# CHUKCHI SEA REGIONAL EXPLORATION OIL DISCHARGE PREVENTION
AND CONTINGENCY PLAN

SHELL
ANCHORAGE, ALASKA

MARCH 2010Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Management Approval and Manpower Authorization

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### MANAGEMENT APPROVAL AND MANPOWER AUTHORIZATION

OIL DISCHARGE PREVENTION AND CONTINGENCY PLAN CHUKCHI SEA EXPLORATION NORTH SLOPE, ALASKA

This Oil Discharge Prevention and Contingency Plan (C -Plan) has been prepared for offshore exploration activities in the Chukchi Sea, Alaska, conduct ed by Shell Gulf of Mexico Inc. (Shell).

This plan is approved for implementation as herein described. Manpower, equipment, and materials necessary for oil discharge prevention and response will be provided as required in accordance with this plan.

Brent Ross Date Asset Manager, Alaska Operations Shell

Scott M. Ham Date C & JV Manager Shell

3601 C Street Suite 1000 Anchorage, Alaska 99503

(907) 770-3700 – telephone (907) 770-3636 – facsimileOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Management Approval and Manpower Authorization

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### RECORD OF REVISIONS

REVISION NUMBER REVISION DATE DATE ENTERED SUMMARY OF REVISION

1 May 2011 Update to the Worst Case Discharge (WCD) volume, corresponding Scenario and plan revisions.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Record of Revisions

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### OIL POLLUTION ACT OF 1990 (OPA 90)

U.S. MINERALS MANAGEMENT SERVICE BUREAU OF OCEAN ENERGY MANAGEMENT, REGULATION AND ENFORCEMENT

U.S. COAST GUARDOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Oil Pollution Act of 1990 – U.S. Bureau of Ocean Energy Management, Regulation and EnforcementBOEMRE/ Minerals Management Service/ U.S. Coast Guard

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### U.S. MINERALS MANAGEMENT SERVICEBUREAU OF OCEAN ENERGY MANAGEMENT, REGULATION AND ENFORCEMENTOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Oil Pollution Act of 1990 – U.S. Bureau of Ocean Energy Management, Regulation and EnforcementBOEMRE/ Minerals Management Service/ U.S. Coast Guard

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CROSS REFERENCE TO U.S. BUREAU OF OCEAN ENERGY MANAGEMENT, REGULATION AND ENFORCEMENT 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 Qualifie d 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 or ganizational 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 (inc luding 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 Envir onmental 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 Equipm ent 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 DOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Oil Pollution Act of 1990 – U.S. BOEMRE/ Minerals Management Service/ U.S. Coast Guard CHUKCHI SEA REGIONAL EXPLORATION OIL DISCHARGE PREVENTION AND CONTINGENCY PLAN

CROSS REFERENCE TO U.S. MINERALS MANAGEMENT SERVICEBOEMRE RESPONSE PLAN REQUIREMENTS [30 CFR 254, SUBPART B] (CONTINUED)

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REGULATION SECTION (30 CFR) SECTION TITLE PLAN SECTION

(g)(9) Methods to Implement Dispersant Use Plan and In situ Burning Plan Sections 1.7 and 3.7

254.24 Equipment Inventory Section 3.6 (a) Inventory of Spill Response Materials and Supplies, Services, Equipment, and Response Vessels Available Locally and Regional ly (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 Tr ansportation 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 3.7Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Oil Pollution Act of 1990 – U.S. BOEMRE/ Minerals Management Service/ U.S. Coast Guard CHUKCHI SEA REGIONAL EXPLORATION OIL DISCHARGE PREVENTION AND CONTINGENCY PLAN

CROSS REFERENCE TO U.S. MINERALS MANAGEMENT SERVICEBOEMRE RESPONSE PLAN REQUIREMENTS [30 CFR 254, SUBPART B] (CONTINUED)

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REGULATION SECTION (30 CFR) SECTION TITLE PLAN SECTION

(b) Summary of Toxicity Data Section 3.7 (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 Ma y be Requested Sections 1.7 and 3.7 (f) Outline of Procedures for Obtain ing 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 Deci sion 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 Notifica tion 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 3.9Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Oil Pollution Act of 1990 – U.S. BOEMRE/ Minerals Management Service/ U.S. Coast Guard

Shell MMSBOEMRE -4 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 The Worst Case Discharge (WCD) volume and storage capacities are calculated to address the Minerals Bureau of Ocean Energy Management , Regulation and Enforcement Service (MMS) (BOEMRE) requirements Notice to Lessees (NTL) No. 2010-N06 and Alaska Department of Environmental Conservation (ADEC) requirements

. BOEMRE references a 30 day timeframe [30 CFR 254.47(b)] and establishes guidelines for calcul ating the WCD volume (30 CFR 254.26). The WCD volume is presented for Shell’s Chukchi Sea Regional ODPCP as 25,000 barr els of oil per day (bopd) x 30 days to total 750,000 bbl. ADEC regulations (18 Alaska Administrative Co de [AAC] 75.434) establish the Response Planning Standard (RPS) for an exploration facility to be 5,500 ba rrels 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 bas ed 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.

U.S. BOEMRE WORST CASE DISCHARGE VOLUME

ELEMENT CAPACITY (BBL) REFERENCE

Sum of Capacity of Oil Storage Tanks 750,000319,646 Table 1.6-8

Estimated Daily Volume of Highest Capacity WellWCD 25,000 30 CFR 254.26

Estimated Daily Volume of Highest Capacity Well 5,500 18 AAC 75.434(b)

Total WCD (Daily Volume X 30-Days) 165,000 750,000 30 CFR 254.47(b)

Total Storage Capacity Requirements (165750,000 x 1.54) + (165750,000 x 20%) = 2871,30750,000,100 Part 5

ADEC regulations (18 Alaska Administrative Code [AAC] 75.434) establishes the Response Planning Standard (RPS) for an exploration facility to be 5,500 bopd, or best producing well data, for the duration of fifteen (15) days. For planning purposes, the ADEC RPS is presented using BOEMRE’s WCD volume, 25,000 bopd for fifteen (15) days totaling 375,000 bbl. Based upon ADEC guidance, the RPS storage capacity requirements consider the emulsification factor of 1.54 and free water additions for a total storage volume of 652,500 bbl.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Oil Pollution Act of 1990 – U.S. BOEMRE Minerals Management Service / U.S. Coast Guard

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### U.S. COAST GUARDOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Oil Pollution Act of 1990 – U.S. BOEMRE Minerals Management Service / U.S. Coast Guard

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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 (incl ude 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, loadi ng 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 au thorities 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 3.8Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Oil Pollution Act of 1990 – U.S. BOEMRE 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)

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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 alte rnate 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 pr obable 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 ListOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Oil Pollution Act of 1990 – U.S. BOEMRE/ Minerals Management Service/ U.S. Coast Guard

Shell USCG-3 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 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 Noble 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. BOEMRE/ Minerals Management Service/ U.S. Coast Guard

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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 ....................................................................... MMSBOEMRE -1 Worst Case Discharge Volume ............................................................................... MMSBOEMRE -4 U.S. Coast Guard .............................................................................................................. ... USCG-1 Potential Discharges .......................................................................................................... .. USCG-3

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

INTRODUCTION .................................................................................................................. ....................... I-1 Objectives .................................................................................................................... ................ I- 43 Alaska Clean Seas Technical Manual and Shell Beaufort and Chukchi Seas Regional Tactics Manual .............................................................................................................. I- 43 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)] ................................................ 1-2 21 1.6.1 Procedures to Stop Discharge [18 AAC 75.425(e)(1)(F)(i)] ............................ 1-2 21 1.6.2 Fire Prevention and Control [18 AAC 75.425(e)(1)(F)(ii)] ............................... 1-2 21 1.6.3 Blowout Control/Relief Well Plan .................................................................... 1-2 72 1.6.4 Discharge Tracking [18 AAC 75.425(e)(1)(F)(iv)] ........................................... 1-2 74 1.6.5 Protection of Sensitive Areas [18 AAC 75.425(e)(1)(F)(v)] .......................... 1- 3025 1.6.6 Containment and Control Strategies [18 AAC 75.425(e)(1)(F)(vi)] ............... 1- 3225 1.6.7 Recovery Strategies [18 AAC 75.425(e)(1)(F)(vii)] ....................................... 1- 3228 1.6.8 Lightering, Transfer, and Storage of Oil from Tanks [18 AAC 75.425(e)(1)(F)(viii)] ........................................................................ 1- 3230 1.6.9 Transfer and Storage Procedures [18 AAC 75.425(e)(1)(F)(ix)] .................. 1- 3230 1.6.10 Temporary Storage and Disposal [18 AAC 75.425(e)(1)(F)(x)] .................... 1- 3330 1.6.11 Wildlife Protection [18 AAC 75.425(e)(1)(F)(xi)] ........................................... 1- 3331 1.6.12 Shoreline Cleanup [18 AAC 75.425(e)(1)(F)(xii)] .......................................... 1- 3431 1.6.13 Spill Response Scenarios ............................................................................. 1- 4542 1.7 NON-MECHANICAL RESPONSE OPTIONS [18 AAC 75.425(e)(1)(G)] ................ 1- 11099 1.7.1 Obtaining Permits and Approvals ............................................................... 1- 11099 1.7.2 Decision Criteria for Use ............................................................................. 1- 11099 1.7.3 Implementation Procedures ...................................................................... 1- 111100 1.8 FACILITY DIAGRAMS [18 AAC 75.425(e)(1)(H)] .................................................. 1- 112101Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Table of Contents

Shell T-ii March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 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 .................................................................................................. 2-1 9 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- 57 3.3.1 Incident Management Team ............................................................................. 3- 68 3.3.2 Unified Command ............................................................................................. 3- 68 3.4 REALISTIC MAXIMUM RESPONSE OPERATING LIMITATIONS [18 AAC 75.425(e)(3)(D)] [30 CFR 254.26(D)] ............................................................ 3-1 35 3.4.1 Adverse Weather Conditions .......................................................................... 3-1 68 3.4.2 Sea States, Tides and Currents .................................................................... 3- 1820 3.4.3 Hours of Daylight and Visibility ..................................................................... 3- 2628 3.5 LOGISTICAL SUPPORT [18 AAC 75.425(e)(3)(E)] .................................................. 3- 2729 3.6 RESPONSE EQUIPMENT [18 AAC 75.425(e)(3)(F)] ................................................ 3- 2931 3.6.1 Equipment Lists............................................................................................. 3- 2931 3.6.2 Maintenance and Inspection of Response Equipment ................................. 3- 3032 3.7 NON-MECHANICAL RESPONSE INFORMATION [18 AAC 75.425(e)(3)(G)] ......... 3- 3032 3.7.1 Assessment of Environmental Consequences and Monitoring .................... 3- 3840 3.7.2 Non-mechanical Response Equipment ........................................................ 3- 39413.7.3 Identification of Necessary Approvals and Application for Nonmechanical Response Options. .................................................................... 3- 4042 3.7.4 Identification of Permits, Approvals or Authorizations .................................. 3- 4042Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Table of Contents

Shell T-iii March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 3.7.5 Plan for Protection Environmentally Sensitive Areas and Areas of Public Concern ......................................................................................................... 3- 4042 3.8 RESPONSE CONTRACTOR INFORMATION [18 AAC 75.425(e)(3)(H)] ................. 3- 4143 3.8.1 Statement of Contractual Terms ................................................................... 3- 4143 3.9 TRAINING PROGRAM [18 AAC 75.425(e)(3)(I)] ...................................................... 3- 4143 3.9.1 Incident Management Team Member Training ............................................. 3- 4244 3.9.2 Other Training ............................................................................................... 3- 4345 3.9.3 Record Keeping ............................................................................................ 3- 4345 3.9.4 Spill Response Exercises ............................................................................. 3- 4345 3.10 PROTECTION OF ENVIRONMENTALLY SENSITIVE AREAS AND AREAS OF PUBLIC CONCERN [18 AAC 75.425(e)(3)(J)] .......................................................... 3- 4446 3.10.1 Sensitive Wildlife Areas ................................................................................ 3- 4446 3.11 ADDITIONAL INFORMATION [18 AAC 75.425(e)(3)(K)] .......................................... 3- 4547 3.12 BIBLIOGRAPHY [18 AAC 75.425(e)(3)(L)] ............................................................... 3- 4547 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- 97 4.3 TRAJECTORY ANALYSES [18 AAC 75.425(e)(4)(A)(i)] ............................................. 4- 108 4.4 WILDLIFE CAPTURE, TREATMENT, AND RELEASE PROGRAMS [18 AAC 75.425(e)(4)(A)(i)] .......................................................................................... 4- 108 4.5 CATHODIC PROTECTION [18 AAC 75.076(h)(4)(A)(ii) ............................................. 4- 108 4.6 LEAK DETECTION TANKS [18 AAC 75.425(e)(4)(A)(ii)] ............................................ 4- 108 4.7 TANK LIQUID LEVEL DETERMINATION [18 AAC 75.425(e)(4)(A)(ii)] ...................... 4- 119 4.8 MAINTENANCE PROCEDURES FOR BURIED STEEL PIPING [18 AAC 75.425(e)(4)(A)(ii)] ....................................................................................... 4- 1412 4.9 PROTECTIVE WRAPPING OR COATING FOR TANKS AND PIPELINE [18 AAC 75.425(e)(4)(A)(ii)] ....................................................................................... 4- 1412 4.10 CORROSION SURVEYS FOR AN EXISTING INSTALLATION ............................... 4- 1412 4.11 PIPELINE LEAK DETECTION ................................................................................... 4- 1412 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- 76 Table 1.1-1 Emergency Action Checklist ....................................................................................... ........ 1-1 Table 1.1-2 Initial Spill Response and Notification Proc ess – Tier I Spill ............................................... 1-2 Table 1.1-3 Initial Spill Response and Notification Proce ss – 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 ........................................................................................... ......... 1-2 10 Table 1.6-1 Shoreline Protection Assessment for Point Barrow to Cape Lisburne .......................... 1- 3936 Table 1.6-2 Summary of How the Worst Case Discharge Scenario Complies with MMS BOEMRE Regulations ................................................................................................... 1- 4946 Table 1.6-3 Well Blowout in Summer Scenario Conditions .............................................................. 1- 5855 Table 1.6-4 Well Blowout in Summer Scenario Response Strategy ................................................ 1- 6057 Table 1.6-5 Well Blowout in Summer Derated Potential Recovery Capability ................................. 1- 6064 Table 1.6-6 Major Equipment For Offshore Response during the Drilling Season .......................... 1- 7366 Table 1.6-7 Major Equipment for Nearshore And Operations .......................................................... 1- 7567 Table 1.6-8 Storage Equipment for Recovery Operations ............................................................... 1- 7668 Table 1.6-9 Staff to Operate Oil Recovery a nd Transfer Equipment For Offshore, Nearshore and Shoreline Operations.............................................................................................. 1- 7669Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Table of Contents

Shell T-iv March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 Table 1.6-10 Response Strategy Subsea Well Blowout in Varying Ice Conditions ........................... 1- 7776 Table 1.6-11 Fuel Transfer Release During Summer Response Strategy ......................................... 1- 8488 Table 1.6-12 ADEC Specific Scenario Uncontrolled Sub-Sea Well Release During Summer Months ...................................................................................................................... ... 1- 10091 Table 1.6-13 ADEC Specific Scenario Uncontrolled Sub-Sea Well Release During Summer Months ...................................................................................................................... ... 1- 10293 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 Noble Discoverer Service Facilities ....................................................................... 3-2 Table 3.3-1 Command Staff Contact Information ............................................................................... 3- 810 Table 3.3-2 IMT Checklist .................................................................................................... ............. 3- 1012 Table 3.4-1 Ice Alert Levels ................................................................................................. ............. 3- 1416 Table 3.4-2 Ice Alert Roles and Responsibilities ............................................................................. . 3- 1517 Table 3.4-3 Average and Maximum Wind Speeds ........................................................................... 3- 1719 Table 3.4-4 Percentages of Days per Month that Temperature Could Reduce Response Effectiveness For Worker Threshold Limit Values ....................................................... 3- 1820 Table 3.4-5 Beaufort Wind Force and Sea State Relationship Between Wind and Wave Conditions in Fully Developed Seas ............................................................................. 3- 1921 Table 3.5-1 Logistical Support Contractors ................................................................................... ... 3- 2830 Table 3.7-1 Minimum Ignitable Oil Thickness on Water (Adapted from Buist et al. 2003) .............. 3- 3234 Table 3.7-2 Burn Removal Rates for Large Fires on Water (Adapted from Buist et al. 2003) ......... 3- 3234 Table 3.7-3 Fire Extinguishing Slick Thickness (Adapted From Buist et al. 2003) .......................... 3- 3335 Table 3.7-4 Inventory of In situ Burning Equipment (Shell and ACS) .............................................. 3- 3436 Table 3.7-5 Safe Working Distances From the Fire ......................................................................... 3- 3638 Table 4.2-1 Best Available Technology Analysis Well Blowout Source Control .................................. 4- 65 Table 4.6-1 Best Available Technology Analysis Leak Detection for Tanks .................................... 4- 1210 Table 4.7-1 Best Available Technology Analysis Tank Liquid Level Determination System ........... 4- 1311

LIST OF FIGURES Figure I-1 Chukchi Sea Lease Blocks February 2008 ........................................................................ I- 65 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- 4138 Figure 1.6-2 Shoreline Containment and Protection ......................................................................... 1- 4239 Figure 1.6-3 Shoreline Containment and Recovery Operations ........................................................ 1- 4239 Figure 1.6-4 Shoreline Cleanup and Backwater Protection .............................................................. 1- 4340 Figure 1.6-5 Nearshore Diversion and Recovery of Oil ..................................................................... 1- 4340 Figure 1.6-6 Nearshore Recovery in Broken Ice ............................................................................... 1- 4441 Figure 1.6-7 Nearshore Ignition of Oil In Ice ................................................................................ ...... 1- 4441 Figure 1.6-8 Predicted Subsea Blowout Trajectory (Without Containment and Recovery) .............. 1- 7870 Figure 1.6-9 Offshore Blowout Tactical Operations Organization ..................................................... 1- 7971 Figure 1.6-10 Primary Response to an Offshore Blowout ................................................................... 1- 8072 Figure 1.8-1 Frontier Noble Discoverer Drillship Outboard Profile Schematic ............................. 1- 113102 Figure 1.8-2 Frontier Noble Discoverer Drillship Main Deck and Above Schematic ..................... 1- 114103 Figure 1.8-3 Frontier Noble Discoverer Drillship Main Deck View ................................................ 1- 115104 Figure 1.8-4 Frontier Noble Discoverer Drillship Lower Deck Schematic ..................................... 1- 116105 Figure 1.8-5 Frontier Noble Discoverer Drillship Lower Deck View 2 ........................................... 1- 117106 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 Noble 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- 6Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Table of Contents

Shell T-v March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 Figure 3.3-1 Incident Command System ......................................................................................... ...... 3- 79 Figure 3.4-1 Comparison of Regional Ice Conditions ........................................................................ 3- 2123



### APPENDICES

Appendix A: General Specifications fo r 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 OilOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Table of Contents

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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 BOEMRE U.S. Department of the Interior, Bureau of Ocean Energy Management, Regulation and Enforcement
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 centimeterOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Acronyms

Shell T-viii March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 CMT Crisis Management Team
CO 2 carbon dioxide COCP Critical Operations and Curtailment Plan CPAI ConocoPhillip s 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
H 2 S hydrogen sulfide
HAZCOM hazard communication HAZWOPER Hazardous Waste Operations and Emergency ResponseOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Acronyms

Shell T-ix March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 HDPE high-density polyethylene HF high frequency 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 DrillOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Acronyms

Shell T-x March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 MARPOL International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978
mcf million cubic feet 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 Associ ation 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 ShelfOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Acronyms

Shell T-xi March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### OEPC Office of Environmental Policy and Compliance OIM Offshore Installation Manager
OOPS O’Brien’s Oil Pollution Services
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
OS R V O ffshore Supply il Spill Response Vessel OST Oil Storage Tanker PIC person in charge PM Primary Maintenance PPE personal protective equipment ppt parts per thousand PREP Preparedness Respon se Exercise Program psi pounds per square inch PWD Pressure-While-Drilling
QI Qq ualified Ii ndividual 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 TimeOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Acronyms

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### SW southwest

t tons
TF Task Force
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 A perture Terminal
W west
WAN Wide Area Network WBS Web-based system WCC Woodward-Clyde Consultants WCD worst case discharge
WNW west-northwest WP working pressureOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Introduction

Shell I-i March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### INTRODUCTION

............................................................................................................................... .......... 11 Objectives ....................................................................................................................

........................... 43 Alaska Clean Seas Technical Manual and Shell Beaufort and Chukchi Seas Regional Tactics Manual

.............................................................................................................................. .................................. 43 Plan Distri bution .............................................................................................................

......................... 44 Updating Pr ocedures

........................................................................................................... ................... 44

LIST OF TABLES

Table I-1 Renewal Require ment .................................................................................................

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

.......................................... 776

LIST OF FIGURES Figure I-1 Chukchi Sea Lease Blocks F ebruary 2008 .............................................................................

. 665Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Introduction

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Shell I-1 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

# 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 el ement of Shell’s overall commitment to conduct its operations in a safe and environmentally sensitive m anner. 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 lo cal, state, and federal per mit applications Shell has submitted or will submit to secure required authorizat ions prior to initiating their drilling program. This C-Plan is specifically designed to aid Shell in their e fforts to prevent spills and, in the unlikely event of a spill, mitigate the impacts of t hat 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 facilit ies located on Shell leases within the Chukchi Sea (see regional map Figure I-1 and Table 1- 2) generally bounded by the following coordinates (presented in NAD 83 UTM Zone 3 system) :

 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 Possible drill sites for the Exploration Drilling Program are at in the Burger Prospect at the following locations:

 Burger A –- 71° 18' 30.92" N, 163° 12' 43.17" W

 Burger F - 71° 20' 13.96" N, 163° 12' 21.75” W

 Burger JC

- − 71° 10' 24.03" N, 163° 28' 18.52” W71o 18’ 17.27” N, 163o 12’ 45.99” W; and

 Burger R - 71° 16' 06.57" N, 163° 30' 39.44 W Burger F

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

 Burger S - 71° 19' 25.79" N, 163° 28' 40.84” W

 Burger V -- 71° 10' 33.39” N, 163° 04' 21.23” W

In the event that these proposed well sites change in t he 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 U.S. Department of Interior, Minerals Management ServiceBureau of Ocean Energy Management, Regulation and Enforcement ( BOEMREMMS ), and all exploration activities will be conducted in compliance with applic able local, state, and federal laws.

Shell recognizes the sometimes harsh conditions asso ciated 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:Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Introduction

Shell I-2 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

###  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 w ill ensure Shell’s ability to mainta in 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.

 A weather and ice forecasting and monitoring progr am will be in place to ensure safe continued operations or, if necessary, cessation of oper ations 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 stati on 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 M/V Frontier Noble Discoverer , or similar. The FrontierNoble Discoverer has been refurbished for use in the arctic and will be operated by Frontier Drillingthe Noble Corporation , under Shell’s supervision. In the very unlikely event of a subsea blowout, the drillship could be moved quickly, allowi ng that vessel to drill its own relief well.

The Frontier Noble 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 material s, fuel, deliveries and remaining items by vessel and helicopter during the season. Arctic-cla ss 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 activiti es will not be conducted after October 31 st 

### . Well drilling activities are complete when the well is plugged and abandoned in accordance with MMSBOEMRE regulations, and there are no exposed format ions capable of flowing oil or gas.

The OSRV would possess sufficient capacity to provi de containment, recovery, and storage for the initial 24-hr operational period. An Arctic Oil Storage T anker (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 s peed 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 mob ilized to act as a Vessel of Opportunity Skimming System (VOSS). The VOSS would possess suffi cient 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 se t up a consistent rotation cycle with the OSRV skimming for 16 hr and the VOSS for another eight hr wh ile 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 bl owout. Additional personnel may also be transported via helicopter or vessel from a land- or vessel-based staging area.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Introduction

Shell I-3 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### Shell’s Chukchi Sea Regional Exploration C-Pl an regional applicability is based upon responding to a worst case discharge ( WCD ) from an exploration well with an OSRV assets located nearby the drillship at all times during critical drilling operations into hydrocarbon zones. The on-site The OSRVOil Spill Response (OSR ) vessel [Task Force 1 (TF-1)] and OSR barge (TF-2) vessel would possess sufficient capacity to provide containment, recovery, and storage for the initial 24-hr operational period. An Arctic Oil Storage Tanker (OST), designated TF-3, would be st aged within 24 hr [240 nautical miles (n mi)] of the Chukchi Sea drill site. 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. Two additional Vessel of Opportunity Skimming Systems (VOSSs) would be mob ilized from their staging location in the Beaufort Sea and would arrive at the recovery site within 42 hours of departure. These VOSSs would be capable of transit speeds of 10 knots. Skimming and light ering operations would be conducted on a rotational basis (two systems skimming while t he others transit and lighter recovered fluids to the OST). The onsite OST would have sufficient capacity to store all recovered liquids (oil and emulsified oil/water) for the first 20 days. A second Shell-chartered OST woul d be mobilized to supplement TF-3 and arrive at the drill site by Day 20 with sufficient capacity to store all the remaining recovered fluids from the 30-day blowout.

The initial OSR vessel may also act as a on-sc ene command vessel performing alternative response countermeasures such as in situ burn operations or dispersant app lication. Additional personnel may also be transported via helicopter or vessel fr om 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 threetwo discrete planning regimes:

 A 30-day spill response scenario written in compliance with MMSBOEMRE and ADEC regulations, based upon conditions likely to be encountered during the drilling season; and

 A 15-day spill response scenario written in compliance with ADEC regulations, based upon conditions likely to be encountered during the drilling season; and

 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 hel p 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 s ubmit 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 ca mpaign updates for a specified season and determine whether the Shell Chukchi Sea Regional Explorati on 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 av ailable at the ADEC office locat ed at 555 Cordova Street, Anchorage, Alaska, 99501.

The C-Plan addresses federal oil spill planning regulations of the MMSBOEMRE and the USCG. The worst case discharge volume here is different than that presented in Shell’s Exploration Plan (EP) submittal. The EP WCD is based on proprietary reserv oir characteristics and modeling which result in a “calculated” WCD, per NTL 10-06. The worst case discharge presented in the scenarios is a “planning” volume and exceeds the daily release rate of the calculated WCD for the thirty day duration.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Introduction

Shell I-4 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### OBJECTIVES
The objective is to minimize potential environmental impacts and to provide for the safety of personnel during drilling operations by preventi ng 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 effi cient, coordinated, and effective spill response.

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

 Drillships and facilities, suppor t 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 pr imary response contractor for all spill response activities. ACS will be availabl e 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 acti vities 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.



### PLAN DISTRIBUTION
The C-Plan is distributed to Shell management, st aff, 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 t he 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 equi pment or response strategies;

 Change in response procedures; or

 Change in ownership.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Introduction

Shell I-5 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### In addition, it is Shell’s intent to provide adminis trative updates to drill site locations, vessel names, and other routine information of a proj ect-specific nature, in advance of each drilling campaign, either as an update to the C-Plan or as part of annual permit applic ations, 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 dat e of approval or when changes are made that diminish the ability to respond.

MMSBOEMRE 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 oper ator. Resubmit every five (5) years.



### Shell will notify MMSBOEMRE 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 c opies are distributed to all plan holders. Plan holders are requested to replace the hard copy pages. Revisi ons are documented in the Record of Revisions history table, which is included with each approved am endment 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 Hope Point Lay Wainwright 155°W 160°W 165°W 170°W

72°N

71°N

71°N

70°N

70°N

69°N

69°N

68°N 

# I

0 40 80 20 Miles C h u k c h i S e a

Scale: Figure: Datum: NAD83 Projection: Alaska Albers Equal Area 

# A r c t i c O c e a n

Block No: 6714 Lease: Y2267

Block No: 6764 Lease: Y2280

I - 1 National Petroleum Reserve - Alaska (NPR-A)



### National Petroleum Reserve - Alaska
National Park System & Wildlife Refuge Alaska Maritime National Wildlife Refuge

UMQ: 14000311_Shell_CC_Cplan_v001 Date: 4/15/2011 

## SHELL B e a u f o r t S e a

Chukchi Sea Regional Exploration Oil Discharge Prevention and Contingency Plan CHUKCHI SEA LEASE BLOCKS APRIL 2011 Block No: 6762 Lease: Y2278

Block No: 6812 Lease: Y2294

Block No: 6912 Lease: Y2321 Block No: 6915 Lease: Y2324

" 

### Village
Shell Exploration Plan Blocks

Shell OCS Lease BlocksOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Introduction

Shell I-7 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### TABLE I-2 LEASES OWNED BY SHELL IN THE CHUKCHI SEA (AS OF FEBRUARY 2008)

PROTRACTION AREA OPD NO. BLOCK NO. MMSBOEMRE 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 Y2032Oil 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 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 PROTRACTION AREA OPD NO. BLOCK NO. MMSBOEMRE LEASE# OCSKARO NR03-01 6464 Y2033 KARO 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 Y2106Oil 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 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 PROTRACTION AREA OPD NO. BLOCK NO. MMSBOEMRE LEASE# OCSKARO NR03-01 6860 Y2107 KARO NR03-01 6861 Y2108 KARO 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 Y2173Oil 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 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 PROTRACTION AREA OPD NO. BLOCK NO. MMSBOEMRE LEASE# OCSPOSEY NR03-02 6165 Y2174 POSEY NR03-02 6213 Y2180 POSEY NR03-02 6214 Y2181 POSEY 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 Y2267 1 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 2 POSEY NR03-02 6763 Y2279 POSEY NR03-02 6764 Y2280 3 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 4 POSEY NR03-02 6813 Y2295 POSEY NR03-02 6814 Y2296 POSEY NR03-02 6815 Y2297 POSEY NR03-02 6816 Y2298

1 OCS Lease Block location for proposed drill site: Burger F
2 OCS Lease Block location for proposed drill site: Burger S
3 OCS Lease Block location for proposed drill site: Burger AC 4 OCS Lease Block location for proposed drill site: Burger ROil 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-11 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 PROTRACTION AREA OPD NO. BLOCK NO. MMSBOEMRE LEASE# OCSPOSEY 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 5 POSEY NR03-02 6913 Y2322 POSEY NR03-02 6914 Y2323 POSEY NR03-02 6915 Y2324 6 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

5 OCS Lease Block location for proposed drill site: Burger J
6 OCS Lease Block location for proposed drill site: Burger VOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Introduction

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### PART 1 RESPONSE ACTION PLAN [ 18 AAC 75.425( e)(1)] ........................................................... 1-11-1 1.1 EMERGENCY ACTION CHECKLIST [18 AAC 75.425( e)(1)(A)] ................................ 1-11-1 1.2 REPORTING AND NOTIFICATION [18 AAC 75.425(e )(1)(B)] .................................. 1-51-5 1.2.1 Initial Reporting .............................................................................................. 1-51-5 1.2.2 External Notification Procedures

................................................................ 1-101-10 1.2.3 Written Reporting Requirements

................................................................ 1-101-10 1.3 SAFETY [18 AAC 75. 425(e)(1)(C)] ......................................................................... 1-131-13 1.4 COMMUNICATIONS [18 AAC 75.425(e)(1)(D)] ..................................................... 1-141-14 1.4.1 Communications Plan ................................................................................ 1-141-14 1.4.2 Communications Equipment ...................................................................... 1-141-14 1.4.3 Equipment Maintenance ............................................................................ 1-181-18 1.5 DEPLOYMENT STRATEGIES [ 18 AAC 75.425( e)(1)(E)] ...................................... 1-191-19 1.5.1 Transport Procedures [18 AAC 75.425(e)( 1)(E)(i)] .................................... 1-201-20 1.6 RESPONSE STRATEGIES [18 AAC 75.425(e) (1)(F)] ........................................... 1-211-21 1.6.1 Procedures to Stop Discharge [18 AAC 75.425(e) (1)(F)(i)] .............................. 1-22 1.6.2 Fire Prevention and Control [18 AAC 75.425(e) (1)(F)( ii)] ................................. 1-22 1.6.3 Blowout Control/Re lief Well Plan ...................................................................... 1-22 1.6.4 Discharge Tracking [18 AA C 75.425(e)(1) (F)(iv)] ............................................. 1-27 1.6.5 Protection of Sensitive Area s [18 AAC 75.425( e)(1)(F)(v )] .............................. 1-27 1.6.6 Containment and Control Strategies [18 AAC 75.425(e)(1)(F)(vi)]

................... 1-27 1.6.7 Recovery Strategies [18 AAC 75.425(e)( 1)(F)(vii)] ........................................... 1-30 1.6.8 Lightering, Transfer, and Storage of Oil from Tanks [18 AAC 75.425(e)(1)(F)(viii)]

............................................................................ 1-32 1.6.9 Transfer and Storage Procedures [18 AAC 75.425(e )(1)(F)(i x)] ...................... 1-32 1.6.10 Temporary Storage and Disposal [18 AAC 75.425(e )(1)(F)(x )] ........................ 1-33 1.6.11 Wildlife Protection [18 AAC 75.425(e)(1)( F)(xi)] ............................................... 1-33 1.6.12 Shoreline Cleanup [18 AAC 75.425(e)(1)(F)(xii)]

.............................................. 1-34 1.6.13 Spill Response Scenarios ................................................................................. 1-45 1.7 NON-MECHANICAL RESPONSE OPTION S [18 AAC 75.425(e)(1)(G)] .................... 1-108 1.7.1 Obtaining Permit s and Appr ovals ................................................................... 1-108 1.7.2 Decision Criter ia for Use ................................................................................. 1-108 1.7.3 Implementation Procedures ............................................................................ 1-109 1.8 FACILITY DIAGRAMS [18 AAC 75.425(e)(1)(H)]

........................................................ 1-110

LIST OF TABLES

Table 1.1-1 Emergenc y Action Checklist ....................................................................................... 1-11-1 Table 1.1-2 Initial Spill Response and Noti fication Process – Tier I Spill ........................................... 1-2 Table 1.1-3 Initial Spill Response and Notifi cation Process – Tier II or Tier III Spill ...................... 1-31-3 Table 1.2-1 Emerge ncy Contact List ...........................................................................................

... 1-61-6 Table 1.2-2 Agency and Exter nal Notification Information ............................................................. 1-71-7 Table 1.2-3 Agency Reporting Requirements fo r Oil Sp ills ....................................................... 1-111-11 Table 1.4-1 Summary of Alaska Statewide Frequency Plan Channels .................................... 1-151-15 Table 1.5-1 Transp ortation Options ............................................................................ 1-211-201-201-20 Table 1.6-1 Shoreline Protection Assessm ent for Point Barrow to Cape Lisburne .... 1-391-371-371-36 Table 1.6-2 Summary of How the Worst Case Discharge Scenario Complies with MMSBOEMRE Regulations .............................................................................................. 1-501-471-471-46 Table 1.6-3 Well Blowout in Summer Scenario Conditions ........................................ 1-591-561-561-55 Table 1.6-4 Well Blowout in Summe r Scenario Resp onse Strategy ........................... 1-611-581-581-57 Table 1.6-5 Well Blowout in Summer De rated Potential Recovery Capability ............ 1-691-651-651-64 Table 1.6-6 Major Equipment For Offs hore Response during t he Drilling Season ..... 1-721-671-671-66Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-ii March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### Table 1.6-7 Major Equipment for Nearshore And Operations

..................................... 1-741-681-681-67 Table 1.6-8 Storage Equipment for Recovery Operations .......................................... 1-751-691-691-68 Table 1.6-9 Staff to Operate Oil Recovery and Transfer Equipment For Offshore, Nearshore and Shoreline O perations ........................................................................ 1-761-701-701-69 Table 1.6-10 Response Strategy Subsea We ll Blowout in Varying Ice Conditions ...... 1-841-771-771-76 Table 1.6-11 Fuel Transfer Release During Summer Response Strategy ................... 1-961-891-891-88 Table 1.6-12 ADEC Specific Scenario Uncontrolled Sub-Sea Well Release During Summer Months ..................................................................................................... 1-991-921-921-91 Table 1.6-13 ADEC Specific Scenario Uncontrolled Sub-Sea Well Release During Summer Months ................................................................................................... 1-1011-941-941-93

LIST OF FIGURES Figure 1.1-1 Tier II and Tier III In cident Response Or ganization Chart .......................................... 1-41-4 Figure 1.1-2 Internal Emergency Notification Process Diagram ..................................................... 1-51-5 Figure 1.2-1 Shell Report of Offs hore Environmental Incident Form .............................................. 1-81-8 Figure 1.6-1 Chukchi Sea Shoreline Protection ACS Map Atlas Sheet Index ............ 1-411-391-391-38 Figure 1.6-2 Shoreline Co ntainment and Protection .................................................... 1-421-401-401-39 Figure 1.6-3 Shoreli ne Containment and Reco very Operations .................................. 1-421-401-401-39 Figure 1.6-4 Shoreline Cleanup and Backwater Protection ......................................... 1-431-411-411-40 Figure 1.6-5 Nearshore Dive rsion and Recove ry of Oil ............................................... 1-431-411-411-40 Figure 1.6-6 Nearshore Re covery in Broken Ice .......................................................... 1-441-421-421-41 Figure 1.6-7 Nearshore Ig nition of O il In Ice ................................................................ 1-441-421-421-41 Figure 1.6-8 Predicted Subsea Blowout Trajec tory (Without Containment and Recovery) .... 1-771-711- 711-70 Figure 1.6-9 Offshore Blowout Ta ctical Operatio ns Organization ................................ 1-781-721-721-71 Figure 1.6-10 Primary Respons e to an Offshor e Blowout .............................................. 1-791-731-731-72 Figure 1.8-1 Noble Frontier Discoverer Drillship Outboard Profile Schematic .... 1-1111-1041-1051-102 Figure 1.8-2 Noble Frontier Discoverer Drillship Main Deck and Above Schematic ..... 1-1121-1051-106 Figure 1.8-3 Noble Frontier Discoverer Drillship Main Deck View ....................... 1-1131-1061-1071-104 Figure 1.8-4 Noble Frontier Discoverer Drillship Lower Deck Schematic ............ 1-1141-1071-1081-105 Figure 1.8-5 Noble Frontier Discoverer Drillship Lower Deck View 2 .................. 1-1151-1081-1091-106Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-1 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

# 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 proper ly respond to a reportable spill. Section 1.6.13 contains a hypothetical scenario describing the stra tegies and tactics for the WCD for an exploration drilling program occurring outside State of Alaska wate rs on the Federal OCS. For planning purposes, the hypothetical blowout involves oil that travels upw ards 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 sp illed 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 reco very operations were conducted. More detailed information is presented in the Scenario 1 discussion.

These time frames have been used to plan the mob ilization 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 inform ation to provide as complete an understanding of the in cident 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 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### 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 s upervisor 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 reso urces not specified in this C-Plan.

If the Initial On-Scene Incident Commander or t he Initial Response Incident Commander (IRIC) determines that the spill is a Tier- II or -III event (Figure 1.1-1), addi tional responses and notifications should take place (Figure 1.1-2, Table 1.1-3). The names, positions, and telephone numbers of facility personnel respon sible for spill notification are lis ted in Table 3.3-1. A summ ary 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 Comm and 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 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### 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 exter nal 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 additi on 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 re sponse equipment and personnel. Coordinate all operations with dedicat ed 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 Sea Regional Exploration ProgramPart 1 – Response Action PlanShell1-4March 2010May 201195-2000.01-25.201-001/09-018Rev.10FIGURE 1.1-1TIER II AND TIER III INCIDENT RESPONSEORGANIZATION CHARTOn-Scene IC/Branch Director (BD)*Deputy IC/BDICS SupportScribe (On-Scene Command Post)If needed:Logistics from Deadhorse/AnchoragePlanning/IAP Support (Anchorage)Information Officer (Anchorage)NOTIFICATIONS(Alaska IC, NRC, Federal On-SceneCoordinator [FOSC], DrillingSuperintendent)*On-Scene IC initiates the response and is responsible for developing and implementing initial IAP (ICS 201 series). Once the full UC isassembled, the On-Scene IC is relieved by theIC and becomes BD in the Operations Section.Safety OfficerFloating Health, Safety, Security, andEnvironment (HSSE) Technician (Primary)Drillship/OSRVOSR VesselHSSE Technicians[Deputies – coordinated by Safety Officer (SO)but assigned to respective Group]On-Water Response GroupOil Spill Response (OSR) Operations Specialist(Group Leader)ACS Superintendent (Deputy Group Leader)Source Control Group –FrontierNobleDiscovererDrilling Foreman (Group Leader)Drillship ManagerDrillship Marine CoordinatorSupport VesselsOil Discharg e Part 1 – Res p

Shell 95-2000.01- 2 

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Shell 1-6 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### 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) 264-7777273-2420 (907) 771-7221 ( 907218 ) 771-7219544-2151 (907) 646-7176 Cell (504) 874-4697 ( 907) 771-7243504) 728-4252 (907) 646-7121 ( 281) 544-6166907) 646-7116 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 Res ponse 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 A ND 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 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### TABLE 1.2-2 AGENCY AND EXTERNAL NOTIFICATION INFORMATION

AGENCY TELEPHONE FACSIMILE (FAX) NRC (800) 424-8802 EPA (NRC will call) (907) 2 71-5083 (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 O gbe) (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 Mayor’s Office (907) 852-0200 (907) 852-0337 NSB Disaster Coordinator (Pat Patterson) (907) 852-2822, (907) 852-6111 (24 hrs on call) (907) 852-2475

USCG – Sector Anchorage COTP Zone (907) 271-6700 (907) 271-6765 USFWS (Alaska Maritime National Wildlife Refuge) (907) 235-6546 (907) 271-1630

MMSBOEMRE (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 Managemen tBOEMRE = U.S. Department of the Interior, Bureau of Ocean Energy Management, Regulation and Enforcement COTP = Captain of the Port 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 ServiceOil Discharg e Part 1 – Res p

Shell 95-2000.01- 2 e Prevention and C p onse Action Pla n

2

5.201-001/09-01 8 

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a y 2011 Rev. 10Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-10 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### 1.2.2 External Notification Procedures

Appropriate agency verbal notificatio ns and written reports may include:

 

### NRC

 

### MMSBOEMRE

 

### BLM

 

### USFWS

 

### EPA

 

### USCG

 

### U.S. Department of Interior (DOI)

 

### U.S. Department of Transportation (DOT)

 

### ADEC

 

### ADF&G

 

### ADNR

 

### National Oceanic and Atmospheric Administrati on (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. MMSBOEMRE , USCG, and ADEC reporting requirements will be met in the fo llowing procedures. Agency and external notification contacts and agency reporting requirements are summari zed above in Table 1.2-2 and in the following Table 1.2-3, respectively.

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

ADEC regulation 18 AAC 75.300 requ ires notification of any spill on state lands or waterways. After notification of the discharge has been made to ADEC, t he 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 Regional Exploration ProgramPart 1 – Response Action PlanShell1-11March 2010May 201195-2000.01-25.201-001/09-018Rev.10TABLE 1.2-3AGENCY REPORTING REQUIREMENTS FOR OIL SPILLSENVIRONMENTAL COMPLIANCEINITIAL AGENCY NOTIFICATIONADMINISTRATIVEWRITTEN REPORT(fax is acceptable)AS SOON AS POSSIBLEWITHIN48 HRMONTHLYIMMEDIATEOR ASSHOWN BELOW5 DAYSAFTERLOSS15 DAYSAFTER LOSS15 DAYSAFTERCLEANUP30DAYSAFTEREVENTSPECIFIC CONDITIONSNRC(EPA)ADECADNRNSBUSCG4MMSBOEMRE5ADF&G6BLM10ADECNSBADNRADECNSBADNRFEDERALLANDONLYBLM10DOTSPCOFAXW/IN48 HRAOGCC3CRUDEGASAOGCC3CRUDEGASEPA7,12BLM,MMSBOEMRE14ADEC8ADNRNSBDOT11SPCOOFFSHORE (DISCHARGES TO WATER)1Sewage9Any quantityX X X XAny oil or chemicalspill(e.g., oil, drilling fluids, glycol, produced water,or brine)X X X X X X X X X XSeawaterTo seawater environment (no report)Any amount seawater to freshwaterenvironmentX X X X X X X XSTAGING AREAChemicalsExceeds federal RQ2X X>55gal>100bblX >10 bbl XLess than RQ, or has no RQX>55galX5X XSelectedHazardousSubstances13>55 galX X X X10 to 55 galX X X<10 gal (no report)SeawaterTo seawater environment (no report)>55 gal to freshwater environment>100bblX X >10 bbl X10 to 55 gal to freshwater environmentX X X<10 gal to freshwater environment (no report)Sewage9Any quantityX9XOil>55 galX X>100bbl or500mcfgasX X X>10 bbl or 50mcf gasX10 to 55 galX X >25 gal X X1 to 10 gal (<1 gal = no report)X X X XIN CONTAINMENTChemicalsAir release, with RQX X X XLess than RQ or has no RQ13Sewage9Any quantity (no report)Oil, Glycol, andSelect HazardousSubstances13>55 gal (less than = no report)X>100bbl or500mcfgasX X X>10 bbl or 50mcf gasXAOGCC = Alaska Oil and Gas Conservation Commissionhr = hour(s) gal = gallon(s)mcf = million cubic feet RQ = reportable quantity SPCO = State Pipeline Coordinator’s OfficeOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration ProgramPart 1 – Response Action PlanShell1-12March 2010May 201195-2000.01-25.201-001/09-018Rev.10TABLE 1.2-3 (CONTINUED)AGENCY REPORTING REQUIREMENTS FOR OIL SPILLSNotes: “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 water, and seawater.3. For State regulated wells: Crude oil spills >25 gal; notifyAOGCC North Slope Representative. Crude oil spills >10 bbl, notify AOGCC North Slope Representative.4. All oil spills to or threatening navigable waters.5. Offshore rig spills <42 gal, call NRC. NotifyMMSBOEMRE(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 oilspills and storm water releases of oil or chemicals >RQ.8. Sewage spills, including domestic wastewater and gray water, spillsare reportable to ADEC Wastewater Program; written report due 7 days after event.9. 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 two discharges within any 12-month period.13. Field Environmentalist must evaluate available information (MSDS, test data, orprocess knowledge) to determine if spilledsubstance is a hazardoussubstance. Reportingis not required if a non-hazardous determination is made.14.MMSBOEMRErequires 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 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### Interim and final written reporting requirements are s pecified 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 caus ing 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 pr event recurrence of the discharge; and

 

### Other information ADEC requires to fully asse ss the cause and impact of the discharge.



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

Based on applicable safety standards, a descriptio n of the steps necessary to develop an incidentspecific safety plan for conducting a respon se 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 inclu de 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, pr epared for each drilli ng 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 form ation characteristics and pr essures; and provides information critical to t he success and safety of t he drilling program. The site-s pecific evacuation plan is maintained on all Shell-owned or ShelI-contracted dr illships and is posted throughout these facilities as part of the “Station Bill.” Weekly dr ills 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 ha zardous ice conditions ar e 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 operat ions during severe environmental conditions.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-14 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### In the event that conflicts arise with the abov e-referenced documents while developing an incident specific safety plan, Shell proced ures will take preceden ce 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 requir es 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 establ ishing a plan that provides coverage in the field and between the field and a command post. Comm unication 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 communicati on links for the duration of the response.

 

### Communication equipment used in the immediate vici nity 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 severa l miles. A repeater radio link would be required to bridge worst-case distances from the fi eld 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 channel s 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 alwa ys prefixed with the letters “OS.” This clarifies the identity of the channel under discussion and minimi zes 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) ve ssels 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 ra dio systems. Additional ACS subscriber units are available for use in OSR or drills. ACS provides for an extensive communicati ons network in the North Slope region, built on the basis of VHF radio covera ge. 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 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### Descriptions of communications resource s 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 c hannels 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 logi stics use, as required. Note that marine channels are specifica lly given OS designations that do not reflect the act ual 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 fa cilities 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 cellul ar 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-vesse l, 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 coor dinating the cleanup operations, although UHF radios are also suitable for this purpose.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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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 fo r 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 un its. Most UHF radios are 3- or 6- (but can be up to 16) channel models with the actual frequen cies 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 an d in undeveloped areas, operators may consider obtaining HF-SSB voice radio equipment. Radio propagation by this mode c hanges 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 communica tions to standard telephone lines, almost anywhere in the world. The asso ciated costs are high, but thes e 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-w ide 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 pu sh-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 broa dband wireless connectivity primarily in the Prudhoe Bay area westward to Alpine, includin g 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 subs criber units that are both handhelds and dash mounts, programmed with the frequencies of ACS- a nd 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### The drillship will have a Very Small Aperture Termin al (VSAT) voice and data service in excess of 512 kilobits per second (kbps) to fac ilitate primary communications with sh ore 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 satellit e communication system via FrontierNoble 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 resour ces, 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 Ir idium satellite telephones [or MSAT telephones]. There will be multiple telephone and facsimile lines ava ilable on the drillship for multiple simultaneous inbound and outbound calls.

Intercom System
Barkway intercom system units are located in mud utilit y, 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 r oom, radio room, and control room to the drilling unit pump room, control room, and stairwell, and operates i ndependently of all other sy stems. 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 ev ent 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 (H 2 

### S) Gas – Hi-Lo – 780 to 600 Hz, alternately – 0.52 seconds each.

A console in the radio room is interfaced to the cont rol 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, FrontierNoble 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, WCS300Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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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 telepho nes, data and fax, and a secondary VSAT system via FrontierNoble 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 system s, 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 ope rational 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### 1.5 DEPLOYMENT STRATEGIES [18 AAC 75.425(e)(1)(E)]

An The OSRVOSR vessel [Task Force 1 (TF-1)] and the OSR barge (TF-2) and tug will be stationed nearby the drillship during drilling operations into liquid hydrocarbon-bearing zones. TF-1 and TF-2The OSRV ha ves trained personnel onboard who are provided wi th the necessary resources to implement containment, control, and recovery tactics. TF-1 and TF-2The 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 hr s of skimming operations. The OST (TF-3) will be staged within 240 n mi of the Chukchi Sea drill site. The task force vesselsOSRV and OST are capable of transit speeds of 10 knots. Using 10 knots as a realistic average transit speed for planning purposes, TF-1 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], TF-2 would be staged approximately 25 n mi from the drillship to arrive at the site within 3 hr, and TF-3the OST would be staged off the Chukchi Sea coast and arrive at the recovery site within 24 hr of depart ure from the staging area. If necessary, two additional Vessel of Opportunity Skimming Systems (VOSSs) would be mobiliz ed from their staging location in the Beaufort Sea and would arrive at the recovery site within 42 hours of departure. These VOSSs would be capable of transit speeds of 10 knots. Skimming and lig htering operations would be conducted on a rotational basis (two systems skimming while the others transit and lighter recovered fluids to the OST). The on-site OST would have sufficient capacity to store all reco vered oil for the first 20 days. A second Shellchartered OST would be mobilized to supplement TF-3 and arrive at the drill site by Day 20 with sufficient capacity to store all the remaining recovered fluids from the 30-day blowout

The initial OSR vessel may also act as the on-sce ne command vessel performing alternative response countermeasures such as in situ burn operations or dispersant a pplication. Additional personnel may also be transported via helicopter or vessel from a land- or vessel-based staging area.

a second vessel, the OSRB 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 OS RVOSV for 8 hr during which time it would lighter recovered fluids to the OST. The OSRVOSV and VO SS would set up a rotation cycle with the OSRVOSV skimming for 16 hr and the VOSS for another 8 hr while the OSRVOSV lighters to the OST. The OST would possess a minimum liquid storage capacity of 2 87,100 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 l and- or vessel-based staging area.

The oil spill personnel onboard TF-1 and TF-2the OSRV are available to respond rapidly to an on-site emergency. During conditions that ma y limit helicopter operations, the OSRVOSRV 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 suppor ting vessels or may utilize other small vessels or work boats for transport.
TF-6, consisting of Aa large, mobile OSROil Spill Response Bb arge (OSRB) and tug, will be mobilized from its stag inged location in Beaufort Sea and arrive within 96 hr in the nearshore zone of the Chukchi Sea in order to best intercept and recover oil potentia lly threatening the coast, as water depth, weather, sea conditions and other circumstances allow. TF-6 would be capable of trans it speeds of 5 knots, ensuring arrival by Hour 96. In the unlikely even t strong, sustained winds develop out of the WNW, trajectory modeling estimates that six days is the earliest possible time oil could reach shore, even if no containment and recovery operations were conducted. 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. ItTF-6 will carry response equipment that includes a 47-foot (ft) skimmingOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### vessel, 34-ft work boats, mini-barges, boom and duplex skimming units for nearshore and shoreline protection and recovery. The TF-6OSRB will mobilize to implement nears hore recovery and support the shoreline protection and recovery task force s (TF-7 and TF-8) . 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 supp ort the OSR effort (refer to Section 1.6.13), will be progressively mob ilized as follows:

 

### From existing call-out arrangements under ACS

 

### Auxiliary Contract Response Team (ACRT) pers onnel 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 operat ing area (subject to 70 percent availability for planning purposes);

 

### 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 dependi ng on a variety of factors, such as weather, personnel safety, and wildlife considerations. Duri ng 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, TF-1 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], TF-2 would be staged approximately 25 n mi from the drillship and arrive at the recovery site within 3 hr, and TF-3the 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 ar e designed for and certified for operation in arctic conditions, including operation in high ice concen trations. Please refer to Appendix A for further information regarding general on-site vessel capabiliti es 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 causin g the spill, the size of the spill, ti me of year, logistical support, and available information.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### TABLE 1.5-1 TRANSPORTATION OPTIONS

MODES OF TRANSPORTATION SEASON

DRILLING BREAKUP/FREEZEUP WINTER
Helicopters X 1 X 1 X 1
Fixed-wing Aircraft X 1 X 1 X 1

Vessels X Conditional 2 Conditional 2
Vehicles/Heavy Equipm ent -- -- Conditional 2
Heavy ATV -- -- Conditional 2

1 Weather dependent
2 Dependent upon ice conditions ATV = all terrain vehicle



### Pre-staged Equipment
The drillship will have TF-1 and TF-2the OSRV on standby within its vicinity during drilling operations into liquid hydrocarbon-bearing zones. One of the support vess els assigned to the drills hip 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 perfor med by ACS as part of their periodic maintenance system, and the inspection records would be maintained through ACS.

Section 1.6.12 describes the equipment and personnel pr e-staged at Wainwright that would be used to initiate and support shoreline response. Pre-stage d equipment would be routinely inspected throughout the drilling season to ensure it is secure and read y for deployment in the event of an emergency. Equipment available through ACS has been scaled to fulfill specific shoreline protec tion strategies (refer to Section 1.6.13). Shoreline response personnel, de scribed in Section 1.6.12, Shoreline Cleanup, and listed in Table 1.6-9, are pre-staged at Wainwri ght, 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 th ese 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 equipm ent 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 incident s arising from Shell’s exploration drilling program.

The narratives provided in these sections compleme nt the information presented in Section 1.6.13, Spill Response Scenarios. Where practicable, project-sp ecific details, including oil trajectories, have been incorporated based on the proposed drilling projects.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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

Procedures to stop the discharge ar e discussed in Section 1.6.3 Blowout Control/Relief Well Plan; Section 2.1.8, Blowout Prevention and Emergency Shut down; Section 4.2, Source Control; Table 4.2-1, Best Available Technology (BAT) Analysis Well Bl owout Source Control; a nd in the Sp ill 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 a nd establishing exposure control zones into which appropriately trained and equipped personnel may enter.

If a fire occurs, it will be controlled as much as possib le with fire monitors on the drillship and supporting vessels.

The drillship contains fire and lifeboat al arms, fire-fighting and wash-down systems:
Alarm systems include vessel-mounted gas detecto rs 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 br idge and in the Emergency Response Room.

 Fire- and wash-down systems include two centrifu gal, 300 gallon per minute (gpm) fire pumps, one centrifugal 300 gpm emergency fire pump, and fi re hydrants located throughout the drillship.

 The vessel is equipped with fixed carbon dioxide (CO 2 

### ) fire-extinguishing systems to cover the propulsion room, generator room, control room, paint locker and emergency generator room.

 Fire-fighting foam systems comprise two monito rs, foam tank, and separate pump for heli-port protection.

Ignition of the vapors surfacing at the blowout may be considered for sa fety 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 t he 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 Contro l/Relief Well Plan

Shell has taken significant precautions to minimize t he potential for a loss of we ll 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 incl udes 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 c ontrol, including relief well drilling.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### In the unlikely event that well cont rol is lost despite these precauti ons, 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 in tervention 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 regaini ng 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 crea te 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:

 

### 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.

Sub-sea Capping and Sub-se a Containment Capability

Containment capability in the unlikely event of a lo ss of well control is provided by a combination of subsea capping, subsea containment and surface se paration equipment installed on a containment vessel.

Surface intervention involves work done on the wellhea d of a subsea well. Surface intervention in the OCS involves subsea devices used on the top of the well or some device connected thereto (e.g., the BOP stack or wellhead).

A set of subsea devices is being a ssembled to provide direct surfac e intervention capability with the following priorities:

1. Attaching a device or series of devices to t he well to affect a seal capable of withstanding the maximum anticipated wellhead pressure (MAWP) and closing the assembly to completely seal the well against further flows (commonly called “capping and killing”). 2. Attaching a device or series of devices to the well and diverting flow to surface vessel(s) equipped for separation and disposal of hydrocarbons (commonly called “capping and diverting”).

These devices form what is gener ally known as a capping stack. The devices include: ram-type BOP bodies equipped with blind and/or pipe rams, spacer spools, flow crosses (or mud crosses for pumping kill weight fluid into the well or for flowing the we ll in a controlled manner through piping to the surface) and connectors to attach to the upper H4 conn ector mandrel. This equipment will be stored aboard aOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### designated vessel in Alaska and ready for use. It is anticipated that surfac e intervention efforts will successfully stop the flow from a blowout in le ss time than is required to drill a relief well.

Should capping fail to completely stop oil leaking from the well, one or more subsea devices will be deployed to capture low-flow rate leaks. Oil and as sociated gas collected from these devices would be piped to separation equipment on the containment vess el. The separation equipment includes a series of gas/water and oil/water separators, knock-out drums pumps and pre-heaters. Gas would be diverted to a flare and the oil would be disposed of either by storing and shipping from the scene or incinerating in a flare. By capturing the oil below the water surface, interference by surface environmental conditions, including inclement weather or ice, is avoided and surface oil spill recove ry efforts are simplified. Surface oil spill response equipment will remain on station in the immediate area to capture any fugitive oil that escapes the subsea collection dome(s).

All of the separation equipment on the containment vessel will be designed for conditions found in the Arctic including ice and cold temperatures. This equipment will also be designed for reliability, ease of operation, flexibility and robustness so it could be us ed for a variety of emergency situations. Capping stacks, subsea collection devices, separation equipment and the containment vessel will be tested prior to the drilling season. The capping system, cont ainment system and the associated processing equipment is being designed and assembled to accommodate the worst case discharge oil and gas volumes expected from wells in this region.

Relief Well
As described in Section 2.1.8, She ll does not rely on relief well drilli ng 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 blow out situation. These layers include planning and risk identification, early kick detec tion and kick response procedures, and installing mechanical barriers. These measures result in an extremely low probab ility of an uncontrolled well release, but in the event this did occu r, the drilling of a relief well is the fi nal tool for regaining well control.

In the scenario developed for this cont ingency 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 suppor t safe recovery operations from a relief well site. As a precautionary measure, relief well preparation operations are initiate d 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 or iginal wellbore at sufficient rates and weight to stop formation fluid from flowing into the original wellbo re, 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 evaluati on at the casing points.

 Kill fluid as well as an additional wellhead and additional surface casing and other casing, drillpipe, mud materials, and ce ment 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 MMSBOEMRE as part of the Application for Permit to Drill (APD).Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### 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 loca tion 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 assuranc e program in place to minimize any ri sks (See Section 2.1.8), Shell believes that a prudent operator can conduct a Chukchi Sea drillin g program using a single dr illship. 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.

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 s upport 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. Th rough a risk/benefit analysis that places human safety as the highest priority, Shell will consider th e feasibility and benefits of i gniting the surfacing vapors after all personnel, equipment, and vessels have been loca ted 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 w ill facilitate a rapid assessment of the potential risks of exposure for personnel, equipmen t, and wildlife to the initial flash of combustible vapors, as well as the heat and combustion produ cts 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 elim inate dangerous vapors in the working vicinity.

Permits
In the event of a discharge due to the loss of well c ontrol, 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 necessa ry (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 nea rshore coastal waters and wetlands. The USACE has issued a Nationwide Permit No. 20, which authorizes placement of fill needed for cleanup of spilled oil. AOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### 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, MMSBOEMRE , 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 MMSBOEMRE prior to drilling. As part of the overall North Slope oil spill preparedness program, ACS holds a series of permits that facilit ate agency authorizations for a variety of response and cleanup-related activities, including bird and mammal hazing and mammal stabilization.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### 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.

Oil movement is tracked primarily through the combination of visual observations, aided where practicable by Global Positioning System (GPS) devic es 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 (F LIR), vessel-mounted infrar ed radar (IR) systems onboard the OSRVOSR vessels 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 equi pped with a transmitter that can be monitored by a receiver located either on a boat or aircraft. Oil locati on 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 resour ce 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 chan ge based on weather, sea stat e, oil condition, hours of daylight, and other factors. A new Shoreline Cl eanup Plan will be developed and submitted to the UC. Oil and oiled ice will be monitored throughout the spill an d for as long as oil is believed to be present. Should oil persist near the shoreline, after winter re covery operations are complete, these areas will be marked and monitored as the ice begins to melt du ring 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 Stra tegies [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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### The TF-1 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 near the drillship and outfitted with skimming equipment, would be mobilized to serve as a VOSS for recovery operations. TF-2 would be staged at approximately 25 n mi from the drillship and mobiliz ed to the drill site within 3 hr. TF-4 and TF5 would be mobilized to arrive at the release site with in 42 hours to supplement containment and recovery operations. Specific tactics are described in the sc enario 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 t he containment and control efforts in the nearshore and shoreline environments and has the ca pability to mount an effective, time ly response for oil containment and recovery operations. TF-6The OSRB would be mobilized as quickly as possible upon notification of a blowout and arrive into the Chukchi Sea nearsh ore 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 o perations were conducted. Nearshore and shoreline operations will utilize equipm ent and personnel on the OSRBOSR barge 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 (TF-7) would mobilize to deploy ex clusion 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 sp ill. Shoreline Protection Task Forces, involving free oil recovery, shoreline protection, and shoreline containment and recove ry are mobilized we ll 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 re spond to a blowout during conditions likely to be encountered during the drilling season. TF-1 and TF-2An OSRVOSV with 12,000 bbl (11,400 bbl at 95 percent capacity with sufficient) of storage for recovered liquids are staged near the Shell drillship and would be used to initiate response operations. TF-1 and TF-2This OSRV are outfitted to deploy boom, high capacity skimmers, and work boats for encountering and recovering oil surfacing from an uncontrolled well blowout. By Hour 42, TF-4 and TF-5 would arriveThe OSRV works to assist with containment, perform skimming operations, and lighter ing fluids to the OST (TF-3. The VOSS would possess sufficient skimming capability and liquid storag e capacity (minimum of 3,200 bbl) to maintain recovery operations during periods when the OSRV OSV 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 format ion of new ice (typically grease ice and the formation of thin continuous layers of ice). Any continuous la yers of ice, and even low concentrations of individual ice cakes or floes (such as 1/10 to 2/10 concentra tions), can obstruct containment or deflection boom, prevent oil from accumulating in lar ge pools, and block the flow of oil to ward a recovery device. As theseOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### conditions develop, the efficiency of physical containment and reco very tactics will be reduced. If ice concentrations threaten the structural integrity of equipment or prevent oil from being deflected or effectively contained, the offsho re response teams will use shorte r 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 increa se 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.

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 co ncentrations, until the conditions threaten the safety of personnel and/or the effective use of vessels. At this point, all phy sical 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 Tact ics 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 t he controlled burning of oil herded against large ice floes, trapped within heavy concentrations of ice, ac cumulated in thick layers against shorelines or landfast ice. When the presence of ice precludes th e 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 proc ess. In some cases, the energy induced from moving ice floes may also pr ovide 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 us ing combustion may continue into periods of light to moderate ice concentrations (including new, solid ic e 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 di rectly over the blowout. During early freezeup, icemanagement vessels upstream of the blowout can enha nce 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 ic e-free path and potentially enhancing the combustion process. Oil that escapes the burn at the surfacing plume will like ly 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 co mbustion during freezeup conditions would soon be encapsulated under a stable ice cover as new ice fo rms around and beneath the oil. The encapsulation process prevents oil from coming into contact with wildlife. Depending on the c oncentration 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 MMSBOEMRE , 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 so urce. Other markers may invo lve passive systems such as radar reflectors and brightly co lored floats and flags. Together with daily weat her recordings, satellite images and ice-movement modeling activities, the continued release and tracking of buoys will enableOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### 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 experienc e periods of little or no ice motion. During these periods oiled ice would remain relatively clos e to the spill source and be easier to track.

Proven techniques for the removal (or mining) of oil fr om 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 ice and in moving broken ice, it w ill be impractical and unsafe to work fr om on the ice surface of the oiled zone because of its movement and ext ensive ridging and rafting of the ice.

As longer periods of light occur and the ice begi ns 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 detec t, 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 drop lets will eventually surf ace and be herded by wind into pockets of oil that can potentially be ignited. Aerial ignition will co ntinue 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 ope n 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 [1 8 AAC 75.425(e)(1)(F)(vii)]

Recovery strategies are discus sed in the scenarios and Shell Beaufort and Chukchi Seas Regional Tactics Manual and the ACS Technical Manual.

Because of safety concerns, operations will be rest ricted 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. Pers onnel safety is Shell’s primary concern. The On-scene Safety Officer provides access zone info rmation and determines personal protective equipment (PPE) requirements. Access to the bl owout 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 volatile s 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 TF-1 consists of a dedicated on-site OSRVOSR vessel with a 12,000 bbl storage capacity (11,400 bbl at 95 percent capaci ty), two (2) brush skimmers; one (1) Transrec skimmer, three (3) 34-ft work boats; and open-ocean containment boom and fire boom. TF-2The VOSS consists of OSR barge with 76,900 bbl of onboard storage capacity and tw o (2) high-capacity weir skimmersis equipped with sufficient equipment and storage capacity to relieve the OSRVOSR vesselV for its transit and offload to the OST. Ten (10) knots is a realistic average trans it speed for planning purposes for each of these response vessels and the OST. Transiting at this speed, TF-1the 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). TF-2The VOSS will also be approximatelywithin 25 n mi of the drill ship and available to assist TF-1relieve the OSRV at hour 324 . The OST (TF-3) would arrive at the recovery site within 24 hr of departure from its staging area offOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### the Chukchi Sea coast. The tactics used for the positioni ng 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 planni ng 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 st orage. 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 OSRVOSR vesselsV (nominal stor age 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 wate r) 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.

TF-3The Arctic Class OST (minimum storage capacity of 513,000287,100 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 2 5, 05 00-bopd discharge escapes the primary offshore recovery efforts at the blowout. This unrecovered 2, 5 05 0 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 prev ailing east (E), northeast (NE), and east-northeast (ENE) wind directions of summer months. TF-6, consisting of a large, mob ile OSR barge and tug, will be mobilized from its staging location in Beaufort Sea and ar rive within 96 hr in the nearshore zone of the Chukchi Sea in order to best intercept and recover o il potentially threatening the coast, as water depth, weather, sea conditions and other ci rcumstances allow. TF-6 would be capable of transit speeds of 5 knots, ensuring arrival by Hour 96. In the unlikely event strong, sustained wind s develop out of the WNW, trajectory modeling estimates that six days is the ear liest possible time oil could reach shore, even if no containment and recovery operations were conducte d. The nearshore OSRB and tug are staged off the Chukchi Sea coast in the nearshore zone, as wa ter depth, weather, sea conditions, and other circumstances allow. The OSRB will generally be po sitioned 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 fo r oil recovery and support of the shoreline protection task force. TF-6The OSRB would be dispatched as needed to intercept the oil as described in the scenario. It is assumed that half of the oil reachi ng the nearshore environment is recovered by the skimming systems dispatched from the TF-6OSRB . The remaining 1,250 275 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. TF-6The 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 Nearshore OSRBOSR barge for recovered fluids.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### 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 cont ainers (e.g., Fast Tanks) for oily waste storage along the shoreline. Additional temporary storage w ill 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 t he burning of oily solids (w ood, vegetation and other combustible materials) at approved onshore burn si tes after a careful assessment of the risks and benefits of various controlled burns.

1.6.8 Lightering, Transfer, and Storage of O il from Tanks [18 AAC 75.425(e)(1)(F)(viii)]

Lightering, transfer, and storage of oil fr om 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 TF-6the OSRB for transfer to TF-3the OST

.
Heavy oil transfer pumps w ill be used to pump product from the mini-barges to TF-6the OSRB . These pumps are modified, positive displacement pumps that are hydraulically dr iven 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 TF-1, TF-2, TF-4, TF-5OSRV, and TF-6 will be retained onboard until transferred to TF-3the 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 OSR B vessels will be via installed cargo system or permanently installed, hydraulically driven GT-A heavy oil trans fer pumps. Each of the tanks on the TF-1 isOSRV 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 OSR vesselOSRV isare 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 OSRVOSR vessels near their capacit iesy , the recovered oily liquids are transferred to TF-3the OST . Stored liquids are gauged and manifested.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### 1.6.10 Temporary Storage and Dis posal [18 AAC 75.425(e)(1)(F)(x)]

Temporary storage of oil, oily wa ste, and debris recovered during a spill clean up may be provided by tanks located on the OSRVOSR vesselsV/VOSS/OSRB . The spill location or other logistical concerns may also require storage of oil, oily waste, and debr is 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 classifi ed and disposed of according to clas sification. 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. Applic ation for agency approvals are completed before the determined method of disposal is implemented.

Disposal and processing of recovered fluids trans ported to Prudhoe Bay will be in accordance with ACS Technical Manual disposal tactics D1 through D5. In the ev ent they are taken to Prudhoe Bay, recovered fluids would be handled in accordance with Ballot Agreements.

Recovered fluids stored onboard TF-3the 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 w ildlife by preventing birds and mammals from entering spill or containment areas. Containment areas w ill be monitored until USFWS and/or ADF&G determine that monitoring is no longer required. In general, wild life protection strategies in clude, 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, “Wildlif e Capture, Treatment and Release Programs, Chukchi Sea Oil Spill Response Planning.”
Bear awareness training will be prov ided to all operations st aff. Trained and certified bear guards will be deployed to support activities at risk of an encounte r with polar bears. In the event of an accidental release that may impact shoreline resources, additional certified bear guards and security staff would beOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### deployed to protect workers and polar bears. USFW S 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 dire ct 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 respons e program that incorporates dedicated response equipment assets and trained personnel provided by ACS. The nearshore TF-6OSRB 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, a nd shoreline protection systems will be pre-staged in Wainwright for rapid deployment of resources to im plement protection strategies and tactics. The response action time frame for pre-staged shoreline pr otection resources is estimated to be 12 hr, which includes mobilization (4 h r), transit (5 hr) and d eployment (3 hr) times. Task Forces have been established to handle free oil recovery operations, s horeline protection booming, and shoreline recovery and cleanup activities. Personnel from ACS, su pplemented 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 s horeline environments along the Chukchi Sea.

Tactics in the shallow coastal and nearshore environment s of the Chukchi Sea are best carried out using relatively small response boats. ACS can mobili ze 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 / s horeline 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 ar e 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, TF-6the OSRB provides a safe haven for personnel and vessels in the event of bad weather. TF-6The OSRB is capable of storing recovered oil /emulsion and debris and serves as a mobile staging platform for nearshore and shoreline pr otection operations along the Chukchi Sea coast. The TF-6OSRB platform, the equipment staged onshore, and supplemented with cascading resources from ACS that includes equi pment and responders (ACS and ACRT), provides a flexible yet rapid response capability sh ould a spill occur in the Chukchi Sea.

Experience has shown that small response boats, wo rking with shallow-draft mini-barges (249-bbl capacity) are ideal for easy maneuvering in thin ice and around ice cakes. Anothe r advantage of the minibarges is that on their return from lightering their contents at TF-6the OSRB , they can be used as cargo platforms to carry equipment and supplies for t he ongoing nearshore and shoreline operations.

Evaluations have been made of the likely spill trajectori es that could result fo r a number of hypothetical spills from Shell’s offshore operati ons. The oil spre ad and transport calculations suggest that shoreline exposures are unlikely and, if oc curring, would not normally involve more than a few high-priorityprotection sites at a time, and that even under infr equent, 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 MMSBOEMRE ’ s 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 t he Chukchi Sea, trajectory analyses suggest that itOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### is highly unlikely that oil could im pact the nearshore environment in le ss 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 prot ection 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 th rough 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 thes e tactics because of the br oad range of shoreline, weather, and ice conditions that could exist during the drilling season.

Priority Protection Sites
In addition to the consideration of appropriate s horeline tactics and equipment, an assessment has been conducted of the Chukchi Sea shoreline from Point Ba rrow 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 pr otect valuable resources. Maps identified in Table 1.6-1, Figure 1.6-1, and the ACS Map Atlas , present the priority protection control sites.

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 resour ces (personnel, boats, skimmers, and booms) required for shoreline protection and cleanup; and

 

### The weather and environmental conditions (preva iling and extreme event s) 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 physica l processes, the nature and amount of oil thatcould 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 par t, by the speed with whic h natural processes might remove oil that is stranded on the shoreline, and t he 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 sensitiv ity 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 MMSBOEMRE

. The ESI rankings reflect the fact that areas exposed to high levels of physical energy generally have low biological activity and rank lo w 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 ShoresOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### 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 S heltered 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 cr itical element when considering priority protection sites. Biological information about animal and plant species is also prov ided 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 biologica l 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 S ensitive Areas Work Gro up (NSSAWG), consisting of representatives from several federal, state, and lo cal 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 c ontrol 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 shore line 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 Nort h Slope Atlas, along with the priority protection sites indicated in the ACS Map Atlas , to consider the nature and extent of resources (vesse ls, barges, booms, skimmers, response equipment, and personnel) to prov ide a timely and effective nearshore and shoreline
response.

Shell has also identified biological resources using an unpublished report by Woodward-Clyde Consultants (WCC), Walnut Cree k, California, to NOAA Assessment Division, Anchorage, Alaska (Robilliard et.al. 1985, Chukchi Sea Coastal Studies: Coastal Geomorphology, Environmental Sensitivity,Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### and Persistence of Spilled Oil ). This report identifies key biological resources in the region of concern including: spotted seals, beluga whales, alcids (m urres 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 c oast, 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 protec tion control sites listed within these general locations). The identification of these recomme nded primary protection priorities is based on a combination of the biological reso urces at risk and existing human use activities. The seven areas include:

 Barrow*

 Peard Bay - Franklin Spit

 Wainwright Inlet

 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 as terisk *) 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 seve n areas are characterized by a sheltered lagoon environment which is connected to t he Chukchi Sea by a tidal inlet or in lets 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-C ape 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 communi ty lives at the shoreline. A di stinction is made between the five primary protection strategic coastal areas, which co ver 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 co nsidered secondary priorities as the areas at risk are small in area compared to the recommended pr imary protection priorities. They include:

 Will Rogers Memorial

 Sinaruruk RiverOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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###  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 inle t 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 consi deration when selecting sites for protection. For example, the distribution and habitat use by Pacific wa lruses 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 ic e 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 sh ore, 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### TABLE 1.6-1 SHORELINE PROTECTION ASSESSMENT FOR POINT BARR OW TO CAPE LISBURNE

PRIORITY PROTECTION SITES ACS MAP REFERENCE LATITUDE LONGITUDE TACTICS (SHELL / ACS)

PPS-168 255 70 o 49' 53.185" N 158 o 1' 39.197" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-169 255 70 o 49 13.442" N 158 o 9' 37.538" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPA-6 254 70 o 53' 42.218" N 158 o 37' 30.199" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-170 254 70 o 47' 8.256" N 158 o 46' 27.046" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-171 254 70 o 49' 0.019" N 159 o 5' 18.898" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-172 253 70 o 48' 37.548" N 159 o 34’ 13.815" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-173 253 70 o 47' 38.500" N 159 o 38' 39.616" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-174 251 70 o 41' 41.453" N 159 o 54' 18.290" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-175 250 70 o 36' 23.573" N 160 o 6' 28.296" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-176 250 70 o 33' 45.189" N 160 o 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 70 o 22' 22.289" N 160 o 48' 53.117" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-182 245 70 o 19' 43.550" N 161 o 4' 14.960" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-183 244 70 o 17' 35.105" N 161 o 17' 40.446" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-184 243 70 o 18' 2.618" N 161 o 57' 2.174" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-185 243 70 o 15' 48.348" N 162 o 5' 6.019" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-186 240 70 o 5' 3.034" N 162 o 30' 33.825" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-187 239 69 o 53' 57.607" N 162 o 49' 46.298" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-188 238 69 o 45' 44.075" N 162 o 57' 54.774" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-189 237 69 o 44' 47.162" N 163 o 3' 39.277" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-190 237 69 o 40' 22.579" N 163 o 6' 2.442" W SR-2, SR-3, or SR-4 / C-13 or C-14Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### TABLE 1.6-1 SHORELINE PROTECTION ASSESSMENT FOR POINT BARR OW TO CAPE LISBURNE

PRIORITY PROTECTION SITES ACS MAP REFERENCE LATITUDE LONGITUDE TACTICS (SHELL / ACS)

PPS-191 235 69 o 27' 23.872" N 163 o 8' 26.842" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-192 235 69 o 24' 53.101" N 163 o 8' 23.636" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-193 233 69 o 15' 17.732" N 163 o 19' 39.914" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-194 233 69 o 14' 8.612" N 163 o 21' 28.840" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-195 233 69 o 12' 3.518" N 163 o 26' 15.885" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-196 232 69 o 8' 22.200" N 163 o 31' 47.420" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-197 230 68 o 54' 51.072" N 164 o 37' 17.810" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-198 229 68 o 53' 29.219" N 164 o 53' 44.537" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-199 228 68 o 51' 38.879" N 165 o 47' 27.582" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-200 223 68 o 25' 10.566" N 166 o 23' 36.592" W SR-2, SR-3, or SR-4 / C-13 or C-14

PPS-201 223 68 o 20' 18.368" N 166 o 50' 40.762" W SR-2, SR-3, or SR-4 / C-13 or C-14OPS9il Discharge PreventioPart 1 – Response ActioShell95-2000.01-25.201-001on and Contingency Plaon Plan/09-018nFCHUKCHI SEASACS MAPA1-41IGURE 1.6-1SHORELINE PRATLAS SHEET IOTECTIONNDEXChukchi Sea Regional ExpMarcloration Programh 2010May 2011Rev.10OPS9ConcentdiversionOil Discharge PreventioPart 1 – Response ActioShell95-2000.01-25.201-001SHORELINEtration of oil atn of oil away fromon and Contingency Plaon Plan/09-018FIGURE 1.6CONTAINMENTnatural and/ormmpriority protectioan6-2AND PROTECTman-made collecon sites.TIONction sites and1-42SHODeflection ofstorage of recoil.ORELINE CONTAfoil toward shorcovered oil in blaChuFIGURE 1.6AINMENT ANDRre for recoverywadders or Fast Takchi Sea Regional ExpMarc6-3RECOVERY OPEwith portable skianks, and burningloration Programh 2010May 2011Rev.10ERATIONSimmers. Temporgof isolated poolsaryofOil Discharg e Part 1 – Res p

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### e tlandOPS9RecovenearshoOil Discharge PreventioPart 1 – Response ActioShell95-2000.01-25.201-001NEARSHOery of oil that isore. Transfer of thon and Contingency Plaon Plan/09-018FIGURE 1.6ORE RECOVERYswind-herdedahe recovered oildan6-6YIN BROKEN ICEand trapped withdirectly to a miniEhin ice cakesbarge.1-44Heli-torch igniBurning withgthe oil.NEARSHORition of oil that isgelled fuel igniterChuFIGURE 1.6-7RE IGNITION OFswind-herded anrs released upstrkchi Sea Regional ExpMarcOIL IN ICEnd trapped withinream and allowedloration Programh 2010May 2011Rev.10nice cakes.dto drift intoOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-45 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### For planning purposes, Shell is using the priority pr otection 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 dischar ge and the safety of all personnel associated with the drilling pr ogram, the second highest priority w ill be the protection of the environment which will be achieved by containment, recovery, and/or elimi nation 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 su stained winds direct it to shor e, Shell will have planned and implemented protection strategies through their near shore program and the shoreline protection program.

1.6.13 Spill Response Scenarios

Introduction

The ADEC Response Scenario/MMSBOEMRE WCD Scenario contained herein was prepared to comply with both MMSBOEMRE regulations found in 30 CFR 254.26 fo r the discussion of the WCD scenario . A scenario is also presented that complies with , 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 MMSBOEMRE and ADEC requ irements, 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 MMSBOEMRE “in adverse weather conditions” with equipment that is “suitable, within the limits of current te chnology, for the range of environmental conditions” anticipated . This response strategy also provides for the , and the ADEC requirements for a response strategy accounting for variations in receiving environm ents and seasonal conditions. The response strategy also illustrates additional spill response ca pabilities 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 Blow out in Varying Ice Conditions (Table 1.6-10)

 

### Response Strategy 2, Offshore Fuel Transf er Release During Summer Months (Table 1.6

- 11)

 

### Scenario 2, ADEC Specific Scenario, Unc ontrolled Sub-Sea Well Release During Summer Months (Tables 1.6-12 to 1.6-13)

The following scenarios and strategies were developed in accordance with MMSBOEMRE regulations in 30 CFR 254.26; 18 AAC 75.425(e)(1)(F); and 18 AAC 75.445(d) as applicable . 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 displa y 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

.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-46 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### Alternative countermeasures such as in situ burn or dispersant application could be used in a spill response to reduce oil impacts, re gardless of whether a scenario hypothesizes that these measures help meet to the RPS.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-47 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

## WORST CASE DISCHARGE SCENARIO 1

ADEC Response Scenario Minerals Management ServiceBOEMRE

Subsea Well Blowout During Summer MonthsOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-48 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

## THIS PAGE INTENTIONALLY LEFT BLANKOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-49 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

## SCENARIO 1 QUALIFICATION STATEMENT

This WCD scenario was prepared to comply with both MMSBOEMRE 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 ev ent of a WCD. The scenario make s certain assumptions about spill conditions and describes equipment, personnel, and stra tegies that would be used to respond to a WCD.

The response timelines are provided for illustration only. Spill response de cisions depend on safety considerations, weather, and other environmental condition s. It is the discretion of the IC and persons in charge of the spill response to se lect any sequence or ta ke 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 per mits 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-r egion resources if needed.

How the Scenario Complies with the MMSBOEMRE Requirements
The scenario provides a simulation of a WCD with th e type of responses that could be employed, to the maximum extent practicable.

Table 1.6-2 addresses how the scenario meets the MMSBOEMRE 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 ar e provided in the table. These documents are publicly available at MMSBOEMRE and ADEC, along with the Shell Beaufort and Chukchi Seas Regional Tactics Manual , and ACS Technical Manual

.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### TABLE 1.6-2 SUMMARY OF HOW THE WORS T CASE DISCHARGE SCENARIO COMPLIES WITH MMSBOEMRE REGULATIONS

MMSBOEMRE 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 RPSa worst case discharge of 25,000 bopd daily volume for an exploration well blowout of 5,500 bopd

. See the OPA 90 MMSBOEMRE crossreference 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

, and OSRVOSVR vessels, 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 Part 1 – Response Action Plan 

### TABLE 1.6-2 (CONTINUED) SUMMARY OF HOW THE WORST CASE DISCHARGE SCENARIO COMPLIES WITH MMSBOEMRE REGULATIONS

Shell 1-51 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 MMSBOEMRE 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 MMSBOEMRE 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.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 MMSBOEMRE REGULATIONS

Shell 1-52 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 MMSBOEMRE 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 OSRVOSR vesselV is assigned to the drillship during critical drilling operations. A description of the OSRVOSR vesselsV, 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, in cluding 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 OSRVOSR vesselsV 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 MMSBOEMRE REGULATIONS

Shell 1-53 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 MMSBOEMRE REGULATION SUMMARY REFERENCE
30 CFR 254.26(d)(4)(iv) Equipment Loadout Time Initial response vessels and equipment are contained on the OSRVOSR vesselsV. An OSRVOSV and VOSS are that are assigned to a regional area in which the drillship isconducting drilling into liquid hydrocarbonbearing 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 MMSBOEMRE REGULATIONS

Shell 1-54 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 MMSBOEMRE 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 OSRVOSR vesselsV 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 env ironmental 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 2Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### 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 2 5, 05 00 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 751650 ,000 bbl of crude oil over 30 days.

For the purposes of the C-Plan, Alaska North Slope (ANS) crude oil is used bec ause it is representative medium weight oil (25 to 30° American Petroleum In stitute [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 ve ctors: 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 curr ent data used for trajectory modeling was based upon the MMSBOEMRE annual means analysis of Haidvogel, Hedstrom, and Francis (2001) coupled iceocean model. Wind data used for the trajectory modeli ng were collected by Shell from 22 locations in the Chukchi Sea during June through November for the y ears 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 orig inated from the NE to so uthwest (SW) 54 percent of the time and the northwest (NW) to SW 23 perc ent of the time during the June through November period. Three predominant wind directions had a measured frequency of occurrence greater than 10Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-56 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### 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 blow out rising through the water column and surfacing above the well location. The trajectory simulation mo ves and spreads the oil under the influence of local winds measured at the closest station for t he August 7 to September 6 time period and the MMSBOEMRE ocean-current 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 direct ed 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 contai nment 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, o ffshore 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 northwest erly winds develop, potentially affe cting the shorelines from Peard Bay to Kasegaluk Lagoon, SW of Wainwright. Therefore, the response scenario plans to deploy resources to implement shoreline protection and reco very 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 BOEMRE 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 ocean-current information for winter and summer seasons and annual conditions. The wind, ice, and ocean-currents 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 hy pothetical launch area will contact a specific land segment or environmental resource area within a given time frame.

The BOEMREMMS report reveals probabilities of oi l contact from a large oil spill ( ≥ 1,000 bbl) during the drilling season to individual land segments to be typi cally 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 BOEMREMMS 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 effectiveOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### response is mobilized and protective measures are implemented before oil impacts priority sites (see 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 occupyi ng the path of the spilled oil. Many of these resources are important both ecologically and econo mically. Three principal sources contain reference information on the biological and cultural resource s 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 di stribution of marine mammals and birds in the spill vicinity and simulated trajectory path. Endang ered and threatened species are also identified with notes describing protection strategies. Shoreline habita ts 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 reso urces 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 reduc e the quantity of oil available to move away from the blowout into sensitive areas late r. The second principal strategy is to contain and recover oil that has escaped the primary recovery operations. This sec ondary recovery would encounter oil using Shell’s Nearshore OSRBOSR barge and self-propelled skimming vessels and boom. The third strategy is for ACS to deploy exclusion and deflection boom at selected shoreline priority protecti on sites. All of these priority protection sites are identified in Table 1.6-1 (refer to ACS Technical Manual, Volume 2 for map reference sheets) and currently under review for the ACS Technical Manual , Volume 2

.
In order to protect shoreline priority sites from o il that escapes the offshore oil removal task forces, responders deploy equipment from the Nearshore OSRBOSR barge and onshore staging areas. The teams consist of ACS and ACRT personnel from the OSRBOSR barge 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 OSRBOSR barge , including vessels, boom, skimmers, and minibarges. 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 mo bilize by air NSSRT, ACRT, and VRT responders to shoreline staging areas, and then crews would travel by helicop ter, 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 hazi ng. Wildlife management plans and protective hazing permits would be coordinated and ap proved by resource trustees. Trai ned 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 t he wildlife stabilization facility at Prudhoe Bay. AnimalsOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-58 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### requiring further treatment are transported to the Al aska Wildlife Response C enter in Anchorage. See ACS Technical Manual Tactics W-1 to W-6 for decision-making and field procedures.

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 Conditio ns section of the scenario. In addition, skimmer capacities are derated to reflect the effects of adv erse weather, among other factors. Adverse weather conditions involving low temperatures and va rying ice conditions are demonstrated in the ADEC Response Strategy following th e is 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 lo ad 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 scenari o. 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 1-59 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### 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 WCDRPS Volume = 2 5, 05 00 bopd x 30 days = 750,000165,000 bbl

No deductions were made to the WCDRPS 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 o il 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 to tal 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 di rection 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 measur ed 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 4 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 Fr ancis (2001) coupled ice-ocean model.

Visibility Variable

Surface The prospect is located in federal waters in the Ch ukchi 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 OSR vessel V and OSR bargeVOSS , and the OST is located 240 n mi (or less) from the drill site. The OSR vessel B is located within 10 n mi of the drillship. Ba sed upon a realistic average transit speed of 10 knots, the OST is located in the Chukchi Sea to ensure it s arrival at the recovery site within 24 hr of mobilization. Similarly, the OSR vessel VOSS is positioned to arrive within 1 hr andbefore the OSR barge is staged to arrive within 3 hr.V 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 1-60 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 INITIAL CONDITIONS

Trajectory Modeling of the oil plume trajectory was c onducted by ASA using historical wind data and the MMS hydrodynamic ocean-ice current model.
The trajectory model uses OILMAP softwar e developed by ASA. Based on environmental conditions including predominant wi nds 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 2 5, 50 00 bopd using ANS crude oil with API gravity of 30.6°. The ASA trajectory model was run using histor ical 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 fr om the blowout and slick direction.
The simulated oil discharge of 2 5, 50 00 bopd is ejected through a 6-inch ID well at the mudline, in water approximately 140 ft deep. Within minutes of t he blowout, oil rises to the surface of the sea. The oil plume migrates to the southwest as a f unction 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 NESW of the blowout for approximately 1732 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 1-61 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### 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 c ontrol 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 2 5, 50 00 bopd.
The On-Site Shell Drill Foreman notifies the On-Scene Incident Commander (OSC) who notifies response personnel on the OSRVOSR vessel accompanying the drillship. Notifications to appropriate state and f ederal 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 OSRBOSR barge staged within 3 hr transit time of the drill site and VOSSs ( staged in the Beaufort Sealocated at a maximum distance of 4 82 0 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 situati on and verifies that all sources of ignition are shut down or removed from the area. T he Site Safety Officer provides access zone information and determines PPE requirements. Monitoring protocol is established for all work areas to ensure personnel protec tion. The monitoring protocol establishes safety zones according to applicable Occupat ional Safety and Health Administration (OSHA) and fire hazard standards.
The OSC determines that ignition of the bl owout 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 per sonnel required for well control arrive at the drillship. Potential subsurface control meas ures 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 planOil 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 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE
(iv) Surveillance and Tracking of Oil Oil movement is tracked using a combi nation of visual observations and remote sensing techniques. Fix ed-wing aircraft and helicopters are used to provide surveillance and remote-sensing systems. Ae rial overflights include spill tracking, vessel movements, wildlife monitoring, and operational system performance.
Response vessels deploy buoys with transmi tters. 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 res ponse 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 obs erved 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 NESW 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 2 58 . However, in the unlikely event strong, sustained winds dev elop out of the WNW, trajectory modeling estimates that 6 days is the earliest possi ble time oil could reach shore. As a precaution, ACS mobilizes to implement protection strategies at priority resource sites. In addition to ACS, the Nearshore OSR barge (TF-6) B is mobilized from its staging location in the Beaufort Sea to arrive into the Peard Bay vicinity within 4 days to support nearshore protection and recovery if sustained WNW winds develop.
Based on trajectory calculations and oil tracking for sustained WNW winds , a 50-mi section of coastline consisti ng of barrier islands and expos ed mainland is identified as the potential impact zone. Protection site s (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 r epresentatives to prioritize resource sensitivities and activate protection guideli nes. 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 shore line protection plan, and Shoreline Cleanup Assessment Teams (SCAT) are placed on standby.
T+4 Days . ACS Shoreline Protection Task Forc es 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. T F-6 he OSRBOSR barge 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 effect ive shoreline respons e 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-14Oil 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 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 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 OSR vesselV and is stationed at or near the drillship. Response assets include an OSR vesselV 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 minibrush/disc skimmer; offshore contai nment boom; water-cooled fire boom and dispersant application capability. TF-1 arrives at the spill site within one hr.

TF-2 consists of the OSR bargeanchor handler, Tor Viking or similar vessel, functioning as a VOSS with a minimum storage capacity of 76,9003,200 bbl. Response assets aboard the OSR bargeVOSS include twoone ( 21 ) Transrec 150 skimmer s . TF-2 is staged approximately 25 n mi fromassists the drillship to move off site and arrives to relieve the OSRV at hour 324

. 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 513,000287,100 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 VOSS with a minimu m storage capacity of 13,000 bbl. Responseassets aboard the VOSS include one (1) Transrec 150 skimmer. TF-4 arrives onscene from its staging location at hour 42.

TF-5 consists of a VOSS with a minimu m storage capacity of 8,000 bbl. Response assets aboard the VOSS include one (1) Transrec 150 skimmer. TF-5 arrives at the scene from its staging location at hour 42.

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- 56 consists of the Nnearshore OSR barge B with 18,636-bbl of onboard storage (17,000 bbl for planning purposes). The OSR bargeB is mobilized from a staging area within 480 n mi of the Chukchi Sea nearshore zone , arriving on location within 96 hr. The OSR bargeB provides a mobile on-water recovery system and staging platform. The OSR bargeB is equipped with two (2) Lamor LSC-5 skimmers; one (1) 47-ft skimming vessel with built-in Lamor LORS-2 C 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 mini-brush/disc skimmer; and one (1) 100-bbl storage bladder.

TF- 67 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 OSR bargeB . 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- 87 consists of ACS response equipment and personnel (ACS, NSSRT, ACRT, and VRTs) mobilized to perform shoreline cl eanup. Based upon shoreline type and oiling conditions, cleanup is performed by 6 or 7 st rike teams. Containment and recovery tactics are used to remove oil from the s horeline. The recovered oil is stored in temporary holding containers (portable fo lding 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 Shell OR-2A, OR-2B, OR-10, OR-8

ACS R --18, R-20

Shell OR-2B (modified)

Shell OR-10

Shell OR-3A ACS R-20 (modified)

Shell OR-3A

Shell OR-10

ACS R-18,

R-32A

Shell OR-9A

Shell OR-1A, OR-1B, OR-4A, OR-4B, OR 5B

ACS C-13, C-14

Shell SR-3, SR-4, SR-5

ACS SH-3, SH-5 through SH-12Oil 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 1-64 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE 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 255

, 05 00 bopd ( 1,042229 bbl/hr) will be used for mechanical recovery calculations. The recovery rate is based upon the planning assumption that a 90% fraction of the daily release volume (938 bbl/hr) remains offshore for recovery and a 10% fraction (104 bbl/hr) may escape the primary offshore recovery operations and drift toward the nearshore and shorelines.
The drillship is relocated a safe distance from any surfacing oil and gas. TF-1 deploys two (2) 34-ft work boats with a n 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 Jboom configuration to recover oil. TF-1The 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 + 3 Hours. TF-2 (OSR barge) arrives on-scene, equipped with two (2) Transrec 150 skimming systems. TF-2 replaceslieves TF-1 to work in conjunction with the two (2) 34-ft workboats towing U-boom. TF-1 and one (1) 34-ft workboat continue skimming operations in a J-boom configuration. TF-1 reaches its storage capacity at Hour 24 and proceeds to the OST to lighter. TF-2 has sufficient storage capacity to conduct continuous skimming operations until Hour 48 before lightering to the OST.

T + 24 Hours. 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-1 proceeds to the OST and lighters its recovered fluids.

T + 42 Hours. The drillship is relocated a safe distance from any surfacing oil and gas. The VOSS ( TF- 42), and TF-5 arrive on-scene. TF-4 and TF-5 are each equipped with one (1) Transrec 150 skimming system . TF-2 continues recovery operations in configuration with the two (2) 34-ft workboat s towing U-boom. TF-5 initiates skimming by deploying its Transrec 150 skimming system into a J-boom configuration towed by a 34-ft workboat (provided by TF-1).

T + 48 Hours. TF-1 and TF-4 , relieve s the OSRV (TF-1TF -2 1) and TF-5 to lighter theirits recovered fluids to the TF-3 OST. TF- 21 and TF-4 ha sve sufficientenough storage capacity to store recovered fluids for 24eight hr of skimming during which time lightering operations from TF-2the OSRV and TF-5 to the OST are completed. TF-2 lightering operations, including transit time and offloading can be conducted in approximately 10 hr and TF-5 can be completed within 6 hr. The TF-1 relieves TF-2 toVOSS work in conjunctions with the two (2) three (3) 34-ft workboats towing U-boom while from TF- 41 relieves TF-5 to deploy its skimmer within the J-boom towed by a workboat.

T + 72 Hours. . standby location not farther than 240 n mi from the drill site. The primary objective of TF-3 is to provide o ffshore 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 TF-1 and TF-4 disengage to conductOSRV lightering operations to the OST, while TF-2 resumes skimming with two (2) Transrec skimmers within the U-boom towed bymaintains two (2) 34-ft workboats with open apex U-boom and TF-5 resumes skimming in J-boom configuration.configurati on downstream of the blowout to containand collect surfacing oil for recovery by the VOSS with one (1) Transrec skimmer in Jboom configuration. TF-2 and TF-5 work in a 24 hr rotation cycle with TF-1 and TF-4 with two task forces recovering oil and two task forces lightering to the TF-3 OST.
During the 824 -hr timeframe set forto complete lightering fromfrom TF-1 and TF-4 the OSRV to the OST beforeand return toresume skimming, TF-2the VOSS and TF-5 encounter s approximately 1 1, 833256 bbl ( 938229 bbl/hr) of surfacing oil and jointly possesses more than sufficient the capacity to store the 3,200 bbl of recovered Shell OR-2 A, OR-2 B, OR-8 OR-10

(Table 1.6-5)

Shell OR-2B, OR-10 ACS R-18, R-20

Shell OR-2B (Table 1.6-5)

Shell OR-3A

Shell OR-2B OR-10

ACS R-20 (modified)

Shell OR-2B, OR-3A

ACS R-18, R-32A

Shell OR-1A, OR-1B

Shell OR-2B, OR-3A

Shell OR-3AOil 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 1-65 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE oilliquids (400 bbl/hr x 8 hr)

. The At Hour 96. TF- 21 and TF-4 relieve TF-2 and TF-5 to maintain recovery operations . Wwhile TF-2 and TF-5 lighter. .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 mechanica l recovery techniques, or if surface oil presents a significant threat to sensit ive environmental resources. To augment mechanical response operations , a request and application to authorize dispersant use is submitted to the UC.
An aerial dispersant task force (d esignated TF-D) is deployedTF-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 shoreli ne, nearshore assets would be mobilized to implement nearshore response, shoreline prot ection 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- 6 , consisting of a Nearshore OSR bargethe 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- 65 targets free oil in windrows and linear slicks. In addition to the OSRBOSR barge with twop (2) LSC-5 skimmers, TF- 56 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 wo rk boat shuttles personnel, supplies, and four (4) mini-barges.

TF- 76 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 c onsisting of (2) landing craft; two (2) work boats; 10,000- ft conventional boom; 10,000-ft coastal boom (6,000-ft from TF-6OSRB and 4,000-ft pre-staged); and 3,000-ft shore seal boom. TF- 67 is also supported by TF-6the OSRB and its personnel and equipment. ACS cascades additional crews, boom and workboats to priority protection sites sele cted by the UC. Exclusion and deflection boom is deployed within 6 days (the predicted ea rliest time oil may reach shorelines if sustained northwesterly winds develop).

TF- 87 is mobilized by ACS from Prudhoe Bay to stage equipment and personnel for shoreline cleanup operations in the unlikel y 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 confi guration and recover oil with a skimmer into Fast Tanks or bladders. One team works 10 lo cations 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 shifts from the NE to moves in a southwesterly direction away from shorelines. After Day 2114 , trajectory modeling predicts oil to begin s drifting to the NNE. Oil recovery vessels adjust their location to maintain containment and recovery operations. T + 20 Days. A Shell-chartered OST arrives on-scene to join TF-3 and supplement storage of recovered oil. The secondary OST relieves the initial OST as it approaches ACS R-18, R-32A

Shell OR-9A, OR-8

Shell OR-9A, OR-8

ACS C-13, C-14

Shell OR-1A, OR-1B OR-4A,OR-4B, O rR -5A, O rR5B

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

Shell SR-1, SR-5, SR-6, SR-7, SR-8, SR-9, SR-10

ACS R-16

Shell OR-2B, OR-10Oil 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 1-66 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE its fill capacity. The second OST (minimum storage of 250,000 bbl) possesses more than sufficient capacity to storage all recovered oil for the duration of the response. T + Day 2 85

. A low probability exists for oil to reach shorelines. As predicted by trajectory modeling using historical wind dat a collected by Shell for the initial blowout date and duration, the earliest that oil could contact shor elines is Day 2 85 . Nearshore recovery operations would be conducted using TF-6the 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- bargebarge s to recover bands of oil approaching shore. TF-6The OSRB ’s storage capacity is sufficient to collect and store all nearshore recovered liquids for more than six days

. Upon reaching capacity, TF-6 transits to the OST staged offshore for lightering. Transit and lightering operations are completed in approximately 10 hr timeframe. TF-6 resumes recovery and nearshore support operations following each lightering cycle.

In the unlikely event oil contacts shoreline, TF- 78 teams would be mobilized to implement shoreline recovery and cleanup stra tegies. 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 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 TF-1, TF-2, TF-4 and TF-5OSRV, VOSS, and OSRB to the OST. Based on a maximum WCD of 5,500 bbl/day (o r 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 and TF-2 have a combinedOSRV has 11,400 bbl 88,300 bbl of storage volume (95 percent capacity). Th ise 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 42, TF-4 and TF-5 arrive on-scene. 24, the VOSS replaces As TF-1the OSRV as it dis engages in lightering operations,from skimming operations, transits to the OST, and commences offloading recovered fluids. The VOSSTF-5 and a 34-ft workboat s replace TF-1the OSRV to continue skimming operations with TF-2 and provide additional interim storage. At Hour 48, TF-1 and TF-4The 34-ft workboats maintain the open apex U-boom configuration safely downstre am of the blowout to direct surfacing liquids for collection by the VOSS. The VOSS replace TF-2 and TF-5 in order to resume skimming operations while TF-2 and TF-5 disengage to conduct lightering to the TF-3 OST. initiates lightering operations to the OST following the resumption of recovery by the OSRV. Skimming and lightering operations ar e scheduled on a 24-hr rotation basis. For the duration of the response, TF- 1 and TF-4the OSRV and VOSS would set up a rotation cycle with TF-2 and TF-5the 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 TF-3 OST. The OSRV is equipped with eight (8) positive displacement hydraulic screw pumps for lightering operations. Each pump has a maxi mum 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 emul sification factor plus 20% retained free water). For planning purposes the OSRV co mpletes lightering operations to the OST within 8 hr. Shell OR-3A

Shell OR-3AOil 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 1-67 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE

The OST is staged approximately 25 n mimaintained in close proximity, typically a mile or two, from the offshore recovery operations and approximately 35 n mi from nearshore operations so that transit times to and from the OST are kept to a minimum. The transfer of recovered fluids (afte r 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 trans fer pumps and annulus injection, each vessel transfer from TF-1, TF-4 and TF-5the OSRV to the OST should require between only 3 to 4 hr with an additional 3 to 4 hr factored in for setup and transit to and from the OST. TF-2 would require approximately 5 to 6 hr for transfer and 3 to 4 hr for setup and transit. The VOSS lighters to the OST when the OSRV resumes recovery operations. Using high-volume transfer pumps ensure, the VOSS offloading requires less than the 2416 hr available for TF-1, TF-4 and TF-5 and 12 hr for TF-2 to complete transfer operations and transit to and from the OST. (ix) Transfer and Storage of Recovered Oil/Water; Volume Estimating Procedure Stored oilliquids isare offloaded from the OSRVOSR vessels and VOSS to the OST. Recovered oilLiquids from the nearshore skimmer vesse ls are stored in mini-barges and transferred to the TF-6 OSRBbarge

. Liquids recovered by the shoreline recovery task forces are stored in Fast Tanks, bladders, mini-barges, or mobile tanks. Fl uids may be transferred to secondary storage containers. See Section 1.6.10.

Stored oil emulsion and free water areis 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 s ubmitted 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 di sposed 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 operat ions. 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 res pond 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 t he lease areas, there exists a very low probability that oil will reach the Chukchi Sea coastline. However, for planning purposes, the contingency plan addresses near shore free oil recovery, priority protection sites, and s horeline cleanup techniques.
It is anticipated to take at least six days for o il 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, prio rities 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. ACS SH-1Oil 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 1-68 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE

Shoreline response would consist of AC S mobilized personnel (ACS, NSSRT, ACRT, and VRT), equipment from Chukchi shore-based staging areas, Prudhoe Bay, and the nearshore TF-6the 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 tr enching 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-10Oil Discharge Prevention and Contingency PlanChukchi Sea Regional Exploration ProgramPart 1 – Response Action PlanShell1-69March 2010May 201195-2000.01-25.201-001/09-018Rev.10TABLE 1.6-5WELL BLOWOUT IN SUMMERDERATED POTENTIAL RECOVERY CAPABILITYABCCDEFGHIJKLSHELL / ACSSPILLRECOVERYTACTICRECOVERYSYSTEMNUMBEROFSYSTEMSDERATEDRECOVERYCAPACITYPERSKIMMER1, 2(BBL/HR)SCENARIORECOVERYRATE3, 4(BBL/HR)MOBILIZATIONAND TRANSITTIME TO SITE(TIME)OPERATINGTIME ONDAY 1(HR/DAY)DERATEDRECOVERYRATECAPACITYONDAY 15[BBL/DAY](C X EDX G)24 HR OPERATING PERIODS48 HR OPERATINGPERIODSDERATEDRECOVERYCAPACITYON DAY 25,6(C X D X 24 HR)DERATEDRECOVERYCAPACITYON DAY 35,6(C X D X 24 HR)DERATEDRECOVERYCAPACITYON DAY 45,6(C X D X 24 HR)DERATEDRECOVERYCAPACITYAFTER DAY 47(C X D X 24 HR)OFFSHORE RECOVERYTF -1:ShellOR-2A,OR-2BLamor LSC-52258938<1 hr2311,868012,384012,384TFTF-2:ShellOR2B10Alternative 2:TF -1:ShellOR-2B,OR-10Transrec 150 –400 cu m/hr(2,516 bbl/hr)derated to 20%nameplatepump rate(20% x 2,516bbl/hr = 503bbl/hr)LamorLSC-5 205 cum/hr (1,289bbl/hr) deratedto 20%nameplatepump rate(20% x 1,289bbl/hr = 258bbl/hr25032589384003 hr<1 hr212321,1269,60024,1441606,40024,1441624,1446,400TF-42:ShellOR-10Transrec 150–400 cu m/hr(2,516 bbl/hr)derated to 20%nameplatepump rate(20% x 2,516bbl/hr = 503bbl/hr)15034009382442hrs0 08012,0723,200803,20012,072TF-5:ShellOR-10Transrec 150 –400 cu m/hr(2,516 bbl/hr)derated to 20%nameplatepump rate(20% x 2,516bbl/hr = 503bbl/hr)150393842 hr003,018012,07212,072Oil Discharge Prevention and Contingency PlanChukchi Sea Regional Exploration ProgramPart 1 – Response Action PlanTABLE 1.6-5 (CONTINUED)WELL BLOWOUT IN SUMMERDERATED POTENTIAL RECOVERY CAPABILITYShell Offshore Inc.1-70March 2010May 201195-2000.01-25.201-001/09-018Rev.10ABCCDEFGHIJKLSHELL / ACSSPILLRECOVERYTACTICRECOVERYSYSTEMNUMBEROFSYSTEMSDERATEDRECOVERYCAPACITYPERSKIMMER1, 2(BBL/HR)SCENARIORECOVERYRATE3, 4(BBL/HR)MOBILIZATIONAND TRANSITTIME TO SITE(TIME)OPERATINGTIME ONDAY 1(HR/DAY)DERATEDRECOVERYRATECAPACITYONDAY 15[BBL/DAY](C X EDX G)24 HR OPERATING PERIODS48 HR OPERATINGPERIODSDERATEDRECOVERYCAPACITYON DAY 25,6(C X D X 24 HR)DERATEDRECOVERYCAPACITYON DAY 35,6(C X D X 24 HR)DERATEDRECOVERYCAPACITYON DAY 45,6(C X D X 24 HR)DERATEDRECOVERYCAPACITYAFTER DAY 47(C X D X 24 HR)NEAR SHORE / SHORELINE RECOVERYTF-65ShellOR-1A,OR-1BLamor LSC5205 cum/hr (1,289bb/hr)derated to20%nameplatepump rate(20% x 1,289bbl/hr = 258bbl/hr22584010496 hrs0 0 0 001040012,384TF-65:ShellOR-4A,OR-4BLamorLORS-2C82cu m/hrbrushskimmers(47-ft workboat)Derated to20%nameplatepump rate(20% x 516bbl/hr = 103bbl/hr)21031044096 hrs0 0 0 00104,944400TF-86:ACS R-16Hook boomconfigurationwitholeophilicskimmer10104010496 hrs0 0 0 00102,400400TOTAL BBLS OF RECOVEREDLIQUIDS/DAY9,60032,9948627,162827,1629,6008636,216879,41610,80086Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration ProgramPart 1 – Response Action PlanTABLE 1.6-5 (CONTINUED)WELL BLOWOUT IN SUMMERDERATED POTENTIAL RECOVERY CAPABILITYShell Offshore Inc. 1-71March 2010May 201195-2000.01-25.201-001/09-018Rev.101. 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 rateof 400 bbl/hristhe estimated quantity of oil / water emulsionand free water available for recovery per hourbased uponthe release rate of 5,500 bbl/day(or 229 bbl/hr), the planning assumption that of 1,042 bbl/hr of oil released per hour a 90% fraction of the release volume (938 bbl/hr) remains offshore for recovery and a 10% fraction (104bbl/hr) may escape the primary offshore recovery operations and drift toward the nearshore andshorelinesa 1.54 emulsificationfactor and free water retained in storage (20% of the WCD)..The derated recovery capacity of the listedoperatingskimmers exceeds the estimated quantity of oilavailable / water emulsion and free water availablefor 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 (23104bbl/hr) may escape the primary offshore recovery operations anddrift toward the nearshore and shorelines.Based upon trajectory modeling, oil would reach the nearshore at the earliest afterDay 6 and only in the unlikely event of sustained winds fromthe W or WNW. The scenario trajectorydeveloped using historical winds and theBOEMREMMSChukchi current model shows that oil has alow probability of shoreline contact by Day 258.55. The scenario recovery rate of 938 bbl/hr is assumed to be shared between recovery systems. The combined systems have sufficient recovery and storage capacity to operate for the 24 hrperiod.6.AfterHour 42Day 1, recovery calculations assume that operations go into a 24-hr rotation withTF2 and TF-5the OSRV and VOSSalternatingwith TF-1 and TF-4as skimming platforms tomaintain recovery operations.The TF-2 and TF 5 recoversOSRV skimsfor1624hr at a time using the Transrec 150or Lamor side collector skimmers and the VOSS skims for 8 hr usingthe Transrec 150whileTF-2 and TF-5 the OSRVlighters to the OST.During the next 24-hr cycle TF-2 and TF-5 recovers using the Lamor side collectors and Transrec 150 skimmers whileTF-1 and TF-4 lighter to the OSTThe OSRV lightering operation isbased upon an 8 hr period including transits to and from the OST and offloading. Once the OSRV resumes skimming, theVOSS lighters its recovered fluids to the OST.Forthepurposes of calculating total recovery, 24 hrsof recovery per day is used for the skimming systems.7. Beyond Day 4, a 48-hr operating period is used to calculate recovery. TF-1, TF-2, TF-3 and TF-4 operate on 24-hr rotation cycles while TF-6, TF-7 and TF-8 operate based upon a 12 hrshift per day or two shifts per 48 hr.68.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 skimmers total for recoverycapacity.Skimming capacity exceedsthe daily offshore recovery rate of 1,042 bbl/hr (938 bbl/hr offshore and the 104 bb/lhr assumed to drift toward the nearshore).Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-72 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### TABLE 1.6-6 MAJOR EQUIPMENT FOR OFFSHORE RESPONSE DURING THE DRILLING SEASON

ITEM EQUIPMENT INFORMATION QUANTITY

TASK FORCE 1
Vessels

OSR VesselV 300-ft Response Vessel with 1 21

, 04 00 bbl Minimum Storage Capacity 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 B oom 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

OSR BargeVOSS 76,90Vessel of Opportunity with 3,20 0 bbl Minimum Storage Capacity 1
Oil Recovery Equipment
Transrec 150 Skimmer Umbilical Weir Skimming Package 12

TASK FORCE 3
Vessels

OST OST ( 513,287,1,0 00 bbl Minimum Storage Capacity) 1

TASK FORCE 4

VesselNon-Mechanical Responses

VOSSC-130 aircraft Aircraft with Integrated Dispersant Tank and Spray ArmsVessel with 13,000 bbl Minimum Storage CapacityStorage 1
Oil Recovery Equipment

Transrec 150 SkimmerCorexit 9500 Umbilical Weir Skimming Package Dispersant 1Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-73 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 ITEM EQUIPMENT INFORMATION QUANTITY
TASK FORCE 5

Vessels

VOSS Vessel with 8,000 bbl Minimum Storage Capacity 1
Oil Recovery Equipment

Transrec 150 Skimmer Umbilical Weir Skimming Package 1Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-74 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### TABLE 1.6-7 MAJOR EQUIPMENT FOR NEARSHORE AND OPERATIONS

TASK FORCE EQUIPMENT QUANTITY

TF- 56 , Nearshore Recovery 18,636 bbl OSRBOSR barge 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- 67 and TF- 78 ) 6,000-ft

TF- 76 , Shoreline Protection Landing Craft 26-32 ft (Shared with TF- 78 ) 2 24-ft Workboat (Shared with TF- 87 ) 2 Workboats

─ ACS Type A & B (Shared with TF- 78 )* 4 Workboats

─ ACS Type C (Shared with TF- 78 )* 2 Conventional Boom (Shared with TF- 87 ) 10,000-ft Coastal Boom (Shared with TF- 87 ) 4,000-ft Shore Guardian Boom 4,000-ft

TF- 87 , 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- 67 and TF- 78 equipment is pre-staged at Wainwright.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-75 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### TABLE 1.6-8 STORAGE EQUIPMENT FOR RECOVERY OPERATIONS

SUM OF CAPACITY OF OIL STORAGE TANKS

ELEMENT PLANNING CAPACITY (BBL) REFERENCE OFFSHORE STORAGE OSRVOSR Vessel 11,400 Shell Charter, available to ACS OSR BargeVOSS 76,9003,200 Shell Charter, available to ACS VOSS 13,000 Shell Charter, available to ACS VOSS 8,000 Shell Charter, available to ACS OST 513,000287,100 Shell Charter, available to ACS OST Minimum 250,000 Shell Charter, available to ACS NEARSHORE STORAGE OSRBOSR barge 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 ManualOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-76 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### 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 SHIFT 56 DAY 1 STAFF PER SHIFT 56 AFTER DAY 4

Team Leader/Field Supervisors 1, 2, 5 TF-1 OSRVOSR Vessel Supervisor 1 2 2 2 TF-2 OSR BargeVOSS Supervisor 3 1 1 1 1 TF-3 Tanker Deck PIC 1 1 1 1 TF-4 OSR Vessel Aerial Dispersant Supervisor 1 1 1 TF-5 OSRBOSR Vessel Supervisor 1 2 1 1

TF-6 OSR Barge Supervisor 1 2 1 Nearshore Recovery Supervisor 1 1 1 1 TF- 76 Shoreline Protection 1 1 21 TF- 87 Shoreline Recovery 1 1 12

Large Vessel Operators, >30 feet 34, 5 TF-1 OSRVOSR Vessel Operator 1 1 1 1 34-ft Work Boat Operator (Shared with TF-2 , 3 & 4 ) 3 1 3 3 TF-2 OSR Barge Operator (Tug) 1 1 1 1 TF-3 Tanker Operator 1 1 1 1

TF- 65 47-ft Skimmer Boat Operator 1 1 1 34-ft Work Boat Operator 3 1 3

Small Vessel Operator, <30 feet 34, 5 TF- 7 /6 / 78 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 Technicians 4, 5 TF-1 OSRVOSR Vessel Deck Crew 1 7 7 7 34-ft Work Boat Crew 3 1 3 3 TF-2 OSR BargeVOSS Deck Crew 1 2 2 2 TF-3 Tanker Deck Crew 1 3 1 3 TF-4 VOSS Deck Crew 1 3 3 TF-5 VOSS Deck Crew 1 3 3

TF- 65 OSRBOSR barge 1 4 4 34-ft Work Boat Crew 3 1 3 47-ft Skimmer Crew 1 2 2

General Laborer 5 TF- 67 / 78 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- 67 Shoreline Protection Labor 2 4 8 TF- 87 Shoreline Recovery Labor 2 4 8

TOTAL 2323 8679

Table notes: 1. For ACS personnel, the Total is the sum of vessel operat ors, technicians, and general l aborers. For ACS personnel, the Team Leader is a separate person. 2. All TF-3 tasks, including PIC = Person-in-Charge, will be perfo rmed by the tanker crew with no additional response staff from Shell or ACS.
3. Beginning Day 2, the TF-2 Team Leader / Fi eld Supervisor is accounted for in TF-1.
4.3. Boats and landing craft are shared between TF- 76 and TF- 78

. 5.4. TF- 65 , TF- 67 , and TF- 78 operate one 12-hr shift per day.
6.5. One (1) shift is (=) twelve (12) hr.FIGURE:

1.6-8

UMQ: 14000311_Shell_CC_Cplan_3day_trajectory_v002 Date: 4/19/2011 Chukchi Sea Regional Exploration Oil Discharge Prevention and Contingency PREDICTED SUBSEA BLOWOUT TRAJECTORY

(WITHOUT CONTAINMENT AND RECOVERY) 

## SHELL

## SHELL

OFFSHORE BLOWOUT MECHANICAL OPERATIONS ORGANIZATION

Chukchi Sea Regional Exploration Oil Discharge Prevention and Contingency Plan
FIGURE:



### 1.6-9 

## Task Force 5 **VOSS**
**Function: Open Water**  **Recovery** 

## Task Force 7

**Function: Shoreline Protection**



## Task Force 8

**Function: Shoreline Recovery** 

## Task Force 6 **Nearshore OSR Barge**

**Function: Response Equipment Platform, Supplies,**  **Staging, Decon, Interim Waste Storage,**  **Nearshore Recovery** 

## Task Force 1 **OSR Vessel Function: Open**  **Water Recovery** 



## Task Force 3 

## Oil Storage Tanker (OST) **Function: Interim Storage of Recovered Fluids** 



## Task Force 4 

## VOSS
**Function: Open Water**  **Recovery** 

# MECHANICAL **OPERATIONS**

**Task Force 2** 

## OSR Barge **Function: Open Water**  **Recovery** 

# Offshore **Response Nearshore**  **Response**

## SHELL

PRIMARY RESPONSE TO AN OFFSHORE BLOWOUT

FIGURE: 

### 1.6-10 •	 Relief Well Drillship



### OSR Vessel OSR Barge OSR Vessel/VOSS •	 (2) Lamor LSC •	 (2) T ransrec •	 (1) T ransrec 

### Relocated for Relief Well



## Blowout

Safe Zone

Note: Figures not drawn to scale. 

## Vapor Ignition

Safety Zone

NEARSHORE Op era ti ons : •	 (1) OSR Barge •	 (1) 47’ Skimming Boat •	 (4) Mini Barges •	 (3) 34’ Workboats •	 OSR Vessel to OST 

### RECOVERY & L I GH T ER I NG Op era ti onsOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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## RESPONSE STRATEGY 1

SUBSEA BLOWOUT IN V ARYING ICE CONDITIONSOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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## 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 pros pect blows out at subsea nine days before freezeup. While the drilling season at the ex ploration well location can extend well into November/December, the formation of new ice by Da y 9 provides ample time for the description of response techniques during freezeup. In this simula tion, 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 1-84 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### 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 appropria te 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 anchor handler assists the drillship move to a safe location. The OSRVOSR vessel and OSR barge staged in the vicinity of the drillship mobilize s to the blowout location and provide s assistance (as needed.) The OSR vessel is assigned Task Force 1 (TF-1) Once the anchor handler, Tor Viking or similar, assists the drillship move to a safe locationand begins recovery with 1 hr. Upon arrival at Hour 3, the OSR barge, it is assigned as a VOSS to Task Force ( TF-2 ) and mobilized to work in conjunction with TF-1relieve the OSRV at hour 24 to perform recovery operations.
The OST on standby (within 240 n mi of the drilling location) and a Nearshorethe OSR barge and two (2) VOSSsB ( staged located at a maximum distance of 4 28 0 n mi from the Chukchi Sea drill sitenearshore 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

Shell OR-2A, OR-2B, OR-2B,

(modified),

OR-3A OR-10

(ii) Preventing or Controlling Fire Hazards The Site Safety Officer analyzes the sit uation and verifies that all sources of ignition are shut down or removed from the area. The Site Safety Officer provides access zone informati on and determines PPE requirements. Monitoring protocol is established fo r all work areas to ensure personnel protection. The monitoring protocol es tablishes safety zones according to applicable Occupational Safety and Heal th Administration (OSHA) and fire hazard standards.
The OSC determines that ignition of the blowout warrants immediate consideration and initiates a request to t he 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 combi nation of visual observations, remote sensing systems from fixed-wing airc raft and helicopters, and from satellites already in place for the tracking of ice conditions throughout the region (RadarSat & EnviroSat)
Visual observation provi des the greatest potential for monitoring oil and/or ice movement on location because aircraft (f ixed-wing and helicopter) play a vital role for the ongoing assessment of weather conditions, oil transport, and conditions at/near the blowout, smok e 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, bas ed upon best available weat her/ice predictions and actual field observations and measurements. Spill trajectories are used to ensure that tactics and strategies are impl emented to protect identified priority protection sites well ahead of any oil that could impact those regions. Additional sources of data could al so include: NASA moderate-resolution imaging spectroradiometer (MODIS) im agery (Aqua & Tera satellites) and the U.S. National Ice Center. Shell TS-1, TS-2, TS-3Oil 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 1-85 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10

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 Octobe r to as late as the end of November. Such landfast ice can provide an effectiv e natural barrier against oil reaching Environmentally Sensitive Areas al ong 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 ma y 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) with in 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 t he field. Environmental specialists together with resource trustee represent atives will identify priority protection sites and develop a Shoreline Cle anup Plan, including appropriate cleanup techniques and endpoints using the NO AA ESI Maps, ACS Atlas Maps, and North Slope, Alaska Subarea Contingency. ACS, including NSSRTs, ACRTs, and VRTs, together with the Nearshore OSRBOSR barge

, (TF-6) would establish protective booms at key loca tions 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 t he 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 o il and divert it into temporary quietwater holding areas and/or exclude it from entering sensitive inland or backwater wetlands. The OSRB ( TF- 56) , having been relocated from its standby location, moves to a central location about a mile offshore. The TF6The barge provides additional boats, booms, and recovery equipment, decontamination facilities, communica tions, and a “safe haven” for boats and personnel in the event weather and/or ice concentrations force a cessation of nearshore operations. TF- 56 consists of the OSRBOSR barge 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- 65 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 prec aution in the event the wind shifts from the ENE to the WNW, response resour ces are mobilized to perform nearshore and shoreline containment and recovery operations (TF- 65 , TF- 76 , & TF- 87 ). 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 conti nues, all nearshore re sponse activities cease, the TF-6OSRB 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. 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-12Oil 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 1-86 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10

ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE A shoreline cleanup plan is approved by the UC; however, it is recognized that shoreline access will be limited as landf ast ice begins to form throughout the region. Should oil move into thes e 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 thick ness increases at these sites, stakes will be positioned to identify areas for on/in-ice recovery techniques. ACS SH-1

(vi and vii) Spill Containment, Control and Recovery Procedures Offshore: OSR operations offshore are initia ted immediately upon notification. Once site characterization efforts are completed and safe operating zones are established, TF-1 ( OSRVOSR vessel ) 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 an OSR vessel andof two (2) 34-ft workboats towing a n open apex U-boom downstream of the oil surfacing from the blowout. TF-1 The OSRV and one (1) 34-ft workboat operate s in J-boom configuration with one (1) Transrec 150 skimmer or with two (2) Lamor LSC-5 skimmers and outriggers positioned within or behind the open apex U-boom. Oil moves into the Uboom 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 ensur e that boom-tending work boats and the OSRVOSR vessel remain at a safe distance downstream of the blowout.

While TF-1 (OSRV) and its recovery operations get underway, TF-2 (OSR barge), TF-3 (OST)

, TF-4 (VOSS), and TF-5 (VOSS) and TF-6 ( OSRBOSR barge ) are already underway toward the blowout from their staging locations. TF-2 arrives on-scene at Hour 3 and replaces TF-1 to begin skimming within the U-boom towed by two (2) 34-ft work boats. TF-1 re-configures with one (1) 34-ft workboat into a J-boom arrangement for recovery. With 11,400 bbl of recovered oil storage capacity aboard TF-1, the OSRV, the OST arrives on scene within 24 hr ( asseveral hours before TF-1 the OSRV approaches holding capacity). Once the OST is on location, the TF-1OSRV disengages from skimming to lighter its recovered oil to the TF-3 OST while TF-2 continues recovery. TF-2 has a minimum of 76,900 bbl of storage which provides more than enough capacity to operate for the first 48 hr. At Hour 42, is relieved by the VOSS (TT F- 42) (VOSS) and TF-5 (VOSS) arrive at the blowout, each equipped with one (1) Transrec 150 skimmer. TF-5 initiates skimming in Jboom configuration using a workboat (fro m TF-1). At Hour 48, TF-2 and TF-5 are relieved form skimming by TF-1 and TF-4. TF-2 and TF-5,The OSRV with theirits Transrec 150 skimmer s pulled onboard, transit ts to the OST and lighter s theirits contents over the next 24-hr period . While TF-2 and TF-5the OSRV engage s in lightering operations, TF-1 and TF-4 the VOSS and one (1) 34-ft workboat in J-boom configuration continue recovery operations , TF-1 (replacing TF-2) operates its two Lamor side collector skimmers within the U-boom towedfollowing by the two (2) 34-ft workboats towing an open apex U-boom. TF-4 (replacing TF-5) deploys its single Tr ansrec in J-boom configuration using the 34-ft workboat. An alternating 24-hr cycle is established with two task forces skimming while the other two lighter their recovered oil to TF-3. 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 oper ates 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 and side collector skimmers have more than adequate capacity to recover the daily oil volume released from the blowout.
The positioning of work boats and the OSRVOSR vessel during darkness and other periods of low visibility is facilitat ed 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 OSRVOSR vessel and workboats would be used to position response assets to intercept surfacing oil. Winds and currents are monitored frequently to ensure that the containment Shell OR-2A, OR-2B

Shell OR-2 A, OR-2 B ,OR-10

ACS R-18, R-20R-20

Shell OR-2B, OR-3A

ACS R-18, R-32A Shell OR-2B, OR-10

ACS R-20

Shell OR-3A

Shell TS-1, TS-2, TS-3Oil 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 1-87 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10

ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE 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 chemic al 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 prov ide an important backup response option should wind/sea conditions or ice preclude the use of booms for mechanical recovery, and/or burning, or when im portant 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, an aerial dispersant task force (designated TF- 4D), consisting of a C130, was mobilized to Barrow from MSRC in 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. Author ization is issued fo r dispersant use downstream of booming and recovery ope rations 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 , TF-4 and TF-5 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 disper ses 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 opt ions for the physical recovery of oil /emulsion and the protection of environm entally 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 laye rs 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 t he 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 drilli ng 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 re latively ice free radius around the surfacing oil and gas. Continued combus tion 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.
T TF -1 and TF- 42 continue to alternate in recovery operations with TF-2 and TF-5 to work immediately downstream and at a safe distance from the blowout. Operating with only outriggers and/or short lengths of boom, the OSRVOSR vessels maneuver s at very slow speeds through the pockets of heaviest oil concentration. Because oil enc ounter rates are reduced, TF-1 , TF-2, TF-4 and TF-5 are is able to stay on location without reaching its holding capacity several days. When ice concentrations pr eclude even the limited use of short boom lengths and outriggers, TF-1 , and TF-2 , TF-4 and TF-5 move into pocket recovery Shell OR-8, OR-9A

Shell OR-9A

Shell OR-2B, OR-3A

ACS R-18, R-32A

Shell OR-2B, OR-10 OR 3A

ACS R-20B (modified)

Shell TS-1, TS-2, TS-3

Shell OR-2C, OR-2D, OR-2EOil 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 1-88 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10

ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE techniques involving onboard, over-the-si de skimmers. The vertical rope mop skimmer (TF-1) is suspended from a crane out over pools of concentrated oil layers, and the umbilical Tr ansrec 150 weir skimmers (TF- 2, TF-41 and TF- 25 ) 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 conti nue 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 us ed 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 k ept from spreading by ice. Even the 34-ft work boats are used in relatively li ght 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. 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 blowou t. All work boats, booms, mini-barges, etc. are loaded back aboard the OSRV TF-1 and TF-2 and prepared for transit back to the mainland. The drillship (for relief well), anchor-handler (VOSS)

, and TF-4 and TF-5 ice-breakers 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 v apors 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. Wher ever oil accumulations are evident at the surface, aerial ignition techniques are used to burn that oil in place. When accessible, TF- 14 and TF-5 recover s 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 implem ented throughout the response (with tracking buoys, satellite monitoring of ice movement, etc.), the swath, speed, and direction of potentially oiled ic e is documented and updated on charts. The delineation of any ice that could cont ain 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-wint er 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- 56 , TF- 67 , and TF- 78 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 determi ned that oil from the blowout could impact the mainland, TF- 65 ( OSRBOSR barge staged within 96 hr480 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 earlie st possible time oil could contact shorelines between Wainwright and Pear d 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- 76 ) and recovery 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

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-3Oil 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 1-89 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10

ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE operations (TF- 78 ). TF- 65 , TF- 67 and TF- 78 arrive on scene within 96 hr. ACS mobilizes response personnel to be on location at their respective staging areas awaiting updates on locations and ti mes for potential shoreline landfall by oil. TF- 65 stages the OSRBOSR barge to perform nearshore free-oil recovery. TF- 67 deploys to initiate priority protection booming and TF- 87 positions crews and equipment for shoreline cleanup operati ons. 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 nearshore OSRBOSR barge , are prepared to fulfill all “decontamination” needs fo r personnel, boats, and equipment. A secondary objective for TF- 56 ( OSRBOSR barge ) is to provide logistical support for the shoreline protection and recovery activities of TF- 76 and TF- 87

. The OSRBOSR barge serves as a large, shallow- draft platform that can help sustain nearshore operations by providing a safe haven for personnel, small vessels and mini-barges; communicati ons; deck space to store boats; equipment and supplies; refueling capabilities; decontamination facilities; and storage for recovered oil and oily debris.

Key equipment aboard the nearshore OSRBOSR barge (TF- 56 ) 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- 56 intercepts oil approaching the mainland. These operations remain within a few miles of shore, involve temporary storage in mini-barges, and transit to the OSRBOSR barge for lightering of recovered oil from the mini-barges.

TF- 76 consists of ACS-mobilized pers onnel 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 pr eviously identified priority protection sites. As necessary, TF- 76 also utilizes the TF-6 for support, fuel, decontamination, etc. TF- 76 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 OSRBTF-6 and 4,000-ft pre-staged); and 4,000-ft shore seal boom.

TF- 87 primarily operates from and along the shoreline, involves booming and skimming operations along the main land, beach cleaning operations, and temporary storage/disposal of recovered oil and oily debris. TF- 87 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- 76 and TF- 87

. TF- 65 , TF- 67 and TF- 87 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 ic e which then keeps oil from impacting the barrier islands and mainland. TF- 87 (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 S-4

Shell S-4

Shell OR-1A, OR-1B OR-4A to OR-4D,

OR-5A, OR-5B

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 OSRVOSR vessel to the OST is accomplished with rotati on cycles beginning after Day 1 that are completed within a 24-hr period for each full cycle. At Hour 42, TF-4 and TF-5 arrive on-scene. At Hour 48, TF-2 di sengages from skimming to begin its first lightering cycle to the TF-3 OST. An al ternating 24-hr cycle is established with two task forces skimming while the other two lighter their recovered oil to TF-3.
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 at a location 25 n mi from offshore recovery operations and 35 n mi from nearshore recovery Shell OR-3A and OR-6

Shell OR-3AOil 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 1-90 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10

ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE operations. The 24-hr cycles allow suffici ent timein close proximity, typically a mile or two, from the rec to transit to and from the OST and complete lightering operations for the task forces.overy operat ions 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 a ccomplished 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 inject ion, each transfer from the OSRVOSR vessels to the OST should require only 23 to 54 hr with an additional 3 to 44 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 1216 hr available to complete transfer operations for each OSR vessel and transit to and from the OST.

Nearshore: Recovered fluids from TF- 56 ’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 Nearshore OSRBOSR barge . Other recovery operations at and on the shoreline will likel y 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 Nearshore OSRBOSR barge has a storage capacity of 17,000 bbl. Once TF-6 reaches fill capacity, transit to the OST and lightering require approximately 10 hr. Th e 10% planning volume to the nearshoreis volume zone 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-6

ACS D-2

Shell OR-3A, OR-6

ACS R-28

(ix) Transfer and Storage of Recovered Oil/Water; Volume Estimating Procedure Task force TF-1 OSRVOSR vessels and TF-2 VOSS are equipped with sensors to indicate liquid levels in its holding tanks; transfer pumps are calibrated; decanting is monitored cl osely 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 OSRBOSR barges , 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 di sposed of according to classification. Non-oily wastes are classified and disposed of accordingly.

Recovered fluids stored onboard the OST s 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 ar e deployed by ACS (NSSRT, VRTs and ACRTs) to protect priority areas. Landf ast ice, if present, also provides protection, keeping oil from impacting ba rrier 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 str ong component out of the east can cause the landfast ice to break free of the shor eline 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 peri od, every effort will be made to work ACS C-13, C-14, C-15Oil 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 1-91 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10

ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE
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. Encaps ulation 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. 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 under stand 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 k eep 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 gi ven serious consider ation. As long as burns are conducted at least 3 mi fr om 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 eliminat e beached oil/debris with overall minimal impact to the environment.
During the winter months, a shorel ine cleanup plan is dev eloped 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

Shell SR-1

ACS SH-10

ACS SH-1, SH-2 through SH-12

Shell SR-5, SR-6, SR-7,SR-8, SR-9, SR10Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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## RESPONSE STRATEGY 2

FUEL TRANSFER RELEASE DURING SUMMER MONTHSOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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## 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 tr ansfer hose failure. The spill durati on 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

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### 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 adj acent to the drillship to conduct a fuel transfer. The fuel transfer is monitored by a de dicated response team equipped with an OSRVOSR vessel and three (3) 34-ft work boats.
A pre-transfer conference is conducted bet ween 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. Additi onally, the response team pre-deploys containment boom down current of the fueling operation.
During the fuel transfer, the fuel hose clos e 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 remo ved 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 es tablished 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 comp liance 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#northslopeOil 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 1-97 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 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 OSRVOSR vessel ; 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 OSRVOSR vessel

. TF-2: ACS Shoreline Protection Task Forces are put on standby to deploy exclusion booms at priority sites. The IC, OSRVOSR vessel 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 operati ons 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 t he U-boom to contain the spilled fuel, and then proceed to the OSRVOSR vessel for recovery. The OSRVOSR vessel utilizes either a mini-brush skimmer or rope mop to collect the contained diesel. Recovered fuel/water mixture is stored in the OSRVOSR vessel

. End of Day 1. Recovery operations have stopped. Approximately 75 bbl of liquid (fuel/water) is collected and stored in the OSRVOSR vessel

. Shell OR-2A, OR-2B OR-5A, OR 5B

ACS C-13, C-14, C-15

Shell OR-5A (modified for OSRVOSR vessel )

Shell S-2, S-3

Shell OR-5A (modified for OSRVOSR vessel )

(viii) Lightering Procedures On a non-emergency basis the recove red diesel is lightered from the OSRVOSR vessel 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 wa ste; and (3) submit a plan to the UC for waste management. Non-liquid oily wastes are classified and di sposed 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 OS T 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 c onduct 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

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## RESPONSE SCENARIO 2

ADEC SPECIFIC SCENARIO WORST-CASE DISCHARGERESPONSE PLANNING STANDARD DISCHARGE – Chukchi Sea

UNCONTROLLED SUB-SEA WELL RELEASE DURING SUMMER MONTHS

RESPONSE SCENAR IO PARAMETERS

This RPSWCD scenario was developed to specifically des cribe a response that addresses each of the ADEC-compliant 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, Tt he following RPS scenario is provided at the specific request of ADEC. This scenario is not a guar antee of performance. Rather, it is an illustration of the spill and response conditions that could be expect ed 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 RPS volume WCDspill

. In the unlikely event primary well control was lost, t he 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 meeti ng 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 t he 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 inciden t, personnel safety is the highest priority.

Simulated weather and sea conditions, oil characterist ics, aerial deposition, oil trajectory modeling and resources of importance are as described in Scenari o 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

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### 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 FrontierNoble Discoverer at the Burger F wellsite (71o 20’ 1413.96 ” N, 163o 12’ 2212.75 ” 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 = 5,50025,000 bopd x 15 days = 375,00082,500 bbl

No deductions were made to the RPS volume to account for burning or evaporation.

Emulsification Factor and free water pickup 1.54 x 82,500375,000 bbl = 577,500127,050 bbl. This is the oil emulsion volume created by skimming/pumping operations. Assuming that approxim ately 20% of the original oil volume recovered is added to this mix as free water (approximately 16,50075,000 bbl), the total volume of fluids (emulsion + free water) coul d conceivably requi re approximately 652,500143,550 bbl.

Average Wind Speed 10 to 11 knots

Wind Direction Prevalent winds are from the ENE. Wind di rection 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 measur ed 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 te mperatures 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 Fr ancis (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 OSRVOSR vessel and VOSS areis located within 10 n mi of the drillship and the OSR barge is staged approximately 25 n mi . 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. A NearshoreThe OSR bargeB is staged at a locat ioned on the Chukchi Sea Coast in the nearshore zon fr om which it can mobilize to the Chukchi Sea nearshore zone within 96 hr

.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### 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 conduc ted by ASA using historical wind data and the MMS hydrodynamic ocean-ice current model.
The trajectory model uses OILMAP software dev eloped by ASA. Based on environmental conditions including predominant winds and currents, the output fr om this model shows esti mated oil concentrations and slick movement over time. Additionally, ASA’s SIMAP software provides probabilities and estimated contact timing if oil were to reac h 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 result s provide graphical representation for instantaneous or continuous release spill volumes on water through time.
Input parameters include a spill volume of 25,000 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 hr s into the spill and identifies the predicted surface oil concentrations from the blow out and slick direction.
The simulated oil discharge of 25,000 5,500 bopd is ejected through a 6-inch ID well at the mudline, in water approximately 140 ft deep. Within minutes of the we ll 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 NESW of the spill site for approximately 1732 n mi. Refer to Figure 1.6-8.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### 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 OSRVOSR vessel and OSR barge accompanying the drilling ship and activate s ACS. Notifications to appropriate state and federal agencies, including MMSBOEMRE , 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 OSRBOSR barge are also notified and immediately mobilized. Upon arrival, Tt he Shell OST is positioned within a safe distance approximately 25 n miand 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 remo ved from the area. The Site Safety Officer provides access zone information and det ermines 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 mo ve 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 descr ibed 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 planni ng purposes, specialty equipment and personnel required for secondary well contro l 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. Hypothet ically, 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 seve ral 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 t he 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 combi nation of visual observations and remote sensing techniques. Within the first hours of init ial 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 pl anning 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-5Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### 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 trajecto ries 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 predict s 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) da ys 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 Nearshore OSRBOSR barge 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 isl ands 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 S ea coastline for priority exclusion or deflection booming. Trajectory model r uns 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 r epresentatives to prioritize resource sensitivities and activate protection guideli nes. 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 shore line protection plan, and SCAT are placed on standby.
T + 4 Days. ACS Shoreline Protection Task Forc es 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 Nearshore OSRBOSR barge 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 effe ctive 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 equi pment stationed near the drillship This equipment includes: an OSRVOSR vessel (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 n OSR barge VOSS, one of the on-site drillship support vessels (76,900 bbl storage) , equipped with two (2)a Transrec 150 skimme s r s 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 arrive s within 24 hr. Decanting (if required) follows FOSC plan and USCG approval. TF-3 provides oil storage capacity for lightering from TF-1 , and TF-2 , TF-4 and TF-5

. Shell OR-2A, OR-2B

ACS R- 1820 , R- 32A17

Shell OR-3A

ACS R-28Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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### 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 VOSS with a minimum storage capacity of 13,000 bbl.Response assets aboard the VOSS include one (1) Transrec 150. TF-4 arrives onscene from its staging location at hour 42.

TF-5 consists of a VOSS with a minimu m storage capacity of 8,000 bbl. Response assets aboard the VOSS include one (1) Transrec 150 skimmer. TF-5 arrives at the scene from its staging location at hour 42.
a C-130 aircraft equipped with 3,200 gal of di spersant and Spray System. TF-4 is mobilized to the Barrow airport from the MSRC in Arizona and arrives in Barrow within 24 hrs.

TF- 65: consists of tT he Nearshore OSRBOSR barge with 17,000 bbl of onboard storage. The OSRBOSR barge is mobilized from a staging area within the Chukchi Sea nearshore zon toe, arriv eing on location within 96 hr. The OSRBOSR barge 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; thr ee (3) 34-ft work boats; four (4) minibarges; 2,500 ft ocean boom; one (1) vertic al rope mop; one (1) duplex minibrush/disc skimmer; and one (1) 100-bbl storage bladder.

TF- 67: consists of pP re-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 nNearshore OSRBOSR barge . 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- 78: consists of ACS response equipment and personnel (ACS, NSSRT, ACRT, and VRTs) mobilized to perform shoreli ne 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 fr om 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 thewell 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 surf aces 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 RPS of 25,0005,500 bopd ( 2291,042 bbl/hr) continues to flow from the well. The recovery rate is based upon the planning assumption that a 90% fraction of the daily release volume (938 bbl/hr) remains offshore for recovery and a 10% fraction (104 bbl/hr) may escape the primary offshore recovery operations and drift toward the nearshore and shorelines.
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 OSRVOSR vessel operates one (1) Transrec 150 skimmer with a derated recovery of 503 bbl/hr or two (2) Lamor LSC5 skimmers with a combined derated recovery of 516 bbl/hr (2 X 258 bbl/hr).

T + 3 Hours. TF-2 arrives on-scene equipped with two (2) Transrec 150 skimming systems. TF-2 relieves TF-1 to work in conjunction with the two (2) 34-ft workboats towing U-boom. TF-1 and one (1) 34-ft workboat continue skimming operations in a J-boom configuration.

T + 4 Hours. The volume of recovered liquids exceeds the volume of discharged oil (with emulsification). Shell OR-10

ACS R-18,

R-32A 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-2A OR-2B

, OR-10

ACS R- 2018 , R- 1732A

(Table 1.6- 145 )

Shell OR-2A, OR-2B

ACS R- 20, R-1718, R-32A

Shell OR-2A, OR-2B , OR 3A,Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-104 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### TABLE 1.6-13 (CONTINUED) ADEC SPECIFIC SCENARIO UNCONTROLLED SUB-SEA WELL RELEASE DURING SUMMER MONTHS
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 twoone ( 12 ) Transrec s 150 skimming system s , maintains skimming while relieves the OSRV ( TF-1 ) disengages to lighter its recovered fluids to the OST. TF-1 can complete lightering operations within 8 hr. TF-2 has enough storage capacity to store recovered fluids for the next twentyfoureight hr period of continuous skimming during which time lightering operations from the TF-1OSRV 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 aJ-boom configuration behind the two (2) 34-ft workboats towing an open apex Uboom. 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 offshor e 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. ACS R- 18

ACS R-2820, R-17

Shell OR-3A

ACS R-28

TF-3 has arrived from its standby location not far from the drill site. The primary objective of TF-3 is to provide offshor e interim storage capacity for recovered fluids. Upon TF-3 arrival, TF-2 relieves the OSR vessel (TF-1) to lighter its recovered fluids to the OST.
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). T + 42 Hours. TF-4 and TF-5 arrive onscene. TF-4 and TF-5 are each equipped with one (1) Transrec 150 skimming system. TF-2 continues recovery operations in configuration with the two (2) 34-ft workboats towing U-boom.

T+ 48 Hours. TF-1, TF-4 and TF-5 relieve TF-2 toThe TF-2 VOSS initiate s its lightering operations to the OST . TF-1 skims using its two (2) Lamor LSC-5skimmers within jib arm booms. TF-4 skims with one (1) Transrec operating in Jboom configuration towed by one (1) 34-ft workboat. TF-5 skims using one (1) Transrec inside U-boom towed by two (2) 34-ft workboats. The three task forces possess sufficient storage capacity to reco ver liquids during the12-hr period during which TF-2 completes lightering operations. following the resumption of recovery by the TF-1 OSRVl.

From this time forward in the response , TF-1 , TF-4 and TF-5 alternate recovery and lightering operations with TF-2 and TF-2 alternate recovery operations so that one task force is always skimming operations are maintained while lightering is conducted to the TF-3 OST

. TF-1, TF-4 and TF-5 recover 12 hr while TF-2 conducts lightering, then TF-2 relieves t hese three task forces and recovers for 24 hr while TF-1, TF-4 and TF-5 lighter. Two workboats continuously tow boom in a U-shape, 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 , TF-4 and TF-5 are detailed in Table 1.6- 145

. 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 shor eline, nearshore assets would be mobilized to implement nearshore response, shore line protection and cleanup. At the very earliest, oil may reach shore on Day 6 if sustained northwesterly winds develop

. TF- 655 , consisting of the Nearshore OSRBOSR barge , arrives to provide support (e.g., platform, safe haven for pe rsonnel and vessels, response equipment, recovered fluid storage) for the near shore recovery and shoreline response operations.

TF- 655 targets free oil in windrows and linear slicks. In addition to the OSRBOSR barge with LSC-5 skimmers, TF- 556 includes one (1) 47-ft skimming vessel configured with two (2) side booms and two (2) built-in Lamor LORS-2C skimmers. OR-3A

ACS R-28

Shell OR-2A, OR-2B, OR-3A

ACS R-20, R-1 7, R-32B, R-287

Shell OR-2B, OR-3A

ACS R-17, R-32B, R-28

Shell OR-2B, OR-3A

Shell OR-1A, OR-1B OR-4A, OR-4B, OR-5A

Shell OR-1A, OR-1B OR-4A, OR-4B, OR-5A

Shell SR-2 through SR-5Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-105 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### TABLE 1.6-13 (CONTINUED) ADEC SPECIFIC SCENARIO UNCONTROLLED SUB-SEA WELL RELEASE DURING SUMMER MONTHS
ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE 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- 76 is mobilized from Wainwright to impl ement 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 the Nearshore OSRB OSR barge and 4,000-ft prestaged); and 4,000-ft shore seal boom. TF- 76 is also supported by TF-6 the OSRB and its personnel and equipment.
ACS cascades additional crews, boom and work boats to priority protection sites selected by the UC.

TF- 87 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 NE 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. 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 OSR vessel and VOSS (TFs 1 & 2 respectively) to the OST.

Based on a maximum RPS of 25,0005,500 bbl/day (or 1,042229 bbl/hr), a 1.54 emulsification factor and free water retained in storage (20% of the RPS), storage is necessary for each skimming vesse l could be filled at a rate of approximately 1,631400 bbl/hr of recovered fluids.

TF-1 OSRV has 11,400 bbl of storage volume (95 percent capacity) and TF-2 has 76,900 bbl (95 percent capacity) of storage

. The combined storage capacity of TF-1 and TF-2The 11,400 bbl storage capacity is more than sufficient to store recovered fluids until the OST arrives on-scene.
At hour 24, TF-1the VOSS replaces the OSRV as it disengages from skimming operations, transits to the OST, and co mmences offloading recovered fluids. TF-2 The VOSS and the 34-ft workboats replace the OSRV to continue skimming operations and provide interim storage for the next 24 hr

. TF-2The VOSS initiates lightering operations to the OST following the resumption of recovery by TF-1, TF-4 and TF-5 the OSRV at Hour 48 . Skimming and lightering operations are scheduled on a 24-hr rotation basis . Ff or the duration of the response . TF-1, TF-4 and TF-5 recover for 12 hr while TF-2 lighters, and TF-2 recovers for 24 hr while TF-1, TF-4 and TF-5 complete lightering. , 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 re lieved to offload recovered fluids to the OST.

The OSRV is equipped with eight (8) positiv e 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 ACS R-28

Shell OR-3AOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-106 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### TABLE 1.6-13 (CONTINUED) ADEC SPECIFIC SCENARIO UNCONTROLLED SUB-SEA WELL RELEASE DURING SUMMER MONTHS
ADEC REQUIREMENT RESPONSE STRATEGY CROSS REFERENCE OSRV completes lightering operations to the OST within 8 hr.
The OST is stagedmaintained approximately 25 n miin close proximity, typically a mile or two, from the offshore recovery operations and approximately 35 n mi from nearshore operations so that transit times to and from the OST are kept to a minimum. The transfer of recovered fl uids (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 tr ansfer of viscous fluids between the skimmer’s onboard storage and the OST. With high-volume transfer pumps and annulus injection, each transfer from TF-1, TF-4 and TF-5 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. TF-2 would require approximately 5 to 6 hr for transfer and 3 to 4 hr for setup and transit. The VOSS lighters to the OST when the OSRV resumes recovery operations. Using high-volume transfer pumps ensures offloading, the VOSS offloading requires less than the 2416 hr available for TF-1, TF-4 and TF-5 and 12 hr for TF-2 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 offshore task forcesthe OSRV and VOSS to the OST. Liquids from the nearshore skimmer vessels are stored in mini-barges and transferred to the TF-6 Nearshore OSRBOSR barge

. 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 di sposed 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

(xi) Wildlife Protection Plan 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 trust ee 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 th e current trajectory; however, for planning purposes a percentage of the oil is proj ected 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, pr iorities are established for cleanup. Cleanup techniques chosen are based on s horeline type and degree of oiling.

Primary delta and shoreline cleanup techniques include:

 Burning of oily vegetation,

 Deluge of minor to moderately oiled s horeline 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-3OPS9Oil Discharge PreventioPart 1 – Response ActioShell95-2000.01-25.201-001on and Contingency Plaon Plan/09-018RESPanPONSE EQUIPMTAWELL BLOMENT MOBILIZAT1-107ABLE 1.6-14OWOUT IN SUMTION CHART FOMERR OPEN WATEChuR TASK FORCEkchi Sea Regional ExpMay2loration Program011March 2010Rev.01Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-108 May 2011March 2010 95-2000.01-25.201-001/09-018 Rev. 01 

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

Shell has incorporated the flexibilit y 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-mechanic al countermeasures will be made to the UC. The ARRT, comprised of federal, state, and local govern mental 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 resour ce agencies within the IMT EU. Requests for approval shall be made consistent with procedure s In Situ Burning Guidelines for Alaska

, Revision 1, dated August 2008.

For dispersant use, the application will be made cons istent with the guidance procedures outlined Annex F “Chemical Countermeasures: Dispersants, Chemic al 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 containmen t 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 equi pment 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 mech anical 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 impl emented 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 ha s been obtained. When mechanical recovery is not practicable orOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

Shell 1-109 May 2011March 2010 95-2000.01-25.201-001/09-018 Rev. 01 

### less effective, removing oil from the water through the use of in situ burning may provide significant protection for fish, wildlife, and sensitive environment s, 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 affecti ng natural resources;

 

### Allow the environment to recover more quickly to the pre-spill state; and

 

### Provide the most effective means to remove oil fr om 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 th e 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 disp ersants in discrete areas and at ti mes when aerial assets may not be available. Mixing of the dispersants into oil using the OSRVOSR vessel ’s propulsion system facilitates the effectiveness of oil dis persion in ice. Dispersant s 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 associat ed with the approval shall be met. Both alternative response techniques shall require a test to determi ne if its use is feasible given environmental and oil conditions. If the event warrants t he consideration of alternative meas ures, assets will be immediately mobilized to support operations. The efficient use of both techniques decreases as t he oil weathers, presenting a relatively narrow window of opportunity for it s use. In addition, dissipation of a dispersed oil plume into deeper waters (more than 10 m [30 ft]) is preferable and relie s 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 Ta ctic 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-res istant 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 1-110 May 2011March 2010 95-2000.01-25.201-001/09-018 Rev. 01 

### 3. Monitor the burn using Special Monitoring of Applied Response Technologies (SMART) maintain constant watch on the fire and smok e plume, condition of containment boom, speed and position of boom-towing vessels, and other safety hazards and issues.

4. To the extent possible, reco ver and dispose of the burn residue.
Dispersants

Dispersants may be applied from either on-water assets or an aerial platform. Shell’s OSR vessel V 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 a nd 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-mount ed dispersant platforms.

4. On-going monitoring of the dispersant effectiveness using SMART protocols.

Additional information on the use of non-mechanica l 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 present ed in Figures 1.8-1 through 1.8-5.SCAL E: F I GURE:

1.8 -1 DISCOVERER DRILL SHIP OUTBOARD PROFILE SCHEMATIC

Chukchi Sea Regional Exploration Oil Discharge Prevention and Contingency Plan 

## S H E L LSCAL E: F I GURE:

1.8 -2 DISCOVERER DRILL SHIP MAIN DECK AND ABOVE SCHEMATIC Chukchi Sea Regional Exploration Oil Discharge Prevention and Contingency Plan 

## S H E L LSCAL E: F I GURE:

1.8 -3   DISCOVERER DRILL SHIP MAIN DECK VIEW Chukchi Sea Regional Exploration Oil Discharge Prevention and Contingency Plan 

## S H E L LSCAL E: F I GURE:

1.8 -4 DISCOVERER DRILL SHIP LOWER DECK SCHEMATIC Chukchi Sea Regional Exploration Oil Discharge Prevention and Contingency Plan 

## S H E L LSCAL E: F I GURE:

1.8 -5 DISCOVERER DRILL SHIP LOWER DECK VIEW 2 Chukchi Sea Regional Exploration Oil Discharge Prevention and Contingency Plan 

## S H E L LOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 1 – Response Action Plan

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# THIS PAGE INTENTIO NALLY LEFT BLANKOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

Shell 2-i March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### PART 2 PREVENTION PLAN [18 AA C 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 75.00 7(e)] ......................................................... 2-22-2 2.1.4 Security Program [ 18 AAC 75.007 (f)] ............................................................ 2-22-2 2.1.5 Fuel Transfer Procedur es [18 AAC 75.025] ................................................... 2-32-3 2.1.6 Maintenance Programs .................................................................................. 2-52-5 2.1.7 Operating Requirements for Ex ploration [18 AAC 75.045] ............................ 2-52-5 2.1.8 Blowout Prevention and Emergency S hutdown [18 AAC 75. 425(e)(1)(I)] ..... 2-62-6 2.1.9 Oil Storage Tanks [18 AAC 75.065] ........................................................... 2-132-13 2.1.10 Emergency Tow and Esco rt Vessels Program .......................................... 2-142-14 2.2 DISCHARGE HISTORY (>55 GAL) [18 AAC 75.425(e)(2)(B)]

............................... 2-142-14 2.3 ANALYSIS OF POTENTIAL DISCHA RGES [18 AAC 75.425(e)(2)(C)] ................. 2-142-14 2.3.1 Potential Areas for Discharge .................................................................... 2-142-14 2.4 OPERATIONAL CONDITIONS INCREASING RISK OF DISCHARGE [18 AAC 75.425( e)(2)(D)] ........................................................................................ 2-172-17 2.4.1 Severe W eather ......................................................................................... 2-172-17 2.4.2 Ice Conditions ............................................................................................ 2-182-18 2.4.3 Structural Icing ........................................................................................... 2-192-19 2.4.4 Critical Operations an d Curtailment Plan ................................................... 2-192-19 2.4.5 Hours of Light at 71°N ................................................................................ 2-202-20 2.5 DISCHARGE DETECTION [ 18 AAC 75.425(e)(2)(E)]

............................................ 2-212-21 2.5.1 Drilling Oper ations ..................................................................................... 2-212-21 2.5.2 Automated Methods ................................................................................... 2-212-21 2.6 RATIONALE FOR CLAIMED PREVENTION CREDITS [18 AAC 75.425(e)(2)(F)] 2-212-21 2.7 COMPLIANCE SCHEDULE [ 18 AAC 75.425(e) (2)(G)] .......................................... 2-212-21

LIST OF TABLES

Table 2.3-1 Summary of Potential Discharges

........................................................................... 2-152-15 Table 2.3-2 Potential Discharge for Al aska Offshore Drillin g (1997 to 2003) ............................ 2-162-16

LIST OF FIGURES

Figure 2.1-1 Models for Site -Specific We ll Control ............................................................................

... 2-82-8 Figure 2.1-2 Real Time Operations Center ......................................................................................

. 2-102-10 Figure 2.1-3 Exam ple of a BOP .................................................................................................

....... 2-112-11 Figure 2.1-4 Noble Discoverer Drillship Blowout Prevention Equipment System ............................. 2-122-12Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

Shell 2-i March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

## THIS PAGE INTENTIONALLY LEFT BLANKOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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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 ac tivities are thoroughly trained and are expected to be knowledgeable of safety, health, and environmental require ments, 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 addi tional training information.

Site personnel who are expected to participate in OSR ac tivities 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 resp onse boat operations, lightering, spill containment and recovery, and ISB operations

In addition, selected site personnel shall be fully aware of waste issues in volving 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, Dr illers, 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, MMSBOEMRE requires weekly pit- and trip-drill exercises designed to keep drill crew personnel alert to well control contingencies. The BOP is regularly pressure- and function-tested, again under MMSBOEMRE requirements, and flow-chart response plans are kept visible on the drill floor as decision aids to t he 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 contra ctors and non-employees who work at Shell facilities must also obey this policy. Shell requires joint vent ure 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 S hell-controlled premises constitutes consent to and recognition of the right of the Company to conduct ran dom drug testing, as well as drug testing for cause.

Beyond these requirements, operators of designated critical equipm ent (such as company drivers, crane operators, and work boat operators) are subject to daily alcohol testing.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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### Failure to cooperate, or repeated positive test result s 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 monitori ng designed to pursue Shell’s international goal of safe working conditions and continuous performanc e improvement. Shell employees and contractor employees are required to have medica l 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 ons et of employment and periodically as specified in the FTW policy. Contract employees who perform dr illing, navigational towline, security, maintenance, fuel transfer or response duties are required to have a medical evaluation of FTW based upon their job responsibilities. W here a Shell protocol exists for a specific j ob 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 t he transportation of Shell and contractor personnel via the Shell Logistical Support Base facility or other co mpany-established logistical bas e. Security services may be provided through coded badges or a professional security company for Shell’s Logistical Support Base and other suppo rt 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 operat ions will be conducted fr om 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 vess els prior to mobilization, and all OSR equipment will be mobilized directly to the Chukchi Sea onboard the OSR V task forces . Transport of any remaining supplies during the drilling season is expected to be minima l, mainly related to tr ansfers of spare parts, drilling tools, and other unforeseen items which can be tr ansported 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 AC S shoreline recovery effort and, in all likelihood, temporary camps would be mobilized to suitable ar eas 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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### 2.1.5 Fuel Transfer Procedures [18 AAC 75.025]

At exploration sites, the following ty pes of fuel transfers will be conducted:

 Fuel transfers to or from the drillship, includ ing transfers from the drillship to other supporting vessels (e.g., anchor handler) or helicopters.

 Fuel transfers to or from the OSR vesselV , including transfers from these vessels to other supporting vessels such as work boats.

Fuel Transfer Procedures for the OSR vesselV and for the FrontierNoble Discoverer are in Appendix C.

The drillship FrontierNoble Discoverer incorporates fuel transfer facilities for helicopter support, fuel barge, and other support vessels.

Fuel transfers will be perfo rmed 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 pr ocedures governing fuel tr ansfers, 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 t he onboard storage tanks to sett ling 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. Thes e transfers generally will occur twice daily, once per shift, and are performed by marine pe rsonnel. Safety procedu res include adherence to an internal fuel transfer checklist, direct communication among pers onnel, 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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### Helicopter Fuel Transfer
Helicopter fuel transfers include stor age, filtering, and transfer of fuel from the fuel pods located on the drillship deck through pump s and filters to the delivery skid on the heli-deck. Em ergency shutdown controls are located at the heli-deck and the forwar d 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 Landi ng Officer or one of three heli-deck crew members) will activate this system.

Drillship Fuel Transfers
No fuel transfers will occur during emergency weather co nditions or alarms without the direct approval of the Offshore Installation Manager (OIM). Safety of di esel fuel transfer to the drillship will rely on direct communication between drillship and fuel supply ve ssel personnel responsible for the transfer procedures. Preventive measures for ensuring safe transfer will rely on pr e-transfer proced ures. 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 fueli ng facility and the drillship personnel. Continuous communication is the best preventive measure for avoiding an emergency sit uation. 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 clos ed 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 fuel transport vessel will receive diesel fuel delivered from a drilling support vessel or third-party fuel barge. The OSRV vessel may also serve as a fuel lightering vessel transporting fuel from a dri lling 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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### Refer to Appendix C for the fuel transfer procedures for the OSRVto be implemented by the fuel transport vessel

.

The OSRV fuel transport vessel may also at times be used to provide diesel bunkering for OSR-related work boats (34-foot work boats), in which case t he transfer would always be conducted under the fuel transfer procedure s in Appendix C. of the OSRV.

In the event that any oil spill response-r elated work boats or support vess els 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 Re sponse Plan, or as required under the lease stipulations, fuel transfers will include the us e 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 FrontierNoble Discoverer drillship include routine internal inspections and maintenance. Maintenance is an important tool for spill preventio n because it monitors mechanical integrity and is documented daily by written reports. During the refu rbishment phase, maintenance records are kept in log books. Under the operating phase, mainten ance is performed according to a computerized maintenance program with records kept in the elec tronic 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 main tenance department is notified and personnel are assigned the repair task by either the Chief Engin eer or the Maintenance S upervisor. Equipment is inspected based on frequency intervals indicated in the maintenance program and in accordance with manufacturer and industry recommendations. For exam ple, 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 an d lines will be conducted da ily. 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 w ill be properly reported in the daily tour report and the Toolpusher will be notified.

Piping between the storage tanks and boilers or engine s is attached to the structure with brackets or double plates that protect the pipi ng 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 inclu de floor drains around the drilling deck to stop minor spills from flowing off the deck. Supplemental one-inch drain lip s at individual doorways are provi ded to contain potential spills to a single room. The FrontierNoble Discoverer floor drains flow to a holding tank. From the holding tank, the spilled liquid is sent through the oi l-water separator. Afte r separation, water is routed overboard and contaminants are stored until shipped ashore for proper disposal.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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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 caus e gas or fluids from the formations to escape in an uncontrolled manner. This section provides info rmation 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 elemen t, whether caused by operational error or equipment failure, should lead to loss of well control. Theref ore, Shell applies the following series of layers of prevention and response to well control issues:

 Layer I includes proper well planning, risk identifi cation, 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 time ly 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 pum ps, 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 w ould 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 form ations, and maintenance of drilling fluids of sufficient volume and density in the wellbore to counteract any experienced geol ogic pressures. Data from previous wells in the area have been used to anticipate formation pr essures that might be experienced when drilling the planned wells and the wells have been designed to handl e the expected pressures. See Figure 2.1-1 for an example of this process.

The primary causes of loss of well control are insuffi cient 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 prevent ed by properly designed casing st rings and drilling fluid systems.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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### Shell’s approach to reduci ng 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 wr iting Shell’s “Drill-the- Well-on-Paper” (DWOP) exercise;

 Contingency planning, including oper ation-specific plans to mitigate all of the potential causes of loss of well control; and

 Flexible well design to accommodate a r ange of uncertainty in subsurface data.

The following training and drills support the proactiv e approach to well control in the well preparation phase.

 On-site Shell and contractor supervisors ma intain current well control certification.

 Prospect-specific well control scenarios and kill techniques are modeled and simulated using Shell’s proprietary software and well control simu lators at the Robert Training and Conference Center.

 Shell foreman, Shell engineers, c ontractor 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 neighbor ing 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 pr essures and interpret existing datasets to design a safe and productive drilling program.

Shell performs a site-specific hazardous operations a nalysis 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, operatio ns 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 opp ortunities; and then 3) use this information to develop the optimum drilling program. Shallow hazards surveys have al so been conducted to assess the shallow areas of the planned wellbore for potential pockets of s hallow gas that could result in loss of control.Oil Discharge Prevention and Contingency PlanChukchi Sea Regional Exploration ProgramPart 2 – Prevention PlanShell2-8 March 201095-2000.01-25.201-001/09-018Rev. 0FIGURE 2.1-1MODELS FOR SITE-SPECIFIC WELL CONTROLOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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### In addition to site-specific hazardous operations anal yses and the DWOP exercise for each prospect, the following additional risk identification and mitigation measures would be taken:

 Site-specific well control modeling fo r 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 automa ted 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 Meas urement-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 m ud logging capabilities at the drillship and allows Shell to easily make the people with the right skills available to support the drilling operation.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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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 ki ck 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 bl owout while drilling a hole at the mudl ine, 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 o il would be expected at t he 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 c onducting drilling operations using high resolution profiling systems. This survey woul d 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 woul d be made to shut-in the well to contain the gas because the shallow formations exposed at these d epths generally would not have enough strength to control the gas. Instead, the gas would be directed aw ay 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 struct ural integrity of the wellbore, the drilling fluid is cooled to ensure that the wellbore rema ins frozen, with the gas tr apped, 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 riskOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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### identification. Isolating formations with casing and appropriately maintaining the drilling fluid properties, including density, are critical to preventi ng loss of well control during drilling.

Once the conductor casing has been set across t he 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 di agram of the BOP to be used with the FrontierNoble 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 un likely 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 imm ediately to shut-in the well and confine the pressure within a closed system. The casing program will be des igned so that any anticipated formation pressure can be shut-in at the subsea BOP without rupturing the casing. Shell repres entatives assigned to the drilling unit have MMSBOEMRE -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 MMSBOEMRE and Shell.

The BOP for the FrontierNoble 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 FrontierNoble Discoverer , refer to Figure 2.1-4.FIGURE:

2.1-4

UMQ: 14000311_Shell_CC_Blowout_Prevention_v002 Date: 4/19/2011 

## SHELL Chukchi Sea Regional Exploration Oil Discharge Prevention and Contingency Plan BLOWOUT PREVENTION SCHEMATICOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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### After installation, the BOP will be tested in accordance with MMSBOEMRE 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 MMSBOEMRE 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 MMSBOEMRE

. Spill Prevention Practices and Training
Blowout prevention drills are perfor med on a frequent basis to ensure the well is shut-i n properly and quickly. Blowout prevention testing in tervals are within the standard of MMSBOEMRE regulations. Blowout preventers will be pressu re-tested every 14 days and function- tested every 7 days. In addition, drilling personnel are MMSBOEMRE -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 dr illship. 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 reco rded 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 ex ploration are integral parts of the FrontierNoble Discoverer which will undertake the drilling program. The FrontierNoble 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 MMSBOEMRE 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 obse rvation and mechanical and remote soundings during transfer operations. Containment save-all is in place around the fuel tank vent outlet.

The FrontierNoble Discoverer fuel tanks are integral to the vessel’s hull. Therefore, all loading stations and vents are provided with save-alls or high coamin gs as per the requirements of SOLAS (International Convention for the Safety of Life at Sea), MARP OL (International Conventi on 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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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 FrontierNoble 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 sa fely 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 discha rges and their impact. The spill history of previous exploration drilling in the Chukchi Sea demonstrates t he low probability of an event causing oil to enter into an open water environment. Table 2.3-1 summar izes 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 operation s 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 ar eas. 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, wh ich prevent transfers duri ng unfavorable wind or sea conditions. Transfers are announced in advance and ve rbal 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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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 water750,000 bbl 30 days (Section 1.0) BOP and related procedures for well control.



### Blowouts
Since 1940, oil and gas exploration and production hav e been conducted in U.S. federal waters. Given the use of modern prevention and cont rol techniques, actual blowouts are extremely rare and of relatively short duration. Often used interchangeably, the term “b lowout” is also known as a “loss of well control”, and often does not result in a release to water. As currently defined by MMSBOEMRE , 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 failu re of surface equipment or procedures.

From 1971 to 2005, 276 exploration and developm ent blowouts occurred on the OCS while drilling approximately 34,000 wells. Thirty-t hree 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 eith er 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 stra tegies are discussed in Section 1.6.Oil Discharge Prevention and Contingency PlanChukchi Sea Regional Exploration ProgramPart 2 – Prevention PlanShell2-16March 2010May 201195-2000.01-25.201-001/09-018Rev.10TABLE 2.3-2POTENTIAL DISCHARGE FOR ALASKA OFFSHORE DRILLING (1997 TO 2003)PLAN NAMEPRODUCTION OREXPLORATIONOPERATOR18 AAC 75.425(e)(1)(f)SCENARIO WELLBLOWOUT WORST CASEDISCHARGE VOLUME(bbl/day)18 AAC 75.425(e)(2)(C)POTENTIAL DISCHARGEANALYSIS BLOWOUTVOLUME (bbl/day)MMSBOEMREWORSTCASE DISCHARGEVOLUME (bbl/day)McCovey Exploration Exploration AEC Oil & Gas, Inc. 5,500 (March 2002) 5,500 (March 2002) 5,500 (March (2002)Warthog #1 Exploration ARCO 5,500 (August 1997) 5,500 (August 1997) 5,500 (August 1997)Northstar Operations ProductionBPXA BP Exploration(Alaska) Inc. (BPXA)7,220 (May 2003) 10,000 (July 2005) 8,872 (January 2005)Milne Point Unit (F Pad) Production BPXA 2,000 (June 2002)142,800 gpd = 3,400bbl/day (March 2003)N/AGreater Prudhoe Bay Exploration BPXA 3,000 (September 2006) 6,005 (September 2003)2,000 (September 2003)Endicott Production BPXA 2,000 (December 2003) 2,250 (December 2003) 2,000 (December 2003)Badami Production BXAP 1,100 (May 2005) 1,045 (May 2005) N/AAlpine Dev. ParticipatingAreaProductionConocoPhillips Alaska,Inc. (CPAI)7,500 (January 2004) 7,500 (August 2004) N/AThomson Gas Cycling Exploration ExxonMobil 517 (May 2003) 517 bbl/day (May 2003) N/AKuparuk Field Production Phillips 66 1,000 (March 2003) N/A N/ACook Inlet AreaExploration ProgramExploration Phillips 66 1,500 (July 2001) 5,500 (February 2001) N/ATyonek Platform Exploration Phillips 66 5,500 (September 1998) 5,500 (September 1998) 5,500 (April 1998)North Slope ExplorationProgramExplorationPioneer NaturalResources5,500 (September 2005) 5,500 (September 2005) N/AKitchen Prospect Exploration Escopeta Oil 4,675(June 2006) 4,353 (June 2006) 4,675 (June 2006)Cook Inlet ProductionFacilitiesProduction/Exploration Unocal 76 300 (December 2006) 1,200 (December 2006) 300 (December 2006)Oil & Gas ProductionOperationsProduction Kerr-McGee 1,000 (September 2005) N/A 1,000 (April 2006)Northwest Milne PointExploration OperationsExploration Kerr-McGee 5,500 (January 2004) 5,500 (January 2004) 5,500 (January 2004)Oooguruk DevelopmentProjectExplorationPioneer NaturalResources Alaska Inc.2,500 (April 2006) 2,500 (April 2006) 2,500 (April 2006)Cook Inlet AreaProduction OperationsProduction/Exploration Forest Oil Corporation 1,500 (February 2002) 1,500 (August 2004) 1,500 (January 2002)Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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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 fact ors most likely to curtail operations and increase the potential for accidental discharge. Drilling operations will be conducted ut ilizing key precautionary measures documented in the COCP to minimize bo th 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 an d increase the likeliho od 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 transportati on activities between the drill site and staging areas. Strict adherence to air safety will be enforced.

 Sabotage or Vandalism: Potential for any sabota ge or vandalism is minimal. Security and specialinterest training by Shell and its contractors sh ould 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 thesummer months. Winds are predominately from the ENE June through November with occasional lowpressure systems moving into the area from the west ern Pacific through the Bering Strait bringing warm air and moisture. Wet conditions pr oducing fog and rain can result in pe riods 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 wa ve 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 determin ed in accordance with t he drillship’s re sponses to heave, pitch, roll, horizontal displacement, and anch or 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 regio nal wind and wave foreca sts will be received on each drilling unit two times a day with two updates between each forecast. Me teorologists with the w eather 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 willOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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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 w eather conditions (see Section 2.4.4 below for more information on this document).

Once on location, the drillship and key personnel monito r weather conditions continually using a variety of data including aerial ice reconnaissance, third-pa rty 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 comp lete 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 ceas e, the drill string is pulled into t he protective casing of the well, the drillpipe is hung off the blowout prev ention stack, and the dr illing 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 re treat 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 oper ations at all times. Exploration drilling will not be conducted after October 31. Other project activiti es 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 monito ring techniques include satellite-ba sed SAR, airborne and icebreaker reconnaissance, ice forecasting, and weather forecasti ng. 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 modi fication 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 dr illing 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 prot ects 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 respondi ng to potentially hazardous ice conditions: one set of protocols for typical summer drillin g when ice driven by wind and curr ents can move into the area; and another set of protocols to address winter freezeup c onditions. 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 im pacting the drillship or reducing ice buildup, then theOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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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 resp onsibilities 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 fo r safely and efficiently stop ping current operations so that the riser can be disconnected and the anchors retrieved or disconnect ed to move off location.” All estimates of operational closure ti me include safety marg ins that guarantee that the well will be completely secured in the best possibl e 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 ic ing. Accumulations of ice on the drill ship 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 gr avity and affect its heeling and righting moments.

The FrontierNoble Discoverer has been arctic-strengthened and has pr e-established ice load limits. If icing for the drillship approac hes the allowable amount, raising the allowed vertic al center of gravity, critical operations will be curtailed until sufficient ice has been removed and the loading is acceptable. The FrontierNoble 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 ess ential 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

MMSBOEMRE requires that offshore oper ators in the Alaska OCS Region develop procedures and maintain an MMSBOEMRE -approved COCP. The plan deals largel y with potential problems associated with severe weather and unexpected levels of ice. The procedures identify ice conditions, weather, and other constraints un der which the exploration activities will be either curtailed or st opped. Shell’s COCP provides a series of procedures for monito ring and responding to various ice conditions and weather/wave conditions at the drill sites. The fo cus 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, oceanographi c observations, sea state forecasts, ice monitoring, and ice forecasting. In addition to the environme ntal monitoring and forecasting system, real-timeOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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### measurements of drillship performance in ambient conditions is obtained from a performance-monitoring system installed onboard. An aler t 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 a nd prudent manner in the unique environment of the Chukchi Sea. The COCP is a compon ent of the Applications for Permit to Drill submitted for approval to the MMSBOEMRE . The COCP is also readily available onboard the drillship and in Shell’s offices.

The COCP defines standards and guidelines for the condu ct of operations on the drillship to minimize any hazard to personnel or the environment. In the Alask an Chukchi Sea, the two primary factors that can cause curtailment of critical operati ons and that potentially increase the risk of discharge while drilling are: sea ice and heavy weather. The object ive 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 descri bed 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 drillshi p lights and portable lighting as necessary.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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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 di scharge detection. Visual inspecti ons 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 drilli ng personnel. Once per day facility personn el will visually inspect tankage, sumps, and drains for indi cations of oil leaks. Piping, valves, pumps, and other machinery will also be visually inspected as part of the da ily 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 dr illing 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) System s limit the scope of any single failure. An ESD can be initiated by process condition s outside pre-set limits or manually initiated by operators at the instrument/control panels. Manually-actuated ESDs (pun ch-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 shut downs 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 hy draulic systems, are loca ted 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. Inci dents are recorded using an approved incident reporting and investigation process.

Further discharge detection is allowed by the cont inuous monitoring of the dr illship’s bilge systems. Potential discharge collects in system where it eventually travels to t he 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 me asures “best in class,” it will not be claiming any prevention credits to offset oil spill respon se 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 2 – Prevention Plan

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## THIS PAGE INTENTIONALLY LEFT BLANKOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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] ............................................................................ 3-13-1

3.1 FACILITY DESCRIPTION AND OPERATIONAL OVERVIEW [18 AAC 75.425( e)(3)(A)] ....................................................................................... 3-13-1 3.1.1 Facility Description .................................................................................... 3-13-1 3.1.2 Bulk Storage Containers ........................................................................... 3-33-3 3.1.3 Transfer Pr ocedures ................................................................................. 3-33-3 3.1.4 Vessel Plans and Diagrams

...................................................................... 3-33-3 3.2 RECEIVING ENVIRONMENT [ 18 AAC 75.425(e )(3)(B)] ...................................... 3-33-3 3.3 COMMAND SYSTEM [18 AAC 75.425(e)(3)(C)]

................................................... 3-73-7 3.3.1 Incident Man agement Team ..................................................................... 3-83-8 3.3.2 Unified Co mmand ..................................................................................... 3-83-8 3.4 REALISTIC MAXIMUM RESPONSE OPERATING LIMITATIONS [18 AAC 75.425(e)(3)(D) ] [30 CFR 254.26(D) ] .................................................. 3-153-15 3.4.1 Adverse Weather Conditions ................................................................ 3-183-18 3.4.2 Sea States, Tides and Currents

............................................................ 3-203-20 3.4.3 Hours of Daylight and Visi bility ............................................................. 3-283-28 3.5 LOGISTICAL SUPPORT [18 AAC 75.425(e) (3)(E)] .......................................... 3-293-29 3.6 RESPONSE EQUIPMENT [18 AAC 75.425(e) (3)(F)] ....................................... 3-313-31 3.6.1 Equipment Lists .................................................................................... 3-313-31 3.6.2 Maintenance and Inspection of Response Equipment ......................... 3-323-32 3.7 NON-MECHANICAL RESPONSE INFORMAT ION [18 AAC 75.425(e)(3)(G)] . 3-323-32 3.7.1 Assessment of Environmental Consequences and Monitoring ............ 3-403-40 3.7.2 Non-mechanical Res ponse Equipment ................................................ 3-413-41 3.7.3 Identification of Necessary Approval s and Application for Non-mechanical Response Options. ............................................................................... 3-423-42 3.7.4 Identification of Permits, A pprovals or Aut horizations .......................... 3-423-42 3.7.5 Plan for Protection Environmentally Sensitive Areas and Areas of Public Concern ................................................................................................ 3-423-42 3.8 RESPONSE CONTRACTOR INFORMAT ION [18 AAC 75. 425(e)(3)(H)]

......... 3-433-43 3.8.1 Statement of Cont ractual Terms ........................................................... 3-433-43 3.9 TRAINING PROGRAM [18 AAC 75.425(e )(3)(I)]

.............................................. 3-433-43 3.9.1 Incident Management Team Member Training

..................................... 3-443-44 3.9.2 Other Training ....................................................................................... 3-453-45 3.9.3 Record K eeping .................................................................................... 3-453-45 3.9.4 Spill Response Exercises ..................................................................... 3-453-45 3.10 PROTECTION OF ENVIRONMENTALL Y SENSITIVE AREAS AND AREAS OF PUBLIC CONCERN [18 AAC 75.425(e)(3)(J)] .................................................. 3-463-46 3.10.1 Sensitive Wild life Areas ........................................................................ 3-463-46 3.11 ADDITIONAL INFORMATION [18 AAC 75.425 (e)(3)(K)] .................................. 3-473-47 3.12 BIBLIOGRAPHY [18 AAC 75.425(e)(3 )(L)] ....................................................... 3-473-47

LIST OF TABLES

Table 3.1-1 Frontier Noble Discoverer Service Fac ilities .................................................................... 3-2 Table 3.3-1 Command Staff Contact Information

....................................................................... 3-103-10 Table 3.3-2 IM T Checklist ....................................................................................................

...... 3-123-12 Table 3.4-1 Ice Alert Levels

........................................................................................................ 3-163-16 Table 3.4-2 Ice Alert Roles and Responsibilities

........................................................................ 3-173-17 Table 3.4-3 Average and Maximum Wind Speeds

..................................................................... 3-193-19 Table 3.4-4 Percentages of Days per Month that Temperature Could Reduce Response Effectiveness For Worker Threshold Limit Values ................................................. 3-203-20Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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### Table 3.4-5 Beaufort Wind Force and Sea State Relationship Between Wind and Wave Conditions in Fully Develop ed Seas ....................................................................... 3-213-21 Table 3.5-1 Logistical Support Contractors ................................................................................ 3-303-30 Table 3.7-1 Minimum Ignitable Oil Thicknes s on Water (Adapted from Buist et al. 2003) ........ 3-343-34 Table 3.7-2 Burn Removal Rates for Large Fires on Water (Adapted from Buist et al. 2003) .. 3-343-34 Table 3.7-3 Fire Extinguishing Slick Thic kness (Adapted From Buist et al. 2003) .................... 3-353-35 Table 3.7-4 Inventory of In situ Burning Equipment (Shell and ACS) ........................................ 3-363-36 Table 3.7-5 Safe Working Distances From the Fire ................................................................... 3-383-38

LIST OF FIGURES

Figure 3.3-1 Incide nt Command System .........................................................................................

..... 3-9 Figure 3.4-1 Comparison of Regional Ic e Conditions......................................................................... 3-23Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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 mult iyear exploration drilli ng program in the Chukchi Sea OCS on current and future lease holdings.

Shell intends to utilize the drillship FrontierNoble 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 FrontierNoble Discoverer Drillship

The FrontierNoble 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 FrontierNoble 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 prov ided in Section 1.8, Figur es 1.8-1 through 1.8-5.

Table 3.1-1 describes the service facilities on the FrontierNoble Discoverer

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### TABLE 3.1-1 FRONTIERNOBLE 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 ve ssels as necessary for anchor handling, ice management, and general logistical support for the mo vement of supplies and personnel. Vessels for the 2010 season are identified in Appendix A. It is She ll’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-Pl an would be conducted by the following vessels (refer to A ppendix A for general specifications):

 OSR vessel and OSR barge, V Nanuq

, stationed near by the drillship while drilling into liquid hydrocarbon-bearing zones in the Chukchi Sea;

 Two (2) VOSS s, consisting of the anchor handler, Tor Viking or similar, stationed in the Beaufort Sea and within 42 hours proximity of the drillship while drilling into liquid hydr ocarbon-bearing
zones;

 Three 34-ft OSR work boats;

 Endeavor OSR bargeB , 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 hydrocarbonbearing zones; andOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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. T he OST would be the Arctic tanker Affinity or similar (70,000 gross metric tons, with a storage capacity of at least 287,100513,000 bbl).

Fuel Systems
The fuel system of the FrontierNoble 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 FrontierNoble Discoverer bilge system consists of a network of piping and mud boxes which are connected to locations where water is likely to co llect from environmental or natural leakage from equipment and other systems under normal operations. The bilge system is connec ted to two electrically driven bilge pumps located in the ship’s service pump room.

The oil-water separator on the FrontierNoble Discoverer is located in the propulsion room to treat effluent propulsion and forward generator room bilges.

3.1.2 Bulk Storage Containers

The FrontierNoble 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 287,100513,000 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. A second Shell-chartered OST would be mobilized and arrive at the drill site by Day 20 as needed with sufficient capacity to provide storage for the remaining recovered liquids for the duration of the 30-day WCD event.

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 and Appendix A, 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 woul d begin with the drillship traveli ng to the Chukchi Sea accompanied by support vessels, including the OSR vesselsV 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 cr eate an open water lead or polynya up to 30 mi (

 50 km) across from shore paralleling the coast betwee n Cape Lisburne and Point Lay. Breakup along the coast typically proceeds rapidly, changing from high ice concentration to open water in a few days. TheOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-4 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 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.

Project activities will commence after July 1 and cont inue 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 mixt ure of broken, eroded blocks and small floes. The edge of the ice pack is irregul ar 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 befor e winter ensues and the pack ice encroaches on the shoreline.

Shell’s lease area lies on the federal OCS within t he Chukchi Sea approximately 52 n mi or more off the north coast of Alaska in the Arctic Ocean. The wa ters of the Chukchi Sea begin just north of the Bering Strait and extend northward to the Ar ctic Ocean. The predominant curr ent 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 ty pically 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 Noat ak Rivers empty into the Chukchi Sea. Annually, the waters of the Arctic go through variations in salini ty. In the summer, waters are less saline than in the winter because of river inflow and ice melt. In wint er, 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 incr ease in range from 0.4 ft (0.1 m) at Barrow to up to 3 ft (1.0 m) in Kotzebue Sound. Fetch distances ar e significantly greater than the Beaufort Sea and wave energy levels are consequ ently greater. The possibility of cross-boundary impacts on Siberian waters does exist.

Predominately, the Chukchi coastal character is com posed 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 S ea offshore exploration area includes polar bears, bowhead whales, gray whales, minke whales, fin whales, walrus, beard ed seal, ringed seal, spotted seal, and marine birds.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-5 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### FIGURE 3.1-1 OIL SPILL RESPONSE VESSEL NANUQ DECK AND PROFILE VIEWOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-6 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### FIGURE 3.1-2 ENDEAVOR OIL SPILL RESPONSE BARGEOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-7 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### 3.3 COMMAND SYSTEM [18 AAC 75.425(e)(3)(C)]

Shell’s oil spill response co mmand 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 easi ly adapted to that described within the Alaska Incident Managem ent System (AIMS) Guide. As with AIMS, Shell’s em ergency management organization structure is based on the National Inci dent 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 inci dent-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 expansi on of the organization as necessary. The first person discovering or responding to any emergency sit uation becomes the On-scene IC unt il that individual relinquishes authority to another person better able to assess the situation.

In most Tier I incidents, the on-site spill technician s 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 perform ed. Once the assessment is complete, response personnel are either released or mobilized to the incident location.

For Tier I incidents, drillship personnel would repo rt 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 Fore man 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 collecti on and distribution of information. Shell and their response contractor provide perso nnel and equipment resources from the on-site OSR vesselsV, assets from the Beaufort Sea operations, , VOSS, and additional North Slope resources.

For Tier II/III incidents, the Drilli ng 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 incorpor ated into the IMT, when applicable.

The QI would be notified during callo ut of the IMT (Tier II or III res ponse). During Tier II events, the response contractor provides pe rsonnel and equipment. During Tier III events, the QI acts as the company representative for commitme nt of additional resources. The QI can be either the IC or the Deputy IC (DIC). As described in Section 1.1, Ti er 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 dr illship, at Wainwright and/or at Barrow, as
necessary.

For significant oil spills of Tier II and III magnitu de, 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,Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-8 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

###  Selecting strategies,

 Planning for tactical activities,

 Conducting integrated tactical operations, and

 Using resources effectively and efficiently. The Responsible Party (RP) would f ill the role of IC in the UC stru cture unless the FOSC determines the RP’s response is inadequate. In such a circumst ance, the FOSC would assume the role of IC.

Response personnel would be available to respond to a Tier II or Ti er III incident at a drill site through Shell’s primary response action contractors. If necess ary, 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 priori tizes strategic obje ctives to respond to an emer gency incident. Shell’s IMT would define the spill response tactic s and provide overall support to t he 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. S hell 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 IM T 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 repres entatives 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 Part 3 – Supplemental Information

Shell 3-9 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### FIGURE 3.3-1 INCIDENT COMMAND SYSTEM

Logistics Section

Support Branch

Service Branch 

### Operations

Section

Staging Area

Manage r

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 Office r Liaison Office r Public Affairs Office r

Safety Office r 

### Incident Commander/ QI

Deputy IC/ QI

FOSC / SOSC / LOSC Corporate CMT

Source Control Group

(Senior Exec. Liaison)

Supply Unit

Facilities Unit

Transport Unit ( V essel / Ground )

Food Unit

Medical Uni t

Communication UnitOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-10 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### TABLE 3.3-1 COMMAND STAFF CONTACT INFORMATION

NAME OFFICE # PAGER # CELL #

COMMAND STAFF

IC/QI

Rick FoxBrent Ross 907- 770-3700771- 7217 907- 360-4813223- 0061

Susan ChildsMoore 907-646-711 92 907-3 01-579282-5474
Deputy IC /QI

Susan Moore 907-646-7119 907-382-5474

Jon EdmondsonGeoff Merrell 907- 771-7221646- 7110 907- 952-7769306- 8016

Public Affairs/Information Officer Jennifer Taylor 907-646-7178 907-382-5974

Phil DyerCurtis Smith 907-646-718 12 907- 382-1410242- 5227

Liaison Officer

Susan Childs Nicole St. Armand 907-646-7152907- 646-7112 907-382-6852907-301- 5792

Nicole St. Armand Greg Horner 907-646-7131907- 646-7152 907-227-1065907-382- 6852
Safety Officer

Brad Boschetto 907- 770-3700646- 7121 907- 382-5050854- 0073

Grantt BedfordMike Corron 907- 771-7201646- 7103 907- 382-2808223- 6878
Legal Officer

Marc Stone 281-544-2596907- 646-7127 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 Pete Slaiby 504-728-6711 281-857-1888

Pete Slaiby Gary Cameron 907-771-72 1049 907- 382-7247230- 5329
Source Control Executive Liaison (IC Support)

Paul GoodfellowJeff Wahleithner 281-544-4545281- 544-2151 303-918-1272281-857- 4014

Chandler Wilhelm Charlie Williams 832-337-1794713 546 6157 281-685-9088713-444- 3811

GENERAL STAFF

Operations Section Chief

Geoff Merrell 907- 771-7221 907-306-8016

ACS Staff 907-659-2405Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-11 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 O’Brien’s Oil Pollution Services (OOPS)AES-RO Staff 800-910-3778907- 339-6200
Staging Area Manager

ACS Staff 907-659-2405
Operations Section Branch Directors

Shell Staff 907-770-3700

ACS Staff 907-659-2405

AES-RO Staff 

### TABLE 3.3-1 (CONTINUED) COMMAND STAFF CONTACT INFORMATION

NAME OFFICE # PAGER # CELL #

Planning Section Chief

Carol TheilenJon Edmondson 907-771-7220907- 646-7110 713-504-9260907-952- 7769

Darla DareBrad Boschetto 907-646-7109907- 646-7121 907-854-4876907-382- 5050
Technical Specialists

Michael Macrander 907-646-7123 907-317-9314 Al Allen (Spiltec) 425-869-0988

Ian Voparil +3 12 0529 5867281-544-6906 +3 16 1596 3775281- 222-8472 David Dickins (contractor) 858-453-8688 ACS Planning and Development Manager (IMT coach/facilitator) 907-659-3220

Logistics Section Chief

Karen Spring Kate Marstall 907-646-7111907- 646-7111 907-306-6038907-382- 2755

Lev YampolskyJack Wallis 907-646-7160907- 646-7168 907-306-2574907-980- 2934
Support Branch Director

John Maketa 907-646-7172 907-980-5146

Finance Section Chief

Zach ReigleJoAnn Spears 907-646-7105907- 646-7191 517-944-1502907-229- 5501Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-12 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 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 r equired 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 hazardsOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-13 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 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 stationsOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-14 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 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 emergenc y 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? R equest 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 Ident ified 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 re sponse 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 m anagement and efficient use of available response resources to implement approved tactics and strat egies. State, local, and federal government participation, as UC representatives and within t he IMT, provides a venue fo r addressing concerns and regulatory issues as objectives, strategies, and tactic s are being developed. UC representatives review and approve the IAP that is presented fo r each defined operational period.

For state, federal, and local representatives, a coor dinated 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-15 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 3.4 REALISTIC MAXIMUM RESPONSE OPERATING LIMITATIONS [18 AAC 75.425(e)(3)(D)] [30 CFR 254.26(D)]

Certain environmental conditions can sometimes lim it the options for resp onse and their overall effectiveness. Some limitations are based on safety and health, and others concern equipment effectiveness or access. The environmental and safe ty 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 fact or. 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 tactic s appropriate for the actual conditions encountered in the field. Personnel safety would always receive t op priority during any spill response.

Environmental conditions that challenge the effect iveness of resp onse 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 drilli ng personnel in determining the co rrect procedures to follow when storm conditions are expected. S hell, consistent with the COCP, w ould evaluate the need to suspend operations during periods of adverse ic e, weather, or sea stat es 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 oper ations will not recommence until it is deemed safe by the appropriate personnel. As part of that decisi on, the Shell Drilling Forema n will assess the risks associated with drilling, including:

 evaluating the forecast for weather conditions;

 fuel and water sustainability;

 safety of operations: type of operation ne eded, 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 vessel s. See Table 3.4-1 (Ice Alert Levels) and Table 3.4-2 (Ice Alert Roles and Responsibilities).Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-16 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### For discussion and details on response equipment operat ing 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 conditi ons 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 woul d include weather, sea conditi ons, ice, daylight hrs, and other environmental conditions. Additional inform ation 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 ti me, in hours, of hazardous ice at the drill site.

Secure Time (ST): ST is the time, in hours, required to c ease drilling operations and temporarily abandon the well in a way tha t 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 pack age, safely store all items aboard the vessel, recover the moorings, an d make the vessel ready to evacuate the site. The move off ti me varies depending on the method of anchor recovery, which in tu rn depends on changing environmental conditions. A very short MT can be achieved in an emergency by actuating the rig anchor releases (RARs) or by si mply running the anchor lines off the winch es, 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 repr esents the total time required to terminate drilling operations, s afely secure the well and move the drillship off the drill site.

Hazardous Ice: Hazardous ice is any ice f eature that is considered to be a threat to the continued safe operation of the drills hip.Oil Discharge Prevention and Contingency PlanChukchi Sea Regional Exploration ProgramPart 3 – Supplemental InformationShell3-17March 2010May 201195-2000.01-25.201-001/09-018Rev.10TABLE 3.4-2ICE ALERT ROLES AND RESPONSIBILITIESAlert Condition Shell Drilling ForemanFrontierNobleOIMMarineSuperintendent Ice AdvisorIce Pilot/ IceManagementVesselCaptainsGreenHazardous ice isnot expected toarrive at locationwithin T-Timeplus >24 hrsEstablishes potential well ST inconjunction with the VMT. AdvisesOIM andFrontierNobleDrillingSupt. regarding any criticaloperations and curtailment plans.Approves Ice Alert Level.Monitors ice reports andforecasts, directs icemanagement operations.Determines Ice Alert Levelin conjunction with VMTEstablishes potentialMTMonitors ice conditionsand predictions, reportsHT to the OIM and VMT,provides link to Ice Pilotsfor ice managementvessel deployment andrecon.Conducts ice recon asdirected by OIMthrough the IA, ordesignate, and reportsto IA and IWC.YellowHazardous ice isnot expected toarrive at locationwithin T-Timeplus >12 but <24hrsMonitors well operations relativeto ice forecast. Establishespotential well ST in conjunctionwith the VMT. Advises OIM andFrontierNobleDrillingSuperintendent regarding anycritical operations and curtailmentplans. ApprovesIce Alert Level.Monitors ice reports andforecasts, directs icemanagement operations.Determines Ice Alert Levelin conjunction with VMTEstablishes MT Monitors ice conditionsand predictions, reportsHT to the OIM and VMT,provides link to Ice Pilotsfor ice managementvessel deployment, reconand ice managementoperations.Conducts ice recon asdirected by OIM, ordesignate, reportspotential hazardousice conditions andlocation to IA and IWC.Provides ops link fromOIM to vessel CaptainOrangeHazardous ice isnot expected toarrive at locationwithin T-Timeplus >6 to <12hrsApproves Ice Alert Level.Establishes potential well ST and,if required, initiates well secureoperations.Determines Ice Alert Levelwith VMT. Monitors andcontrols ice operations.Continuously updatesall the potential MT.Ensures anchorhandling and RARcapability.Monitors ice conditionsand predictions, reportsHT to the OIM and VMT,provides link to Ice Pilotsfor ice managementoperations.Supports icemanagementoperations. Continuesto provide ice data toIA and IWC. Assists inpredicting HT.RedHazardous ice isexpected toarrive at locationwithin MT plus <6 hrsApproves Ice Alert Level.Manages well secure operationsand updates OIM on well status.Establishes availability ofadditional support for sitedeparture operations.Monitors ice conditions anddirects ice managementoperations for return to drillsite. Confers with theDrilling Foreman on courseof action to be takenManages mooringrecovery operationsMonitors ice conditionsand predictions, reportsHT to the OIM and VMT,provides link to Ice Pilotsfor ice managementoperations.Supports icemanagement andanchor handlingoperations.BlackHazardous ice isexpected toarrive at locationwithin 1 hourApproves Ice Alert Level. Conferswith OIM and monitors iceconditions for return to drillinglocation. Prepares well reentryprognosis with Drilling Engineers,and reviews withMMSBOEMREField Representative.Monitors conditions forreturn. Confers with DrillingForeman on the return IceAlert Level and tentativetiming.Safely clears drillinglocation with thedrillship. Prepares forreturnContinues to monitor iceconditions, prepares newestimates of HT for anyhazardous ice features,assist in establishing timeto return to drill site.Supports icemanagement, anchorhandling, and towingoperations. Conductsice recon as directed,assists in estimatingreturn time.IA = Ice Advisor RAR = Rig Anchor Release MT = Move Off TimeIWC = Ice and Weather Information Center ST = Secure TimeOIM = Offshore Installation Manager VMT = Vessel Management TeamOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-18 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### 3.4.1 Adverse Weather Conditions

MMSBOEMRE 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 re sponse equipment and tactics may be impacted by extreme weather conditions. Activities at the drill si te 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 visibili ty to a few feet. Drill site activity may al so be curtailed if crucial materials or supplies cannot be delivered. If conditions should ar ise 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 participat ion 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-pres sure 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 hi gh 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, al though rough weather may on occasion persist for many days.

Weather and ice conditions that may be present dur ing the drilling season are also represented in the Sections 1.6.13, Response Strategies. Additional in formation 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 oc cur predominately from October through March and near the coast. Extreme winds, recorded at the Barr ow weather station for all months, may be directly attributed to the large fetch of the Arctic Ocean to t he north, east, and west, as well as the lack of physical barriers and level tundra stretching 20 0 mi (322 km) to the south.

Shell leases are situated approximately 52 n mi or mo re 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 represent s measurements for the period June to November of 1980, 1982, and 1983. Based upon these measurement s, the aggregate and predom inant 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-19 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 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 offshor e/coastal boom and the skimmer systems may be deployed and operated in sea states associated with up to B eaufort Wind Force 6. The corresponding wind speeds for these sea states are up to 22 knots. Alternat ive countermeasures woul d 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, wh ile being the primary means of protecting personnel from the effects of wind chill, may also hinder the abilit y 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; ici ng 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 indoor s. At temperatures below -45°F, all non-emergency work will stop. Table 3.4-4 lists the percentage of days per month when the av erage monthly temperature falls below -20°F and response effectiveness may be reduced solely due to temperature.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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, complica ting 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 oper ating 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 consi deration, 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 a pproximately 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 fa ctors together with sea st ate can only be evaluated on a case-by-case basis. Alternative response met hods, from both aerial and vessel-based platforms, may continue to be used beyond this sea state.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-21 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 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 no t only upon the storm characteristics, but also on the topography onshore and bathymetry offshore. The characteristics of a stor m that affect the surge height include atmospheric pressu re, wind speed and direction, as we ll as the storm’s direction and speed. Storm surges are greater when air temperatur e 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 affe ct offshore drilling or re sponse operations. Ho wever, the high winds and sea states associated with these storms ma y hamper offshore response operations. Shell, consistent with the COCP, will ev aluate the need to susp end 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 impa ct 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-22 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 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 enc ountering 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 Ju ly 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 ov er the past 30 years to a summer average of 17 weeks. However, the range of open water is variabl e 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 acti vities will conclude with freezeup, which historically varies from late Oct ober 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 so lid ice in a matter of hours. Freezeup at the shoreline in this region is highly variab le with first new ice appearing as early as the first week in October and as late as the end of November. The inter-ann ual variability at a given coastal location is greater than the average north-south differe nce in timing of first ice (for example, comparing Wainwright and Barrow). Historic ally, the average freezeup dates at thes e two locations have differed by less than a week.

The Chukchi Sea ice environment differs significantly from the Beaufort Sea. Impor tant ice characteristics in this area (first-year ice thickness, multiy ear 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 t ends 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 br oadest 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 afte r April. However, in extreme cases, sustained westerly winds can prevent the lead from opening in la te 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 Wainwri ght) 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, fr om mid-May to mid-August in the ex tremes. In most years (10 out ofOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-23 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 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 wi th 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 brea kup 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 vari ability in breakup and freezeup dates. A record year of ice retreat in 2005 was followed by a late devel oping 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 free zeup (first appearance new ice) in the vicinity of the previously drilled Burger prospect occurred betw een 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 on e 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 counter measures. Recovery techniques in broken ice conditions would be similar to those employed during an open wa ter response, such as locating pockets of oil contained by ice for skimming or burning. As freeze up begins and ice concentrations beyond 10 percent develop, various techniques and equipment that ca n 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 potent ially 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 fo llowing spring, response efforts continue.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-24 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 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 perc ent in most situations (Shell et al. 1983; SL Ross 1983; SL Ross and DF Dickins 1987; Allen 1990; A llen 1991; Allen and Ferek 1993; Singsaas et al. 1994). Results of considerable resear ch have demonstrated the success of in situ burning in broken ice. The research includes several smaller-scale field a nd 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 brok en 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 bet ween 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 th at current (primarily wind-driven) could have upon the distribution of oil and, therefore, the f easibility of collecting and igniting the oil.

Open Water with Current

The initial distribution of the surfacing oil droplet s in open water could involve a surface area with a diameter of several hundred meters. The outer reache s of this area would involve a relatively small percentage of the total blowout release as the larges t 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 w ould 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 contai ned oil, a second fire boom could be positioned downstream of the open-apex to collect oil for a second burn. The elim ination of oil at the first boom could easily be completed in time to relieve the second collection e ffort 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 li ttle or no current, it is lik ely that authorization would have been secured (as in the previous scenario) to igni te the free gas directly over the blowout to avoid harmful exposures to personnel and any accidental igni tion 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 in to a layer that could support combustion. In this case, it is likely that the heat gener ated by the burning of free gas woul d be sufficient to ignite vapors from the surfacing oil, thereby enlarging the burn area and removing a substantial portion of the blowout.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-25 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 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 t he U-configuration. Two b oom-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 surf acing oil is held naturally at and near the spill source. In fact, the heated air rising above the blow out 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 burn ing 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 c onventional or fire booms may be reduced (depending upon the size and distribution of t he ice pieces) for the collection of oil. If the distribution of ice is such that ice could not be av oided or deflected away from the opening of a boom configuration, then ice could accumulate in high co ncentrations 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 ic e 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 act ually help in a number of ways. The ice would tend to dampen waves, reduce surface spreading radially over the blow out, and promote recoalescence of the surfacing oil droplets in the reduced water surface between ice ca kes 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 exce ssive (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 woul d 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, mo st oil would be exposed for combustion while it is fresh and relatively free of emulsification. Should th e natural floes be large enough to entrap some of the oil beneath them and keep the oil from surfacing, effo rts 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 comple tely modify the composition of the ice moving over a drilling location. For example, a 2004 coring pr ogram at 88°N saw two ic e 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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### Another approach that could enhance combustion of o il 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 mo deling efforts to show that such large-scale deflection of ice appears safe and feasible for the creat ion 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 conven tional 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 brea k 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-defle ction systems upstream of the blowout as described above. Such deflection would prov ide 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 necess ary 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 forwar d (or upstream) of the blowout. Oil (even widely scattered particles) surfacing within the cleared path downstream of the deflect ion system would soon be trapped within the downstream opening bounded on eac h 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 enhan ce 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 it s 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 s oon provide a “lip” around the oil (typically within hours to a day, depending upon air temperature and ice thic kness) further ensuring that the oil would not migrate out over a larger area. Typically within a day or two, new ice would co mpletely surround the oil, encapsulating, immobilizing and preserving the conditi on 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 surf ace through brine-channel migration or through surface melt down to the small entrapped oil droplets. The loca tion 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 pool s in the spring. The elim ination of evaporation,Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-27 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### emulsification and other weathering phenomena while the o il 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 in volves the use of vessels to break the newly formed ice with oil under it, or about to be encapsulated with in 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 o il 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, mu ltiyear 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 invo lve 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 oi l and gas at the surface. Depending upon the current and the rate of ice transport over the blowout, the r upturing 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 likel y 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 ic e 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 fo r 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 o il using on-ice “mining” techniques. Promising results of tests with Ground Penetrating Radar and other re mote-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 wa y 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 S ea 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 si gnificant 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 im pacting response operations because of a fairly complete sea ice cover. Structural ic ing becomes a concern as br eakup occurs in June. By July, the air temperature has warmed enough that onl y 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 Lisbur ne 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 toOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-28 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### the possibility of structural ice occurrence for the m onths of June through November. However, this value does not reflect the amount of time that structural ici ng will result in unsafe ic e 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 darkne ss, fog, snow, heavy precipitation, or low clouds. If wi nd, sea state, temperature, visibilit y 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 increas ed 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 hour s 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 sha ll 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 lo cate oil and assist recovery operations during periods of darkness. Visibility
The increase of daylight also paralle ls the occurrence of cloudiness, pr ecipitation, and heavy fog. All three build up to a maximum concurrent with the increas ed 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 limit ation varies between 0.125 and 0.5 n mi (200 to 800 m), depending upon temperature, sea state, wind, and prec ipitation. 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 aircra ft assistance to locate recoverable slicks, the limitations would likely be for the aircraft. A rea listic 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-29 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### In the event of adverse weather, f light limitations caused by adverse ceiling and visibility combinations may restrict offshore operations and response. Custom ary 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 re sponsible for providing facilities, transportation, communications, services, and material in support of the incide nt. 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. Tabl e 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 pr imarily be conducted from the Barr ow airport. The air strips at Wainwright, Point Hope, and Point Lay (to a limited ex tent) 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 al so support the response. Examples of these functions incl ude ordering, tracking and servicing government resources, arranging for transportation and lodging for gover nment response staff, providi ng communications to government oversight staff, and performi ng other logistical functions specific ally in support of the government oversight role. These governmental functions may bec ome an integral part of the overall Logistics Section.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-30 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### 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

Ukpik, LLCWire-Com - UIC 6700 Arctic Spur Road Anchorage, AK 99518 Communications, Data & Electrical (907) 563-2240

ProComm Alaska, LLC/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. 800-620-6520Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

Shell 3-31 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### TABLE 3.5-1 (CONTINUED) LOGISTICAL SUPPORT CONTRACTORS

COMPANY SERVICES CONTACT

FACILITIES

Marsh Creek LLC 2000 E. 88 th 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. 5 th 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 in formation 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 resp onse activities as discussed in Section 1.6.

Information on mechanical response equip ment 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 dditional list of the primary response assets that are available on the OSR vesselsV 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 ar e a number of conexes included in the vessel fleet which include a supply of contingency materials, t ools, PPE, and spare parts.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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: Clas ses MMPD, WCD1, WCD2, and WCD3;

 Inland environments: Classe s MMPD, WCD1, WCD2, and WCD3;

 Nearshore environments: Classes MMPD, WCD1, WCD2, and WCD3;

 Offshore: Classes MMPD, WCD1, WCD2, and WCD3; and

 Open ocean environments: Classe s MMPD, WCD1, WCD2, and WCD3.
ACS has fulfilled the equipment maintenance and testi ng 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 RE SPONSE INFORMATION [18 AAC 75.425(e)(3)(G)]

In situ burning and dispersant application will be cons idered as secondary response techniques. Additional information and considerations for when t hese options are to be considered are provided in Section 1.7 of this C-Plan.

In Situ Burn One of the most important factors t hat influence drilling activities is t he movement and amount of ice. Ice can pose a significant challenge for spill response; how ever, 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 resource s 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 prec lude the effective use of oil containment boom, responders may still operate with short boom exte nsions 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 c ontainment 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 bl owout) will likely become immobilized and encapsulated within the ice and therefore isolated from any contact with airborne or waterborne

resources.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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###  Oil encapsulated within the ice will be pres erved physically and chemically so that its unweathered state upon release (de liberately exposed, or naturally released during breakup) will support combustion.

In addition to the environmental factors described abov e, there are other spill sour ce considerations that should be recognized as they influence the full potent ial for elimination of spilled oil with burning:

 The spill scenarios associ ated with Shell’s operatio ns 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 theref ore be released to a relatively small area on the water with initial slicks with widths of typically a few hund red meters or less. Even with the gas-induced flow of oil and water toward the surface and the resulti ng radial spread of oil outward from the source, the initial area of involvement will be localized an d relatively easy to cont ain 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 ignit ed 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 comb ustion at/near the source. As discussed in Section 1.6.3, the potential ignition is int ended 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, becaus e this potential ignition is not posed as a response tactic, we anticipate the decision to i gnite 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 desc ribed in Section 1.7.1.

 With or without ignition of the blowout, preva iling atmospheric co nditions 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 fo r 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 stat e of understanding of the sci entific 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 th ickened 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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 (Die sel 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 (o r diameter), slick thickness, oil type and ambient environmental conditions. For most large [g reater 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 whil e 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) th ick 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) thick 1 90% of rate stated above Slick 2 mm (0.1 inches) thick 1 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 reduc tion in burn rate only applies at the end of a burn.

2. If ignited, emulsions will burn at a slower rate almost propor tional 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 fi re. 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 ty pe ceases to affect burn rate for the same reason.

An in situ oil fire extinguishes naturally when the slick bu rns down to a thickness that allows enough heat to pass through the slick to the water to cool the su rface of the oil, below the temperature required for sustained combustion. The thickness at which an oil fi re 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 wi nd (winds greater than 20 knots preclude in situ burning in most cases) current herding of slicks against barriers, and oil weathering.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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 co mbustion. 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 b ooms 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 mo re difficult to ignite and, once ignited, display reduced flame spreading and more sensitivity to wi nd and wave action. Stable emulsion water contents are typically in the 60 percent to 80 percent range wi th some up to 90 percent. The oil in the emulsion cannot reach a temperature higher than 100°C until t he water is either boiled off or removed. The heat from the igniter or from the adjacent burning oil is us ed 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 ma y not be a significant operational factor in planning in situ burning of oil on solid ice or naturally cont ained 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:Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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 e fficiency: 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) slic k 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 dur ing the proposed drilling season.

Operational Preparedness

Shell and its contractors maintain a comprehensive inv entory 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 o il with an open-apex U-boom configuration so t hat 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 specif ic 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 Secti on 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) 2Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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### In addition, Shell and ACS maintain all appropriate l ogistical support for controlled burning, including boom-tending vessels, helicopters and vessels to tr ansport 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 Augus t 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 ne cessary 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 pa cked ice cakes. Wind may provide such desired herding of oil naturally.

 Ignite the oil using the heli-torch or handheld igni ters, 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 ot her safety hazards and issues as appropriate.

 Make every effort to recover and dispose of the burn residue.

Safety procedures and planning in accordance wi th 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 fr om 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 ar e 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 eliminati on of gas as a safety meas ure, not related to oil elimination, is a UC decision that may follow the sa me planning process, but does not seek the permit necessary in the In Situ Burning Guidelines and issued by the ARRT.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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, an d 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 env ironmental impacts from spills when sea states or other factors limit or negate conventional countermea sures. 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 beyon d the limitations of mechanical equipment.

Dispersants are chemical formulatio ns containing surfactants that, when applied to a slick, lower the surface tension between oil and water, facilitating t he formation of oil droplets under wave action and preventing them from coalescing and resurfacing, th erefore enhancing oil dispersion and biodegradation into the water column. Dispersants may be strategi cally 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 t he several factors including: the effectiveness of mechanical response; whether dispersant applicatio n strategies can be employed to augment and not impede mechanical recovery; and whether environmental co nditions are right for dispersant use.

A critical window of opportunity ex ists in which both dispersants and in situ burning are best used. Generally, dispersants are most effect ive on fresh crude oil as the dispersant reacts with the more volatile hydrocarbons. Overtime, spilled oil in the marine environment will weat her losing volatile hydrocarbons and forming water-in-oil emulsion. For the Chukchi S ea blowout scenario, the dec ision to use dispersants may be considered daily until several da ys after well control is achieved.

Dispersants shall be recommended to augment mech anical response operations when mechanical recovery is not feasible and/or has reduced efficienci es, 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;Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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###  type of dispersant; and

 application systems and strategies.

Shell recognizes that when proposing the use of di spersants 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 explor ation operations and flow tests are complete. SMART protocols also recommend a fi eld test application for any proposed treatment of spilled oil with dispersants. Because the oil pr operties 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 e ffectiveness 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 ex tend response operations beyond mechanical recovery and in situ burning possibilities. Dispersants c an 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 Cont ingency Plan (NCP), the dispersant proposed and available for use in Alaska (Corexit® EC950 0 and Corexit® EC9527) are on the NCP Product Schedule and approved for use by EPA. Tests ha ve shown that both 95 00 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 disp ersion 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 wo uld be solid at seawater temperatures. If the water temperature is below the pour point of the oil, di spersant 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 inch es (0.1 mm) would require a dosage of about 5 gal of dispersant per acre for a commonly acc epted dispersant-to-oil (DOR) ratio of 1:20.

 Although near shore [<33 ft (10 m) water depth] di spersant application may in some cases be considered to protect sensitive resources, operatio ns in the Chukchi will more likely be offshore (approximately 52 n mi or more) near the sale area. Consistent with the guidelines establishedOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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 chemica lly dispersed oil does not adhere to some organisms or habitats to the extent of untr eated 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. Wh en 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 effectiv eness, 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 whic h 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 ener gy. 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 increase s in salinity (Chandrasekar et al. 2006). The OSR V vessels 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 dispersab ility of some oils with an increa se in salinity (Chandrasekar et al. 2006). The salinity of sea water normally r anges 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 st eps 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, burni ng is feasible, and the burn is a safe distance from populated areas.

The source location of a spill associated with Shell’s exploration activities woul d be at a great distance from shore (over 52 n mi), which far exceeds the mi nimum safe distance (>1 mile) to protect populated areas from the use of in situ burning. At these distances from population centers, Shell will performOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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 ar ea, 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 (typic ally less than 2 to 3 percent) and low toxicity; batch samples of the floating residue would be analyzed to conf irm 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 th e three tiers defined within NOAA’s dispersant use SMART protocol. Accepted by the response comm unity 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 re sponse and the incident -specific environmental conditions.

Shell would mobilize aerial and on-water monitoring c ontractors to the spill location located over 52 n mi offshore. Tier I SMART protocols would be implemen ted for approved dispersant application. Subject to UC and ARRT approvals for dispersant use, implementation of Tier II or Tier III SMART pr otocols provide for real-time fluorometry data collection, supplemented with water sample collection for later chemical analyses. The fluorometry readings provide data on the di spersant efficacy and the dispersed oil plume. Tier III also provides for the colle ction of data on physical parameters such as water temperature, conductivity, and turbidity that, when correlated with Ti er I visual observations and Tier II / Tier III fluorometry readings, may be used to evaluate dispersa nt 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 Anchora ge and 1,300 gal pre-staged with ACS on the North Slope. Both of these products are solvent-based “c oncentrate” dispersants that may be applied in their undiluted (neat) or diluted form. Toxicity info rmation 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 effectiv e 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 st andard DOR application rate of 1 to 20 would be used; however, this may be modified based upon incident specif ic needs and UC approval. Multiple passes or applications may also provide an added level of control.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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### Aerial application of dispersants would likely invo lve 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 ta nks on the MSRC C-130 Hercules have a 3,200 gal capacity. As a member of MSRC and ACS, Shell al so 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 stat e. However, vessel appl ication 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 re covery and/or burning of oil, vessels might be used to apply dispersants at or near the spill site. Even in the presence of broken ic e, dispersants could be applied and then agitated with drives that may be used to enhance the dispersion process. Any application of dispersants, whether fr om vessels or aircraft in open water or in broken ice, would always involve a thorough assessment of t he benefits and risks, and involve appr opriate authorization for use. Shell has equipped the an OSR vesselV 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 r equirements, 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 dispersant s 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 requir ed permits, approvals, and/or authorizations.

3.7.5 Plan for Protection Environmentally Se nsitive 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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 sensitiv e 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 co ncern, and the public from adverse effects when authorizing these response operations. The Un ified 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, thr eatened or endangered species receive priority to mitigate impact of spilled oi l 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 operati ons would be conducted in OCS waters far offshore and closely monitored for wildlife in the area. Trus tee agencies would be consulted for recommendations or necessary approvals to protect wildlife from the po tentially negative consequenc es 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, an d 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 a nd 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 manpowe r and resources required to respond to a large or lengthy spill response. If additional resources are requir ed, they will be accessed through master services agreements maintained by ACS and through other cont racts 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 Te rms is provided in Appendix B.



### 3.9 TRAINING PROGRAM [18 AAC 75.425(e)(3)(I)]

Shell and ACS provide training for HS SE 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 fiel d. This includes ensuring all requirements for pre-Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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### deployment site training to ensure personnel profic iency, both in open water and broken ice conditions. Spill response training is based on The National Pr eparedness for Response Ex ercise Program (NPREP) guidelines (August 2002).

ACS coordinated spill respon se training includes:

 Federally mandated; HAZWOPER, hazard communication (HAZCOM)

 Company directed; Shell, Edison Chouest, Cr owley, 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 av ailable 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 tr aining program. At a minimum, all North Slope spill re sponse personnel will receive the following required training: Initial Em ergency 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 In cident Management System (NIMS) required training guidelines. NIMS training that will be conducted fo r Shell and ACS personnel include online courses and classroom training. In addition, Shell will sponsor IM T 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-t he-job training to ensure response personnel are trained and kept current in the specifics of plan im plementation, equipment deployment, and mobilization of personnel and resources. Examples of ICS training courses include:Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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 des cription 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 expl oration activities . Shell’s HSSE Training Department maintains and conduc ts frequent training for HSSE awareness.

3.9.3 Record Keeping

Training records for Shell IMT training are kept at S hell’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 qua lifications are also maintained in the database. Records are kept for a minimum of five years or for t he duration of time that the employee or contractor is assigned respon sibilities in this C-Plan.

3.9.4 Spill Response Exercises

Shell will notify the MMSBOEMRE 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 S hell’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 prio r to the commencement of critical drilli ng 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 unschedul ed, may be conducted at the request of MMSBOEMRE or other authorities.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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 fo r 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 co ntaining aromatic hydrocarbon compounds. In various concentrations, the aromatic hydrocarbon constituents of crude oil ma y 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 resp onse 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 environment ally 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 signi ficance exist on the nearby shorelines. Because the proposed exploration activities w ill be offshore, these sites should not be impacted. If, at some point, onshore activities are required to support response ac tions, the Alaska Office of History and Archeology will be consulted in order to avoid arch eological disturbance s to these sites.

3.10.1 Sensitive Wildlife Areas

In the event of a major spill, se nsitive areas along the coastline may be affected. The environmental sensitivities for this explorat ion are summarized in Sections 1.6.11 and 1.6.12 and the ACS Technical Manual, Volume 2, Map Atlas. Additional sources in clude the North Slope Coastal ESI Maps (Maps 13 through 24) and Most Environmenta lly Sensitive Area (MESA) maps p ublished by NOAA and available online at http://www.asgdc.state.ak.us/maps/c plans/subareas.html#northslope

.
Primary areas of sensitivity are the habitats or rout es 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 in cluding 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 identif ication and protection of sensit ive sites during response efforts.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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 MMSBOEMRE 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/do cs/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 Semi nar, 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 Part 3 – Supplemental Information

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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 Departm ent 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 Environmen tal Information and Data Center, University of Alaska, Anchorage Alaska.

Brunner, R.D., Lynch, A.H., Pardikes, J., Ca ssano, 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, Mary land. 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 Environment al Conservation, Anchorage AK.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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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 Univ ersity 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 Product ion 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. Al aska 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 Part 3 – Supplemental Information

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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 Sensitivit y, 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 Co mpany, Exxon Company, U.S.A., Amoco Production Company. 1983. Oil Spill Response in the Arctic - Part 2: Field Demonstrati ons in Broken Ice

. Shell Oil Company, Sohio Alaska Petroleu m 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 Condition s 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, Baltim ore, Maryland. American Petroleum Institute, Washington, D.C. pp 383-387.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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### Vaudrey, K. 2000. Part II: A Review of Ice Conditi ons, 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 & A ssociates, San Luis Obispo, CA.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 3 – Supplemental Information

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### THIS PAGE INTENTIONALLY LEFT BLANKOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 4 – Best Available Technology

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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)] ...................................................... 4-24-2 4.2 SOURCE CONTROL [18 AA C 75.425(e)(4) (A)(i)] ...................................................... 4-34-3 4.2.1 Well Source Control ....................................................................................... 4-34-3 4.2.2 Tank Source Control ...................................................................................... 4-94-7 4.3 TRAJECTORY ANALYSES [18 AAC 75.425(e)(4)(A)(i)]

.......................................... 4-104-8 4.4 WILDLIFE CAPTURE, TREATME NT, AND RELEASE PROGRAMS [18 AAC 75.425(e) (4)(A)(i)] ....................................................................................... 4-104-8 4.5 CATHODIC PROTECTION [18 AAC 75.076(h)(4 )(A)(ii) .......................................... 4-104-8 4.6 LEAK DETECTION TANKS [18 AAC 75.425(e)(4 )(A)(ii)] ......................................... 4-104-8 4.7 TANK LIQUID LEVEL DETERMINATIO N [18 AAC 75.425(e )(4)(A)(ii)] ................... 4-114-9 4.8 MAINTENANCE PROCEDURES FOR BURIED STEEL PIPING [18 AAC 75.425(e) (4)(A)(ii)] .................................................................................... 4-144-12 4.9 PROTECTIVE WRAPPING OR COATIN G FOR TANKS AND PIPELINE [18 AAC 75.425(e) (4)(A)(ii)] .................................................................................... 4-144-12 4.10 CORROSION SURVEYS FOR AN EXISTING INSTALLATION ............................ 4-144-12 4.11 PIPELINE LEAK DETECTION ................................................................................ 4-144-12

LIST OF TABLES

Table 4.2-1 Best Available Technology A nalysis Well Blowout Source Control ............................ 4-64-5 Table 4.6-1 Best Available Technology Analysis Leak Detection for Tanks .............................. 4-124-10 Table 4.7-1 Best Available Technology Analys is Tank Liquid Level De termination System ..... 4-134-11Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 4 – Best Available Technology

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# PART 4 BEST AVAILABLE TECHNOLOGY [18 AAC 75.425(e)(4)]

This section discusses the BAT requirements cont ained in 18 AAC 75.425(e)(4)(A), (B), and (C) to address technologies not subject to RPS or perform ance 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 Avai lable 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 in jection 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 stor age 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 rate s 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 signific antly aid in the recovery effort s by accelerati ng 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 prim ary 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 OSR assets include four (4) Transrec 150 weir skimmers. V The offshore OSR barge is equipped with two (2) skimmer units mounted near the stern of the vessel, port and starboard. The and two VOSS , staged within 42 hr of the drill site, are is each equipped with one skimmer unit mounted near the stern of the vessel , port and starboard . This configuration permits the self-prope lled, 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 Shell’s the OSR skimming capability V and VOSS a combined total capacity up to 10,0645,032 bbl/hr ( 1,600800 cu m /hr ).

 Lamor-Lori brush skimmers, each consisting of five parallel, stiff-brush chains, were selected as proven systems for conducting reco very operations. Shell’s OSR vesselV and Nearshore OSR bargeB 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 recirc ulates 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 4 – Best Available Technology

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###  Lamor-Lori brush skimmers were selected as the primary recove ry system for Shell’s 47-ft, selfpropelled skimmer that will be stored on, and la unched 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 of the vessel, with a name-plate recovery capaci ty of approximately 516 bbl/hr (82 cu m/hr) gives this system a total potential reco very 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 maneuverabl e 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 OSR vesselV , 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 float ing 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 OSR vesselV , 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 (1 10 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 OSR vesselV , providing deflection for an OSR vesselV ; and as independent U-boom configurations for the collection of oil.

 Three water-cooled, Hydro-Fireboom packages, ea ch 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 OSR vesselV and OSR bargeB . 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-configur ation to capture and burn contained oil, or it can be held (in a station-keeping mode) at a su rfacing blowout, providing enough burn area to eliminate 10,000 to 15,000 bopd. This boom has under gone 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 co mpatibility with communication systems of Shell,Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 4 – Best Available Technology

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### ACS, all North Slope operators, and the worldwide te lephone network. Specifically, the drillship will be equipped with VSAT communication systems.

On-site communications systems are believed to be ade quate for most Tier 1 response efforts. In the event of a major or moderate Tier II/Level III sp ill response, the Global Mari time Distress and Safety 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 cont rol (i.e., a blowout) is also addressed in Sections 1.6.3 and 2.1.8, which includes a discussion of prevent ive measures that may be taken, along with other possible methods of well control. Shell’s Well Contro l Plan provides a detailed assessment of various methods of well control including surface control m easures, relief well drilling, blowout ignition, and the services of a professional well control firm, if we ll 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 liqui d 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 effo rts will begin immediately upon the incident escalating to a blowout.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 4 – Best Available Technology

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### 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 ca sing to become stuck in the hole. It is for this reason that an 8 1⁄2-inch pilot hole is drilled below the 30-inch casing and ope ned 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 prov ided in the annulus between the drill string and the hole and it provides the optimum condition for killing t he 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 we ll control as described in Section 2.1.8

. which involves early kick detection and kick contro l, 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 e ffectiveness of surface control measures:

 BOP element failure.

 Insufficient pump rate. In the event that the ava ilable 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 at tempt 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 ex tent 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 tech niques, Shell would be preparing to mobilize and drill a relief well as a contingency.

Well Capping
Subsea well capping capability has recently been devel oped that will secure a blowout by installing a purpose-built capping stack directly onto the top of the wellhead or a component of the original BOP stack. These techniques have been utilized and proven effective in dealing with several wells in the Gulf of Mexico following storm damage to platforms that initiated a well control event. Additionally, well capping was successfully employed to stop the flow from the Ma condo well blowout in deep water. When compared to the time required for drilling a relief well, well capping can be more rapidly implemented to reduce or stop flow of oil escaping into the wate r column thereby reducing associated environmental impacts. Well capping techniques have improved, especia lly since its frequent application during the IraqKuwait 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, si milar techniques for performing well capping in MLCsOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 4 – Best Available Technology

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### constructed on the sea floor from moored vessels ha ve not been proven. Theref ore, well capping would not be an effective option for regaining well cont rol while operating from a moored vessel.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration ProgramPart 4 – Best Available TechnologyShell4-6March 2010May 201195-2000.01-25.201-001/09-018Rev.10TABLE 4.2-1BEST AVAILABLE TECHNOLOGY ANALYSISWELL BLOWOUT SOURCE CONTROLBEST AVAILABLE TECHNOLOGY(BAT) EVALUATION CRITERIAPROPOSED METHOD:DYNAMIC SURFACE CONTROLALTERNATE METHOD:WELL CAPPINGALTERNATE METHOD:RELIEF WELL DRILLINGAVAILABILITY:Whether technology is best in use inother similar situationsor is available foruse by applicantDynamic surface control is in use globally.Subsea capping capability has recentlybeen developed that will allow a blowoutto be secured by installed a purpose-builtcapping stack directly onto the top of thewellhead or a component of the originalBOP stack. By closing valves on thiscapping stack, flow can quickly be halted.In the alternative, kill fluids can bepumped from a surface vessel into theflowing well to stop the flow.Equipment isnot available for wells drilled from mooreddrillships.Relief well drilling equipment (drilling unitdownhole tools, etc.) are widely availableaside from equipment required from a fewspecialty providers (e.g., rangingservices).TRANSFERABILITY:Whether each technology is transferableto applicant’s operationsTechnique is directly transferable, andequipment is the same as is used on thedrillship during normal operations.This technique is directly transferrable toShell’s operations in the Chukchi Sea.There are several capping systems nowavailable commercially, although Shell’sarctic capping stack was designed forexploration wells in the ChukchiSea.Proven technology is not available.Relief well drilling is directly transferableand can be performed by the drillship inuse by Shell in the Chukchi Sea.EFFECTIVENESS:Whether there is a reasonableexpectation each technology will provideincreased spill prevention or otherenvironmental benefitsIn the majority of cases, the technique ishighly effective. Application of dynamicsurface control provides the bestopportunity for minimizing pollutionimpacts because most blowout wells arecontrolled with dynamic surface controlswhile other methods are being mobilized.Technique would not be effective if BOPhad failed, and a safe work environmentcould not be ensured in the event ofextensive drillship or equipment damage,or if the drillship had to move from thelocation.Capping has proven to be effective indealing with several wells in shallow waterin the Gulf of Mexico (GOM) followingstorm damage to platforms that initiated awell control event. Capping was mostrecently used to stop the flow from the BPMacondo well after a subsea blowout indeep water in the GOoM.Proven effectivetechnology is not available.Technique is generally understood to beeffective in a wide range of situations.COST:The cost to the applicant of achievingBAT, including consideration of that costrelative to the remaining years of serviceof the technology in use by the applicantThe costs are relatively low, assumingthat the drillship is available to kill the welland consumables suchas drilling fluidsand cement are readily available.Cost for capping equipment are relativelylow compared with other drilling costs andthe cost of drilling a relief well andextending the time required for surfacecleanup operations. The cappingequipment will be available fordeployment from one of the surfacesupport vessels at or near the drill site.Notapplicable, because proven technology isThe cost of permitting, mobilization, andexecuting relief wells is high. Costsinclude day-rate of the vessel to drill therelief well, casing, drilling fluids and otherconsumables, as well as the cost of lostopportunity should the vessel have toprematurely end work on its intendedprospect.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration ProgramPart 4 – Best Available TechnologyShell4-7March 2010May 201195-2000.01-25.201-001/09-018Rev.10BEST AVAILABLE TECHNOLOGY(BAT) EVALUATION CRITERIAPROPOSED METHOD:DYNAMIC SURFACE CONTROLALTERNATE METHOD:WELL CAPPINGALTERNATE METHOD:RELIEF WELL DRILLINGnot available.TABLE 4.2.1 (CONTINUTED)BEST AVAILABLE TECHNOLOGY ANALYSISWELL BLOWOUT SOURCE CONTROLBEST AVAILABLE TECHNOLOGY(BAT) EVALUATION CRITERIAPROPOSED METHOD:DYNAMIC SURFACE CONTROLALTERNATE METHOD:WELL CAPPINGALTERNATE METHOD:RELIEF WELL DRILLINGAGE AND CONDITION:The age and condition of technology inuse by the applicantThe age and condition of the drillingequipment is appropriate for theoperation. Equipment is the same as isused on the drillship during normaloperations.Capping equipment is compatible with thewellheads, BOP stacks and connectionsavailable thereto. The capping stackinvolves components that are similar tothose found in subsea blowout preventersused in normal exploration drillingoperations.Not applicable, becauseproven technology is not available.The age and condition of the drillship andassociated equipment available for a reliefwell are appropriate for the operation.COMPATIBILITY:Whether each technology is compatiblewith existing operations and technologiesin use by the applicantTechnology is compatible and equipmentis the same as is used on the drillshipduring normal operations.Capping equipment is compatible with thewellheads, BOP stacks and connectionsavailable thereto. The capping stackinvolves components that are similar tothose found in subsea blowout preventersused in normal exploration drillingoperations.Not applicable, becauseproven technology is not available.Technology is compatible. The drillshiphas comparable equipment available.FEASIBILITY:The practical feasibility of eachtechnology in terms of engineering andother operational aspectsMethod is feasible for all drillingoperations. Would not be a feasible optionif the BOP had failed. Applied at thesurface, the technology is not sensitive towell type. Demonstrated success inhistorical well control efforts.Capping technology is both feasible andoperationally viable. Recent engineeringdesigns have proven to be effective andwill are expected to provide blowoutcontrol even in the event of a failedblowout preventer. Proven technology isnot available.Method feasibility is contingent upongeographical access near area of blowout.Seasonal ice conditions (e.g., offshoreChukchi) limit application to the drillingseason.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration ProgramPart 4 – Best Available TechnologyShell4-8March 2010May 201195-2000.01-25.201-001/09-018Rev.10BEST AVAILABLE TECHNOLOGY(BAT) EVALUATION CRITERIAPROPOSED METHOD:DYNAMIC SURFACE CONTROLALTERNATE METHOD:WELL CAPPINGALTERNATE METHOD:RELIEF WELL DRILLINGENVIRONMENTAL IMPACTS:Whether other environmental impacts ofeach technology, such as air, land, waterpollution, and energy requirements, offsetany anticipated environmental benefitsTechnology provides the best-provenopportunity to quickly reduceenvironmental impacts.Deployment and rapid blowout shutoff willreduce the volume of oil escaping into thewater column from a subsea flow therebyreducing environmental impacts whencompared to the time required for drilling arelief well. No additional impacts wouldresults from, say, mooring the relief welldrilling vessel, constructing a mudlinecellar or discharging waste streams intothe sea. In short, capping is the leadingconcept for shallow water blowout controlin the Chukchi Sea.Not applicable,because proven technology is notavailable.Technology provides additional exposureand environmental risks during application(additional well control problems).Additional environmental costs wouldinclude the resource consumption (e.g.,fuel, casing, and drilling fluids), wastegenerated, and emissions associated withdrilling the relief well. Technologyapplication may be seasonally limited,leading to durations of 60-180 days.Drilling a relief well is accompanied by theadditional risk of a second well controlevent.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 4 – Best Available Technology

Shell 4-9 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### Relief Well Drilling A relief well would be drilled by the drillship in th e Chukchi Sea (see Sectio n 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-con suming 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 2534 days for TVD up to 814 ,000 ft ( 2,3484,267 m) in the Chukchi Sea . 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. Statisti cally, it is more than likely that the blowout well would kill itself before the need to mobilize the drillship.

Relief well drilling technology is comp atible 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 avail able 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 wh ile drilling the ARCO Cirque exploration well. Control of the well was regained in approximately tw o 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 t he 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 specif ically 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 MMSBOEMRE and USCG as part of the drillship inspection prior to exploration activities.

Fuel storage tanks are equipped with manual shutdow n 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 s hut down the fuel transfer in the event of an emergency.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 4 – Best Available Technology

Shell 4-10 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### 4.3 TRAJECTORY ANALYSES [18 AAC 75.425(e)(4)(A)(i)]

As exploration drilling utilizes a subs ea BOP, oil associated with a blow out WCD is presumed to reach the mud-water interface (i.e. seabed) almost immediatel y. 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 Chukch i Sea. The trajectory presented in Scenario 1 is based upon the assumption that oil on open water move s as the sum of vectors representing surface currents and wind speed. The results of the trajectory analysis are present in Fi gure 1.6-8. Additional computer trajectories were run to calculate minimum response times under specific wind conditions to deploy shoreline protection for environmentally sens itive 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 releas e 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 pr ograms 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 FrontierNoble Discoverer drillship will have MMOs on board at a ll 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 a ll 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 le akage. Daily visual inspections, as outlined in Section 2.5, provide the most reliable, feas ible, 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 MMSBOEMRE 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 ac cordance 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 e quipment will be checked primarily by visual means prior to filling (e.g., by direct obse rvation 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 obse rvation may be more accurate and reliable than other devices such as sightglasses, float gauges, or tank st rapping, due to the tendency for these devices to fail under arctic conditions (Table 4.7-1). BMPs indicate tw o 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 time s for visual observations include the refueling of both the wireline unit and the crane fuel tanks.

The FrontierNoble Discoverer’s major integral tanks are sounded at least once per day to verify liquid levels. Tank levels also are man ually 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 va lves, filling the tanks, and manually closing the tanks. Visual inspection and proper communicati on between the pump operator and the person supervising the tank fueling is considered BAT for t hese transfers. Overflow fr om the temporary or deck equipment fuel tanks are captured in drip pans and deck drains.

All fuel transfers to temporary or deck fuel tanks ar e executed under the Permit to Work system following an associated Job Safety Analysis. Preventative ma intenance measures of control include careful planning of equipment placement for the storage tan ks. For example, tempor ary and deck equipment are not positioned over ope n grating if they are equipped with fuel tanks or associated fueling facilities.

These visual and manual methods, together with ad here 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 re liable, feasible, and cost-effective alternative.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 4 – Best Available Technology

Shell 4-12 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 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 extens ively 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 trans ferable 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 impac ts 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 Regional Exploration ProgramPart 4 – Best Available TechnologyShell4-13 March 201095-2000.01-25.201-001/09-018Rev. 0TABLE 4.7-1BEST AVAILABLE TECHNOLOGY ANALYSISTANK LIQUID LEVEL DETERMINATION SYSTEMBEST AVAILABLE TECHNOLOGY(BAT) EVALUATION CRITERIAPROPOSED METHOD: VISUALINSPECTION AND MANUALGAUGINGALTERNATIVE 1:SIGHT GLASS WITH BALL CHECKVALVE CONTROL SYSTEMALTERNATIVE 2:FLOAT LEVEL GAUGE (VAREC)CONTROL SYSTEMAVAILABILITY:Whether technology is best in use inother similar situations or is availablefor use by applicantProposed method. Sight glass with ball check valvesystems are used today, but lessfrequently than other devices.Float-actuated level gauges, such as Varecdevices, are widely used in the industrytodayTRANSFERABILITY:Whether each technology istransferable to applicant’s operationsTransferable. Undetermined. Transferable.EFFECTIVENESS:Whether there is a reasonableexpectation each technology willprovide increased spill prevention orother environmental benefitsHighly effective with strictadherence to BMPs and localprocedure. Tank liquid levels willbe determined from directobservation through the hatchusing a flashlight and manualmeasurement. As good as orbetter than other “low tech”devices.Not effective in this application. Sightglass systems are prone to breaking,becoming obstructed, and freezing ifmoisture buildup occurs in the tubing.In addition, the ball check valves areprone to freezing and sticking in eitherthe open or closed position.Effective in this application. However,condensation or freezing conditions mayobscure the measurement reading window.In addition, this system will provideinaccurate measurements if there isuneven sedimentation build up in the tank.COST:The cost to the applicant of achievingBAT, including consideration of thatcost relative to the remaining years ofservice of the technology in use bythe applicantNot applicable. Undetermined.Undetermined.AGE AND CONDITION:The age and condition of technologyin use by the applicantProcedures have been in place atNorth Slope facilities since 1993 forvisual fuel transfer operations andtank strapping devices have beenin use for 50 years.Sight glass devices have been used inthe industry for over 20 years, mostlyon permanent tanks.Float-actuated devices have been used inthe industry for over 20 years.COMPATIBILITY:Whether eachtechnology is compatible with existingoperations and technologies in use bythe applicantCompatible and widely used.Requires no change.Compatible but breakage potential is aconcern.Compatible and used in the industry ontanks in Alaska.FEASIBILITY:The practical feasibility of eachtechnology in terms of engineeringand other operational aspectsFeasible and preferred due toreliability in conjunction with BMPand monitoring procedures.Sight glass devices are typically notused in exposed areas as they canbecome a source for a leak ifdamaged.Feasible, but would require someengineering modifications to install andoperational modifications. There is concernover the use of float devices due to severalfailures of float devices within the state.ENVIRONMENTAL IMPACTS:Whether other environmental impactsof each technology, such as air, landor water pollution, and energyrequirements offset any anticipatedenvironmental benefitsNone. None. None.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 4 – Best Available Technology

Shell 4-14 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 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

Shell 5-1 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

# PART 5 RESPONSE PLAN NING STANDARDS [18 AAC 75.425(e)(5)]

This section discusses the applicable RPS used in th is 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)
ADEC’s regulations, 18 AAC 75.434, establish that an 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). For planning purposes, the total RPS volume in the ADEC Specific Scenario is based upon the WCD volume of 25,000 bopd for the duration of 15 day time period (25,000 x 15 = 375,000 bbl). Scenario 2 represents the RPS Scenario prepared to meet the response planning requirements of ADEC. 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 375,000 bbl [(375,00 0 x 1.54 = 577,500) + (375,000 x 0.20 = 75,000) = 652,500] for a total storage volume of 652,500 bbl.

Fuel Transfer Strategy (18 AAC 75.025)

The WCD for the fuel transfer strategy prepared for th is 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 me asures “best in class,” it will not be claiming any prevention credits to offset oil spill respon se planning requirements, based on exploration well operations as specified in 18 AAC 75.434.

The recovery equipment provided in support of th is plan (refer to Tables 1.6-5 and 1.6-6 in Section 1.6.13) substantially exceed the mech anical recovery capability needed to contain the WCD RPS (see Section 1).Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Part 5 – Response Planning Standards

Shell 5-2 March 2010 95-2000.01-25.201-001/09-018 Rev. 0Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

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## APPENDIX A GENERAL SPECIFICATIONS FOR MARINE AND AERIAL SUPPORT VESSELSOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

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# THIS PAGE INTENTIO NALLY LEFT BLANKOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

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### 1. MARINE VESSELS IN SUPPORT OF CHUK CHI SEA EXPLORATION DRILLING PROGRAM 2. AERIAL SUPPORT OF CHUKCHI SEA EXPLORATION DRILLING PROGRAMOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

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### 1. MARINE VESSELS IN SUPPORT OF CHUK CHI SEA EXPLORATION DRILLING PROGRAM

LIST OF MARINE VESSELS IN SUPPORT OF CHUKCHI SEA EXPLORATIO N DRILLING PROGRAM

Anchor-Handling M/V Tor Viking or similar
Anchor-Handling M/V Hull 247 or similar
Ice Management M/V FennicaVladimir Ignatyuk or similar
Offshore Oil Spill Response Vessel (OSRV) M/VOSRV Nanuq or similar

Offshore Supply Vessel M/V C-Leader or similar
Offshore Supply Vessel M/V Harvey Spirit or similar
Offshore Oil Spill Response Work Boats (3) 34-ft work boats
Offshore Oil Spill Response Barge OSR Barge Klamath or similar
Arctic Oil Storage Tanker Affinity or Perserverance, or similar

Nearshore Oil Spill Response Barge (OSRB) OSR BargeB Endeavor or similar
(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.)Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

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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 SuperOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-3 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### MSV TOR VIKING MULTIPURPOSE ANCHOR HANDLER/ 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)Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-4 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### M/V HULL 247 MULTIPURPOSE ANCHOR HANDLER OR SIMILAR

GENERAL SPECIFICATIONS

Length 360 ft Width 80 ft Draft 24 ft Accommodations 64 berths Maximum Speed 15 knots Fuel Storage 12,575 bblOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-5 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### THE M/V FENNICA MULITPURPOSE ICEBREAKER OR SIMILAR

The Fennica was specifically designed as a multifunctional icebreaker for operations in the northern seas for anchor handling, towing and ice management. The Fennica is equipped with a heli-deck and life saving watercraft.



### GENERAL SPECIFICATIONS

Deadweight Capacity 4,500 TONS Power 21,000 KW Length 116 M Width 26 M Draft 8.4 M Cruising Speed 16 KNOTS Berthing 82 Class 1A1-EOEO ICEBREAKER POLAR-10 TUG SUPPLY VESSEL SFSF OR HELDK EPR EO DYNPOS -AUTROil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-6 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### OSR V ESSEL – 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 (O SV) and I (cargo); ABS= A1 (Hull); ABS= AMS (Machinery); ABS Load Line; ABS DP-2; Ice Class A1, SOLAS 2000; MARPOL 99Oil 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 

### 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 arou nd 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 galOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-8 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### THE M/V C-LEADER OFFSHORE SUPPLY VESSEL OR SIMILAR

GENERAL SPECIFICATIONS

Length 280 ft Width 60 ft Draft 19 ft Accommodations 29 berths Maximum Speed 13 knots Fuel Storage 7,217 bblOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-9 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### THE M/V HARVEY SPIRIT OFFSHORE SUPPLY VESSEL OR SIMILAR

GENERAL SPECIFICATIONS

Length 280 ft Width 60 ft Draft 15.9 ft Accommodations 37 berths Maximum Speed 13 knots Fuel Storage 6,233 bblOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-10 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### OFFSHORE OIL SPILL RESPONSE BARGE KLAMATH OR SIMILAR

GENERAL SPECIFICATIONS

Length 351 ft Width 76 ft Depth 22 ft Liquid Cargo Storage (95%) 76,900 bbl Classification ABS - +A1, Grade B Oil Tank BargeOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-11 March 2010May 2011 95-2000.01-25.201-001/09-018 Rev. 10 

### OFFSHORE SEA ROBIN CLASS TUG OR SIMILAR

GENERAL SPECIFICATIONS

Length 126 ft Width 34 ft Draft 16.5 ft Main Engines (2) 3606 Caterpillar Horsepower 5,000 BHP Fuel Storage 1,786 bblOil 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 

### ARCTIC TANKER: AFFINITY OR PERSEVERANCE OR SIMILAR

Shell has chartered for the purposes of mass oil stor age 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 dime nsions 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, VC S-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: 6S 60 MC-C 7S60 MC-C Speed (knots): 16Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-13 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 COil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-14 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 waterl ine 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 lightOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-15 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 tanksOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-16 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 0.4Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-17 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### *GENERAL SPECIFICATIONS AGUSTA WESTLAND (IFR) TWIN TURBINE HELICOPTER

* specifications may vary betw een 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 0.7Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix A – General Specifications for Marine and Aerial Support Vessels

Shell A-18 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### *GENERAL SPECIFICATIONS LOCKHEED C-130A HERCULES

* specifications may vary betw een 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 fuelOil 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 RESPONDERSOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix B – Contractual Terms with Primary Responders

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## 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 Res ources, OSRO Classification

Reference: 33 CFR 1028

Dear Sir or Madam;

This is to certify that the following resources, un der 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, rec overed oil storage capacity 16,000 Bbls.

Oil Tanker Affinity or Perseverance , recovered oil storag e capacity 513,000 Bbls.

Please note that these resources wi ll be available within the stipulated res ponse times and within the geographic areas outlined in the Shell Exploration Oil Discha rge Prevention and Contingency Plans for the Beaufort and Chukchi Seas. If ch anges 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 CompanyOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix B – Contractual Terms with Primary Responders

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# STATEMENT OF CONTRACTUAL TERMS OSR VESSELV

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# STATEMENT OF CONTRACTUAL TERMS OSR VESSELV

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# STATEMENT OF CONTRACTUAL TERMS OSR VESSELV

Shell B-11 March 2010May 2011 95-2000.01-25.201/09-018 Rev. 10 

## 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 VESS EL REQUEST ORDER FOR M/V NANUQ (“VESSEL”) is entered into this 25 th 

## 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 entere d into a Vessel Request Order for the VESSEL on May 9, 2006 (hereinaft er 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 VE SSEL 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 retu rned to SHELL. No la ter 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 week s notice prior to retu rning 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 th e 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

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# STATEMENT OF CONTRACTUAL TERMS OSR BARGE

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# STATEMENT OF CONTRACTUAL TERMS OSR BARGE

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# STATEMENT OF CONTRACTUAL TERMS OSR VESSELBARGEV

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# STATEMENT OF CONTRACTUAL TERMS OSR VESSELBARGEV

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# STATEMENT OF CONTRACTUAL TERMS OSR VESSELBARGEV

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# STATEMENT OF CONTRACTUAL TERMS CROWLEY POINT OLIKTOK TUG

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# STATEMENT OF CONTRACTUAL TERMS CROWLEY POINT OLIKTOK TUG

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# STATEMENT OF CONTRACTUAL TERMS CROWLEY POINT OLIKTOK TUG

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# STATEMENT OF CONTRACTUAL TERMS ARCTIC TANKER (AFFINITY-PERSEVERENCE) OR SIMILAR

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# STATEMENT OF CONTRACTUAL TERMS ARCTIC TANKER (AFFINITY-PERSEVERENCE) OR SIMILAR

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# STATEMENT OF CONTRACTUAL TERMS ARCTIC TANKER (AFFINITY-PERSEVERENCE) OR SIMILAR

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# STATEMENT OF CONTRACTUAL TERMS OSV HARVEY SPIRIT OR SIMILAR

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# STATEMENT OF CONTRACTUAL TERMS OSV HARVEY SPIRIT OR SIMILAR

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# STATEMENT OF CONTRACTUAL TERMS OSV HULL 247 OR SIMILAR

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# STATEMENT OF CONTRACTUAL TERMS OSV HULL 247 OR SIMILAR

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Shell C-i March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

## APPENDIX C FUEL TRANSFER PROCEDURESOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix C – Fuel Transfer Procedures

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## 1. FrontierNoble Discoverer Fuel Transfer Procedures 2. Oil Spill Response Vessel and Barge Fuel Transfer ProceduresOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix C – Fuel Transfer Procedures

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## 1. FrontierNoble Discoverer Fuel Transfer ProceduresOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix C – Fuel Transfer Procedures

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### Fuel Transfer Procedures: FrontierNoble 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 familia rize 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

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## 2. Oil Spill Response Vessel and Barge Fuel Transfer ProceduresOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix C – Fuel Transfer Procedures

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### OSR V essel Fuel Transfer ProcedureOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix C – Fuel Transfer Procedures

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Shell C-17 March 2010 95-2000.01-25.201-001/09-018 Rev. 0Oil 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. 0Oil 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. 0Oil 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. 0Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix D – Oil and Debris Disposal Procedures

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## APPENDIX D OIL AND DEBRIS DISPOSAL PROCEDURESOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix D – Oil and Debris Disposal Procedures

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# INTRODUCTION

The collection, storage, transportation, treatment, and disposal of waste will be conducted in a manner that is both safe and environmentally sound. Proce dures 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 expl oration and production exempt waste.

However, crude oil contains benzene, which can be considered hazardous waste under the Resource Conservation and Recovery Act (RCRA) toxicity charac teristic 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 volat ilize rapidly from a spill. If oily waste is determined to be hazardous under RCRA, it will be labeled accordingly and s ent to a permitted facility for disposal.

In the event of a spill, a site-specific waste ma nagement plan will be developed to address the equipment, staffing, and other support necessary to address wa ste management issues under the known conditions of the spill. The template for the Shell Waste Mana gement Plan (which will be attached to the Incident Action Plan) is provided in Figure D-1. If an oil sp ill occurs during Shell’s Chukchi Sea exploration operations, wastes may be generated of fshore, near shore, and onshore.



### WASTE CATEGORIES Oil spills can result in several different types of gene rated wastes including those listed below. This waste may include oiled personal protecti ve equipment (PPE), possible shor eline 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 Appendix D – Oil and Debris Disposal Procedures

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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 fo r 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 me chanical recovery will involve t he 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 me thods for recovered oil/water/debris. The figure also depicts methods that may be employed to separate free a nd/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 fo rward of the recovery pump. This method is called “decanting.” This process is vital to the efficient mech anical recovery of spilled oil because it allows maximum use of limited st orage 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 t anker will be disposed of at a Shell Group refinery or a third-party processor.

 Oiled debris collected at sea requires specif ic handling. Contaminated materials should be placed in leak proof, sealable containers on the recovery vessels and transported to appropriate facilities for proces sing, recycling, or disposal.

 Oil recovered from onshore areas will typically contain substantial qu antities of water and debris. Excess water, sand, and other beach mate rials greatly increase the quantity of waste and its associated cost for transportation, proce ssing, 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. Usi ng 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 empt y fuel storage tanks.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix D – Oil and Debris Disposal Procedures

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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 designat ed waste treatment or disposal facility.

DISPOSAL REGULATIONS

 Oiled Materials – If these materials have not contacted extraneous su bstances, they will be disposed of at a Shell-approved disposal site.

 Oil and oily wastes that are contaminated or excessively weat hered will require transport to an approved disposal site. Any transport or dispos al of material that is considered hazardous waste must follow the re quirements 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 includ es 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 Expl oration and Production is listed in the manifest as the generator. The manifest should be signed by the designated Shell representative, and marked with the statem ent: “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 Tr ansportation (DOT) Hazardous Materials Regulations in 49 CFR 171 through 178, and applicable ADEC regulations. Ensure shipments of waste collected during spill cleanup activi ties are transporte d in appropriate containers to eliminate secondary releases during transport. If the nature of the waste precludes packaging in the requi red container, the Incident Commander should request emergency exemptions from the regulations following procedures outlined in 49 CFR 107.

o Waste haulers will use only stat e-certified disposal sites.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix D – Oil and Debris Disposal Procedures

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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, OS R V, or tanker.

 Transportation of oil or oily waste from shor eline locations will be by shallow-draft vessel, towed bladders, or air (helicopter sling-l oads 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 Heal th, Safety and Environment).Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix D – Oil and Debris Disposal Procedures

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### FIGURE D-1 WASTE MANAGEMENT PLAN

Always work safely in an environmentally sound man ner. Minimize waste. Consider waste management and generation in all actions. Never mix waste; alwa ys segregate. Report any accident or incident to your supervisor immediately. Reference the Wast e 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 ma p :

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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix D – Oil and Debris Disposal Procedures

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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 severa l 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 a nd equipment decontamination operations; waste storage and disposal area storm water runoff control operations; wildlife washing operat ions; 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 restor ation operations; personnel and equipment decontamination operat ions; equipment demobilization operations; wildlife capture, cleani ng and rehabilitation operations.

- Non-Oily Solids Offshore and onshore recovery operations; debris removal operations; garbage collection operations; construction operations; site restoration operations; wildlife capture, cleani ng and rehabilitation operations; equipment demobilization operations.

Hazardous

Vessels, vehicle, aircraft and equipment operat ions; dispersant use operations; wildlife rehabilitation operations.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix D – Oil and Debris Disposal Procedures

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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 tempor ary storage techniques. Note that each waste stream will have to be classified as to its hazardo us 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. Securi ty 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 (c leanup operations as well as the general public), tidal influx, local wildlife impact, security, cl eanup 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 fa cility 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 ForOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix D – Oil and Debris Disposal Procedures

Shell D-8 March 2010 95-2000.01-25.201-001/09-018 Rev. 0 

### 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 transpo rt 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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix D – Oil and Debris Disposal Procedures

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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 as sistance 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, Containe r 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 Appendix D – Oil and Debris Disposal Procedures

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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 separa te 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 sievingOil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix D – Oil and Debris Disposal Procedures

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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.Oil Discharge Prevention and Contingency Plan Chukchi Sea Regional Exploration Program Appendix D – Oil and Debris Disposal Procedures

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## APPENDIX E WILDLIFE CAPTURE, TREATMENT, AND RELEASE PROGRAMS CHUKCHI SEA OIL SPILL RESPONSE PLANNINGOil 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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### 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 99503Oil 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 protec tion, 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)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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### Table 1 Wildlife Response Contractors

Species Potential Contractors Wildlife Response Contractors

Observe

and/or Identify Develop Wildlife Assessment Haze Collect and Hold Treat Carcass Collection 4

Migratory Birds AES-RTS 1

ABR 6 , LGL 6 AES-RTS 1

ABR 6 , LGL 6 ACS 4

AES-RTS 1 IBRRC IBRRC 2,3,4 IBRRC 2 AES-RTS
ACS

Walrus and Polar Bears AES-RTS 1 AES-RTS 1 ACS 4

AES-RTS 1

IBRRC IBRRC 2,3,4 IBRRC 5 AES-RTS
ACS

Whales, Porpoises, Seals and Sea Lions AES-RTS 1 AES-RTS 1 ACS 4

AES-RTS 1

IBRRC IBRRC 2,3,4 IBRRC 5 AES-RTS
ACS

Terrestrial Mammals AES-RTS 1

ABR 6 , LGL 6 AES-RTS 1

ABR 6 , LGL 6 ACS 4

AES-RTS 1

IBRRC IBRRC 2,3,4 IBRRC 5 AES-RTS
ACS

Endangered Species* AES-RTS 1

ABR 6 , LGL 6 AES-RTS 1

ABR 6 , LGL 6 ACS 4

AES-RTS 1

IBRRC IBRRC 2,3,4 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 subcont ract 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 Appendi ces 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 – Re gulatory and Technical Services ABR = ABR Inc. Environmen tal Research & Services IBRRC = International Bird Rescue and Rehabilitation Center LGL = LGL LimitedOil 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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# 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 hol ders provide for a conflict avoidance mechanism to protect subsistence Whaling and Other Mari ne 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 incorporat e wildlife protection measures into facility design, implement wildlife monitoring and conflict avoidanc e 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,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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###  habitat types,

 spill trajectory, and

 hazing or treatment options. Qualified individuals to generate a “Wildlife As sessment” 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 Re quired 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 Wildlif e 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.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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# 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 m anagement 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 SpeciesOil 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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# 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 offs hore) S = Subsistence Species TS = Threatened Species ES = Endangered Species SMC = Special Management ConcernOil 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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# 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/Uni fiedPlan/index.shtmlOil 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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