regional Tactics Manual, Tactics OR-8. 

3.7.3 Identification of Necessary Approvals and Application for Non-mechanical Response 

Options. 

In situ burning in the OCS waters is under the command of the FOSC, in this case, the USCG. Although 

the FOSC may have final authority within OCS waters, if an IC is established, application will be made 

through the UC. Shell will comply with Unified Plan requirements, including the use of the State of Alaska 

checklists prior to the use of burning (e.g., size of burn, use of fire boom, trained personnel, and ignition). 

Shell will comply with UC conditions of approval and is prepared to implement monitoring of efficacy and 

the SMART protocols as conditions allow. 

Use of dispersants in federal waters is also under the command of the USCG as the FOSC. Although the 

FOSC has final authority within OCS waters, if an Incident Command is established application will be 

made through the UC. Shell will follow the guidelines established within the Unified Plan, Annex F to 

apply for the approval. Prior to the use of dispersants in state waters, approval would be requested from 

the ADEC, acting as the SOSC. 

3.7.4 Identification of Permits, Approvals or Authorizations 

Reference Section 1.7 for discussion on the required permits, approvals, and/or authorizations. 

3.7.5 Plan for Protection Environmentally Sensitive Areas and Areas of Public Concern 

Strategies to recover, burn, or disperse oil offshore prior to the spill reaching State of Alaska lands and 

waters would be of the highest priority when responding to a spill in the Chukchi Sea. 
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Non-mechanical response operations, including in situ burning and dispersant use, would be conducted 

far from Alaska’s shorelines (Shell’s leases are 52 n mi or more offshore) as a component of the overall 

tactical plan to protect environmentally sensitive areas and areas of public concern. The UC in 

consultation with natural resource agencies will require appropriate measures be implemented to protect 

environmentally sensitive areas, areas of public concern, and the public from adverse effects when 

authorizing these response operations. The Unified Plan and UC process of approving both in situ burn 

and dispersant use require coordination with resource trustees as members of the ARRT. These 

procedures ensure that sensitive environments, critical habitat, threatened or endangered species receive 

priority to mitigate impact of spilled oil and response operations, which includes in situ burn or dispersant 

use. Continuous on-site monitoring required by the UC provides the IMT with information to immediately 

suspend or modify operations, precluding adverse impacts to resources or the public. 

Consistent with the guidance within the Unified Plan residue from burning operations would be recovered 

where practicable using manual collection methods to retrieve the residue within fire booms or from 

secondary booms (see ACS Tactic B-6). Burn operations would be conducted in OCS waters far offshore 

and closely monitored for wildlife in the area. Trustee agencies would be consulted for recommendations 

or necessary approvals to protect wildlife from the potentially negative consequences of burn operations 

and any unrecovered residues. 

The principal benefit of dispersing oil when recovery is not possible is to enhance natural dispersion and 

biodegradation and, by making the remaining free floating oil less adhesive to birds and mammals, 

reduce impacts to or protect sensitive habitats, and prevent shoreline impacts. Operations shall be 

controlled to avoid applying dispersant on or near sea birds or marine mammals. 

Oil that reaches state waters will be addressed as part of nearshore and shoreline response efforts as 

presented in Section 1.6.12. 

3.8 RESPONSE CONTRACTOR INFORMATION [18 AAC 75.425(e)(3)(H)] 

Shell will activate ACS to provide the initial manpower and resources required to respond to a large or 

lengthy spill response. If additional resources are required, they will be accessed through master services 

agreements maintained by ACS and through other contracts as needed, established by Shell during the 

spill. ACS will be activated and lead spill response operations as the primary response contractor for all 

spill response activities. 

Contact information for ACS is presented in Table 1.2-1.

3.8.1 Statement of Contractual Terms 

Shell Gulf of Mexico Inc. as a wholly-owned subsidiary Shell Offshore Inc. operates under the 

membership contract and Statement of Contractual Terms executed between Shell Gulf of Mexico Inc. 

and ACS. Supporting documentation of the Statements of Contractual Terms is provided in Appendix B. 

3.9 TRAINING PROGRAM [18 AAC 75.425(e)(3)(I)] 

Shell and ACS provide training for HSSE programs for all employees. 

ACS is responsible for coordination of the oil spill training for Shell employees and contractors including 

all response tactics that may be utilized in the field. This includes ensuring all requirements for pre-
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deployment site training to ensure personnel proficiency, both in open water and broken ice conditions. 

Spill response training is based on The National Preparedness for Response Exercise Program (NPREP) 

guidelines (August 2002). 

ACS coordinated spill response training includes: 

 Federally mandated; HAZWOPER, hazard communication (HAZCOM) 

 Company directed; Shell, Edison Chouest, Crowley, and others, which includes North Slope 

Training Cooperative (NSTC) topics, first-aid, employee orientation, and oil spill specific and 

technical training (including fate and behavior of oil, site characterization, specialized equipment 

and tactics, non-mechanical response, and C-Plan overview). 

All required training for site personnel who will be participating in oil spill response activities will be 

completed prior to commencement of operations, and will include classroom as well as actual field 

deployment. 

ACS offers an ADEC-approved spill prevention and response training program available for Shell and 

ACS oil spill response personnel. This training includes regulatory required training as well as training 

specific to aspects of spill response. As new training needs are identified, ACS will develop and 

incorporate these needs into the training program. At a minimum, all North Slope spill response personnel 

will receive the following required training: Initial Emergency Response (24-Hour Hazmat Technician), 

and Hydrogen Sulfide Training. ACS holds contracts with other response action contractors and OSROs 

that will be able to provide additional trained and qualified spill responders. Some examples of general 

training courses offered by ACS (ACS Technical Manual Tactic A-4) include: 

 Arctic Cold Weather Survival 

 Open Ocean Water Survival 

 Summer Spill Operation 

 ICS (all sections) 

 Wildlife Hazing 

 Helicopter Slinging Operations 

 Shoreline Response Training Workshop 

 Swiftwater First Responder 

A complete list of available ACS training courses can be found on the Web site at 

www.alaskacleanseas.org. 

3.9.1 Incident Management Team Member Training 

Shell will provide IMT training for required personnel, prior to deployment and during the active drilling 

season. This training will follow the National Incident Management System (NIMS) required training 

guidelines. NIMS training that will be conducted for Shell and ACS personnel include online courses and 

classroom training. In addition, Shell will sponsor IMT workshops that focus on the planning cycle for oil 

spill response. Shell and ACS will conduct equipment training in the field (e.g., boom deployment, 

skimmer and lightering equipment operation) and on-the-job training to ensure response personnel are 

trained and kept current in the specifics of plan implementation, equipment deployment, and mobilization 

of personnel and resources. Examples of ICS training courses include: 
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 ICS/100, ICS/200, and ICS/700 (online training), 

 ICS/300 as a two-day training event, and 

 ICS/400 that will cover Command Staff and Section Chiefs’ training. 

Shell’s training management system includes an in-house training database that is maintained for all 

personnel. 

ACS provides IMT training for ACS IMT personnel. A description of this IMT training program is provided 

in Volume 3, Section 6.0, of the ACS Technical Manual. 

3.9.2 Other Training 

There may be specific departmental training requirements for Shell’s exploration activities. Shell’s HSSE 

Training Department maintains and conducts frequent training for HSSE awareness. 

3.9.3 Record Keeping 

Training records for Shell IMT training are kept at Shell’s offices. These records will be maintained for a 

minimum of five years. 

ACS maintains a database as a record of the courses taken by each employee and contractor. The 

course description, date completed and the employee or contractor current status are available from the 

database. The ACS instructors’ training records and qualifications are also maintained in the database. 

Records are kept for a minimum of five years or for the duration of time that the employee or contractor is 

assigned responsibilities in this C-Plan. 

3.9.4 Spill Response Exercises 

Shell will notify the MMS Alaska Region 30 days in advance of any exercises that meet the requirements 

of 30 CFR 254.42(b)(2) or (4). 

The NPREP guidelines (August 2002) is the basis for Shell’s spill response exercises. Section 6 of these 

guidelines describes the expected participants, scope, and objectives of exercises for Offshore Facilities. 

The current plan for internal Shell response exercises includes: 

 Pre-mobilization training exercises using the oil spill response equipment and selected vessels 

prior to the mobilization of personnel and equipment to the Chukchi Sea. 

 Pre-startup exercises prior to the commencement of critical drilling activity, to be conducted in the 

vicinity of the first drilling location. 

 Regularly scheduled exercises to maintain response capability while drilling is underway. 

Periodic IMT and Spill Management Team (SMT) tabletop exercises will also be conducted during active 

drilling seasons. 

Additional drills, both scheduled and unscheduled, may be conducted at the request of MMS or other 

authorities. 
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As a member of Mutual Aid through ACS, Shell may be called upon to participate in a Mutual Aid Drill 

(MAD) to be conducted once a year as per NPREP guidelines. The MAD exercise satisfies the NPREP 

requirements to exercise all aspects of the response plan at least every three years. 

3.10 PROTECTION OF ENVIRONMENTALLY SENSITIVE AREAS AND AREAS OF 

PUBLIC CONCERN [18 AAC 75.425(e)(3)(J)] 

For the protection of environmentally sensitive areas, the IMT will plan for mitigation of impacts of a spill, 

or to monitor over-season migration of oil in the ice. Section 1.6 details these response strategies and 

how they pertain to the protection of environmentally sensitive areas. 

Crude oil is a persistent product containing aromatic hydrocarbon compounds. In various concentrations, 

the aromatic hydrocarbon constituents of crude oil may have toxicity effects on marine mammals, birds, 

fish, lower trophic aquatic organisms, and humans. The actual properties of the crude oil are unknown 

due to the lack of well test data. For the purposes of the C-Plan, ANS crude oil is used as an analogous 

medium weight crude oil (25 to 30° API). Any potential crude oil spill sources would be located more than 

52 n mi from shorelines. In the event of a crude oil release, pre-staged response resources would be 

rapidly deployed to control and recover oil. 

Any oil escaping recovery actions would be dispersed by winds and currents and undergo weathering. 

Based upon the distance to shore, stoichastic spill modeling predicts that the oil would not contact 

shoreline areas in less than six days. In the unlikely event oil reaches environmentally sensitive areas, it 

would be in small quantities and low concentrations. As described in the Scenario in Section 1.6.13, 

Shoreline Protection Task Forces would be mobilized before oil reaches shoreline to deploy exclusion 

boom at protection sites. 

A number of sites of archaeological or cultural significance exist on the nearby shorelines. Because the 

proposed exploration activities will be offshore, these sites should not be impacted. If, at some point, 

onshore activities are required to support response actions, the Alaska Office of History and Archeology 

will be consulted in order to avoid archeological disturbances to these sites. 

3.10.1 Sensitive Wildlife Areas 

In the event of a major spill, sensitive areas along the coastline may be affected. The environmental 

sensitivities for this exploration are summarized in Sections 1.6.11 and 1.6.12 and the ACS Technical 

Manual, Volume 2, Map Atlas. Additional sources include the North Slope Coastal ESI Maps (Maps 13 

through 24) and Most Environmentally Sensitive Area (MESA) maps published by NOAA and available 

online at http://www.asgdc.state.ak.us/maps/cplans/subareas.html#northslope. 

Primary areas of sensitivity are the habitats or routes of polar bears, Pacific walrus, beluga and bowhead 

whales, and various species of seal including ringed, bearded, and spotted. Multiple and varied species 

of birds seasonally occur along the Chukchi coast including the spectacled eider, Steller’s eider, and 

Kittlitz’s murrelet. 

Forty-three (43) marine species of fish, 18 species of terrestrial mammals, and at least 10 species of 

marine mammals have been identified in the Chukchi Sea and along the coastline. There are several 

million birds of approximately 150 species on and near the North Slope, although they tend to concentrate 

in the Arctic Coastal Plain and in nearshore waters of less than 20 m (66 ft) depth. Section 1.6.11 and 

1.6.12 provide details on the identification and protection of sensitive sites during response efforts. 
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3.11 ADDITIONAL INFORMATION [18 AAC 75.425(e)(3)(K)] 

Please refer to the following Appendices of the C-Plan for additional information: 

APPENDIX A: General Specifications for Marine and Aerial Support Vessels 

APPENDIX B: Contractual Terms with Primary Responders 

APPENDIX C: Fuel Transfer Procedures 

APPENDIX D: Oil and Debris Disposal Procedures 

APPENDIX E: Wildlife Capture, Treatment, and Release Programs 

APPENDIX F: Production Specification for Low Sulfur Diesel Fuel Oil 

In addition, Shell acknowledges that MMS will review proposed Shell exploration well locations as part of 

the application package for individual well(s) and will determine whether the Shell C-Plan is applicable for 

each well. Additional information regarding reservoir modeling, well plans, and derivation of worst case 

discharge volumes are available from Shell upon request. 

3.12 BIBLIOGRAPHY [18 AAC 75.425(e)(3)(L)] 

Alaska Department of Environmental Conservation. 2006. North Slope Nearshore and Offshore Breakup 

Study Literature Search and Analysis of Conditions and Dates. 

Alaska Clean Seas, 1983. Oil Spill Response Considerations Manual.

Alaska Clean Seas. 2008. ACS Technical Manual, Volume 1, Tactics Descriptions: Volume 2, Map Atlas; 

and Volume 3, North Slope Incident Management System. 

Alaska Department of Environmental Conservation, U.S. Environmental Protection Agency, and United 

States Coast Guard. August 2008. In situ Burning Guidelines for Alaska, Revision 1, Anchorage, 

AK. http://dec.alaska.gov/spar/perp/docs/ISB-Rev1(Final-August%202008).pdf

Alaska Regional Response Team. 1999. The Alaska Federal / State Preparedness Plan for Response to 

Oil and Hazardous Substance Discharges/Releases - Unified Plan, Change 2, 

http://dec.alaska.gov/spar/perp/plan.htm

Allen, A.A. 1991. Oil Spill Response to Blowouts at Sea. Proceedings First Offshore Australia 

Conference, November 25-27, Melbourne, Australia. 

Allen, A.A. 1990. Contained Controlled Burning of Spilled Oil During the Exxon Valdez Oil Spill. 

Proceedings 13th Annual AMOP Technical Seminar, June 6-8, Edmonton, AB, Canada. 

Allen, A.A. and R.J. Ferek. 1993. Advantages and Disadvantages of Burning Spilled Oil. Proceedings 

1993 International Oil Spill Conference, March 29-April 1, Tampa, FL. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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Atwater, S.G. 1991. 1990 Endicott Environmental Monitoring Program Final Report: Ice Break-up and 

Freeze-up. Prepared by SAIC for the U.S. Army Corps of Engineers, Anchorage AK. 

Bech, C., P. Sveum, and I. Buist. 1993. The Effect of Wind, Ice and Waves on the In situ Burning of 

Emulsions and Aged Oils. Proceedings of the Sixteenth Arctic and Marine Oilspill Program 

Technical Seminar, Calgary, AB. pp 735-748. 

Bronson, M. 1998. In situ burning safe distance predictions with ALOFT-FT model. Prepared by 

EMCON Alaska, Inc., for Alaska Department of Environmental Conservation. 

Bronson, M., Thompson, E, McAdams F. and J. McHale. 2002. Ice Effects on Barge-based Oil Spill 

Response Systems in the Alaskan Beaufort Sea. Proceedings 25th Arctic and Marine Oilspill 

Program Technical Seminar (AMOP), Calgary, pp 1253-1268. 

Brown, H.M. and R.H. Goodman. 1986. In situ Burning of Oil in Experimental Ice Leads. Environmental 

Studies Revolving Funds Report 064. National Energy Board, Calgary. 

Brower, W.A., Baldwin, R.G., Williams, Jr., C.N. 1988. Climatic Atlas of the Outer Continental Shelf 

Waters and Coastal Regions of Alaska, Volume III Chukchi Beaufort Seas. National Climatic 

Data Center, National Environmental Satellite, Data and Information Service, National Oceanic 

and Atmospheric Administration, Arctic Environmental Information and Data Center, University of 

Alaska, Anchorage Alaska. 

Brunner, R.D., Lynch, A.H., Pardikes, J., Cassano, E. N., Lestak, L.R., Vogel, J. 2003. An Arctic Disaster 

and Its Policy Implications, Accepted and in press for a special issue of Arctic on the Human 

Dimensions of the Arctic System.

Buist, I.A. and D.F. Dickins. 1987. Experimental Spills of Crude Oil in Pack Ice. Proceedings of the 1987 

Oil Spill Conference, April 6-9, Baltimore, Maryland. American Petroleum Institute, Washington, 

D.C. pp 373-382. 

Cambell, T.E., Taylor, E. and D. Aurand. 1994. Ecological Risks Associated with Burning as a Spill 

Countermeasure in a Marine Environment. Proceedings of the 17th AMOP Technical Seminar, 

Jun 8-10, Vancouver, British Columbia, pp. 707-716. 

Canadian Ice Service. Archived Regional Ice Analysis Charts for the Western Arctic – http://iceglaces.ec.gc.ca. Ottawa, Canada. 

Chandrasekar, S., Sorial, G. A., Weaver, J.W. 2006. Dispersant Effectiveness on Oil Spills –Impact of 

Salinity. ICES Journal of Marine Science, 64: 1418 -1430. 

Coastal Frontiers. August 2001. Spring Breakup Equipment Access Test Program (Draft and Final), 

prepared for BP Exploration (Alaska), Anchorage.

Craig, P.C., 1984. Fish Use of Coastal Waters of the Alaskan Beaufort Sea: A Review. Transactions of 

the American Fisheries Society 113: 265-282. 

Dickins (DF Associates Ltd.) and OASIS Environmental. 2006. North Slope Nearshore and Offshore 

Breakup Study Literature Search and Analysis of Conditions and Dates. Report prepared for the 

Alaska Department of Environmental Conservation, Anchorage AK. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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DF Dickins Associates Ltd., Vaudrey & Associates Inc., and SL Ross Environmental Research Limited. 

Sept. 2000. Oil Spills in Ice Discussion Paper. Prepared for Alaska Clean Seas, Prudhoe Bay, 

AK. 

Dickins, D.F. 1984. Alaskan Beaufort Sea Ice Atlas. Prepared for SOHIO Petroleum Company, Dallas. 

Dickins, D. F., Brandvik, P.J., Faksness, L.-G., Bradford, J., and L. Liberty. 2006. Svalbard Experimental 

Spill to Study Spill Detection and Oil Behavior in Ice. Report prepared for MMS and sponsors by 

DF Dickins Associates Ltd., SINTEF, The University Centre in Svalbard, and Boise State 

University, Washington DC and Trondheim, Norway. 

Dickins, D.F., and I.A. Buist. 1981. Oil and Gas Under Sea Ice Study: Vols. I & 2. Prepared by Dome 

Petroleum Ltd. for COOSRA, Report CV-1, Calgary, AB, Canada. 

Eicken, H., Shapiro, L., Gaylord, A., Mahoney, A. and P. Cotter. 2006. Mapping and Characterization of 

Recurring Spring Leads and Landfast Ice in the Beaufort and Chukchi Seas. Prepared for 

Minerals Management Service, Anchorage, AK. 

Guénette, C.C. and R. Wighus. 1996. In situ Burning of Crude Oil and Emulsions in Broken Ice.

Proceedings of the 19th AMOP Technical Seminar. Calgary, AB. pp 895 - 906. 

Haidvogel, D.B., K.S. Hedstrom, and J. Francis, 2001. Numercial Simulations of Atmosphere/Ocean/Sea 

Ice Interaction in the Arctic Ocean 1982-1996. OCS Study MMS 2001-069. Anchorage, AK. 

Industry Task Group representing AMOCO Production Company, Exxon Company USA, Shell Oil 

Company, SOHIO Alaska Petroleum Company. 1983. Oil Spill Response in the Arctic: An 

Assessment of Containment, Recovery, and Disposal Techniques. 

Keinonen, A.J., Shirley, K., Liljeström, G. and R. Pilkington. 2006. Transit and Stationary Coring 

Operations in the Central Polar Pack. Proceedings ICETECH06 International Conference on 

Performance of Ships and Structures in Ice, July 16-19, Banff, Alberta, Canada. 

Kovacs, A. 1976. Grounded Ice in the Fast Ice Zone along the Beaufort Coast of Alaska. U.S. Army 

Corps of Engineers CRREL Report 76-32, Hanover, NH.

Minerals Management Service (MMS). 1996. Beaufort Sea Planning Area Oil and Gas Lease Sale 144, 

Final Environmental Impact Statement. Alaska Outer Continental Shelf Region. OCS EIS/EA 

MMS 2007-026. Anchorage, AK. 

Minerals Management Service (MMS). 2007. Chukchi Sea Planning Area Oil and Gas Lease Sale 193 

and Seismic Surveying Activities in the Chukchi Sea, Final Environmental Impact Statement. 

Alaska Outer Continental Shelf Region. 

National Oceanic and Atmospheric Administration (NOAA), 2005. Sensitivity of Coastal Environments and 

Wildlife to Spilled Oil, North Slope, Alaska Map Atlas. 

National Oceanographic and Atmospheric Administration (NOAA). Beaufort Wind Scale and Sea Height 

Relationships. http://www.srh.noaa.gov/bro/beau.htm. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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National Response Team Science & Technology Committee. 1997. Fact sheet: Site Safety Plans for 

Marine In situ Burning Operations. 

Robilliard, Gordon, A., John R. Harper, Jon Isaacs and Carl Foget. 1985. Chukchi Sea Coastal Studies: 

Coastal Geomorphology, Environmental Sensitivity, and Persistence of Spilled Oil. Volume 1: 

Final Report and Volume 2: Coastal Resource Inventory and Spill Sensitivity Index Maps. 

Prepared by Woodward-Clyde Consultants for NOAA, Alaska Office, Oceans Assessment 

Division, Anchorage, AK. 

Reimnitz, E. and E. Kempema, 1984. Pack Ice Interaction with Stamukhi Shoal Beaufort Sea, Alaska. In:

The Alaskan Beaufort Sea Ecosystems and Environments (Eds. Barnes, P., Schell, D, and E. 

Reimnitz), Academic Press, pp. 159-183. 

Shell Gulf of Mexico Inc. and Shell Offshore Inc., 2009. Beaufort and Chukchi Seas Regional Tactics 

Manual. 

Shell Oil Company, Sohio Alaska Petroleum Company, Exxon Company, U.S.A., Amoco Production 

Company. 1983. Oil Spill Response in the Arctic - Part 2: Field Demonstrations in Broken Ice. 

Shell Oil Company, Sohio Alaska Petroleum Company, Exxon Company, U.S.A., Amoco 

Production Company. Anchorage, AK. 

Singaas, I., P. Brandvik, P. Daling, M. Reed and A. Lewis. 1994. Fate and Behaviour of Oils Spilled in the 

Presence of Ice – a Comparison of the Results from Recent Laboratory, Meso-scale Flume and 

Field Tests. Proceedings of the 17th AMOP Technical Seminar, June 8-10, Vancouver, British 

Columbia, pp 355-370. 

SL Ross Environmental Research Ltd., DF Dickins Associates Ltd. and Alaska Clean Seas. 2003. Tests 

to Determine the Limits of In situ Burning of Thin Oil Slicks in Broken Ice. Report prepared for the 

US Minerals Management Service and ExxonMobil Upstream Research. 

S.L. Ross Environmental Research Ltd. 1983. Evaluation of Industry's Oil Spill Countermeasures 

Capability in Broken Ice Conditions in the Alaskan Beaufort Se. Prepared for Alaska Department 

of Environmental Conservation, Anchorage. 

S.L. Ross Environmental Research Ltd. 2002. Dispersant Effectiveness Testing in Cold Water. Final 

Report for U.S. Department of the Interior, Minerals Management Service., Herndon, VA and 

ExxonMobil Research and Engineering Co., Fairfax, VA. 

S.L. Ross Environmental Research Ltd. and MAR Incorporated. 2003. Dispersant Effectiveness Testing 

on Alaskan Oils in Cold Water. Report for U.S. Department of the Interior, Minerals Management 

Service, Herndon, VA. 

S.L. Ross Environmental Research Ltd. and DF Dickins Associates Ltd. 1987. Field Research Spills to 

Investigate the Physical and Chemical Fate of Oil in Pack Ice. Environmental Studies Revolving 

Funds Report No. 062. 95 p. 

Smith, N.K. and A. Diaz. 1987. In-place Burning of Crude Oils in Broken Ice. Proceedings of the 1987 Oil 

Spill Conference, April 6-9, Baltimore, Maryland. American Petroleum Institute, Washington, D.C. 

pp 383-387. 
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Vaudrey, K. 2000. Part II: A Review of Ice Conditions, Oil Behavior, and Monitoring and Appendix B: 

Weather and Ice Statistics; In: Oil Spills in Ice Discussion Paper. Prepared by for Alaska Clean 

Seas, Prudhoe Bay, AK by DF Dickins Associates Ltd., Vaudrey & Associates Inc., and SL Ross 

Environmental Research Limited. 

Vaudrey, K. 1996. Design Basis Ice Criteria for the Northstar Development, Prepared for BP Exploration 

(Alaska) Inc. by Vaudrey & Associates, San Luis Obispo, CA. 
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PART 4 BEST AVAILABLE TECHNOLOGY [18 AAC 75.425(e)(4)] ..................................................... 4-1

4.1 COMMUNICATIONS [18 AAC 75.425(e)(4)(A)(i)] ........................................................... 4-2

4.2 SOURCE CONTROL [18 AAC 75.425(e)(4)(A)(i)] ........................................................... 4-3

4.2.1 Well Source Control ............................................................................................ 4-3

4.2.2 Tank Source Control ........................................................................................... 4-7

4.3 TRAJECTORY ANALYSES [18 AAC 75.425(e)(4)(A)(i)] ................................................. 4-8

4.4 WILDLIFE CAPTURE, TREATMENT, AND RELEASE PROGRAMS 

[18 AAC 75.425(e)(4)(A)(i)] .............................................................................................. 4-8

4.5 CATHODIC PROTECTION [18 AAC 75.076(h)(4)(A)(ii) ................................................. 4-8

4.6 LEAK DETECTION TANKS [18 AAC 75.425(e)(4)(A)(ii)] ................................................ 4-8

4.7 TANK LIQUID LEVEL DETERMINATION [18 AAC 75.425(e)(4)(A)(ii)] .......................... 4-9

4.8 MAINTENANCE PROCEDURES FOR BURIED STEEL PIPING 

[18 AAC 75.425(e)(4)(A)(ii)] ........................................................................................... 4-12

4.9 PROTECTIVE WRAPPING OR COATING FOR TANKS AND PIPELINE 

[18 AAC 75.425(e)(4)(A)(ii)] ........................................................................................... 4-12

4.10 CORROSION SURVEYS FOR AN EXISTING INSTALLATION ................................... 4-12

4.11 PIPELINE LEAK DETECTION ....................................................................................... 4-12

LIST OF TABLES 

Table 4.2-1 Best Available Technology Analysis Well Blowout Source Control ................................. 4-5

Table 4.6-1 Best Available Technology Analysis Leak Detection for Tanks ..................................... 4-10

Table 4.7-1 Best Available Technology Analysis Tank Liquid Level Determination System ............ 4-11

 
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PART 4 BEST AVAILABLE TECHNOLOGY [18 AAC 75.425(e)(4)] 

This section discusses the BAT requirements contained in 18 AAC 75.425(e)(4)(A), (B), and (C) to 

address technologies not subject to RPS or performance standards in 18 AAC 75.445(k)(1) and (2). The 

discussion of each technology covers the requirement to analyze applicable technologies and to provide 

a justification that the technology used is BAT. 

Additional information about BAT is also provided in the ACS Technical Manual, Volume I, Tactics L-11A 

through C. 

In addition, Shell has reviewed the ADEC Best Available Technology 2004 Conference Report issued in 

June 2006 and has adopted the following recommended technologies for the purposes of this C-Plan: 

 Annular water injection – Annular water injection is considered a proven breakthrough 

technology. It can be used during a spill response to expedite the transfer of discharged oil from a 

temporary storage tank to a more permanent storage facility. The technology involves reducing 

the discharge line pressure of a discharge hose by injecting a sleeve of water through the hose 

as the oil is pumped. The reduced pressure results in faster transfer rates and therefore, faster 

recovery time. 

 GT-A Pumps – GT-A pumps are considered BAT and are used for lightering of viscous oil. During 

a spill response, the pumps significantly aid in the recovery efforts by accelerating the transfer 

rate for the discharge. 

Shell has also selected response equipment for the containment and recovery of oil and the potential 

burning of oil that is considered to be the BAT for conditions commonly found in the Chukchi Sea. Brief 

descriptions of these systems follow: 

 Transrec 150 weir skimmer is a well-proven recovery system and selected by major response 

organizations, including SERVS, and MSRC, and the Norwegian Clean Seas Association for 

Operating Companies (NOFO), as the primary open-ocean-skimming device. NOFO has 

performed extensive field tests of the Transrec skimmer both in actual spill events and open 

ocean trials using free crude oil. Shell’s OSRV and VOSS is each equipped with one skimmer 

unit mounted near the stern of the vessel, port and starboard. This configuration permits the selfpropelled, floating skimmer heads attached to a 312-ft (95-m) umbilical hose to be maneuvered 

into the thickest oil layers within the apex of the containment boom for optimum recovery. Each 

Transrec 150 has a name-plate recovery capacity up to approximately 2,516 bbl/hr (400 cu m/hr), 

giving the OSRV and VOSS a combined total capacity up to 5,032 bbl/hr (800 cu m). 

 Lamor-Lori brush skimmers, each consisting of five parallel, stiff-brush chains, were selected as 

proven systems for conducting recovery operations. Shell’s OSRV and OSRB are each equipped 

with two of these over-the-side skimming packages, yielding a total name-plate recovery capacity 

of approximately 2,580 bbl/hr or 410 cu m/hr for each vessel. The unique Lamor-Lori Recovery 

Channel design recirculates surface water back into the recovery area, increasing the system’s 

overall throughput efficiency. The skimmer automatically separates oils, emulsions and oily 

debris/ice from sea water making efficient use of on-board storage. Recovered oil normally 

contains less than 5 percent free water. 

 Lamor-Lori brush skimmers were selected as the primary recovery system for Shell’s 47-ft, selfpropelled skimmer that will be stored on, and launched from the OSRB. This skimmer is capable 

of operating effectively at vessel speeds of 2 to 3 knots, which results in much higher oil 

encounter rates than other types of advancing skimmers. The built-in skimmers, one on each side 
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of the vessel, with a name-plate recovery capacity of approximately 516 bbl/hr (82 cu m/hr) gives 

this system a total potential recovery of approximately 1,032 bbl/hr (164 cu m/hr). This skimming 

system is ideally suited for a broad range of oil viscosities; it can operate in adverse weather and 

sea conditions; and, it is sufficiently maneuverable for the recovery of oil trapped or herded in 

pockets against ice. 

 Vertical Rope Mop Skimmers by Crucial Inc. have been selected as part of Shell’s backup 

recovery system, each skimmer consists of eight continuous loops of oleophilic fiber mops with a 

combined name-plate capacity of approximately 503 bb/hr (80 cu m/hr). Stored onboard the 

OSRV, two of these skimmers provide an additional 1,006 bbl/hr (160 cu m/hr) recovery potential. 

Operated from a crane over the side of a skimming vessel or barge, these skimmers allow for the 

placement of the mops directly into heavy pockets of oil contained within a boom or trapped by 

ice. 

 Small Duplex Disc/Brush skimmers (with a floating Lobe Pump) provide for the careful placement 

of a skimming device into smaller pockets of oil (within a boom or trapped among ice cakes). Two 

of these disc/brush skimmers, each rated at approximately 88 bbl/hr (14 cu m/hr), will be located 

onboard the primary OSRV, giving flexibility for the recovery of oil from isolated pools. Their 

combined recovery potential represents another approximately 176 bbl/hr (28 cu m/hr). 

 RubberMax boom is made of vulcanized neoprene and hypalon, and is a durable, inflatable boom 

for use in open water and light ice conditions. The boom is manufactured to International 

Organization for Standardization (ISO) 9001-2000 standards; has a high buoyancy-to-weight 

ratio; and, comes with a high visibility orange color. A complete system consists of a reel, power 

pack, and 200 m (656 ft) of boom. The height of the boom is 67 inches (170 cm) with a freeboard 

of 24 inches (60 cm) and a draft of 43 inches (110 cm). Eight of these systems will be available 

on site for use in multiple configurations such as a large open-apex deflection system; deflection 

booms secured to an OSRV, providing deflection for an OSRV; and as independent U-boom 

configurations for the collection of oil. 

 Three water-cooled, Hydro-Fireboom packages, each with 500 ft (152 m) of inflatable boom [with 

14-inch (36 cm) floatation and 18-inch (46 cm) skirt] are stored on Shell’s OSRV and OSRB. 

Each package is supported by two water pumps, along with long tow lines and fire hose 

assemblies to provide each of the booms in a U-configuration with adequate cooling seawater to 

keep the boom from being damaged by the intense (approximately 1,000 o

C) flames of a 

contained oil fire. The boom is towed in a U-configuration to capture and burn contained oil, or it 

can be held (in a station-keeping mode) at a surfacing blowout, providing enough burn area to 

eliminate 10,000 to 15,000 bopd. This boom has undergone rigorous testing with pit burns and in 

large tanks (Ohmsett Facility in New Jersey). 

4.1 COMMUNICATIONS [18 AAC 75.425(e)(4)(A)(i)] 

The communications system for use in a spill response at proposed locations is described in the ACS 

Technical Manual, Volume 1, Tactic L-5 and L-11A, Shell Beaufort and Chukchi Seas Regional Tactics 

Manual (Tactic LE-1), and in Section 1.4 of this C-Plan. As described in Section 1.4, satellite 

communications systems will be used to maintain compatibility with communication systems of Shell, 

ACS, all North Slope operators, and the worldwide telephone network. Specifically, the drillship will be 

equipped with VSAT communication systems. 

On-site communications systems are believed to be adequate for most Tier 1 response efforts. In the 

event of a major or moderate Tier II/Level III spill response, the Global Maritime Distress and Safety 
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System (GMDSS) will be used to communicate with authorities. In the event of a major blowout, the 

existing on-site systems might not be accessible for safety reasons. However, blowout conditions require 

that an operations center is established. 

4.2 SOURCE CONTROL [18 AAC 75.425(e)(4)(A)(i)] 

The following sections provide an analysis of BAT as it relates to source control for a well blowout, and 

the avoidance of piping and valve failures on the diesel tanks located on the drillship. In addition to the 

narrative contained in these sections, loss of well control (i.e., a blowout) is also addressed in Sections 

1.6.3 and 2.1.8, which includes a discussion of preventive measures that may be taken, along with other 

possible methods of well control. Shell’s Well Control Plan provides a detailed assessment of various 

methods of well control including surface control measures, relief well drilling, blowout ignition, and the 

services of a professional well control firm, if well control is not regained by conventional mechanical 

means or natural bridging. 

4.2.1 Well Source Control 

This BAT analysis for well source control (Table 4.2-1) reviews the techniques and methods to control a 

deep well blowout that has the potential to release liquid hydrocarbons to water surface. Inherent to this 

analysis is the assumption that the first three layers of prevention (see Section 2.1.8) have failed or have 

not been sufficient to control the well. The assumptions for this BAT analysis are that the following 

planned layers of prevention have failed: 

 Even with the proper well planning and preparation, a kick occurred (Layer I); 

 Early kick detection and timely implementation of kick response procedures were not sufficient to 

kill the well (Layer II); and 

 A mechanical barrier (e.g., the BOP, casing, or cement) failed (Layer III). 

Operations are also monitored by Shell’s RTOC, which assists in monitoring operations, analyzing 

penetrated formations, and analyzing pressure trends. The Houston RTOC supplements the mud-logging 

capabilities of the drillship. 

There are three methods of regaining well control once an incident has escalated to a blowout scenario; 

implementation of dynamic surface control measures, well capping, and relief well drilling. This analysis 

indicates that for the planned wells, regaining control via surface control measures is the preferred 

method whenever possible. Well capping is not feasible for offshore wells from moored vessels with BOP 

sitting below the mudline in a MLC; and killing a well by relief well drilling can take significantly longer to 

implement, increasing the duration of discharge. Given the uncertainties of the success of implementing 

surface control measures in these situations, relief well drilling mobilization efforts will begin immediately 

upon the incident escalating to a blowout. 

Surface Control Measures 

Dynamic surface control is accepted by industry and government as a BAT method for source control of a 

blowout from an offshore well with a subsea BOP. Dynamic surface control is the process of pumping 

fluid down the drill string or casing, and circulating the fluid up the pipe by hole annulus at a sufficient rate 

to create fluid friction that will: a) match or exceed reservoir bottomhole pressure to stop the flow, b) flush 

hydrocarbons from the annulus, and, c) prevent annular plugging by friable formation flow (e.g., sand) 

that would cause the drill string or casing to become stuck in the hole. It is for this reason that an 8 1⁄2-inch 
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pilot hole is drilled below the 30-inch casing and opened to 26-inch to accept the 20-inch casing, another 

8 1⁄2-inch pilot hole is drilled below the 20-inch casing and opened to 17 1⁄2-inch to accept the 13 3/8-inch 

casing and so on. In each hole segment, the smaller diameter pilot hole reduces the rate from an 

uncontrolled formation flow due to a limited area provided in the annulus between the drill string and the 

hole and it provides the optimum condition for killing the flow via the dynamic surface pumping technique. 

This same technique is used when intersecting a blowing well with a relief well. Fluid is pumped down the 

relief well and up the blowout well at a rate sufficient to kill the flow by creating fluid friction in what is 

commonly called a dynamic kill. This is not the same as Layer II of well control as described in Section 

2.1.8. which involves early kick detection and kick control, usually shutting in the well rapidly. Dynamic 

Surface Pumping is a technique used to control a flow after it begins. Kick circulation is normally done at 

slower pump rates where fluid friction in the annulus is not needed as a control mechanism. 

The following factors could limit the effectiveness of surface control measures: 

 BOP element failure. 

 Insufficient pump rate. In the event that the available pump capacity is insufficient to kill the well, 

other methods with lower rates can be applied to kill the well (e.g., weight and wait). 

 Inability to divert the blowout fluid and ensure a safe environment for workers. 

In the unlikely event of a blowout, Shell would attempt to kill the well via dynamic surface control 

methods. Factors that would make this method infeasible include: 

 Any situation where the BOP has failed and was not available to hold back pressure on the well; 

 Efforts were implemented to divert the blowout fluids to create a safe work environment; 

 The drilling equipment was damaged to an extent to make it ineffective; or 

 The vessel had to move off the location for safety and/or vessel stability reasons. 

Concurrent with implementing surface control techniques, Shell would be preparing to mobilize and drill a 

relief well as a contingency. 

Well Capping 

Well capping techniques have improved, especially since its frequent application during the Iraq-Kuwait 

conflict in the early 1990s. Well capping techniques have been proven to be both efficient and effective in 

regaining control of damaged wells and reducing the associated environmental impacts for wells with 

accessible BOP or wellheads. However, similar techniques for performing well capping in MLCs 

constructed on the sea floor from moored vessels have not been proven. Therefore, well capping would 

not be an effective option for regaining well control while operating from a moored vessel. 
Oil Discharge Prevention and Contingency Plan Chukchi Se

Part 4 – Best Available Technology 

Shell 4-5 95-2000.01-25.201-001/09-018 

TABLE 4.2-1 

BEST AVAILABLE TECHNOLOGY ANALYSIS 

WELL BLOWOUT SOURCE CONTROL 

BEST AVAILABLE TECHNOLOGY 

(BAT) EVALUATION CRITERIA 

PROPOSED METHOD: 

DYNAMIC SURFACE CONTROL 

ALTERNATE METHOD: 

RELIEF WELL DRILLING 

ALT

AVAILABILITY:Whether technology is best in use in other similar situations or is available for use by applicant 

Dynamic surface control is in use globally. Relief well drilling equipment (drilling unit 

downhole tools, etc.) are widely available aside from equipment required from a few specialty providers (e.g., ranging services). 

Equipment is from moored 

TRANSFERABILITY:Whether each technology is transferable to applicant’s operations 

Technique is directly transferable, and equipment is the same as is used on the drillship during normal operations. 

Relief well drilling is directly transferable and can be performed by the drillship in use by Shell in the Chukchi Sea. 

Proven techn

EFFECTIVENESS:Whether there is a reasonable expectation each technology will provide increased spill prevention or other environmental benefits 

In the majority of cases, the technique is highly effective. Application of dynamic surface control provides the best opportunity for minimizing pollution impacts because most blowout wells are controlled with dynamic surface controls while other methods are being mobilized. Technique would not be effective if BOP had failed, and a safe work environment could not be ensured in the event of extensive drillship or equipment damage, or if the drillship had to move from the location. 

Technique is generally understood to be effective in a wide range of situations. 

Proven effecavailable. 

COST:The cost to the applicant of achieving BAT, including consideration of that cost relative to the remaining years of service of the technology in use by the applicant 

The costs are relatively low, assuming that the drillship is available to kill the well and consumables such as drilling fluids 

and cement are readily available. 

The cost of permitting, mobilization, and executing relief wells is high. Costs include day-rate of the vessel to drill the relief well, casing, drilling fluids and other consumables, as well as the cost of lost opportunity should the vessel have to prematurely end work on its intended prospect. 

Not applicabtechnology is 

AGE AND CONDITION:The age and condition of technology in use by the applicant 

The age and condition of the drilling equipment is appropriate for the operation. Equipment is the same as is used on the drillship during normal operations. 

The age and condition of the drillship and associated equipment available for a relief well are appropriate for the operation. 

Not applicabtechnology is 

COMPATIBILITY:Whether each technology is compatible with existing operations and technologies in use by the applicant 

Technology is compatible and equipment is the same as is used on the drillship during normal operations. 

Technology is compatible. The drillship has comparable equipment available. 

Not applicabtechnology is 
Oil Discharge Prevention and Contingency Plan Chukchi Se

Part 4 – Best Available Technology 

Shell 4-6 95-2000.01-25.201-001/09-018 

TABLE 4.2.1 (CONTINUTED) 

BEST AVAILABLE TECHNOLOGY ANALYSIS 

WELL BLOWOUT SOURCE CONTROL 

BEST AVAILABLE TECHNOLOGY 

(BAT) EVALUATION CRITERIA 

PROPOSED METHOD: 

DYNAMIC SURFACE CONTROL 

ALTERNATE METHOD: 

RELIEF WELL DRILLING 

ALT

FEASIBILITY:The practical feasibility of each technology in terms of engineering and other operational aspects 

Method is feasible for all drilling operations. Would not be a feasible option if the BOP had failed. Applied at the surface, the technology is not sensitive to well type. Demonstrated success in historical well control efforts. 

Method feasibility is contingent upon geographical access near area of blowout. Seasonal ice conditions (e.g., offshore Chukchi) limit application to the drilling season. 

Proven techn

ENVIRONMENTAL IMPACTS:Whether other environmental impacts of each technology, such as air, land, water pollution, and energy requirements, offset any anticipated environmental benefits 

Technology provides the best-proven opportunity to quickly reduce environmental impacts. 

Technology provides additional exposure and environmental risks during application (additional well control problems). Additional environmental costs would include the resource consumption (e.g., fuel, casing, and drilling fluids), waste generated, and emissions associated with drilling the relief well. Technology application may be seasonally limited, leading to durations of 60-180 days. Drilling a relief well is accompanied by the additional risk of a second well control event. 

Not applicabtechnology is 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 4 – Best Available Technology 

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Relief Well Drilling 

A relief well would be drilled by the drillship in the Chukchi Sea (see Section 1.6.3, and the Blowout 

Scenario in Section 1.6.13. During a blowout, the drillship would be redeployed to a suitable location to 

initiate a relief well.

Relief well drilling in a blowout zone can be a time-consuming and costly process. The lead-time involved 

drilling a relief well necessitates early planning. Within Shell’s exploration, it is estimated that once on 

location, a relief well can be drilled within 34 days for TVD up to 14,000 ft (4,267 m). The relief well plan 

may be initiated concurrently with the implementation of control methods. The total time to regain well 

control via a relief well would depend on the depth of well interception required and ice and water 

conditions. Statistically, it is more than likely that the blowout well would kill itself before the need to 

mobilize the drillship. 

Relief well drilling technology is compatible with drilling operations in the Chukchi, although it may be 

sensitive to both the well location and well type. Downhole and surface equipment (e.g., tubulars, 

wellheads, or similar equipment) is readily available to support relief well drilling operations. 

Relief well drilling has been attempted only once on the North Slope as a mitigation measure to control a 

blowout. The 1992 incident was a natural gas blowout while drilling the ARCO Cirque exploration well. 

Control of the well was regained in approximately two weeks through the application of surface well 

capping techniques assisted by natural bridging. 

Because Shell’s plans for the Chukchi Sea do not include extended reach wells, relief well operations 

would be relatively straightforward in comparison to the original well, apart from ensuring well intersection. 

The differences between the two wells would be: 

 There is no MLC for the relief well; 

 There is no open-hole logging on wireline at casing points for relief well; and 

 The use of ranging services to specifically locate the original wellbore. 

Relief well drilling in the Chukchi Sea would be similar to current methods used to drill offshore wells 

elsewhere in the world. Advances in directional technology that allow for more precise wellbore 

placement increase the likelihood of success of drilling a relief well. 

4.2.2 Tank Source Control 

Drillship tanks are inspected in accordance with API 653 by the MMS and USCG as part of the drillship 

inspection prior to exploration activities. 

Fuel storage tanks are equipped with manual shutdown valves that remain closed except during fuel 

transfer operations. Remote temporary exploration sites will be staffed 24 hrs/day. Best management 

practices (BMPs) indicate two operators present and in direct line of sight and in constant communication 

for the duration of the fuel transfer, with one person having the ability to shut down the fuel transfer in the 

event of an emergency. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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4.3 TRAJECTORY ANALYSES [18 AAC 75.425(e)(4)(A)(i)] 

As exploration drilling utilizes a subsea BOP, oil associated with a blowout WCD is presumed to reach the 

mud-water interface (i.e. seabed) almost immediately. Various techniques for monitoring the spill 

trajectory include the use of the established oil spill trajectory models (e.g., GNOME, OILMAP) and use of 

aerial reconnaissance. 

Computer-based trajectory analyses (see Section 1.6.13, Scenario 1) were performed using Shellcollected wind data and modeled currents for the Chukchi Sea. The trajectory presented in Scenario 1 is 

based upon the assumption that oil on open water moves as the sum of vectors representing surface 

currents and wind speed. The results of the trajectory analysis are present in Figure 1.6-8. Additional 

computer trajectories were run to calculate minimum response times under specific wind conditions to 

deploy shoreline protection for environmentally sensitive sites located between Point Barrow and Point 

Hope (see Section 1.6.12). 

4.4 WILDLIFE CAPTURE, TREATMENT, AND RELEASE PROGRAMS 

[18 AAC 75.425(e)(4)(A)(i)] 

Wildlife capture, treatment, and release programs are described in the ACS Technical Manual, Volume 1, 

Tactic L-11C, and related Tactics W-1 through W-5, and the ARRT Wildlife Protection Guidelines for 

Alaska (Annex G of the ARRT Unified Plan). These programs are considered BAT for this exploration 

program. 

Additional information is provided in a report prepared by Shell, Wildlife Capture, Treatment and Release 

Programs, for their Chukchi Sea Oil Spill Response Planning program. This report is presented in 

Appendix E of this C-Plan. 

The Frontier Discoverer drillship will have MMOs on board at all times. This is considered the BAT for 

wildlife monitoring. 

4.5 CATHODIC PROTECTION [18 AAC 75.076(h)(4)(A)(ii) 

Not applicable. 

4.6 LEAK DETECTION TANKS [18 AAC 75.425(e)(4)(A)(ii)] 

Visual inspection is BAT for the detection of leaks from drillship tanks. The drillship will be staffed 24 

hrs/day during operations and closely monitored at all times for leaks. Standard operating procedures 

and BMPs provide for daily inspections of fuel tanks. Personnel will visually inspect tankage, sumps and 

drains at a minimum once per day for indications of leakage. Daily visual inspections, as outlined in 

Section 2.5, provide the most reliable, feasible, and cost-effective means to detect leaks. 

Prior to exploration operations, drillship tanks are inspected in accordance with American Petroleum 

Institute (API) 653 by the MMS and USCG as part of the drillship inspection to ensure the structural 

integrity of all components. 

These inspections are evaluated in Table 4.6-1 in accordance with the criteria set forth in 18 AAC 

75.445(k)(3) and ACS Technical Manual, Tactic L-11. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 4 – Best Available Technology 

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4.7 TANK LIQUID LEVEL DETERMINATION [18 AAC 75.425(e)(4)(A)(ii)] 

Tank liquid levels are manually measured to determine the required volume prior to any fuel transfer. The 

levels are determined either by visual observation through the tank opening using sightglass readings or 

by manual soundings with an applicable sounding tape. Manual soundings are taken at any time that 

there is an uncertainty with other sounding methods. Fluid transfers follow the inspection and procedures 

noted in Sections 2.1.5 and Appendix C. 

Tank liquid levels in temporary and deck-mounted equipment will be checked primarily by visual means 

prior to filling (e.g., by direct observation through the hatch or fill cap using a flashlight). Direct visual 

observation using a flashlight is highly reliable, as a functional check is performed on the flashlights prior 

to use and actual liquid levels are noted. Visual observation may be more accurate and reliable than other 

devices such as sightglasses, float gauges, or tank strapping, due to the tendency for these devices to fail 

under arctic conditions (Table 4.7-1). BMPs indicate two operators present, in direct line of sight of each 

other, and in constant communication via radio or hand signal, for the duration of the fuel transfer, with 

one person having the ability to shut down the fuel transfer in the event of an emergency. Tank liquid 

levels will be monitored visually (e.g., by direct observation through the hatch using a flashlight) 

throughout the duration of the filling process. Key times for visual observations include the refueling of 

both the wireline unit and the crane fuel tanks. 

The Frontier Discoverer’s major integral tanks are sounded at least once per day to verify liquid levels. 

Tank levels also are manually measured prior to any fuel transfer to determine their volume and 

remaining capacity. Strict procedures are observed for fuel transfer and discharge prevention. Fuel 

transfers between internal tanks and onboard equipment are made regularly, depending on equipment 

and usage. Fuel transfers include manual opening of valves, filling the tanks, and manually closing the 

tanks. Visual inspection and proper communication between the pump operator and the person 

supervising the tank fueling is considered BAT for these transfers. Overflow from the temporary or deck 

equipment fuel tanks are captured in drip pans and deck drains. 

All fuel transfers to temporary or deck fuel tanks are executed under the Permit to Work system following 

an associated Job Safety Analysis. Preventative maintenance measures of control include careful 

planning of equipment placement for the storage tanks. For example, temporary and deck equipment are 

not positioned over open grating if they are equipped with fuel tanks or associated fueling facilities. 

These visual and manual methods, together with adhere to strict procedures, are a proven BAT method 

for monitoring tank levels. These methods are as good as or better than the alternative methods 

presented in Table 4.7-1, and provide the most reliable, feasible, and cost-effective alternative. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 4 – Best Available Technology 

Shell 4-10 March 2010 

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TABLE 4.6-1 

BEST AVAILABLE TECHNOLOGY ANALYSIS 

LEAK DETECTION FOR TANKS 

BEST AVAILABLE TECHNOLOGY (BAT) 

EVALUATION CRITERIA CURRENT METHOD: VISUAL INSPECTIONS 

AVAILABILITY: 

Whether technology is best in use in other similar situations or 

is available for use by applicant 

This approach has been extensively used for similar 

exploration drillships and is currently proposed by Shell. 

TRANSFERABILITY: 

Whether each technology is transferable to applicant’s 

operations 

This approach is directly transferable for Shell operations. 

EFFECTIVENESS: 

Whether there is a reasonable expectation each technology 

will provide increased spill prevention or other environmental 

benefits 

Effective with strict adherence to BMPs and local 24-hr staffing 

at drill sites provides a reliable and effective method of leak 

detection. 

COST: 

The cost to the applicant of achieving BAT, including 

consideration of that cost relative to the remaining years of 

service of the technology in use by the applicant 

No cost. 

AGE AND CONDITION: 

The age and condition of technology in use by the applicant 

Not applicable. 

COMPATIBILITY: 

 Whether each technology is compatible with existing 

operations and technologies in use by the applicant 

Compatible and widely used on remote drilling operations. 

Requires no change. 

FEASIBILITY:

The practical feasibility of each technology in terms of 

engineering and other operational aspects 

Currently planned to be used and is feasible. With 24-hr 

operations on the drillship, this provides a practical and reliable 

method of leak detection. 

ENVIRONMENTAL IMPACTS:

Whether other environmental impacts of each technology, such 

as air, land, water pollution, and energy requirements, offset 

any anticipated environmental benefits 

None. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regiona

Part 4 – Best Available Technology 

Shell 4-11 95-2000.01-25.201-001/09-018 

TABLE 4.7-1 

BEST AVAILABLE TECHNOLOGY ANALYSIS 

TANK LIQUID LEVEL DETERMINATION SYSTEM 

BEST AVAILABLE TECHNOLOGY 

(BAT) EVALUATION CRITERIA 

PROPOSED METHOD: VISUAL 

INSPECTION AND MANUAL 

GAUGING 

ALTERNATIVE 1: 

SIGHT GLASS WITH BALL CHECK 

VALVE CONTROL SYSTEM 

ALTER

FLOAT LEVEL 

CONTRO

AVAILABILITY:Whether technology is best in use in other similar situations or is available for use by applicant 

Proposed method. Sight glass with ball check valve 

systems are used today, but less frequently than other devices. 

Float-actuated level devices, are widely utoday 

TRANSFERABILITY: Whether each technology is transferable to applicant’s operations 

Transferable. Undetermined. Transferable. 

EFFECTIVENESS:Whether there is a reasonable expectation each technology will provide increased spill prevention or other environmental benefits 

Highly effective with strict adherence to BMPs and local procedure. Tank liquid levels will be determined from direct observation through the hatch using a flashlight and manual measurement. As good as or better than other “low tech” devices. 

Not effective in this application. Sight glass systems are prone to breaking, becoming obstructed, and freezing if moisture buildup occurs in the tubing. In addition, the ball check valves are prone to freezing and sticking in either the open or closed position. 

Effective in this applcondensation or free

obscure the measurIn addition, this systinaccurate measureuneven sedimentatio

COST:The cost to the applicant of achieving BAT, including consideration of that cost relative to the remaining years of service of the technology in use by the applicant 

Not applicable. Undetermined. Undetermined. 

AGE AND CONDITION:The age and condition of technology in use by the applicant 

Procedures have been in place at North Slope facilities since 1993 for visual fuel transfer operations and tank strapping devices have been in use for 50 years. 

Sight glass devices have been used in the industry for over 20 years, mostly on permanent tanks. 

Float-actuated devicthe industry for over 

COMPATIBILITY: Whether each technology is compatible with existing operations and technologies in use by the applicant 

Compatible and widely used. Requires no change. 

Compatible but breakage potential is a concern. 

Compatible and usetanks in Alaska. 

FEASIBILITY:The practical feasibility of each technology in terms of engineering and other operational aspects 

Feasible and preferred due to reliability in conjunction with BMP and monitoring procedures. 

Sight glass devices are typically not used in exposed areas as they can become a source for a leak if damaged. 

Feasible, but would engineering modificaoperational modifica

over the use of float failures of float devic

ENVIRONMENTAL IMPACTS: Whether other environmental impacts of each technology, such as air, land or water pollution, and energy requirements offset any anticipatedenvironmental benefits

None. None. None. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 4 – Best Available Technology 

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4.8 MAINTENANCE PROCEDURES FOR BURIED STEEL PIPING 

[18 AAC 75.425(e)(4)(A)(ii)] 

Not Applicable. 

4.9 PROTECTIVE WRAPPING OR COATING FOR TANKS AND PIPELINE 

[18 AAC 75.425(e)(4)(A)(ii)] 

Not Applicable. 

4.10 CORROSION SURVEYS FOR AN EXISTING INSTALLATION 

Not Applicable. 

4.11 PIPELINE LEAK DETECTION 

Not Applicable. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Part 5 – Response Planning Standards 

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PART 5 RESPONSE PLANNING STANDARDS 

[18 AAC 75.425(e)(5)] 

This section discusses the applicable RPS used in this plan, as set forth in 18 AAC 75.430 through 18 

AAC 75.440 and 18 AAC 75.442. 

Well Blowout (18 AAC 75.434) 

The RPS for a Chukchi Sea regional exploration well is based upon the ADEC’s regulations that establish 

the RPS volume for an exploration facility to be 5,500 bopd, or best producing well data, for the duration 

of 15 days (18 AAC 75.434). Additionally, because this plan is under the jurisdiction of MMS regulations, 

the WCD volume is calculated using the RPS volume of 5,500 bopd for a total duration of 30 days [30 

CFR 254.47(b)]. 

The total release will involve 165,000 bbl of oil during the entire 30 day time period (5,500 x 30 = 165,000 

bbl). This value represents the WCD Scenario prepared to meet the response planning requirements of 

ADEC and MMS. See Section 1.6.13, Scenario 1, for a discussion of reservoir characteristics. 

For storage purposes, an emulsion factor of 1.54 and a percentage of free water (20 percent) has been 

added to the initial RPS of 165,000 bbl [(165,000 x 1.54 = 254,100) + (165,000 x 0.20 = 33,000) = 

287,100] for a total storage volume of 287,100 bbl. 

Fuel Transfer Strategy (18 AAC 75.025) 

The WCD for the fuel transfer strategy prepared for this C-Plan is based on the definition contained in 33 

CFR 154.1029(b)(2), using the following values: 

 maximum time to discover release: 5 min 

 maximum time to shutdown pumping: 0.5 min (30 sec) 

 maximum transfer rate: 320 gpm (based on representative fuel transfer pumps on the OSRV = 

7.6 bbl/min) 

 total line drainage volume: 163 gal [premising 4 inch by 820 ft (10 cm by 250 m)] marine hose 

between the pump manifold on the barge and the delivery flange on the inlet piping at the 

drillship) or 3.9 bbl 

Rationale for Claimed Prevention Credits (18 AAC 75.425(e)(2)(F)) 

Although Shell considers its well prevention and control measures “best in class,” it will not be claiming 

any prevention credits to offset oil spill response planning requirements, based on exploration well 

operations as specified in 18 AAC 75.434. 

The recovery equipment provided in support of this plan (refer to Tables 1.6-5 and 1.6-6 in 

Section 1.6.13) substantially exceed the mechanical recovery capability needed to contain the WCD (see 

Section 1). 
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APPENDIX A 

GENERAL SPECIFICATIONS FOR MARINE AND AERIAL SUPPORT VESSELS 
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1. MARINE VESSELS IN SUPPORT OF CHUKCHI SEA EXPLORATION DRILLING PROGRAM 

2. AERIAL SUPPORT OF CHUKCHI SEA EXPLORATION DRILLING PROGRAM 
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1. MARINE VESSELS IN SUPPORT OF CHUKCHI SEA EXPLORATION DRILLING PROGRAM 

LIST OF MARINE VESSELS IN SUPPORT OF 

CHUKCHI SEA EXPLORATION DRILLING PROGRAM 

Anchor-Handling Tor Viking or similar

Ice Management Vladimir Ignatyuk or similar 

Offshore Oil Spill Response Vessel 

(OSRV) OSRV Nanuq

Offshore Oil Spill Response Work Boats (3) 34-ft work boats

Arctic Oil Storage Tanker Affinity or Perserverance, or similar

Oil Spill Response Barge (OSRB) 

OSRB Endeavor

(1) 47-ft skimming boat 

(3) 34-ft work boats 

(4) 249-bbl mini-barges 

Other Misc. short-term support vessels 

(crew changes, supplies, etc.)
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THE VLADIMIR IGNATYUK DIESEL-ICEBREAKER OR SIMILAR 

The Vladimir Ignatyuk was specifically designed as a multifunctional icebreaker for operations in the 

northern seas for anchor handling, towing and ice management. The Vladimir Ignatyuk is equipped with a 

heli-deck and life saving watercraft. 

Deadweight Capacity 2,113 tons

Power 23,200 hp

Length 88.02 m

Wi dth 17.51 m

Draft 8.30 m

Cruising Speed 15.5 knots

Berthing 34

Class Lloyd's Register of Shipping + 100 A1 Icebreaker Tug + LMC 

Lloyd's Register of Shipping 100 A1 LMC, icebreaking tow, 

ice class - 1A Super
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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MSV TOR VIKING MULTIPURPOSE ICEBREAKER OR SIMILAR 

The MSV Tor Viking is a multifunctional, diesel-powered vessel, providing ice management 

capabilities, towing, and supply services. The ship is equipped with double hulls between all 

tanks that contain oil. 

DNV ID: 21779 IMO No: 9199622 

Operational Status: In Operation Class Relation: In DNV Class 

Speed: 16 knots − Abt. 42.7 MT 

Engine Output: 13,440 kW 

Dimensions: 

Loa: 83.7 m Gross Tonnage (ITC 69): 3,382

Lbp: 75.2 m Net Tonnage (ITC 69): 1,145

Breadth Moulded: 18 m Deadweight Tonnage: 2,528

Depth Moulded: 8.5 m Bollard Pull Foward 200 T 

Draught: 7.2 m Bollard Pull Astern 120 T 

Flag: Sweden Signal Letters: SLJT 

Port: SKÄRHAMN 

Owner: Trans Viking Icebreaking & 

Offshore AS 

 

Manager: Viking Supply Ships AS 

Kristiansand, Norway 

 

Yard: Havyard Leirvik A.S. (108910) Year of Build: 2000 

Type: 630 – Supply Vessel/Tug 

Class Notation: 1A1 ICE-05 Icebreaker (for max draught 6.70m) Tug 

Supply Vessel SF HELDK-SH E0 DYNPOS-AUTR 

NAUT-OC DK(+) HL(2.8) 
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OSRV – NANUQ OR SIMILAR 

GENERAL SPECIFICATIONS 

Vessel Name Nanuq (Hull 235) 

Principal Dimensions 301 ft 6 inches x 60 ft x 24 ft 

Horsepower 7,268 BHP 

Deck Space 169 ft x 50.5 ft 

Main Engines (2) 3608 Caterpillar 

Bow Thruster 2 x 1,700 HP/CP Tunnel 

Stern Thruster 1,700 HP/CP Tunnel 

Electronics As per GMDSS requirements 

Fuel Oil Capacity 6,867 bbl 

Liquid Storage 12,690 bbl 

Certification USCG Subchapter L (OSV) and I (cargo); ABS= A1 

(Hull); ABS= AMS (Machinery); ABS Load Line; ABS 

DP-2; Ice Class A1, SOLAS 2000; MARPOL 99 
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KVICHAK 34-FT OIL SPILL RESPONSE WORK BOAT OR SIMILAR 

Vessel use: 

 Operates in open ocean and shallow water with adequate protection to propellers and rudders. 

 Capable of operating in up to 6-ft seas depending upon wave characteristics. 

 Has an approximate 7,000 lbs of bollard pull. 

 Vessel strengthened with ice belting around waterline for incidental ice contact. 

GENERAL SPECIFICATIONS 

Overall Length 34 ft 6 inches 

Overall Beam 12 ft 

Deck Length 34 ft 

Draft, Light Load 32 inches 

Draft, Full Load 38 inches 

Engine, Twin Marine Diesels 305 hp, each 

Approx. Top Speed 20 knots 

Approx. Bollard Pull 7,000 lbs 

Fuel Oil 300 gal 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix A – General Specifications for Marine and Aerial Support Vessels 

Shell A-6 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

ARCTIC TANKER: AFFINITY OR PERSEVERANCE OR SIMILAR 

Shell has chartered for the purposes of mass oil storage an arctic tanker with ST Shipping and Transport 

Pte Ltd for the provision of the Affinity or its identical sister ship, the Perseverance. A tanker with similar 

functional specifications would be engaged if the Affinity and the Perseverance are unavailable when 

operations begin. 

A summary of its principal dimensions and capabilities follows: 

Name: Affinity Perseverance 

IMO Number: 9289776 9289752 

Where Built: ST Shipbuilding Co. Ltd, Korea 

Date Delivered: 05 Jul 2005 08 Jun 2005 

Type of Vessel: Oil Tanker 

Type of Hull: Double Hull 

Port of Registry: Singapore 

Flag: Singapore 

Classification: Det Norske Veritas 

Class Notation: +1A1 Tanker for Oil ESP, 

ICE-1A, E0, VCS-2, T-MON 

Dimensions (meters): 

Length: 228 

Breadth: 32.292 

Draft (summer): 14.3 

Tonnages (metric): 

Gross Tonnage : 42,661 

 

Deadweight (tonnes): 73,741 73,789 

Crude Capacity (bbl): 553,494 

Performance: 

Engine Output (kW): 13,736 

Engine Type/Builder: Marine Diesel/STX 

Engine Designation: 6S60 MC-C 7S60 MC-C 

Speed (knots): 16 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix A – General Specifications for Marine and Aerial Support Vessels 

Shell A-7 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

OIL SPILL RESPONSE BARGE AND ICE CLASS TUG OR SIMILAR 

GENERAL SPECIFICATIONS 

Vessel Name Point Oliktok Vessel Name Arctic Endeavor 

Principal Dimensions 90 ft x 32 ft x 11.5 ft Principal Dimensions 205 ft x 90 ft x 15 ft 

Horsepower 2110 Horsepower Non-powered 

Deck Space 30 ft x 30 ft Deck Space Approx 200 ft x 80 ft 

Main Engines (2) Caterpillar 3512 Liquid Storage 18,636 bbls 

Certification USCG - Uninspected 

Towing Vessel 

ABS - A1, Towing 

Service, AMS 

Certification USCG - Freight 

Barge 

ABS - +A1, Oil Tank 

Barge, Ice Class C 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix A – General Specifications for Marine and Aerial Support Vessels 

Shell A-8 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

KVICHAK 47-FT OIL SPILL RESPONSE WORK BOAT 

(WITH LAMOR HK2 BRUSH SKIMMERS) 

Vessel use:

 Rapid response to the spill site. 

 Oil recovery via LAMOR brush skimmer system. 

 Operates in shallow water with adequate protection to propellers and rudders. 

 Capable of operating in 6- to 8-ft seas. 

 Has an approximate 22,000 lbs of bollard pull. 

 Able to tow vessels and barges with a maximum weight of 75 gross tons alongside, astern, and 

pushing ahead. 

 Capable of slow speed operation for skimming oil via the engine’s MGX transmissions. 

 Vessel strengthened around waterline for incidental ice contact. 

GENERAL SPECIFICATIONS 

Length Overall 51 ft x 16 ft 8 inches x 54 inches 

Deck Length 47 ft 

Deck Width 16 ft 

Fuel Tank 800 gal 

Engine, Twin Marine Diesel 600 hp, each 

Molded Dimensions 47 ft x 16 ft 

Approx. Top Speed 22 knots 

Approx. Bollard Pull 22,000 lbs 

Approx. Draft 60 inches light 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix A – General Specifications for Marine and Aerial Support Vessels 

Shell A-9 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

249-BARREL MINI-BARGES 

GENERAL SPECIFICATIONS 

Overall Length 46 ft

Overall Beam 12 ft 

Overall Depth 5 ft 5 inches 

Maximum Storage Capacity 249 bbl in two tanks 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix A – General Specifications for Marine and Aerial Support Vessels 

Shell A-10 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

2. AERIAL SUPPORT OF CHUKCHI SEA EXPLORATION DRILLING PROGRAM 

GENERAL SPECIFICATIONS 

BELL 412 (IFR) TWIN TURBINE HELICOPTER 

DIMENSIONS 

Length 56 ft 2 inches 

Width 9 ft 4 inches 

Height 15 ft 1 inches 

Main rotor diameter 46 ft 0 inches 

CARGO/BAGGAGE 

Tailboom cargo space - 28 cu ft (400 lbs) 

Internal cargo space - 220 cu ft with 49 inches x 

 92 inches 

Sliding doors 

SPECIFICATIONS 

Maximum gross weight 11,900 lbs 

Average basic weight 7,700 lbs 

External sling load 4,000 lbs 

Fuel capacity 214 gal/1,455 lbs 

 (293 gal [one aux tank]) 

Fuel consumption 110 gph/800 pph 

Average cruise speed 117 kts/135 mph 

Maximum range - 252 nm/290 sm (30-minute fuel 

 reserve) 

Passenger seats 11 to 13 passengers 

 depending on configuration 

Crew 2 pilots 

POWER PLANT 

Two (2) Pratt & Whitney PT6T-3B engines developing 1,800 

SHP derated to a total of 1,350 SHP. 

LANDING GEAR 

Fixed skid type landing gear with automatic and pilot 

activated emergency pop-out float system. 

LOADING INFORMATION 

Basic weight 7,700 lbs 

Full fuel (one auxiliary tank) 1,992 lbs 

Pilots (2) 400 lbs 

Operating weight 10,092 lbs 

Maximum gross weight 11,900 lbs 

Minus operating weight 10,092 lbs 

Total payload 1,808 lbs (full fuel) 

PAYLOAD - *Includes 30-minute reserve. 

DISTANCE

(round-trip)

FUEL

REQUIRED*

PAYLOAD 

OUTBOUND

FLIGHT

TIME

252 nm/269 sm 1,992 lbs 1,808 lbs 2.2 

200 nm/230 sm 1,657 lbs 2,143 lbs 1.7 

150 nm/172 sm 1,337 lbs 2,463 lbs 1.3 

100 nm/115 sm 1,016 lbs 2,784 lbs 0.9 

50 nm/57 sm 696 lbs 3,104 lbs 0.4 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix A – General Specifications for Marine and Aerial Support Vessels 

Shell A-11 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

*GENERAL SPECIFICATIONS 

AGUSTA WESTLAND (IFR) TWIN TURBINE HELICOPTER 

*specifications may vary between operators’ configurations 

DIMENSIONS 

Length 54.7 ft 

Height 16.3 ft 

Width (landing gear) 10.0 ft 

Main Rotor Diameter 45.3 ft 

CARGO/BAGGAGE 

Tailboom cargo space – 120 cu ft 

Internal cabin dimensions – 8.9 ft L x 6.9 ft W x 4.6 ft H 

Sliding doors on both sides – 5.5 ft wide each 

SPECIFICATIONS 

Max ramp gross weight 14,219 lbs 

Max T/O weight 14,110 lbs 

Average basic weight 8,600 lbs 

External sling load TBD 

Standard fuel capacity 413 gal / 2,808 lbs 

Aux fuel tank 132 gal / 898 lbs 

Fuel consumption 150 gph / 1,020 gph 

Average cruise speed 140 knots 

Max range with aux tank & reserves 430 n mi 

Passenger seats (offshore) 12 

Crew (pilots) 2 

POWER PLANT 

Two (2) Pratt & Whitney PT6C-67C turboshaft engines with 

FADEC 

LANDING GEAR 

Retractable tricycle landing gear with emergency pop-out 

float system 

LOADING INFORMATION 

Basic weight 8,600 lbs 

Pilots x 2 (offshore survival gear) 500 lbs 

Max fuel (standard tanks only) 2,808 lbs 

Operating weight 11,908 lbs 

Maximum gross weight 14, 110 lbs 

Minus operating weight 11,908 lbs 

Total Payload 2,202 lbs 

**FUEL REQUIRED – includes ~30 minutes reserve fuel 

TOTAL 

DISTANCE

**FUEL

REQUIRED

PAYLOAD 

OUTBOUND

FLIGHT

TIME

430 nm 3,670 lbs 1,340 lbs 3.1 

250 nm 2,336 lbs 2,674 lbs 1.8 

100 nm 1,214 lbs 3,796 lbs 0.7 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix A – General Specifications for Marine and Aerial Support Vessels 

Shell A-12 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

*GENERAL SPECIFICATIONS 

LOCKHEED C-130A HERCULES 

*specifications may vary between operators’ configurations 

DIMENSIONS 

Length 97.8 ft 

Height 38.3 ft 

Wingspan 132.6 ft 

DISPERSANT PAYLOAD 3,250 gal

SPECIFICATIONS 

Max Gross Weight 124,200 lbs 

Average Basic Weight ~60,000 lbs 

Fuel Capacity Unknown (depends on 

 configuration) 

Fuel Consumption 575 - 800 gal per hr 

 (dependent upon altitude / 

 airspeed) 

Average Cruise Speed 298 knots 

Maximum Range 2,000 n mi 

Passenger Seats Not Authorized 

Crew 2 pilots 

 1 Flight Engineer 

POWER PLANT 

Power Plant Four (4) Allison T56 engines; 

 3750 SHP each 

LANDING GEAR 

Retractable 

LOADING INFORMATION 

Basic Weight ~60,000 lbs 

Full Fuel Unknown (depends on 

 configuration) 

Pilots / Crew 600 lbs 

Operating Weight Unknown without fuel load 

Max Gross Weight 124,200 lbs 

Minus Op Weight Unknown without fuel load 

Total Dispersant 

Payload 3,250 gal / ~26,000 lbs 

 

TOTAL 

DISTANCE

**FUEL

REQUIRED

PAYLOAD 

OUTBOUND

FLIGHT

TIME

2,000 n mi Full None 7.0 

1,400 n mi Unknown 26,000 lbs 4.5 

**FUEL REQUIRED – includes ~30 minutes reserve fuel
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-i March 2010 

95-2000.01-25.201/09-018 Rev. 0 

APPENDIX B 

CONTRACTUAL TERMS WITH PRIMARY RESPONDERS 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-ii March 2010 

95-2000.01-25.201/09-018 Rev. 0 

THIS PAGE INTENTIONALLY LEFT BLANK 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-1 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-2 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-3 March 2010 

95-2000.01-25.201/09-018 Rev. 0 

February 11, 2009 

Commanding Officer 

United States Coast Guard 

National Strike Force Coordination Center 

ATTN: OSRO Section 

1461 North Road Street 

Elizabeth City, North Carolina 27909-3241 

Subject: Dedication of Resources, OSRO Classification 

Reference: 33 CFR 1028 

Dear Sir or Madam; 

This is to certify that the following resources, under charter to Shell, are available to Alaska 

Clean Seas and should be considered in their OSRO classification application: 

Oil Spill Response Vessel Nanuq, recovered oil storage capacity 12,000 Bbls. 

Oil Spill Response Barge Arctic Endeavor with attending tug, recovered oil storage capacity 

16,000 Bbls. 

Oil Tanker Affinity or Perseverance, recovered oil storage capacity 513,000 Bbls. 

Please note that these resources will be available within the stipulated response times and within 

the geographic areas outlined in the Shell Exploration Oil Discharge Prevention and Contingency 

Plans for the Beaufort and Chukchi Seas. If changes occur regarding the above listed equipment 

in future seasons, notifications may be made accordingly. 

Regards, 

Susan M. Moore 

Alaska Operations Manager 

Shell Exploration and Production Company 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-4 March 2010 

95-2000.01-25.201/09-018 Rev. 0 

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Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-5 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-6 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-7 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-8 March 2010 

95-2000.01-25.201/09-018 Rev. 0 

THIS PAGE INTENTIONALLY LEFT BLANK 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

STATEMENT OF CONTRACTUAL TERMS 

OSRV 

Shell B-9 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

STATEMENT OF CONTRACTUAL TERMS 

OSRV 

Shell B-10 March 2010 

95-2000.01-25.201/09-018 Rev. 0 

 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

STATEMENT OF CONTRACTUAL TERMS 

OSRV 

Shell B-11 March 2010 

95-2000.01-25.201/09-018 Rev. 0 

Addendum #2 

To 

Vessel Request Order 

for 

NANUQ 

(Farm out of NANUQ up to 1 year) 

As per CONTRACTOR’s offer dated February 2, 2009 and SHELL’s acceptance dated February 

9, 2009, this ADDENDUM #2 TO VESSEL REQUEST ORDER FOR M/V NANUQ 

(“VESSEL”) is entered into this 25th day of March, 2009 by and between SHELL OFFSHORE, 

INC. (“SHELL”) and NAUTICAL VENTURES, L.L.C. (hereinafter referred to as 

“CONTRACTOR”), owner of the VESSEL. 

WITNESSETH:

 WHEREAS, SHELL and CONTRACTOR entered into a Vessel Request Order for the 

VESSEL on May 9, 2006 (hereinafter referred to as the “VRO”) for M/V NANUQ pursuant to 

the terms of that Master Marine Transportation Services Agreement entered into as of the 6th 

day of December, 1995 between SHELL and CONTRACTOR; 

WHEREAS SHELL and CONTRACTOR now wish to memorialize the agreement dated 

February 9, 2009 to farm out the VESSEL, until VESSEL is no longer needed for the farm out or 

March 1, 2010, in writing; 

THE PARTIES HEREBY AGREE AS FOLLOWS:

Both parties agree, effective March 16, 2009 at midnight, SHELL will be relieved of the time 

charter of the VESSEL until the VESSEL is returned to SHELL. No later than March 1, 2010, 

or sooner than November 1, 2009, the VESSEL will be returned to SHELL under the existing 

contract to serve out the remainder of the time charter (which expires on June 3, 2010). 

CONTRACTOR shall provide SHELL with two weeks notice prior to returning the VESSEL to 

SHELL to serve out the remainder of the time charter. VESSEL redelivery to SHELL will be 

Port Fourchon, LA. 

Section A & B following is a breakdown of the payment term from SHELL to CONTRACTOR 

in consideration of the charter relief. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-12 March 2010 

95-2000.01-25.201/09-018 Rev. 0 

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Appendix B – Contractual Terms with Primary Responders 

STATEMENT OF CONTRACTUAL TERMS 

OSRB 

Shell B-13 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

STATEMENT OF CONTRACTUAL TERMS 

OSRB 

Shell B-14 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

STATEMENT OF CONTRACTUAL TERMS 

OSRB 

Shell B-15 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-16 March 2010 

95-2000.01-25.201/09-018 Rev. 0 

THIS PAGE INTENTIONALLY LEFT BLANK
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

STATEMENT OF CONTRACTUAL TERMS 

CROWLEY POINT OLIKTOK TUG 

Shell B-17 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

STATEMENT OF CONTRACTUAL TERMS 

CROWLEY POINT OLIKTOK TUG 

Shell B-18 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

STATEMENT OF CONTRACTUAL TERMS 

CROWLEY POINT OLIKTOK TUG 

Shell B-19 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-20 March 2010 

95-2000.01-25.201/09-018 Rev. 0 

THIS PAGE INTENTIONALLY LEFT BLANK 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

STATEMENT OF CONTRACTUAL TERMS 

ARCTIC TANKER (AFFINITY-PERSEVERENCE) OR SIMILAR 

Shell B-21 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

STATEMENT OF CONTRACTUAL TERMS 

ARCTIC TANKER (AFFINITY-PERSEVERENCE) OR SIMILAR 

Shell B-22 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

STATEMENT OF CONTRACTUAL TERMS 

ARCTIC TANKER (AFFINITY-PERSEVERENCE) OR SIMILAR 

Shell B-23 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-24 March 2010 

95-2000.01-25.201/09-018 Rev. 0 

THIS PAGE INTENTIONALLY LEFT BLANK
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-25 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix B – Contractual Terms with Primary Responders 

Shell B-26 March 2010 

95-2000.01-25.201/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-i March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

APPENDIX C 

FUEL TRANSFER PROCEDURES 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-ii March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

THIS PAGE INTENTIONALLY LEFT BLANK 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-1 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

1. Frontier Discoverer Fuel Transfer Procedures

2. Oil Spill Response Vessel and Barge Fuel Transfer Procedures 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-2 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

THIS PAGE INTENTIONALLY LEFT BLANK 
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Appendix C – Fuel Transfer Procedures 

Shell C-3 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

1. Frontier Discoverer Fuel Transfer Procedures 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-4 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

THIS PAGE INTENTIONALLY LEFT BLANK 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-5 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

Fuel Transfer Procedures: Frontier Discoverer

Prior to taking part in any bunker transfer operations, the Chief Engineer shall ensure that any 

assistants are fully conversant with the system and understand the implications of the MARPOL 

regulations. 

All persons involved in bunker fuel transfer shall read and understand the posted bunkering 

procedures. 

Prior to working material fuels, crew members are advised to consult the relevant Material 

Safety Data Sheet (MSDS) in order to familiarize themselves with the potential health risks 

caused by “inhalation,” “skin contact,” and “ingestion”. 

A list of all persons involved in the bunker operation shall be posted in a prominent position. 

The Chief Engineer will coordinate with the Chief Officer regarding the possible transfer of 

ballast to ensure the ship remains in a proper list and trim. 

The Chief Engineer will conduct a pre transfer conference with the bunker suppliers, or with the 

appropriate ship staff for an internal transfer. Ensure sequence of loading/transfer is verified. 

The Chief Engineer will check the requirements are carried out, and sign the pre-transfer 

shore/ship, ship/ship, and bunker checklist forms as appropriate. 

Bunker Fuel Transfer Procedure: 

1. Suspend all hot work permits. 

2. Terminate all internal transfers if in progress. 

3. Ensure all fuel storage tank valves are closed. 

4. Take a full set of soundings. 

5. Clean the inlet strainer and zero the meter count. 

6. Liaise with Bridge to confirm which tanks are being filled. 

7. Confirm that the bunker connection save-all is drained. 

8. Ensure deck scuppers are plugged. 

9. Check spill kit is on location and complete. 

10. Where appropriate, ensure red light and bunker flag are deployed. 

11. Bunkering stations to be manned continually during the entire operation. 

12. Check hose and bunker line is clear. Make the connection and secure the hose. 

13. Establish communication between E.C.R. Bridge and bunker station and fueling vessel. 

14. Confirm the pumping rate and quantity to be pumped with fueling vessel. 

15. Bridge to make P.A. announcement regarding the start of fueling operations. 

16. Ensure any heading or position changes are communicated to the fueling vessel. 

17. Open the bunker station valves and tank valves. 

18. Start the operation. 

19. 10 minutes after starting, collect a sample. (Check the sample with the senior watchkeeper. 

If okay, continue bunkering operations) 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-6 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

20. Collect a sample in the middle of the operation. (Check sample with senior watchkeeper. If 

okay, continue bunkering operation) 

21. Take manual soundings throughout the operation. 

22. Always aim to finish on a non-full tank. 

23. At completion close tank and bunker station valves. 

24. Before disconnecting hose, confirm quantity received. 

25. Secure bunker hose so that end is over save-all. 

26. Inform Bridge of terminating operations. Hot work permits may be resumed. 

27. Bridge to make P.A. announcement regarding termination of fueling operations. 

28. Ensure oil record book is completed with correct information. Also make entries in engine 

room and deck logs.
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-7 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

2. Oil Spill Response Vessel and Barge Fuel Transfer Procedures 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-8 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

THIS PAGE INTENTIONALLY LEFT BLANK 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-9 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

OSRV Fuel Transfer Procedure 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-10 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-11 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-12 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-13 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-14 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-15 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-16 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-17 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-18 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-19 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix C – Fuel Transfer Procedures 

Shell C-20 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix D – Oil and Debris Disposal Procedures 

Shell D-i March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

APPENDIX D 

OIL AND DEBRIS DISPOSAL PROCEDURES 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix D – Oil and Debris Disposal Procedures 

Shell D-ii March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

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Appendix D – Oil and Debris Disposal Procedures 

Shell D-1 March 2010 

95-2000.01-25.201-001/09-018 Rev. 0 

INTRODUCTION 

The collection, storage, transportation, treatment, and disposal of waste will be conducted in a manner 

that is both safe and environmentally sound. Procedures are in place to insure that all laws and 

regulations are followed and that necessary permits are obtained in conjunction with waste management. 

Wastes generated from an oil spill response will be handled in accordance with federal and state 

hazardous waste regulations and company policy. Most of the waste collected during response 

operations will be classified as exploration and production exempt waste. 

However, crude oil contains benzene, which can be considered hazardous waste under the Resource 

Conservation and Recovery Act (RCRA) toxicity characteristic rule. The hazardous waste characteristics 

include ignitability, reactivity, corrosivity and toxicity. Oily waste will be tested before a disposal option is 

selected. Benzene will normally volatilize rapidly from a spill. If oily waste is determined to be hazardous 

under RCRA, it will be labeled accordingly and sent to a permitted facility for disposal. 

In the event of a spill, a site-specific waste management plan will be developed to address the equipment, 

staffing, and other support necessary to address waste management issues under the known conditions 

of the spill. The template for the Shell Waste Management Plan (which will be attached to the Incident 

Action Plan) is provided in Figure D-1. If an oil spill occurs during Shell’s Chukchi Sea exploration 

operations, wastes may be generated offshore, near shore, and onshore. 

WASTE CATEGORIES 

Oil spills can result in several different types of generated wastes including those listed below. This waste 

may include oiled personal protective equipment (PPE), possible shoreline debris, and oily sorbents. 

 Oily Liquid Wastes 

o Recovered or skimmed mixtures 

o Used engine oils, hydraulic fluids 

o Fuels contaminated with water and solids 

o Engine room bilge/ballast waters from vessels 

o Wash waters from cleaning boats, equipment, and gear 

o Other oily waters 

 Non-Oily Liquid Wastes 

o Sewage, liquid human waste (gray and black waters) 

 Oily Solid Wastes 

o Sand, gravel, tar balls 

o Asphalt patches 

o Sludge 

o Sorbent pads/boom/wood 

o Shoreline vegetation 

o Oily personnel gear and clothing 

o Damaged response equipment and gear 

o Empty drums and containers 

 Non-Oily Solid Wastes 

o Domestic trash and garbage 

o Bagged human waste 

o Discarded equipment and construction materials 

Wildlife carcasses and contaminated fish may be retained by trustee agencies. Once they are released or 

determined to be solid wastes, tier disposal will comply with applicable regulations. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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COLLECTION AND SEGREGATION OF RECOVERED OIL 

 Oil and emulsion from offshore oil recovery will be transferred from skimmer vessels with 

storage tanks or barges to the Arctic tanker for storage and ultimate disposal. 

 Oil and emulsion from nearshore oil recovery will be collected with shallow draft vessels 

and/or mini-barges. Mini-barge would be used for temporary storage of oily liquid wastes. 

 Oil and emulsion from shoreline oil recovery will be collected with skimmer systems and 

pumped off into holding tanks. Each tank’s oil and free-water volumes will be gauged and 

logged, and then pumped to mini-barges or other storage containers. Solid waste and debris 

will be removed and brought to a segregated interim storage area. 

OIL AND DEBRIS SEPARATION AND DISPOSAL 

Oil spill cleanup offshore using mechanical recovery will involve the further handling of recovered 

oil and oiled materials. These should be transported from offshore to the staging area for proper 

handling or from onshore directly to the appropriate reclamation/disposal site. 

Figure D-2 depicts separation methods for recovered oil/water/debris. The figure also depicts 

methods that may be employed to separate free and/or emulsified water from the oily liquid 

waste. 

TEMPORARY STORAGE OF RECOVERED OIL AND WASTE 

Figure D-3 depicts the temporary storage methods for recovered oil/water/debris for onshore or 

offshore operations. 

 Oil recovered at sea via skimmer(s) is transferred to portable tanks onboard recovery vessels 

or barges. 

 The skimmer tanks allow for gravity separation of the oil from the water. The separated water 

is transferred through a hose and discharged forward of the recovery pump. This method is 

called “decanting.” This process is vital to the efficient mechanical recovery of spilled oil 

because it allows maximum use of limited storage capacity, thereby increasing recovery 

operations. Approval must be obtained from the USCG and respective state agencies by the 

Incident Management Team Liaison Officer prior to decanting. 

 Recovered fluids stored onboard the Arctic tanker will be disposed of at a Shell Group 

refinery or a third-party processor. 

 Oiled debris collected at sea requires specific handling. Contaminated materials should be 

placed in leak proof, sealable containers on the recovery vessels and transported to 

appropriate facilities for processing, recycling, or disposal. 

 Oil recovered from onshore areas will typically contain substantial quantities of water and 

debris. Excess water, sand, and other beach materials greatly increase the quantity of waste 

and its associated cost for transportation, processing, and disposal. To remedy this, different 

methods can be employed at the cleanup site to separate oiled debris from excess materials 

that may be returned to the shoreline. Using screens, filters, conveyor systems and settling 

tanks, oil/water mixtures can be drained from debris and collected in temporary containers for 

further treatment. 

 Clean sand and beach materials can be separated from oiled materials. 

 Oil spills would occur in remote sites that are some distance from transportation routes and 

storage facilities. In these situations, temporary on-scene storage arrangements may be 

required. Oil may be stored in tanks, 55-gallon drums, bladders, or empty fuel storage tanks. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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Such tanks permit decanting of water from the oil. Pits should be lined with plastic sheeting to 

prevent oil leakage and soil penetration. 

 Contaminated gravel from cleanup operations would be temporarily stored on site and later 

transported by vessel or air off site to a designated waste treatment or disposal facility. 

DISPOSAL REGULATIONS 

 Oiled Materials – If these materials have not contacted extraneous substances, they will be 

disposed of at a Shell-approved disposal site. 

 Oil and oily wastes that are contaminated or excessively weathered will require transport to 

an approved disposal site. Any transport or disposal of material that is considered hazardous 

waste must follow the requirements of the RCRA. 

 Regulatory Guidelines 

o All wastes scheduled for disposal at a Prudhoe Bay oilfield facility, with prior written 

approval from the facility owner, will be handled in accordance with the requirements 

of the U.S. Environmental Protection Agency (EPA), Alaska Department of 

Environmental Conservation (ADEC), and Alaska Oil and Gas Conservation 

Commission (AOGCC) regulations and policy guidelines. These regulations and 

guidelines have been synthesized into an operational document titled, “Alaska 

Waste Disposal and Reuse Guide” (red book) prepared by BP Exploration (Alaska) 

Inc. and ConocoPhillips Alaska, Inc. (CPAI) to ensure consistency in waste handling 

practices on the North Slope. This includes directions for using the North Slope 

manifest, and other requirements for third-party contractors using BP or CPAI 

facilities. 

o Only state-licensed hazardous material haulers are used to transport recovered oil. 

These licensed waste haulers must have an EPA ID number and a state transporter 

ID number. 

o When completing the manifest, Shell Exploration and Production is listed in the 

manifest as the generator. The manifest should be signed by the designated Shell 

representative, and marked with the statement: “This material is being disposed of 

by Shell as part of a response action in accordance with the National Oil and 

Hazardous Substances Pollution Contingency Plan (40 CFR 300).” 

o Recovered waste oil must be properly packaged and labeled prior to transport in 

accordance with 40 CFR 262.30. 

o All wastes shipped off site for disposal must be transported in compliance with 

applicable regulations. These include the RCRA regulations in 40 CFR 262 and 263, 

the U.S. Department of Transportation (DOT) Hazardous Materials Regulations in 

49 CFR 171 through 178, and applicable ADEC regulations. Ensure shipments of 

waste collected during spill cleanup activities are transported in appropriate 

containers to eliminate secondary releases during transport. If the nature of the 

waste precludes packaging in the required container, the Incident Commander 

should request emergency exemptions from the regulations following procedures 

outlined in 49 CFR 107. 

o Waste haulers will use only state-certified disposal sites. 
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o Unit personnel must track the Hazardous Waste Manifest and retain the appropriate 

records per 40 CFR 262.40. Unit personnel should receive a signed copy of the 

manifest from a designated disposal facility within the specified time limits. 

DISPOSAL TRANSPORTATION AND DESIGNATED SITES 

 Transportation of oil and oily waste at sea may be accomplished via barge, OSRV, or tanker. 

 Transportation of oil or oily waste from shoreline locations will be by shallow-draft vessel, 

towed bladders, or air (helicopter sling-loads of small containers, if approved), 

 Oil or oily debris recovered from a spill site may only be disposed of at authorized sites (List 

is maintained by Shell Health, Safety and Environment). 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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Shell D-5 March 2010 

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FIGURE D-1 

WASTE MANAGEMENT PLAN 

Always work safely in an environmentally sound manner. Minimize waste. Consider waste management 

and generation in all actions. Never mix waste; always segregate. Report any accident or incident to 

your supervisor immediately. Reference the Waste Management Plan for the specific process required 

for each waste type. 

 

A. INTRODUCTION 

 Incident Name: 

 Date of Incident: 

 Time of Incident: 

 Individual in Charge of Site: 

 

B. SITE DESCRIPTION 

 Location of Site: 

 

Description of Site Including 

Surrounding Area (e.g., 

beach, marsh) - attach map: 

 

Access/Limitations (e.g., 

highway/bridge limitations, 

boat/shallow water) - attach 

map: 

 

Any Additional Information / 

Considerations: 

 

 Present Weather Conditions: 

 

 

 12-hour Forecast: 

 

 

 24-hour Forecast: 

 

 

C. SITE-SPECIFIC SAFETY PLAN

This plan must be completed and attached before starting any physical work. One plan must be 

completed for each waste handling/storage area. 
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FIGURE D-1 

WASTE MANAGEMENT PLAN 

 

D. TYPE OF WASTE GENERATED FROM RESPONSE OPERATIONS 

Wastes generated by oil spill cleanup fall into several different types. Use the following to identify 

your wastes. Remember - never mix wastes! 

 

Waste Stream Sources 

 

Non-Hazardous

- Oily Liquid Offshore and onshore recovery operations; vessels, vehicle, aircraft and 

equipment operations; personnel and equipment decontamination 

operations; waste storage and disposal area storm water runoff control 

operations; wildlife washing operations; equipment demobilization 

operations. 

- Non-Oily Liquid Sewage collection operations; gray water collection operations; laundry 

operations; oil/water separation operations; wildlife rehabilitation 

operations. 

- Oil Solids Offshore and onshore recovery operations; debris removal operations; in 

situ burning operations; site restoration operations; personnel and 

equipment decontamination operations; equipment demobilization 

operations; wildlife capture, cleaning and rehabilitation operations. 

- Non-Oily Solids Offshore and onshore recovery operations; debris removal operations; 

garbage collection operations; construction operations; site restoration 

operations; wildlife capture, cleaning and rehabilitation operations; 

equipment demobilization operations. 

Hazardous

Vessels, vehicle, aircraft and equipment operations; dispersant use operations; wildlife 

rehabilitation operations. 
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FIGURE D-1 

WASTE MANAGEMENT PLAN 

E. CONTAINERIZED AND STORED WASTE 

Waste accumulated at spill cleanup sites will have to be containerized and stored. Use F through 

K of possible waste streams to identify temporary storage techniques. Note that each waste 

stream will have to be classified as to its hazardous nature. Additionally, each container will have 

to be properly identified and marked for hazard communications as well as properly marked and 

labeled to meet DOT requirements before shipment. All hazardous waste must be transported 

immediately to the nearest shore base for continued storage. 

 

F. TEMPORARY WASTE SITES will have to be identified and established. These sites will need to 

be in close proximity to the cleanup site. Security requirements must be considered along with the 

access to outside transportation. These storage areas should be established with the following 

considerations: distance to living/working areas (cleanup operations as well as the general public), 

tidal influx, local wildlife impact, security, cleanup of spilled product and rainwater runoff. The 

following section should be completed for each temporary storage site. To establish security, 

contact the Logistics Section Chief.

Site Location Security Access 

 

 

 

 

 

 

G. COMPANY-APPROVED TREATMENT, RECYCLING AND DISPOSAL FACILITIES are listed 

below. Prior contact must be made with the facility as soon as the waste is identified and an 

estimated volume is established. 

Company Name, 

Address, Telephone Number 

Contact 

(Complete When Called) 

Type Waste 

Approved For 

 

 

 

 

 

 
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FIGURE D-1 

WASTE MANAGEMENT PLAN 

H. COMPANY-APPROVED WASTE TRANSPORTERS shall be used to haul all waste. The following 

is a list of transporters presently used to transport wastes. The shipper must ensure that all DOT 

requirements are met. Additionally, all waste must be accompanied by a properly completed 

manifest or shipping paper. All containers must be secure and strong. All dump trucks or roll-off 

bins should be lined to prevent spillage or contamination of other areas.

Company Name, 

Address,Telephone Number 

Contact 

(Complete When Called) 

Type Waste 

Approved For 

 

 

 

 

 

I. WASTE MATERIAL MUST BE CONTROLLED WHEN ENTERING AND LEAVING the storage 

area. The following can be used to accomplish this task. 

Waste 

Type 

Type / # 

Containers 

Control 

Number 

Date 

IN 

Date 

OUT Transporter Disposer 

Type / 

Manifest 

# 

 

 

J. If ADDITIONAL HELP OR ASSISTANCE is required, immediately contact your on-scene safety or 

environmental representative or contact the Operations Section Chief or the Safety Officer. 

 
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FIGURE D-1 

WASTE MANAGEMENT PLAN 

K. EQUIPMENT, MANPOWER AND EXPENDITURES must be controlled and documented. The 

following can be used for this purpose. If additional assistance is required for cost control, contact 

the Finance Section Chief. If additional assistance is required for purchasing or locating equipment 

or supplies, contact the Logistics Section Chief. 

EQUIPMENT 

Waste Handling 

Equipment Vendor S.O. # Days Used Cost Per Day Total Cost 

 

 

 

 

 

 

MANPOWER 

Waste Handling 

Equipment Vendor S.O. # Days Used Cost Per Day Total Cost 

 

 

 

 

 

OTHER COSTS (Fuel, Tools, Repair, Container Rental/Purchase, Other Equipment) 

Waste Handling 

Equipment Vendor S.O. # Days Used Cost Per Day Total Cost 

 

 

 

 

 

TOTAL COST = 

L. WASTE MANAGEMENT SITES are identified in this Section. 

 

M. Report all ACCIDENTS/INCIDENTS immediately to your supervisor. Always work safely and in an 

environmentally sound manner. 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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Shell D-10 March 2010 

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FIGURE D-2 

Oil/ Water/ Debris Separation Strategies 

The different types of wastes generated during response operations require different disposal methods. 

Waste shall be separated by material type for temporary storage prior to transport. The following table 

lists some of the options available for separating oily wastes into liquid and solid components. The table 

also depicts methods that may be employed to separate free and/or emulsified water from the oily liquid 

waste. 

TYPE OF MATERIAL SEPARATION METHODS 

(1) LIQUIDS 

Non-emulsified oils Gravity separation of free water 

Emulsified oils Emulsion broken to release water by: 

 Heat treatment 

 Emulsion breaking chemicals 

 Centrifuge 

 Filter/belt press 

(2) SOLIDS 

Oil mixed with sand  Collection of liquid oil leaching from sand during temporary 

storage 

 Extraction of oil from sand by washing with water or solvent 

 Mechanical sand cleaner 

 Removal of solid oils by sieving 

Oil mixed with cobbles, 

pebbles or shingle 

 Screening 

 Collection of liquid oil leaching from beach material during 

temporary storage 

 Mechanical sand/gravel cleaner 

 Extraction of oil from beach material by washing with water or 

solvent 

Oil mixed with wood, plastics, 

seaweed and sorbents 

 Screening 

 Collection of liquid oil leaching from debris during temporary 

storage 

 Flushing of oil from debris with water 

Tar balls Separation from sand by sieving 
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FIGURE D-3 

TEMPORARY STORAGE METHODS 

Container Onshore Offshore Solids Liquids Notes 

Barrels     May require handling devices. 

Barges    Liquids only in tanks. Consider 

venting of tanks. 

Oil Storage 

Tanks    Consider problems of large volumes of water in oil. 

Bladders    May require special hoses or pumps 

for oil transfer. 

Pits    Liner(s) required. 

Roll-off Bins   Require impermeable liner and cover. 

Mud Tanks     500 – 21,000 gal 

Frac Tanks     Portable, can be deployed anywhere. 
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APPENDIX E 

WILDLIFE CAPTURE, TREATMENT, AND RELEASE PROGRAMS 

CHUKCHI SEA OIL SPILL RESPONSE PLANNING 
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Insert logo here 

Wildlife Capture, Treatment, and 

Release Programs 

Chukchi Sea Oil Spill Response Planning 

September 2008 

Shell Gulf of Mexico Inc. 

3601 C Street, Suite 1334 

Anchorage, Alaska 99503 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix E – Wildlife Capture, Treatment and Release Programs 

Chukchi Sea Oil Spill Response Planning 

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1.0 EXECUTIVE SUMMARY 

Secondary and tertiary responses: 

 Develop a wildlife assessment (describing affected species and concentrations relative 

to spill), 

 Prepare a plan of operations for protection, hazing, capture, or treatment, 

 Complete state and federal permit applications, and 

 Mobilize qualified wildlife response contractors. 

Resources to develop agency-acceptable wildlife response plans, listed in order of preference 

(Specific contractors are identified in Table 1): 

 Local residents possessing local knowledge and Traditional Knowledge 

o Whaling Captains and crews 

o Alaska Eskimo Whaling Commission (AEWC) 

o Village Elders and Leaders 

o Marine Mammal Observers (MMO) 

o Subsistence Advisors 

 Trained biologists with permit experience 

o ASRC Energy Services, Regulatory and Technical Services (AES-RTS) 

personnel 

o Other subcontractor support (ABR, LGL) 

 Alaska Clean Seas (ACS) 

o ACS Permits for Birds and Terrestrial Mammals (Tactic W-1) 

o Master Service Agreement with International Bird Rescue and Rehabilitation 

Center (IBRRC) 

o ACS Mobile Wildlife Stabilization Center 

 Wildlife Response Contractors 

o IBRRC and network of subcontractors 

o Medical support personnel 

 Agency Personnel 

o North Slope Borough, Department of Wildlife Management 

o Alaska Department of Fish and Game (ADF&G) 

o U.S. Fish and Wildlife Service (USFWS) 

o U.S. National Marine Fisheries Service (NMFS) 
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Shell E-4 March 2010 

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Table 1 

Wildlife Response Contractors 

Species 

Potential Contractors Wildlife Response Contractors 

Observe 

and/or 

Identify 

Develop 

Wildlife 

Assessment Haze 

Collect 

and Hold Treat 

Carcass 

Collection4 

Migratory Birds 

AES-RTS1 

ABR6 , LGL6 

AES-RTS1 

ABR6 , LGL6

ACS4

AES-RTS1

IBRRC 

IBRRC2,3,4 IBRRC2 AES-RTS 

ACS 

Walrus and Polar 

Bears AES-RTS1 AES-RTS1 ACS4 

AES-RTS1 

IBRRC

IBRRC2,3,4 IBRRC5 AES-RTS 

ACS 

Whales, Porpoises, 

Seals and Sea Lions AES-RTS1

 AES-RTS1 ACS4 

AES-RTS1 

IBRRC 

IBRRC2,3,4 IBRRC5 AES-RTS 

ACS 

Terrestrial Mammals 

 AES-RTS1 

ABR6 , LGL6

 AES-RTS1 

ABR6 , LGL6

ACS4 

AES-RTS1 

IBRRC 

IBRRC2,3,4 IBRRC5 AES-RTS 

ACS 

Endangered 

Species* 

AES-RTS1 

ABR6 , LGL6

 AES-RTS1 

ABR6 , LGL6

ACS4 

AES-RTS1 

IBRRC 

IBRRC2,3,4 IBRRC 

AES-RTS 

ACS 

Notes: 

1. The capability is available through AES-RTS; however, it requires enhancement to be response-ready. AES-RTS 

would contract for local hire directly or through other North Slope-based corporations. 

2. IBRRC is available through the ACS Master Services Agreement. 

3. IBRRC would likely contract or subcontract local experts or residents. 

4. Village Response Teams are available through ACS Master Service Agreements to fill these roles. 

5. This response action is likely restricted to young animals. 

6. The capability of this contractor to perform these duties is assumed through other experience, not necessarily oil 

spill response. 

*Endangered and threatened species are listed in Appendices 2 through 4 of the Alaska Regional Response Team 

(ARRT) Wildlife Protection Guidelines. Check at the time of the spill for current listing. 

ACS = Alaska Clean Seas 

AES-RTS = ASRC Energy Services – Regulatory and Technical Services 

ABR = ABR Inc. Environmental Research & Services 

IBRRC = International Bird Rescue and Rehabilitation Center 

LGL = LGL Limited 
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2.0 BACKGROUND INFORMATION 

Marine mammal spill response options in the Arctic Ocean remain limited due to federal 

prohibitions and the practicality of capturing large animals for treatment. The Exxon Valdez 

incident provided the impetus for the development of a successful bird and sea otter capture 

and treatment program in Alaska. Regulatory agencies have promoted a strong bird capture 

and treatment capability for North Slope operators. 

MMS lease stipulations require that leases holders provide for a conflict avoidance mechanism 

to protect subsistence Whaling and Other Marine mammal subsistence-harvesting activities. In 

2006 and 2007, Shell has chosen to pursue and enter into Conflict Avoidance Agreements 

(CAAs) with the AEWC before exploring for oil offshore to meet this requirement. The use of 

MMOs during the seismic surveying and drilling phases of an operation to address subsistence 

and whale harvest protection mitigation measures. 

In recent years the focus has been to incorporate wildlife protection measures into facility 

design, implement wildlife monitoring and conflict avoidance programs, and develop response 

plans to contain and control oil spills at the source, thereby preventing the spread of oil and 

direct impacts to habitats and wildlife. 

Response options such as hazing are available and can be effective for birds and certain 

terrestrial mammals. However, hazing large marine mammals is difficult and success has been 

mixed. Depending upon the species, wildlife conditioned to human activity may not respond to 

hazing and the risk of oiling may be a lesser concern than the consequences of hazing, such as 

when seals abandon their pups. Because of these considerations, capture, treatment, and 

rehabilitation need to be credible and sensitive to local concerns and knowledge. 

Facilities exist in Alaska to capture and stabilize oiled birds and marine mammals. On the 

North Slope, ACS maintains a Mobile Wildlife Stabilization Center and maintains a service 

agreement with the IBRRC. 

3.0 PERMITS AND INFORMATION REQUIREMENTS 

The required permits are based on the jurisdiction and resource protection interests of each 

agency. See the attachment for a brief description of these responsibilities and interests. Each 

permit can be applied for during the response to the Unified Command, using the checklists and 

permit applications provided in Annex G of the North Slope Subarea Contingency Plan (Unified 

Plan). 

The permit applications were developed by the ARRT for use by responsible parties during a 

spill event, if needed. The ARRT serves as a regional body for federal and state agencies to 

coordinate planning and preparedness activities in support of response operations for pollution 

incidents. For a detailed description of wildlife response planning requirements and options in 

Alaska, refer to “Annex G – Wildlife Protection Guidelines” of the Unified Plan for the State of 

Alaska, located at the ARRT Web site: http://www.akrrt.org/UnifiedPlan/index.shtml. 

The Unified Command requires the following types of information to process the request: 

 potentially affected species, 

 estimated distribution, 
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 habitat types, 

 spill trajectory, and 

 hazing or treatment options. 

Qualified individuals to generate a “Wildlife Assessment” can be provided by the Responsible 

Party (RP) and/or agency personnel, at the discretion of the Federal On-Scene Coordinator. 

The Wildlife Assessment is best performed by biological specialists and incorporate local 

knowledge and Traditional Knowledge of the affected species. Federal agencies actively 

promote the involvement of local knowledge and Traditional Knowledge to determine 

alternatives for wildlife rescue and protection. 

The following table is from the ACS Technical Manual, Tactic W-1 and summarizes permits 

required for hazing, capture, and holding of live animals. 

Table 2 

State and Federal Permits and/or Authorizations Required for Hazing, Collecting, or Holding Live 

Animals 

Species 

Alaska Department of 

Fish and Game 

U.S. Fish and Wildlife 

Service 

National Marine 

Fisheries Service 

Collect 

and Hold Haze 

Collect 

and Hold Haze 

Collect 

and Hold Haze 

Migratory Birds No Yes Yes No No No 

Sea Otters, Walrus 

and Polar Bears No No Yes Yes No No 

Whales, Porpoises, 

Seals and Sea Lions No No No No Yes Yes 

Terrestrial Mammals Yes Yes No No No No 

Endangered 

Species* Yes Yes Yes Yes No No 

Source: Appendix 16 of the ARRT Wildlife Protection Guidelines, Unified Plan 

*Endangered and threatened species are listed in Appendices 2 through 4 of the ARRT Wildlife Protection Guidelines. 

Check at the time of the spill for current listing. 

 
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4.0 ARCTIC OCEAN CONSIDERATIONS 

Species identification is crucial to developing the wildlife assessment and response plans. The 

species of birds and mammals discussed below are those likely to be encountered in the Arctic 

operating area. 

4.1 MIGRATORY BIRDS 

The major group to which each species belongs is indicated as follows: waterfowl (WF), seabird 

(SE), and other diving bird (DB), shorebird (SH), raptor (RA), and upland bird (UB). Also 

indicated are endangered species (ES), threatened species (TS), and those of special 

management concern (SMC) to the ADF&G. Species of SMC are generally defined as species 

established as a priority for study and management by public agencies to prevent their 

populations from declining to a level warranting a listing action under the Endangered Species 

Act. 

Table 3 

Migratory Birds 

Species of Interest Population Density 

Code Species of Interest Population Density Code 

Loons (DB) P/S Scoter (WF) U/S 

Grebes (DB) A Mallard (WF) R/S 

Tundra Swans (WF) P/S Bald Eagles (RA) A 

Greater White-fronted Goose (WF) P/S Osprey (RA)(SMC) A 

Snow Goose (WF) P/S Arctic Peregrine Falcon (RA) P 

Emperor Goose (WF) R/S Snowy Owl (RA) U/S 

Black Brant (WF) P/S Sandhill Crane (SH) U/S 

Canada Geese (WF) P/S Wandering Tattler (SH) A 

Oldsquaw (WF) P/S Bristle-thighed Curlew (SH)(SMC) R 

Greater Scaup (WF) U/S American Golden Plover (SH) P 

Red-breasted Merganser (WF) R/S Semipalmated Plover (SH) U 

Northern Pintail (WF) P/S Aleutian Tern (SE) A 

Bufflehead (WF) A Arctic Tern (SE) U 

Goldeneye (WF) A Gulls (SE) P/S 

Canvasback (WF) A Murres (SE) P/S 

Northern Shoveler (WF) R Guillemots (SE) U 

Spectacled Eider (WF)(TS) U/S Murrelets (SE) R 

Steller's Eider (WF)(TS) U/S Kittlitz's Murrelet (SE)(SMC) R 

King Eider (WF) P/S Puffins (SE) R 

Common Eider (WF) P/S Northern Fulmar (SE) R 

Harlequin Duck (WF) (SMC) R Black-legged Kittiwake (SE) P 

American Widgeon (WF) U/S Cormorants (SE) R 

Green-winged Teal (WF) U/S Ptarmigan (UB) P/S 

P = Present U = Uncommon R = Rare A = Casual/Accidental O = Pelagic (well offshore) S = Subsistence Species 
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4.2 MARINE MAMMALS 

Table 4 lists mammal species of concern in offshore Arctic operating area. Agency jurisdiction 

for specific mammal is indicated by USFWS or NMFS in parentheses. 

Table 4 

Marine Mammals 

Species of Interest Population Density Code Species of Interest Population Density Code 

Polar Bear (FWS) P/S Beluga Whale (NMFS)(SMC) P/S 

Ringed Seal (NMFS) P/S Brown Bear P/S/SMC 

Spotted Seal (NMFS) P/S Black Bear P/S 

Bearded Seal (NMFS) P/S Caribou/Reindeer P/S 

Pacific Walrus (FWS) P/S Moose P/S 

Ribbon Seal (NMFS) P(pack ice)/S Muskoxen P/S/SMC 

Bowhead Whale (NMFS)(ES) P/S Dall Sheep P/S 

Gray Whale (NMFS) P Wolf P/S 

Minke Whale (NMFS) U Arctic Fox P/S 

Aquatic Furbearers P/S Red Fox P/S 

Harbor Porpoise (NMFS) P/S Killer Whale (NMFS) P 

P = Present U = Uncommon R = Rare O = Pelagic (well offshore) S = Subsistence Species TS = Threatened Species 

ES = Endangered Species SMC = Special Management Concern 
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ATTACHMENT 1 

AGENCY JURISDICTION/RESPONSIBILITIES 

Under federal statutes, the National Marine Fisheries Service (NMFS), as an agency of the U.S. 

Department of Commerce, National Oceanic and Atmospheric Administration, has responsibility 

for managing and protecting all cetaceans and pinnipeds, except walruses. The U.S. Fish and 

Wildlife Service (USFWS), as an agency of the U.S. Department of the Interior has responsibility 

for managing and protecting migratory birds, walruses, sea otters, and polar bears. 

FWS has joint statutory responsibility with Alaska Department of Fish and Game (ADF&G) for 

management of wildlife on all federal lands in Alaska (e.g., national park system units, national 

wildlife refuges, national forest system lands, military reservations). 

NMFS is responsible for the administration of the Endangered Species Act as it applies to 

certain cetaceans (whales and porpoises) and pinnipeds (e.g., seals, sea lions) in Alaska. 

These include most species of whales and the northern (Steller) sea lion. USFWS is responsible 

for the administration of the Endangered Species Act as it applies to remaining marine 

mammals and terrestrial mammal and bird species in Alaska. These species found in Alaska 

are as follows: 

 Beluga Whales 

 Bowhead Whales 

 Humpback Whales 

 Gray Whales 

 Killer Whales (Orcas) 

 Minke Whales 

 Northern Right Whales 

The Marine Mammal Protection Act (MMPA) of 1972 gave NMFS responsibility for the 

management and conservation of all but three species of marine mammals in Alaska. The 

USFWS, Region 7, Alaska, Marine Mammals Management Office is responsible for 

management of the three Alaska species: polar bears, sea otters, and Pacific walrus. 

The hyperlink connects to the following resources that are located in the Unified Plan, Annex G, 

Wildlife Protection Guidelines: 

 Wildlife Hazing, Capture and Treatment Facilities 

 Oil Spill Hazing and Treatment Application Forms 

Hyperlink: http://www.akrrt.org/UnifiedPlan/index.shtml
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APPENDIX F: 

PRODUCT SPECIFICATION FOR LOW SULFUR DIESEL FUEL OIL 
Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

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Appendix F – Product Specification for Low Sulfur Diesel Fuel Oil 

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Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program 

Appendix F – Product Specification for Low Sulfur Diesel Fuel Oil 

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