# PUBLIC INFORMATION COPY

Exploration Plan 2010 Exploration Drilling Program Posey Blocks 6713, 6714, 6763, 6764, and 6912 Karo Blocks 6864 and 7007 Burger, Crackerjack, and SW Shoebill Prospects OCS Lease Sale 193 Chukchi Sea, Alaska

July 2009

Submitted to:

U.S. Department of the Interior Minerals Management Service Alaska OCS Region

Submitted by:

Shell Gulf of Mexico Inc. 3601 C Street, Suite 1000 Anchorage, AK 995032010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. i July 2009 15276-03-09-001A/09-011A Rev. 1 Table of Contents Page
ACRONYMS & ABBRE VIATIONS ...................................................................................................... ..... v CROSS-REFERENCE TO APPLICA BLE REGULATIONS .................................................................. viii
SECTION 1.0 EXPLORATION PLAN CONTENTS ......................................................................... 1 a) Description, Objectives, and Schedule ................................................................................... 1 b) Location ...................................................................................................................... ........... 2 c) Drillship ..................................................................................................................... ............ 6 d) Service Fee ................................................................................................................... .......... 8
SECTION 2.0 GENERAL INFORMATION ...................................................................................... 9 a) Application and Permits ....................................................................................................... .. 9 b) Drilling Fluids ............................................................................................................... ......... 9 c) Chemical Products ............................................................................................................. .. 10 d) New or Unusual Technology ............................................................................................... 10 e) Bonds, Oil Spill Financial Responsibility , and Well Control Statements ............................ 10 f) Suspension of Operations ..................................................................................................... 10 g) Blowout Scenario .............................................................................................................. ... 11 h) Contact Information ........................................................................................................... .. 11
SECTION 3.0 GEOLOGICAL AND GEOPHYSICAL INFORMATION ....................................... 13
3.1 Burger Prospect (Confidential) ............................................................................................ 13 a) Geological Description .............................................................................................. 13 b) Proposed Drill Sites and Bathymetry Maps............................................................... 13 c) Structure Contour Maps ............................................................................................. 13 d) Key Seismic Lines ..................................................................................................... 13 e) Geological Cross-Sections ......................................................................................... 13 f) Stratigraphic Columns and Time-versus-Depth Charts .............................................. 13 g) Shallow Hazards Report, Assessment, and High Resolution Seismic Lines ............. 13 h) Geochemical Information .......................................................................................... 13 i) Future Geological and Geophysical Activities ........................................................... 13
3.2 Crackerjack Prospect (Confidential) .................................................................................... 16 a) Geological Description .............................................................................................. 16 b) Proposed Drill Site and Bathymetry Maps ................................................................ 16 c) Structure Contour Maps ............................................................................................. 16 d) Key Seismic Lines ..................................................................................................... 16 e) Geological Cross-Sections ......................................................................................... 16 f) Stratigraphic Columns and Time-versus-Depth Charts .............................................. 16 g) Shallow Hazards Report, Assessment, and High Resolution Seismic Lines ............. 16 h) Geochemical Information .......................................................................................... 16 i) Future Geological and Geophysical Activities ........................................................... 16
3.3 Southwest Shoebill Prospect (Confidential) ........................................................................ 17 a) Geological Description .............................................................................................. 17 b) Proposed Drill Site and Bathymetry Maps ................................................................ 17 c) Structure Contour Maps ............................................................................................. 17 d) Key Seismic Lines ..................................................................................................... 17 e) Geological Cross-Sections ......................................................................................... 17 f) Stratigraphic Columns and Time-versus-Depth Charts .............................................. 17 g) Shallow Hazards Report, Assessment, and High Resolution Seismic Lines ............. 17 h) Geochemical Information .......................................................................................... 17 i) Future Geological and Geophysical Activities ........................................................... 17
SECTION 4.0 HYDROGEN SULFIDE INFORMATION ............................................................... 192010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. ii July 2009 15276-03-09-001A/09-011A Rev. 1 a) Concentration ................................................................................................................. ...... 19 b) Classification ................................................................................................................ ........ 20 c) Contingency Plan .............................................................................................................. ... 21 d) Modeling Report ............................................................................................................... ... 21
SECTION 5.0 BIOLOGICAL, PHYSICAL, AND SOCIOECONOMIC INFORMATION ............ 23 a) Biological Environment Reports .......................................................................................... 23 b) Physical Environment Reports ............................................................................................. 23 c) Socioeconomic Study Reports ............................................................................................. 24
SECTION 6.0 SOLID AND LIQUID WASTE AND DISCHARGE INFORMATION ................... 27
6.1 Burger Prospect ............................................................................................................... ..... 27 a) Projected Generated Wastes ...................................................................................... 27 b) Projected Ocean Discharges ...................................................................................... 28
6.2 Crackerjack Prospect .......................................................................................................... .. 29 a) Projected Generated Wastes ...................................................................................... 29 b) Projected Ocean Discharges ...................................................................................... 30
6.3 Southwest Shoebill Prospect ................................................................................................ 32 a) Projected Generated Wastes ...................................................................................... 32 b) Projected Ocean Discharges ...................................................................................... 34
6.4 NPDES Permit .................................................................................................................. ... 35
6.5 Modeling Report ............................................................................................................... ... 37
6.6 Cooling Water Intake .......................................................................................................... . 38
6.7 Disposal Caisson .............................................................................................................. .... 38
6.8 Desalination Unit BrineWater .............................................................................................. 38
SECTION 7.0 AIR EMISSIONS INFORMATION .......................................................................... 39 a) Projected Emissions ........................................................................................................... .. 39 b) Emission Reduction Measures ............................................................................................. 45 c) Processes, Equipment, Fuels, and Combustibles ................................................................. 45 d) Distance to Shore ............................................................................................................. .... 46 e) Impact Evaluation for Non-Exempt Drilling Units .............................................................. 46 f) Modeling Report ............................................................................................................... ... 46
SECTION 8.0 OIL AND HAZARDOUS SUBSTANCES SPILL INFORMATION ....................... 47 a) Oil Spill Response Planning ................................................................................................. 4 7 b) Location of primary oil spill equipment base and staging area ............................................ 47 c) Name(s) of spill removal organization(s) for both equipment and personnel ...................... 47 d) Calculated volume of worst case dischar ge scenario [30 CFR 254.26(a)] .......................... 48 e) Description of worst case discharge scenario ...................................................................... 48 f) Modeling Report ............................................................................................................... ... 48
SECTION 9.0 ALASKA OUTER CONTINENTAL SH ELF PLANNING INFORMATION ......... 51 a) Emergency Plan ................................................................................................................ ... 51 b) Critical Operations and Curtailment Procedures .................................................................. 51 c) Well Control Plan ............................................................................................................. .... 51 d) Fuel Transfer Plan ............................................................................................................ .... 51
SECTION 10.0 ENVIRONMENTAL MONITORING ..................................................................... 101 a) Monitoring Systems ........................................................................................................... 101 b) Incidental Takes .............................................................................................................. ... 101
SECTION 11.0 LEASE STIPULATIONS INFORMATION ........................................................... 105 Stipulation No. 1 - Protection of Biological Resources ............................................................... 105 Stipulation No. 2 - Orientation Program ...................................................................................... 106 Stipulation No. 3 - Transportation of Hydrocarbons ................................................................... 107 Stipulation No. 4 - Industry Site-Specific Bowhead Whale Monitoring Program ....................... 1082010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. iii July 2009 15276-03-09-001A/09-011A Rev. 1 Stipulation No. 5 - Lease Sale 193 Conflict A voidance Mechanisms to Protect Subsistence Whaling and other Subsiste nce-Harvesting Activities ....................................................... 112 Stipulation No. 6 - Pre-Booming Requirements for Fuel Transfers ............................................ 116 Stipulation No. 7 - Lighting of Lease Structures to Minimize Effects to Spectacled and Steller’s
Eider ......................................................................................................................... .......... 117
SECTION 12.0 ENVIRONMENTAL MITIGATION MEASURE INFORMATION ..................... 121 a) Permits and Authorizations ................................................................................................ 121 b) Protected Species ............................................................................................................. .. 121 c) Mitigation Measures .......................................................................................................... 122
SECTION 13.0 SUPPORT VESSELS AND AIRCRAFT INFORMATION ................................... 125 a) Shell 2010 Chukchi Sea Drilling Vessels and Aircraft List ............................................... 125 b) Air Emissions ................................................................................................................. .... 131 c) Drilling Fluids and Chemical Products Transportation ...................................................... 132 d) Solid and Liquid Wastes Transportation ............................................................................ 133 e) Vicinity Map and Travel Routes ........................................................................................ 133 f) Aircraft Waste Transportation ............................................................................................ 133
SECTION 14.0 ONSHORE SUPPORT FACILITIES INFORMATION ........................................ 137 a) General ....................................................................................................................... ........ 137 b) Air Emissions ................................................................................................................. .... 138 c) Unusual Solid and Liquid Wastes ...................................................................................... 138 d) Waste Disposal ................................................................................................................ ... 138
SECTION 15.0 COASTAL ZONE MANAGEMENT ACT ............................................................. 139
SECTION 16.0 ENVIRONMENTAL IMPACT ANALYSIS........................................................... 175
SECTION 17.0 ADMINISTRATIVE ................................................................................................ 177 a) Exempted Information (public information copies only) ................................................... 177 b) Bibliography .................................................................................................................. ..... 177

List of Tables

TABLE 1.a-1 Shell Lease Blocks Identified in the 2010 EP for the Chukchi Sea ............................. 1 TABLE 1.b-1 Proposed Drill Sites – Burger, Crackerjack, and SW Shoebill Prospects,
Chukchi Sea .................................................................................................................. 2
TABLE 1.c-1 Frontier Discoverer Specifications .............................................................................. 6 TABLE 2.a-1 Permit Applica tions Pending or Approved................................................................... 9 TABLE 2.b-1 Drilling Fluid Type, Qu antity and Discharge Rates ................................................... 10 TABLE 6.1-a Projected Generated Wastes Duri ng Drilling Season 2010 – Burger Prospect .......... 27 TABLE 6.1-b Types and Estimated Volume Ocean Discharges During Drilling Season 2010 – Burger Prospect .......................................................................................................... 28 TABLE 6.2-a Projected Generated Wastes During Drilling Season 2010– Crackerjack Prospect ... 29 TABLE 6.2-b Types and Estimated Volume Ocean Discharges During Drilling Season 2010 – Crackerjack Prospect .................................................................................................. 31 TABLE 6.3-a Projected Generated Wastes During Drilling Season 2010– Southwest Shoebill Prospect ...................................................................................................................... 32 TABLE 6.3-b Types and Estimated Volume Ocean Discharges During Drilling Season 2010– Southwest Shoebill Prospect ...................................................................................... 34 TABLE 6.4-1 Drilling Fluid Components and Load Out List for the Chukchi Sea Exploration Drilling Program ........................................................................................................ 37
TABLE 6.6-1 Screen Mesh Size on Wa ter Intakes on the Discoverer .............................................. 38 TABLE 7.a-1 Description of Discoverer Drilling Vessel Emission Units and Associated Fleet ..... 40 TABLE 7.a-2 Projected Peak Hourly Emissions of Discoverer Drilling Vessel Emission Units and
Associated Fleet ......................................................................................................... 412010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. iv July 2009 15276-03-09-001A/09-011A Rev. 1 TABLE 7.a-3 Projected Annual and Duration of Activity Potentials to Emit for the Discoverer Emission Units and Associated Fleet ......................................................................... 42 TABLE 7.a-4 Proposed Owner-Re quested Restrictions ................................................................... 43 TABLE 7.f-1 Summary of Maximum Estimated Concentrations .................................................... 46
TABLE 8.d-1 A Calculated Volume of a Worst Case Discharge ..................................................... 48 TABLE 10.b-1 Number of Potential Exposures of Marine Mammals to Received Sound Levels in the Water of >120 dB rms and (>160 dB rms) during Shell’s Planned Exploration Drilling Activities in the Chukchi Sea, Alaska, (July–October) 2010 ..................... 103 TABLE 11.0-1 Dates and Locations of Meetings Held Regarding the 2010 Chukchi Sea Exploration Drilling Program for Development of the POC ....................................................... 115 TABLE 12.b-1 Species Found in the Northeastern Chukchi Sea that are Protected under the Endangered Species Act. .......................................................................................... 121
TABLE 12.b-2 Marine Mammals Found in the Northeastern Chukchi Sea that are Protected under
the Marine Mammal Protection Act. ........................................................................ 121 TABLE 13.a-1 Specifications of Support Vessels ............................................................................ 12 5 TABLE 13.a-2 Specifications of the Major Oil Spill Response Vessels .......................................... 127 TABLE 13.a-3 Fuel Storage Capacity and Trip In formation for Support Vess els and Aircraft ....... 130 TABLE 13.b-1 Projected Annual Air Emissions from the Support Vessels Associated with the Drillship Discoverer for the Chukchi S ea Exploration Drilling Program ................ 131 TABLE 13.c-1 Drilling Fluid Loadout for the Discoverer for the Chukchi Sea Exploration Drilling Program .................................................................................................................... 13 2 TABLE 13.d-1 Transportation of Wastes ........................................................................................ .. 133 TABLE 14.d-1 Shorebase Waste Disposal Facilities, Waste Type, Amount, Rate, and Disposal
Method ..................................................................................................................... 13 8

List of Figures

Figure 1.b-1 Exploration Plan Location Map ................................................................................... 3 Figure 1.b-2 Crackerjack and SW Shoebill Prospects Location Map ............................................... 4 Figure 1.b-3 Burger Prospect Location Map ..................................................................................... 5 Figure 3.0-1 Stratigraphic Column - Chukchi and Beaufort Shelves ............................................. 14 Figure 3.0-2 Historic Oil and Gas Exploration in the Chukchi Sea ................................................ 15 Figure 6.4-1 Sewage and Gray Water Treatment System on the Discoverer .................................. 35 Figure 6.4-2 Oily Waste Separator System on the Discoverer ....................................................... 36 Figure 13.e-1 Marine Vessel Routes ............................................................................................... 134 Figure 13.e-2 Flight Corridor .......................................................................................................... 135

List of Appendices

Appendix A Outer Continental Shelf Plan Information Forms (Form 137) Appendix B National Pollutant Discharge Elimination System Notice of Intent Appendix C Application for National Marine Fisheri es Service Incidental Harassment Authorization Appendix D Marine Mammal Monitoring and Mitigation Plan Appendix E Application for U.S. Fish & Wildlife Service Letter of Authorization Appendix F Environmental Impact Analysis Appendix G U.S. Army Corps of Engineers Nationwide Permit 8 Appendix H H 2 S Contingency Plan for Frontier Discoverer Appendix I Plan of Cooperation Appendix J Bird Strike Avoidance and Lighting Plan Chukchi Sea, Alaska Appendix K Subsistence Advisor Program Summary, North Slope, Alaska2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. v July 2009 15276-03-09-001A/09-011A Rev. 1 ACRONYMS & ABBREVIATIONS

 g microgram
2D two-dimensional
3D three-dimensional 4MP Marine Mammal Monitoring and Mitigation Plan
AAC Alaska Administrative Code ACMP Alaska Coastal Management Program ACRT Auxiliary Contract Response Team
ACS Alaska Clean Seas ADEC Alaska Department of Environmental Conservation ADNR Alaska Department of Natural Resources AEWC Alaska Eskimo Whaling Commission APD Application for Permit to Drill
API American Petroleum Institute ASA Applied Science Association, Inc. ASRC Arctic Slope Regional Corporation AWAC Acoustic Wave and Current (meter) BACT Best Available Control Technology bbl barrel(s) BOP blowout preventer bopd barrels of oil per day BWASP Bowhead Whale Aerial Survey Project CFR Code of Federal Regulations CLO Community Liaison Officer cm centimeter(s)
CO carbon monoxide COCP Critical Operations and Curtailment Plan
Com Centers Communications and Call Centers CRT Contingency Response Team cu m cubic meter(s) dB decibel(s)
DHC DeHavilland Twin Otter
Discoverer drillship M/V Frontier Discoverer DOI Declaration of Inspection DPP development and production plan
E east EIA Environmental Impact Analysis
ENE East-northeast EP Exploration Plan EPA U.S. Environmental Protection Agency EPW Shell Exploration and Production Americas ESA Endangered Species Act
ft foot/feet
ft 2 square feet
ft 3 cubic feet gal gallon(s)
H 2 S hydrogen sulfide HAPs hazardous air pollutants HC hydrocarbon Hp horsepower2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. vi July 2009 15276-03-09-001A/09-011A Rev. 1 HSE Health, Safety, and Environment HSSE Health, Safety, Security and Environment
HT hazard time ICAS Iñupiat Community of the Arctic Slope
IHA Incidental Harassment Authorization IMP Ice Management Plan in inch(es) ISGOTT International Safety Guide for Oil Tankers and Terminals km kilometer(s) kW Kilowatt(s) Lb pound(s) LCMF LCMF Incorporated LMRP lower marine riser package
LOA Letter of Authorization m meter(s), also million
M/V motor vessel

m 2 square meter(s)

m 3 cubic meter(s) MARPOL marine pollution mi statute mile(s)
MLC Mudline cellar
MMO Marine Mammal Observer
MMPA Marine Mammal Protection Act MMS U.S. Department of the Interi or, Minerals Management Service MODU Mobil Offshore Drilling Unit
MT move-off time NAAQS National Ambient Air Quality Standards
NAD 83 North American Datum 1983
NE northeast
NMFS National Marine Fisheries Service
NNE north-northeast
No. Number
NOI Notice of Intent
NO

x Nitrogen oxides NPDES National Pollutant Discharge Elimination System NSB North Slope Borough
NSR New Source Review NSSRT North Slope Spill Response Team NWAB Northwest Arctic Borough
OCS Outer Continental Shelf ODPCP Oil Discharge Prevention and Contingency Plan OIM Offshore Installation Manager
OPA Oil Pollution Act of 1990 OSFR oil spill financial responsibility OSR oil spill response OSRB oil spill response barge OSRV oil spill response vessel OST oil storage tanker
PM 10 particulate matter less than 10 microns
PM 2.5 particulate matter less than 2.5 microns POC Plan of Cooperation2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. vii July 2009 15276-03-09-001A/09-011A Rev. 1 ppb parts per billion ppm parts per million PSD Prevention of Significant Deterioration PTE potentials to emit RAR rig anchor release rms root mean square ROV remotely operated vehicle RS/FO Regional Supervisor, Field Operations
SA Subsistence Advisor
SAR search and rescue SCR selective catalytic reduction
Shell Shell Gulf of Mexico Inc. SIMOPS Simultaneous Operations
SO 2 sulfur dioxide SOPEP Shipboard Oil Pollution Emergency Plan
ST Secure Time
SW Southwest
TBD to be determined TD total depth
T-Time total time TVD true vertical depth UIC Ukpeagvik Ioupiat Corporation USACE U.S. Army Corps of Engineers
USCG U.S. Coast Guard
USFWS U.S. Fish and Wildlife Service VMT Vessel Management Team VOC volatile organic compound(s) VRT Village Response Team WCD worst-case discharge2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. viii July 2009 15276-03-09-001A/09-011A Rev. 1 CROSS-REFERENCE TO APPLICABLE REGULATIONS

Regulation

Section Regulatory Information EP Section* Minerals Management Service

30 CFR 250.211 What must the EP include Section 1.0 & Appendix A

(a) Description, objectives and schedule Section 1.0 a) (b) Location Section 1.0 b) (c) Drilling Unit Section 1.0 c) (d) Service fee Section 1.0 d)

30 CFR 250.212 What information must accompany the EP Sections 2.0 through 17.0 & Appendices A-H (a) General information required by 250.213 Section 2.0 (b) Geological and geophysical (G&G) information required by 250.214 Section 3.0

(c) Hydrogen sulfide information requ ired by 250.215 Section 4.0 & Appendix H (d) Biological, physical, and socioeconomic information required by 250.216 Section 5.0

(e) Solid and liquid wastes and discharges information and cooling water intake information required by 250.217 Section 6.0 & Appendix B

(f) Air emissions information r equired by 250.218 Section 7.0 (g) Oil and hazardous substance spills information required by 250.219 Section 8.0 & Appendix F

(h) Alaska planning information required by 250.220 Section 9.0 (i) Environmental monitoring information required by 250.221 Section 10.0

(j) Lease stipulations information required by 250.222 Section 11.0 (k) Mitigation measures informati on required by 250.223 Section 12.0 (l) Support vessel and aircraft information required by 250.224 Section 13.0 & Appendix F

(m) Onshore support facilities information required by 250.225 Section 14.0

(n) Coastal zone management information required by 250.226 Section 15.0

(o) Environmental impact analysis information required by 250.227 Section 16.0 & Appendix F

(p) Administrative information required by 250.228 Section 17.0

30 CFR 250.213 General information Section 2.0 & Appendices B, D, E, F, & H (a) Applications and permits Section 2.0 a) Appendices B,C,D,E (b) Drilling fluids Section 2.0 b) & Section 6.0 (c) Chemical products Section 2.0 c) (d) New or unusual technology Section 2.0 d) (e) Bonds, oil spill financial responsibility, and well control
statements Section 2.0 e)

(e)(1) Activity and facility bonds (see 30 CFR 256, subpart I) Section 2.0 e)2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. ix July 2009 15276-03-09-001A/09-011A Rev. 1

(e)(2) Oil spill financial responsi bility for facilities (see 30 CFR 253) Section 2.0 e)

(e)(3) Relief well financial capability and can conduct other emergency well control operations Section 2.0 e) Attachment 9.4

(f) Suspensions of operations Section 2.0 f), Section 9.0 & Attachments 9.1 & 9.2 (g) Blowout scenario Section 2.0 g) & Section 8.0 e) (h) Contact Section 2.0 h)

30 CFR 250.214 Geological and geophysical (G&G) information required by 250.214 Section 3.0

(a) Geological description Section 3.1 a) BurgerSection 3.2 a) CrackerjackSection & 3.3 a) Southwest Shoebill

(b) Structure contour maps Section 3.1 c); 3.2 c) & 3.3 c)

(c) Two-dimensional (2-D) and three-dimensional (3-D) seismic lines Section 3.1 d); 3.2 d) & 3.3 d)

(d) Geological cross-sections Se ction 3.1 e); 3.2 e) & 3.3 e)

(e) Shallow hazards information Section 3.1 g); 3.2 g) & 3.3 g)

(f) Stratigraphic column & time-vs-depth ch arts Section 3.1 f); 3.2 f) & 3.3 f)

(g) Geochemical information Section 3.1 h); 3.2 h) & 3.3 h)

(h) Future G&G activities Section 3.1 i); 3.2 i) & 3.3 i)

30 CFR 250.215 Hydrogen sulfide (H 2 S) information Section 4.0

(a) Concentration Section 4.0 a) (b) Classification Section 4.0 b) (c) Contingency plan Section 4.0 c) & Appendix H (d) Modeling report Section 4.0 d) (d)(1) Site specific and area analysis N/A (d)(2) H 2 S emissions N/A

30 CFR 250.216 Biological, physical, and socioeconomic information Section 5.0

(a) Biological environment reports Section 5.0 a) (b) Physical environment reports Section 5.0 b) (c) Socioeconomic study reports Section 5.0 c)

30 CFR 250.217 Solid and liquid wastes and discharges information and cooling water intake information Section 6.0 & Appendices
B (a) Projected wastes Section 6.1a), 6.2a), 6.3a) (a)(1) Method used to determine this in formation Section 6.1a), 6.2a), 6.3a), & 6.4a),2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. x July 2009 15276-03-09-001A/09-011A Rev. 1

(a)(2) Plans for treating, storing and downhole disposal of
wastes Section 6.1a), 6.2a), 6.3a), & 6.4a), (b) Projected ocean discharges Section 6.1b), 6.2b) & 6.3b)

(b)(1) Table of waste name, projected amounts, rate of discharge Section 6.1b), 6.2b) & 6.3b)

(b)(2) Description of discharge met hod Section 6.1b), 6.2b) & 6.3b)

(c) NPDES permit Section 6.4 & Appendix B (c)(1) Compliance discussion N/A (c)(2) Copy of the application Appendix B (d) Modeling report Section 6.5 (e) Projected cooling water intake Section 6.6, Appendix B

30 CFR 250.218 Air emissions information Section 7.0

(a) Projected emissions Section 7.0 a) (a)(1) For each source on the drill rig list the following: (a)(1)(i) Projected peak hourly emissions Section 7.0 a) & Appendix F (a)(1)(ii) Total annual emissions in tons per year Section 7.0 a) & Appendix F (a)(1)(iii) Emissions over the duration of the EP Section 7.0 a) & Appendix F (a)(1)(iv) Frequency and duration of emissions Section 7.0 a) & Appendix F (a)(1)(v) Total of all emissions listed in (a)(1)(i) through (iv) Section 7.0 a) & Appendix F (a)(2) Basis for emission calculations Section 7.0 a) & Appendix F (a)(3) Base projected emissions on maximum rated capacity of the equipment Section 7.0 a) & Appendix F

(a)(4) Specific drill unit emissions Section 7.0 a) & Appendix F (b) Emission reduction measures Section 7.0 b) (c) Processes, equipment, fuels, and combustibles Section 7.0 c) (d) Distance to shore Section 7.0 d) (e) Non-exempt drilling units Section 7.0 e) (f) Modeling report Section 7.0 f)

30 CFR 250.219 Oil and hazardous substance sp ills information Section 8.0

(a) Oil spill response planning Section 8 a), ODPCP, separate cover (a)(1) Oil spill response plan (OSRP) Section 8 a), ODPCP, separate cover (a)(2) OSRP to include: Section 8 a), ODPCP, separate cover (a)(2)(i) Discussion of regional OSRP Section 8 a), ODPCP, separate cover (a)(2)(ii) Location of primary o il spill equipment base and staging

area Section 8 b), ODPCP, separate cover (a)(2)(iii) Name(s) of oil spill removal organizations for both equipment and personnel Section 8 c), ODPCP, separate cover (a)(2)(iv) Calculated volume of the wo rst case discharge Section 8 d), ODPCP, separate cover (a)(2)(v) Description of the worst case scenario discharge Section 8 e), ODPCP, separate cover (b) Modeling report Section 8 f), ODPCP,2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. xi July 2009 15276-03-09-001A/09-011A Rev. 1 separate cover
30 CFR 250.220 Alaska planning information Section 9.0

(a) Emergency plans Section 9.0 a)

(b) Critical operations and curtailm ent procedures Section 9.0 b) and Attachments 9.1 and 9.2

30 CFR 250.221 Environmental monitoring inform ation Section 10.0 & Appendices E & F (a) Monitoring systems Section 10.0 a) (b) Incidental takes Section 10.0 b), Appendix C (b)(1) Threatened and endangered species list under the ESA Section 12.0 b), Appendix C, D, E, F (b)(2) Marine mammals Section 12.0 b), Appendix C, D, E, F (c) Flower Garden Banks National Marine Sanctuary not applicable

30 CFR 250.222 Lease stipulations information Section 11.0 & Appendices C, E , F, I, J Stipulation No. 1 Section 11.0, Appendix F Stipulation No. 2 Section 11.0 Stipulation No. 3 Section 11.0 Stipulation No. 4 Section 11.0, Appendix C, D Stipulation No. 5 Section 11.0, Appendix I Stipulation No. 6 Section 11.0, Section 9.0 d), Attachment 9.4 Stipulation No. 7 Section 11.0, Appendix J

31 CFR 250.223 Mitigation measures information Section 12.0

(a) Mitigation measure beyond those required by regulations Section 12.0 c)

(b) Mitigation measures to avoid or minimize incidental takes of: Section 12.0 c) and Appendices C, D, E, F, J (b)(1) Threatened and endangered species list under the ESA Section 12.0 b) and Appendices C, D, E, F, J (b)(2) Marine mammals Section 12.0 b) and Appendices C, D, E, F

31 CFR 250.224 Support vessel and aircraft information Section 13.0

(a) General Section 13.0 a) (b) Air emissions Section 13.0 b) (c) Drilling fluids and chemical product s transportation Section 13.0 c) (d) Solid and liquid wastes transportation Section 13.0 d) and 13.0 f) (e) Vicinity map Section 13.0 e)

31 CFR 250.225 Onshore support facilities information Section 14.0

(a) General Section 14.0 a) (a)(1) Onshore facility existing, to be constructed or expanded Section 14.0 a) (a)(2) Onshore facilities in the western GOM N/A (b) Air emissions Section 14.0 b) (c) Unusual solid and liquid wastes Section 14.0 c)2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. xii July 2009 15276-03-09-001A/09-011A Rev. 1

(d) Waste disposal Section 14.0 d)

31 CFR 250.226 Coastal zone management information Section 15.0, Attachment 15.1 (a) Consistency certification Section 15.0 a), Attachment 15.1 (b) Other information N/A

31 CFR 250.227 Environmental impact analysis information Section 16.0, Appendix F

(a) General requirements Appendix F (Section 1.0) (a)(1) Assess the potential environm ental impacts Appendix F (Section 4.0) (a)(2) Be project specific Appendix F (Section 2.0) (a)(3) Be as detailed as necessary (b) Resources, conditions and activities Appendix F (Section 3.0) (b)(1) Meteorology, oceanogr aphy, geology, and shallow hazards Appendix F (Section 3.0)

(b)(2) Air and water quality Appendix F (Sections 3.1- 3.2) (b)(3) Benthic communities, marine mammals, sea turtles, coastal and marine birds, fish and shellfish, and plant life Appendix F (Sections 3.4- 3.7)

(b)(4) Threatened and endangered species and their critical habitat Appendix F (Section 3.8)

(b)(5) Sensitive biological resources or habitats Appendix F (Section 3.9) (b)(6) Archaeological resources Appendix F (Section 3.10) (b)(7) Socioeconomic resources Appendix F (Section 3.11) (b)(8) Other coastal and marine uses Appendix F (Section 3.12) (b)(9) Other resources, conditions, and activities identified by the Regional Supervisor N/A

(c) Environmental impacts Appendix F (Section 4.0) (c)(1) Analyze the potential direct and i ndirect impacts Appendix F (Section 4.1) (c)(2) Analyze and potential cumulative impacts Appendix F (Section 4.2) (c)(3) Describe the potential im pacts and their consequences and implications Appendix F (Sections 4.1 & 4.2) (c)(4) Describe potential mitigation measures Appendix F (Section 2.10, 4.3) (c)(5) Summarize information incorporated by reference Appendix F (Section 1.5.2) (d) Consultation Appendix F (Section 5.0) (e) References cited Appendix F (Section 6.0)

31 CFR 250.228 Administrative information Section 17.0, Appendix F

(a) Exempted information description Section 17.0 a) (b) Bibliography Section 17.0 b) (b)(1) List of all report and materials referenced Section 17.0 b) (b)(2) Location of referenced materials if not submitted with the EP Section 17.0 b)

U.S. Environmental Protection Agency - Air Quality 40 CFR 55.4 Outer Continental Shelf Air Regulations Section 7.02010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. xiii July 2009 15276-03-09-001A/09-011A Rev. 1

U.S. Environmental Protection Agency - NPDES

40 CFR 122.21 Application for a permit Section 6.0 and Appendix B

National Marine Fisheries Service

50 CFR 216.104 Submission of requests Section 10.0 b) and Appendix C, D
50 CFR 216.107 Incidental harassment authorization for Arct ic waters Section 10.0 b) and Appendix C, D

U.S Fish and Wildlife Service

50 CFR 18.124 How do I obtain a Letter of Authoriz ation Section 10.0 b) and Appendix
E

U.S. Army Corps of Engineers 33 CFR 325.1 Applications for permits Appendix G2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. xiv July 2009 15276-03-09-001A/09-011A Rev. 1 

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Shell Gulf of Mexico Inc. 1 July 2009 15276-03-09-001A/09-011A Rev. 1 SECTION 1.0 EXPLORATION PLAN CONTENTS

a) Description, Objectives, and Schedule

This 2010 Exploration Plan (EP) with appendices, including an Environmental Impact Analysis (EIA) (Section 16 and Appendix F) describe th e exploration drilling activities Shell Gulf of Mexico Inc. (Shell) plans to conduct in 2010 in the Chukchi Sea Outer C ontinental Shelf (OCS), Alask a. Shell has identified seven lease blocks within three prospects known as Burger, Crackerjack, and Southwest Shoebill (SW Shoebill) for its 2010 Chukchi Sea EP (Table 1.a-1). Sh ell has identified a single potential drill site within five of these lease blocks for 2010. These five possible drill sites for exploration are addressed in this EP.

TABLE 1.a-1 Shell Lease Blocks Identified in the 2010 EP for the Chukchi Sea

Shell Prospect Area Protraction Lease Block Shell Lease
Burger Posey NR03-02 6713 OCS-Y-2266
Burger Posey NR03-02 6714 OCS-Y-2267
Burger Posey NR03-02 6763 OCS-Y-2279
Burger Posey NR03-02 6764 OCS-Y-2280
Burger Posey NR03-02 6912 OCS-Y-2321
Crackerjack Karo NR03-01 6864 OCS-Y- 2111

SW Shoebill Karo NR03-01 7007 OCS-Y- 2142

Three possible drill sites (one per block) are located on three different blocks (6714, 6764 and 6912) in the Burger Prospect, one is on a single block (6864) in the Crackerjack Prospect, and one is on a single block (7007) in the SW Shoebill Prospect. Shell plan s to drill exploration wells to total depth (TD) at three of these five possible drill sites in 2010 given fa vorable ice conditions, weather, sea state, and any other pertinent factors. Shallow hazards data have been collected at each of these drill sites, and each drill site has been reviewed for potential shallow hazard s and archaeological evidence. Formal reports for
each of these drill sites have been submitted to the U.S. Department of the Interi or, Minerals Management Service (MMS) under separate cover. Each of these fi ve drill sites will be permitted for drilling in 2010 to allow for operational flexibility in the event sea ice conditions prevent access to one or more locations. Shell will only drill a maximum of three (3) wells in 2010. Applications for Permits to Drill will be submitted to MMS prior to the 2010 drilling season.

The actual order of drilling activities will be contro lled by a complex interplay between actual ice conditions immediately prior to a rig move, ice forecast s, any regulatory restrictions with respect to the dates of allowed operating windows, whether the planned drilling activity involves only drilling the shallow non-objective section or penetrating potential hydrocarbon zones, the availability of permitted sites having approved shallow hazards clearance, the anticipated duration of each contemplated drilling activity, and the results of preceding wells. Any of th ese factors, individually or in combination, may cause a predicted annual activity plan to be altered at short notice.

Given favorable conditions, it is anticipated that the initial drilling activity will begin at the Burger Prospect. If Burger is not accessible, then the next preferred location to begin the exploration drilling, if favorable conditions exist, is at the SW Shoebill Prospect. If neither the Burger nor SW Shoebill Prospects are accessible, then the Crackerjack Prospect, if open, will be the site of initial exploration drilling well. It should be noted that focus of the 2010 drilling program will be shifted immediately to the Burger Prospect as soon as it becomes safe to anchor and operate the drillship on that Prospect. Given2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 2 July 2009 15276-03-09-001A/09-011A Rev. 1 favorable drilling performance and subsurface results at the initial Burger drill site, another of the permitted drill sites in the Burger Prosp ect may be the next well drilled.

The number of actual wells that will be drilled will depend on ice conditions and the length of time available for the 2010 drilling season. The predicted “average” drilling season, constrained by prevailing ice conditions and regulatory restrictions, is long enough for two to three typical exploration wells to be drilled from spud to TD.

The ice reinforced drillship M/V Frontier Discoverer ( Discoverer ) will move into the Chukchi Sea on or about July 1 and onto the prospects when ice allows on or about July 4. Drilling will be curtailed on or before October 31 as per existing Alaska Depart ment of Environmental Conservation (ADEC) regulations. The drillship and support vessels will exit the Chukchi Sea at the conclusion of the drilling

season.

Based on past experience and current planning, Shell e xpects to drill up to three exploration wells during the 2010 timeframe of this EP, but the actual number may be less. The exploration wells will be plugged and abandoned in compliance with MMS regulations afte r drilling operations have been completed. It is likely that during the period covered by this EP that a well may be started, temporarily abandoned due to ice conditions and finished later in the same drilling season. This was an operational reality during the 1989 – 1991 Chukchi drilling campaign.

Resupply will be from Dutch Harbor, Wainwright or Barrow using a coastwise qualified vessel. Aviation operations will be conducted from Barrow and Wainwright to minimize flying time over water. These are the plans only for the 2010 exploration drilling campaign and do not reflect Shell’s longer term
commitments for shorebases or othe r facilities needed to support future exploration drilling plans or development of any of its Chukchi Sea prospects.

b) Location

OCS Lease Sale 193 was held in February 2008 and Shell was subsequently awarded 275 leases (blocks) through a competitive bidding process. The locations of these lease blocks are depicted in Figure 1.b-1. The seven blocks identified for the three prospects (B urger, Crackerjack and SW Shoebill) contained in this exploration plan are described above in Table 1.a- 1, and their locations are indicated on Figure 1.b-1.
Locations of the five drill sites are indicated in Figure 1.b-2 and Figure 1.b-3 for the three prospects
included in this EP. Coordinates of the surface locat ions of these drill sites are presented below in Table
1.b-1. Surface and bottomhole coor dinates, OCS Area name and bloc k number, lease number, distance from block line, and other information for each of th e drill sites are provided on the respective OCS Plan Information Forms (MMS Fo rm-137) in Appendix A.

TABLE 1.b-1 Proposed Drill Sites – Burger, Crackerjack, and SW Shoebill Prospects, Chukchi Sea

Prospect Well Area Block Lease Number 1 Coordinates, m
X Y Latitude Longitude

Burger C Posey 6764 OCS-Y-2280 563929.70 791 2335.98 N71° 18' 17.2739" W163° 12' 45.9891" Burger F Posey 6714 OCS-Y-2267 564063.30 791 5956.94 N71° 20' 13.9640" W163° 12' 21.7460" Burger J Posey 6912 OCS-Y-2321 555036.01 789 7424.42 N71° 10' 24.0292" W163° 28' 18.5219" Crackerjack C Karo 6864 OCS-Y-2111 455609.48 7903840.77 N71° 13' 58.9211" W166° 14' 10.7889" SW Shoebill C Karo 7007 OCS-Y-2142 419386.88 7887070.89 N71° 04' 24.4163" W167° 13' 38.0886"

Notes:

1 Coordinate system is NAD 83 UTM Zone 32010Outer Continental Shelf Leases Exploration PlanChukchi Sea, AlaskaShell Gulf of Mexico 3July 200915276-03-09-001A/09-011ARev. 1Figure 1.b-1 Exploration Plan Location Map!

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. i n t e r v a l )2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 6 July 2009 15276-03-09-001A/09-011A Rev. 1 c) Drillship

All planned exploration drilling in the identif ied lease blocks will be conducted with the Discoverer. The
Discoverer is a true drillship, and is a largely self-contained drilling vessel that offers full accommodations for a crew of up to 124 persons. The Discoverer is an anchored drillship with an 8-point anchored mooring system and will likely have a maxi mum anchor radius of 3,600 ft (1,100 m). The hull
has been reinforced for ice resistan ce. Specifications for this drillship are provided below in Table 1.c-1.

TABLE 1.c-1 Frontier Discoverer Specifications

FRONTIER DISCOVERER SPECIFICATIONS TYPE-DESIGN Drillship - Sonat Offshore Drilling Discoverer Class SHAPE Monohull with sponsons added for ice-resistance

SHIP BUILDERS & YEAR Namura Zonshno Sh ipyard, Osaka, Japan - hull number 355

YEAR OF HULL CONSTRUCTION 1965

YEAR OF CONVERSION 1976

DATE OF LAST DRY-DOCKING 2008

FRONTIER DISCOVERER DIMENSIONS

LENGTH 514 ft 156.7 m

LBP 486 ft 148.2 m MAX HEIGHT (ABOVE KEEL) 274 ft 83.7 m

HEIGHT OF DERRICK ABOVE RIG FLOOR 175 ft 53.3 m2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 7 July 2009 15276-03-09-001A/09-011A Rev. 1 FRONTIER DISCOVERER OPERATING WATER DEPTH MAX WATER DEPTH 1,000 ft with present equipment (can be outfitted to 2,500 ft)
MAX DRILLING DEPTH 20,000 ft

FRONTIER DISCOVERER DRILLING PACKAGE
DRAW WORKS EMSCO E-2,100, 1,600 hp ROTARY National C-495 with 49-1/2" opening MUD PUMPS 2 x Continental Emsco Model FB-1600 Triple Mud Pumps DERRICK Pyramid 170 ft. with 1, 300,000 lb nominal capacity PIPE RACKING BJ 3 arm system

DRILL STING COMPENSATOR Shaffer 400 K x 18 ft stroke

RISER TENSIONS 8 x 80k Shaffer 50 ft stroke tensioners CROWN BLOCK Pyramid with 9 each 60" diam eter sheaves rated at 1,330,000 lb

TRAVELING BLOCK Continental - Emsco RA60-6 BOP Cameron 18-3/4" x 10,000 psi RISER Cameron RCK type
TOP DRIVE Varco TDS-3S, with GE-752 motor, 500 ton BOP HANDLING Hydraulic skid based system, drill floor FRONTIER DISCOVERER MOORING EQUIPMENT Anchor pattern symmetric 8 points syst em. The unit is fitted with Sonat Offshor e Drilling patented ro ller turret mooring system giving the unit the ability to maintain favorabl e heading without an interrupti on of the drilling operations ANCHORS Stevpris New Generati on 7,000 kg ea 15,400 lb ea

ANCHOR LINES Chain Wire Combination
SIZE/GRADE 2-3/4" wire 3" ORQ Chain LENGTH 2,750 ft (838 m) wire + 1,150 ft (351 m) chain (useable) per anchor

FRONTIER DISCOVERER DISPLACEMENT FULL LOAD 20,253 Metric Tons (mt) DRILLING 18,780 mt (Drilling, ma x load, deep hole, deep water)

FRONTIER DISCOVERER DRAUGHT

DRAFT AT LOAD LINE 27 ft 8.20 m TRANSIT 27 ft (fully loaded, operating , departure) 8.20 m

DRILLING 25.16 ft 7.67 m

FRONTIER DISCOVERER HELIDECK MAXIMUM HELICOPTER SIZE Sikorsky 61N & 92N FUEL STORAGE 2 ea 720 gallon tanks

FRONTIER DISCOVERER ACCOMODATIONS

NUMBER OF BEDS 124 SEWAGE TREATMENT UNIT Hamworthy ST-10

FRONTIER DISCOVERER PROPULSION EQUIPMENT
PROPELLER 1 ea 15' 7" diameter, fixed blade PROPULSION DRIVE UNIT Marine Diesel, 6 cylinder, 2 cycle, Crosshead type HORSEPOWER 7,200 hp @ 135 RPM

TRANSIT SPEED 8 knots2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 8 July 2009 15276-03-09-001A/09-011A Rev. 1 The Discoverer will comply with all of the regulations of Det Norske Veritas, the International Maritime Organization, and the U.S. Coast Guard (USCG). All drilling operations will be conducted under the provisions of 30 Code of Federal Re gulations (CFR) Part 250 Subpart D, and other applicable regulations and notices including those regarding the avoidance of potential drilling hazards and safety and pollution
control. Such measures as infl ow detection and well control, mon itoring for loss of circulation and seepage loss, and casing design will be the primar y safety measures. Primary pollution prevention
measures are the contaminated and non-contaminated dr ain systems, the mud drain system, and the oily water processing system.

The procedures for monitoring and reacting to ice in the prospect areas are provided in the Critical Operations and Curtailment Plan (COCP) and the Ice Management Plan (IMP) located in Section 9.0 of
this EP.

d) Service Fee

The required permit fee of $17,210 (5 drill sit es at $3,442 each) has been paid in full. GENERAL STORAGE CAPACITIES SACK STORAGE AREA 934 cubic meters (m3) BULK STORAGE BENTONITE/BARITE 180 m3 - 4 tanks

BULK CEMENT 180 m3 - 4 tanks LIQUID MUD Active 1,200 Barrels (bbls)
Reserve 1,200 bbls
Total 2,400 bbls POTABLE WATER 1,670 bbls / 265.5 m3 (aft peak can be used as add. pot water tank)
DRILL WATER 5,798 bbls / 921.7 m3

FUEL OIL 6,497 bbls / 1,033 m3 (2S, 2P, 3S, 3P, 4S and 4P upper wings can be used as additional fuel storage or well test crude tankage)2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 9 July 2009 15276-03-09-001A/09-011A Rev. 1 SECTION 2.0 GENERAL INFORMATION

a) Application and Permits

Table 2.a-1 lists permit applications that have been or will be submitted to the appropriate agencies, and agency authorizations that have been issued. Th ese permits and authorizations will be submitted for planned wells to be drilled on the Burger, Crackerj ack, and SW Shoebill Prospects in 2010. The number of wells that will be drilled will depend on ice cond itions and the length of time available during the drilling season. Based on past experience and current pl anning, Shell expects that up to three exploration
wells will be drilled in the Chukchi Sea in 2010.

TABLE 2.a-1 Permit Applications Pending or Approved

Permits & Authorizations Agency Submittal Date Authorization Date Document Location Alaska Coastal Management Program (ACMP) Consistency Review Alaska Department of Natural Resources (ADNR) to be submitted Pending Attachment 15.1 of this document

Application Permit to Drill MMS to be submitted Pending under separate

cover EP MMS to be submitted Pending this document

Oil Discharge Prevention and Contingency Plan (ODPCP) MMS to be submitted Pending under separate

cover Air Quality Permit – Discoverer U.S. Environmental Protection Agency (EPA) submitted 12/11/08 revised 02/23/09 Pending --

National Pollutant Discharge EliminationSystem (NPDES) General Permit AKG28-000 - Discoverer EPA to be submitted Pending Appendix B of this document

Marine Mammal Protection Act (MMPA) Incidental Harassment Authorization (IHA) Application (Whales and Seals) National Marine Fisheries Service (NMFS) to be submitted Pending Appendix D of this document

MMPA Letter of Authorization (LOA) Application (Polar bears & Pacific walrus); Incidental and Intentional Take U.S. Fish and Wildlife Service (USFWS) to be submitted Pending Appendix E of this document

U.S. Army Corps of Engineers (USACE) Nationwide Permit #8 Oil and Gas Structures – Discoverer USACE to be submitted Pending Appendix G of this document

b) Drilling Fluids

Drilling activities will use a maximum of 5,905 to 6,50 5 bbl of water-based drilling fluids per well. These are considered maximums as they include circulating/ reserve pit volumes. Drilling fluids will be recycled, to the extent practicable based on operati onal considerations (e.g., wh ether mud properties have deteriorated to the point where they cannot be used fu rther), by carrying forward fluids from the previous well. Thus, these quantities are maximums and generally applicable to the last well of the season, with previous wells in the same season re quiring lower drilli ng fluids volumes.

Details regarding waste stream volumes, discharge rates, mud additives and other information can be
found in Section 6.0.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 10 July 2009 15276-03-09-001A/09-011A Rev. 1 TABLE 2.b-1 Drilling Fluid Type, Quantity and Discharge Rates
Prospect Drilling Fluid Type Quantity Discharge Rate Burger Water-based (seawater, fres h water, barite) 7,310 bbl 660 bbl/day Crackerjack Water-based (seawater, fr esh water, barite) 8,510 bbl 660 bbl/day SW Shoebill Water-based (seawater, fr esh water, barite) 7,960 bbl 660 bbl/day

Notes:
1. Volume of drilling fluid includes drilling mud (1,500 bbl) in tanks at end of well plus dilution volume.
2. Dilution Calculations based on washout factor of 30% and 1:1 ratio of drill cuttings and drilling fluids.

c) Chemical Products

No chemicals will be stored on the Discoverer above reportable quantities.

d) New or Unusual Technology

No new or unusual technology will be used in the drilling of the planned wells.

e) Bonds, Oil Spill Financial Responsibility, and Well Control Statements

The MMS has determined that She ll Oil Company has the financial cap acity to allow the MMS to waive supplemental bond requirements of Shell (Operator No.YK02117). However, Shell does have an areawide bond, covering the offshore coast of Alaska, in the amount of $1,000,000. This bond number is 022-014-198 through Liberty Mutual Insurance Company.

Shell is of sound financial strength and reliability an d has demonstrated oil spill financial responsibility (OSFR) according to 30 CFR 253 for the facilities pla nned in the EP. This financial reliability ensures that Shell has the capability to deal with all emerge ncy situations such as blow out control including relief well drilling and kill operations if such an unlikely event should occur.

This is a planned drilling program with temporary sea sonal operations. There will be minimal subsea bed disturbance for mudline cellars (MLCs) at each drill site. MLCs are designed to protect the wellhead, casing and blowout preventers from potential ice gouge events. Vessel anchoring systems employed during operations will be removed upon abandonment of each well. Pe rmanent facilities will be limited to the casing and the guide base remaining subsurface after well abandonment and will comply with Abandonment of Wells regulations at 30 CFR 250.1710 - 1723. It is noted that the casing and guide base will be set in the base of the MLC at approximately 35 ft below the mud line. No portion of any of these permanent facilities will extend above the mud line.

f) Suspension of Operations

Shell has plans and mitigation measures in place thataccommodate the forced or voluntary suspension of operations during implementation of the proposed EP. Forced suspension of operations could result from conditions such as weather, ice conditions, drills hip mechanical conditions, or downhole conditions, among others. In order to facilitate a possible su spension of operations, Shell has drafted several operations plans containing suspension procedures and protocols including a COCP. This plan is
discussed in Section 9.0.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 11 July 2009 15276-03-09-001A/09-011A Rev. 1 g) Blowout Scenario

A blowout scenario has been developed and is describ ed in Section 8.0 and will be submitted to MMS as part of the Oil Discharge Prevention and Contingenc y Plan (ODPCP). Relief well drilling procedures are
also discussed in the ODPCP.

A Well Control Plan is also attached in Section 9.0. Well control is the pro cess of maintaining positive hydrostatic pressure in the drilled wellbore greater th an that in any drilled formation, a process called positive pressure drilling, that prevents gas or fluids from underground reservoirs escaping from the wellbore in any uncontrolled manner.

h) Contact Information

Contact Susan Childs, Regulatory Affairs Manage r, Alaska Venture, at telephone number 907-646-7112, fax 907-770-3636, or e-mail at susan.childs@shell.com

.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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Shell Gulf of Mexico Inc. 13 July 2009 15276-03-09-001A/09-011A Rev. 1 SECTION 3.0 GEOLOGICAL AND GEOPHYSICAL INFORMATION

3.1 Burger Prospect (Confidential)

a) Geological Description

b) Proposed Drill Sites and Bathymetry Maps

c) Structure Contour Maps

d) Key Seismic Lines

e) Geological Cross-Sections

f) Stratigraphic Columns and Time-versus-Depth Charts

g) Shallow Hazards Report, Assessment, a nd High Resolution Seismic Lines

h) Geochemical Information

i) Future Geological and Geophysical Activities



# THE INFORMATION IN THIS SECTION CONTAINS CONFIDENTIAL/PROPRIETARY INFORMATION AND IS
NOT AVAILABLE IN THIS PUBLIC INFORMATION COPY
OF THE EXPLORATION PLAN.2010 Outer Continental Shelf Leases Exploration PlanChukchi Sea, AlaskaShell Gulf of Mexico Inc. 15 July 200915276-03-09-001A/09-011ARev.1Figure 3.0-2 Historic Oil and Gas Exploration in the Chukchi Sea2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 16 July 2009 15276-03-09-001A/09-011A Rev.1 3.2 Crackerjack Prospect (Confidential)

a) Geological Description

b) Proposed Drill Site and Bathymetry Maps

c) Structure Contour Maps

d) Key Seismic Lines

e) Geological Cross-Sections

f) Stratigraphic Columns and Time-versus-Depth Charts

g) Shallow Hazards Report, Assessment, a nd High Resolution Seismic Lines

h) Geochemical Information

i) Future Geological and Geophysical Activities



# THE INFORMATION IN THIS SECTION CONTAINS CONFIDENTIAL/PROPRIETARY INFORMATION AND IS
NOT AVAILABLE IN THIS PUBLIC INFORMATION COPY
OF THE EXPLORATION PLAN.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 17 July 2009 15276-03-09-001A/09-011A Rev.1 3.3 Southwest Shoebill Prospect (Confidential)

a) Geological Description

b) Proposed Drill Site and Bathymetry Maps

c) Structure Contour Maps

d) Key Seismic Lines

e) Geological Cross-Sections

f) Stratigraphic Columns and Time-versus-Depth Charts

g) Shallow Hazards Report, Assessment, a nd High Resolution Seismic Lines

h) Geochemical Information

i) Future Geological and Geophysical Activities



# THE INFORMATION IN THIS SECTION CONTAINS CONFIDENTIAL/PROPRIETARY INFORMATION AND IS
NOT AVAILABLE IN THIS PUBLIC INFORMATION COPY
OF THE EXPLORATION PLAN.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 18 July 2009 15276-03-09-001A/09-011A Rev.1 

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Shell Gulf of Mexico Inc. 19 July 2009 15276-03-09-001A/09-011A Rev.1 SECTION 4.0 HYDROGEN SULFIDE INFORMATION

a) Concentration

During the historic 1989 – 1991 Chukchi explora tion drilling program, no hydrogen sulfide (H 2 S) was recorded while drilling in open-hole conditions in any of the five historic wells: OCS-Y 1482 Klondike #1, OCS-Y 1275 #1 (Popcorn), OCS-Y 1413 #1 (Burger), OCS-Y 1320 # 1 (Crackerjack) and Chevron OCS-Y 0996 #1 (Diamond). However, two occurrences of minor amounts of H 2 S, related to the bacterial digestion of the XC polymer in the mud that was le ft inside the casing during an extended period of operational suspension, were recorded and are described below.

In early October, 1989, a string of 13 3⁄8 -inch (in.) (34 centimeters [cm]) casing was set and cemented at 5,516 ft (1,681 m) in the historical OCS-Y 1413 #1 (B urger) well. The cement w as displaced by the same XC polymer based drilling mud as that used to drill the 171⁄2-in. (44.5 cm) hole below 20-in. (50.8 cm) casing set at 1,440 ft (439 m). The cement was displ aced to the float collar some 43 ft (13 m) above the casing shoe leaving a cement plug in the bottom of the casing along with two check valves (i.e., floats). This cement plug and the floats, along with the hydr ostatic pressure from the mud column within the 20- in. (50.8 cm) casing, prevented formation fluids from entering the casing. The well was temporarily abandoned with a corrosion cap set on top of the wellh ead after pressure testing the wellhead hanger. The well remained in this configur ation until it was re-entered.

In August 1990 the MLC was cleaned out on the OCS-Y 1413 #1 (Burger) well and the corrosion cap was removed. Then a 121⁄4-inch (in.) (31 cm) bit was run through the old mud to the top of the cement plug inside the casing. The old mud was then displaced out of the 20-in. (50.8 cm) casing with newly mixed drilling mud. When the bottom portion of th e old mud reached the surface, a maximum H 2 S concentration of 30 parts per million (ppm) was detected at the shale shaker. As the new mud circulated to surface, the H 2 S concentration returned to zero. Once the H 2 S concentration returned to zero the 121⁄4- in. (31 cm) bit then drilled through the cement plug and both check valves. It th en proceeded to drill new formation on its way to the main objective target.

It is concluded that the H 2 S was the byproduct of bacterial digestion of the polymer in the old mud contained within the 20-in. casing. There had been no H 2 S detected while drilling the 171⁄2-in. (44.5 cm) hole and the casing was sealed during the 10-month time between depositing the mud inside the casing and circulating it out. No other H 2 S was recorded while drilling the re maining hole segments to the well’s final TD of 8,202 ft (2500 m).

In October, 1990, the 13 3⁄8 -in. (34 cm) surface casing was set and cemented in the historical OCS-Y 1320 #1 (Crackerjack) well at 5,448 ft (1,661 m) in a 171⁄2-i n. (44.5 cm) hole below 20-in. (50.8 cm) casing set at 1,326 ft (404 m). On this casing string, two joints of casing separated the float collar at 5,363 ft (1,635 m) from the float shoe at 5,448 ft (1,661 m), leaving at least 85 ft (26 m) of cement inside the base of the pipe. Again, the cement was displaced with the same XC polymer mud used to drill the 171⁄2-in. (44.5 cm) hole. The combination of the cement plug and th e floats along with the hydrostatic pressure from the
mud column within the 13 3⁄8 -in. (34 cm) casing, prevented formation fluids from entering the casing. In addition, an H 2 S scavenger, Sulf-X ES at a concentration of 1.0 parts per billion (ppb) was added to the mud to prevent bacterial degradation of the mud (as seen at the Burger well). The Crackerjack well was temporarily abandoned without drilling out cement in side the surface casing using a corrosion cap.

In late-July, 1991, the rig returned to the OCS-Y 1320 #1 (Crackerjack) well and re-entered the temporarily abandoned hole. A 121⁄4-in. (31 cm) bit was run to the top of cement inside the 13 3⁄8 -in. (34 cm) casing and the old mud was circulated out of the hole. The returned mud was monitored for H 2 S by a safety specialist and by mud loggers. When mud fr om approximately 4,000 ft (1,219 m) in the well2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 20 July 2009 15276-03-09-001A/09-011A Rev.1 reached the surface, H 2 S in trace concentrations was released at the shakers. As the old mud was displaced with new mud, the H 2 S concentration fell to zero prior to drilling out the cement plug, and
floats and into new formation. No other H 2 S was recorded while drilling the remaining hole segments to the well’s final TD of 9,573 ft (2,918 m).

Again, it is concluded that the H 2 S in this well was the product of bacterial digestion of the XC polymer
in the old mud. There was no H 2 S encountered while drilling the 171⁄2-in. (44.5 cm) hole and none was released into the mud during subsequent drilling. Apparently, the H 2 S scavenger was not completely successful in preventing the H 2 S, but the concentration was reduced from that seen in the Burger well
after about the same on-bottom time.

No H 2 S was detected or released while drilling any of the other wells in the Chukchi Sea during the 1989- 1991 campaign. This reinforces the conclusion that the source of H 2 S detected in these two wells was indeed the result of bacterial degradation of the pol ymer mud left in each hole for approximately 10 months each and not from any geologic formation penetrated by either well.

b) Classification

H 2 S is not expected in any hole segment in any e xploration well planned in Shell’s 2010 exploration drilling program based on the absence of H 2 S in any previously drilled e xploration well in the Chukchi Sea, the Beaufort Sea or the Canadi an Beaufort Sea. It is recognized that some hole segments and one of the three prospects involves intervals that have not been penetrated by the five historic Chukchi Sea wells, and that the region may be classified by the MMS Regional Supervisor Field Operations (RS/FO) as “H 2 S unknown”. Shell has therefore prepared an H 2 S Contingency Plan and will install all equipment, provide required training and follow all em ergency protocols required by 50 CFR 250.490 for the entire drilling

season.

For the Burger Prospect drill sites, all of the wells could be classified as “H 2 S absent” since none of the wells is projected to drill below the equivalent stratigra phic interval penetrated by the depth of the historic OCS-Y 1413 #1 Burger Well (8,202 ft [2500 m], some 500 ft [152 m]below the Kuparuk Sands in the top of the Kingak). There was no H 2 S encountered while drilling the historic Burger well. All of the exploration wells planned for the 2010 drilling campaign would have sim ilar total depths in the Kingak. Thus, if only the Burger Prospect drill sites were planned for 2010, th e RF/SO could exempt the Burger Prospect from the provisions of 50 CFR 250.490.

Similarly, at the Crackerjack Prospect drill site, th e entire prospect could be classified by the RS/FO as
H 2 S absent since the proposed drilling will stop a bove the Jurassic Unconformity. The Cenozoic, Cretaceous and Jurassic age equivalent stratigraphic secti on has been penetrated in nearby historical wells (the OCS-Y 1320 #1 Crackerjack Well, the OC S-Y 1482 #1 Klondike Well and the OCS-Y 1275 #1 Popcorn Well) and all have confirmed the absence of H 2 S above the Jurassic Unconformity in this region.

At the SW Shoebill Prospect drill site, however, the proposed well will be drilled in an area that is untested by previously drilled historical exploration wells. Thus, it must be classified as “H 2 S unknown.”

Since the latter would require co mpliance with the requirements of 50 CFR 250.490, Shell has prepared and will employ an H 2 S Contingency Plan. Ice or other cond itions may require drilling the SW Shoebill Prospect instead of the Burger or Crackerjack exploration wells, so Shell will comply with the requirements of the H 2 S plan for all drilling operations in the Chukchi Sea in 2010.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 21 July 2009 15276-03-09-001A/09-011A Rev.1 c) Contingency Plan

An H 2 S Contingency Plan is provided in Appendix H. H 2 S-resistant tubular goods and wellheads have been selected for each proposed Chukchi Sea pros pect string design. Although these materials of construction will probably not be needed, Shell has chosen them for use in exploration wells to avoid risk in the unlikely event that H 2 S is present in some well segment.

d) Modeling Report

A Modeling Report is not included, but one will be prepared if deemed necessary by the MMS. The
absence of H 2 S in any of the five historic Chukchi Sea wells limits the ability to predict H 2 S concentrations necessary for preparing such a mode l, and there is no reliable analog reservoir on the North Slope containing H 2 S with which to compare the planned prospects. An assumed H 2 S concentration would therefore be required to prepare such a model, and no basis for such an assumption is available. Any release model, as a tool for predicting H 2 S radii of exposure, would therefore be questionable. It is unlikely that an H 2 S release, even at maximum release flowrate and normal concentrations at the remote planned prospect s ites 66-126 mi offshore could significantly impact the public on the northwest coast of Alaska due to expect ed diffusion and dispersion in the air column over such a long distance.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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Shell Gulf of Mexico Inc. 23 July 2009 15276-03-09-001A/09-011A Rev.1 SECTION 5.0 BIOLOGICAL, PHYSICAL, AND SOCIOECONOMIC INFORMATION

a) Biological Environment Reports

Results of the shallow hazard surveys indicate that the seafloor at all five drill sites is relatively level and smooth with sediments consisting largely of silts and clays. No evidence was ob served of hard bottom or other special habitats. The MMS has not requested that Shell conduct biological studies at any of the proposed drill sites. Remotely Operated Vehicle (ROV) surveys have not been conducted at the sites. However, Shell conducted a number of other types of baseline studies in 2008 to gather data regarding resources in the project area and plans to continue these studies in 2009. A multi-faceted study focused on a 35 mile (mi) x 35 mi study area (56 km x 56 km) was conducted on Shell’s Burger Prospect. The data collected during the course of these programs was used in the EIA. Shell expects to further conduct further analyses of the data and submit the final reports to MMS in October 2009. Draft reports are currently available for following:

 Baseline survey of birds in the Burger Prospect area (Gall and Day in prep)

 Baseline survey of marine mammals in the Burger Prospect area (Brueggeman in prep)

Preliminary results of the marine mammal and bird su rveys conducted at Burger are discussed in the EIA (Appendix F). Results of other studies are pending.

In addition to the baseline surveys described above , Shell has partially funded USGS walrus tagging studies in the Chukchi Sea and ringed seal tagging studi es in Kotzebue Sound with the Native Village of
Kotzebue. Results of these studies are found on the internet at http://alaska.usgs.gov/science/biolog y/walrus/2008animation_Norseman.html and http://kotzebueira.org/current_projects2.html

.

Shell has also collected a large amount of informat ion regarding marine mammals in the northeastern Chukchi Sea, including the area of Shell’s prosp ects, through its marine mammal monitoring program associated with seismic surveys. Data collected over the last thr ee years is summarized in the 2008 comprehensive report (Ireland et al. 2009), which has been forwarded to the MMS under separate cover.

b) Physical Environment Reports

Shell has conducted shallow hazards surveys at the fi ve drill sites. Archeological resource assessments were conducted for each drill site based on geophysical data collected during the surveys. The shallow hazard survey reports and archeol ogical assessments have been submitte d to MMS under separate cover.
The results of the shallow hazard surv eys are summarized in Section 3.1, 3.2, and 3.3. The results of the archeological assessments are discussed in Sec tion 3.10 of the EIA (Appendix F). No potential archeological resources were identified at or near the Burger C, Burger F, Burger J, and SW Shoebill C drill sites. Anomalies in the geophysical data nearthe Crackerjack C drill site were identified as paleochannels. The margins of these types of geological feat ures are considered to potentially hold pre-historic archeological resources as favored encampment sites. Although the presence of intact resources at such
sites in the Chukchi Sea is considered low due to th e prevalence of ice gouging and other dynamic forces, Shell relocated the Crackerjack C drill site so that the paleo-channel margin w ould not be disturbed by mooring of the drillship, drill site preparation (MLC construction), or drilling. No anomalies were observed at any drill sites that would indicate the possi ble presence of historic cultural resources such as shipwrecks.

Shell also collected oceanographic information as pa rt of the multi-faceted baseline study conducted at Burger in 2008 described above in Section 5 (a). Additionally, Shell:2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 24 July 2009 15276-03-09-001A/09-011A Rev.1  Deployed metrological buoy in the Chukchi Sea n ear the Burger Prospect in 2008 that reported hourly measurements via satellite – this work is being continued in 2009

 Deployed a waves and current meter (AWAC) in the Chukchi Sea near the Burger Prospect in 2008, which will be serviced in 2009 and redeployed.

Shell also established a meteorologi cal and air quality monitoring station at Wainwright. Preliminary results for November –December 2008, indicate that measured concentrations of air pollutants are well below NAAQS (AECOM 2009).

c) Socioeconomic Study Reports

Shell continues with its Plan of Cooperation (P OC) meetings, as required by NMFS, USFWS and MMS in order to gather comments and questions and to address the concerns of the communities that are potentially affected by the planned exploration drilling program.

In addition, Shell offers several programs that i nvolve the training and subsequent hiring of local residents. Programs include the following:

 Marine Mammal Observers (MMO) Program: The MMO program involves intensive training for marine mammal identification and documentation, computer use, and health and safety. Some MMO's are recruited locally from North Slope comm unities to work during exploration activities, including the planned exploration drilling program.

 Subsistence Advisors (SA) Program: In the SA program, select villages are represented by one of its residents to relay subsistence information a nd issues to Shell. The SA speaks with other village members and documents subsistence info rmation. This information may then be integrated into the various Shell exploration programs.

 Community Liaison Officers (CLO) Program: The CLO program involves direct hiring of community liaisons that serve as Shell’s point-of-c ontact for questions regarding Shell programs
in the area.

 Cultural Awareness Program: Shell and contractor personnel involved in field operations during the planned 2010 exploration drilling program will at tend the orientation training annually, which addresses environmental, social, and cultural concerns related to the project area. The program is designed to increase sensitivity and understanding by Shell and its contractors of community values, customs, and lifestyles in the area they will be working, and how to avoid conflicts with Native Alaskans and their subsistence activities. The program stresses the importance of not disturbing archaeological and biological resour ces and habitats, including endangered species, fisheries, bird colonies, and marine mammals a nd provides guidance on how to avoid disturbance.

Shell collected information on the use of coastal ar eas along the Chukchi Sea for subsistence through its SA Program. Data were collected through a number of person-to-person interviews. Subsistence users from Barrow, Wainwright, Point Lay, and Point H ope were interviewed. A report was prepared summarizing and mapping the results of these interv iews. The report (ASRC Energy Services 2009) is attached as Appendix K. Results of these intervie ws were used in the preparation of the EIA (Appendix F).2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 25 July 2009 15276-03-09-001A/09-011A Rev.1 While developing its ODPCP, Shell conducted intervie ws with residents of Barrow, Wainwright, Point Lay, and Point Hope to supplement existing formal e nvironmental and resource data for the Chukchi Sea coastline. Data collected pertained to hunting, fishin g, land use, and coastal processes such as erosion, ice movement and melting, and coastal dynamics. A report was prepared summarizing and mapping the results of these interviews. The report (Sound Enterp rises and Associates, LLC 2008) is available to the MMS on request. Results of these interviews were used in the preparation of the EIA (Appendix F).

Shell also conducted an economic analysis of future oil and gas exploration and development in the Beaufort Sea, Chukchi Sea, and North Aleutian Ba sin. The results (Northern Economics 2009) of the analysis have been presented to the MMS.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 26 July 2009 15276-03-09-001A/09-011A Rev.1 

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Shell Gulf of Mexico Inc. 27 July 2009 15276-03-09-001A/09-011A Rev.1 SECTION 6.0 SOLID AND LIQUID WASTE AND DISCHARGE INFORMATION

6.1 Burger Prospect

a) Projected Generated Wastes The type, composition, and amount of solid and liquid wastes expected to be generated on the Discoverer during the planned exploration drilling program at the Burger Prospect are listed below in Table 6.1-a, along with the storage and disposal methods. The volumes were calculated based on empirical information and past experience.

TABLE 6.1-a Projected Generated Wastes During Drilling Season 2010 – Burger Prospect

Type of Waste Composition Total Projected Amount Treatment, Storage, and Disposal

Drill cuttings (from MLC and 36-inch section) Drill cuttings; no drilling muds used 3,070 bbl/well Deposited on t he surface of the seafloor

Spent drilling fluids Water based drilling fluids 4,405 bbl/well Discharged to sea through disposal caisson after 30:1 dilution with seawater Cuttings from water based intervals (does not include MLC and 36-inch section) Cuttings coated with water based drilling muds 2,905 bbl/well Discharged to sea through disposal caisson after 30:1 dilution with seawater

Sanitary waste Treated human body waste from toilets 27 bbl/day Treated sanitary wastewater to be discharged to water through disposal caisson (based on 124 people at a rate of 9 gal/person/day) Domestic waste Gray water (laundry, galley, lavatory) 83 bbl/day Discharged to water through disposal caisson (based on 124 people at a rate of 28 gal/person/day) Excess cement Cement slurry 50 bbl/well Disc harged at seafloor during 30-in and 20-in casing cementing operations
Desalination unit brine
water Rejected water from watermaker unit 125 bbl/day Discharged to water through disposal caisson

Deck drainage Uncontaminated fresh or
seawater 5 bbl/day Drain to oily water separator; uncontaminated water to be discharged to sea through disposal caisson, contaminated water stored in waste oil tank then transferred by boat to an approved treatment/disposal site Trash and debris Refuse generated during installation and production 300 bbl/month Trash and debris to be segregated and disposed of at an approved disposal facility Cooling water Seawater 45,000 bbl/day Discharged to water through a number of outlets Firewater Treated seawater 0 bbl/month No discharge except in the event of a fire
Ballast water Uncontaminated seawater 620 bbl/day Discharged to water through disposal caisson

Used oil Lube oil 100 bbl/year Stored on board in waste oil tank; transferred to lube cubes for transport by boat to an approved treatment/disposal site Hazardous waste Chemical products and general hazardous waste 10 bbl/well Stored onboard in approved container; transferred for transport by boat to an approved treatment/disposal site Bilge water Oily seawater and freshwater 1000 bbl/well Treated in oily water separator, uncontaminated water discharged to sea through disposal caisson, oily water stored onboard, transferred for transport by boat to an approved treatment/disposal site
BOP fluid water + ≤ 3% Stack Magic Eco-F additive + ≤ 25% Stack Glycol (MEG) 42 bbl/well Discharged subsea at BOP2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 28 July 2009 15276-03-09-001A/09-011A Rev.1 b) Projected Ocean Discharges

Table 6.1-b lists the types of wastes, expected quantiti es, and rates of discharge that are expected to be generated on the Discoverer during the offshore exploration drilling program at the Burger Prospect and discharged into the sea. This in formation has been submitted to th e Environmental Protection Agency (EPA) to support a Notice of Intent (NOI) applicati on for authorization to discharge the wastes under National Pollutant Discharge Elimination System (N PDES) General Permit AKG-28-0000. A copy of the NOI is provided in Appendix B. The projected wast es and amounts listed in Table 6.1-b are applicable only to the Discoverer. Discharges from drilling support vessels will be made pursuant to the International Convention for the Prevention of Pollution from Ships (Marine Pollution or MARPOL) standards and requirements. The projected genera ted waste values were calculated based on empirical information and past experience; therefore, the actual ocean discharges may differ.

TABLE 6.1-b Types and Estimated Volume Ocean Discharges During Drilling Season 2010– Burger Prospect

Type of Waste Total Amount to be Discharged Discharge Rate* Discharge Method Drill cuttings (from MLC and 36-inch section) 3,070 bbl/well (cuttings only; no drilling muds used) 614 bbl/day Deposited on the surfac e of the seafloor

Spent drilling fluids 4,405 bbl/well spent mud plus mud in tanks (if multiple wells drilled per season, water based muds to be transferred to and used at the next well) 138 bbl/day (including discharge of
excess water based drilling fluid at end of the drilling season) Discharged to sea through disposal caisson after 30:1 dilution with seawater

Cuttings from water based intervals (does not include MLC and 36-inch section) 2,905 bbl/well 91 bbl/day Discharged to sea through disposal caisson after 30:1 dilution with seawater

Sanitary waste 1,000 bbl/well 27 bbl/day Treated in marine sanitary device prior to discharge to meet NPDES limits (based on 124 people at 9 gal/person/day) Domestic waste 3,071 bbl/well 83 bbl/day Discharged to water through the disposal caisson (based on 124 people at 28 gal/person/day). All food waste to be incinerated

Excess cement 50 bbl/well Two occasions at 1 bbl/min Discharged at seafloor during 30-inch and 20- inch cementing operations
Desalination unit brine water 4,625 bbl/well 125 bbl/day Discharged to water through disposal caisson

Deck drainage 185 bbl/well 5 bbl/day (dependent on rainfall) Drains to the oily water separator. Uncontaminated water id discharged through the disposal caisson; contaminated water is stored in a waste oil tank then transferred by boat to an approved treatment/disposal site. Cooling water 1,665,000 bbl/well 45,000 bbl/day Discharged to water through number of outlets Firewater 0 0 bbl/month No routine firewater system testing anticipated Ballast water 22,940 bbl/well 620 bbl/day Discharged to sea through disposal caisson Bilge water 1000 bbl/well 27 bbl/day Treated in oily water separator, uncontaminated water discharged to sea through disposal caisson, oily water stored onboard, transferred for transport by boat to an approved disposal site BOP fluid 42 bbl/well (6 tests; 7 bbl per test) 7 bbl/day Discharged subsea at BOP when testing BOP

* assumes 5 days to complete the MLC and 36-inch section; 32 days to complete the remainder of the well2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 29 July 2009 15276-03-09-001A/09-011A Rev.1 6.2 Crackerjack Prospect

a) Projected Generated Wastes

The type, composition, and amount of solid and liquid wastes expected to be generated on the Discoverer during the planned exploration drilling program at the Crackerjack Prospect are listed below in Table 6.2- a, along with the storage and disposal methods. The volumes were calculated based on empirical information and past experience.

TABLE 6.2-a Projected Generated Wastes During Drilling Season 2010– Crackerjack Prospect

Type of Waste Composition Total Projected Amount Treatment, Storage, and Disposal

Drill cuttings (from MLC and 36-inch section) Drill cuttings; no drilling muds used 3,160 bbl/well Deposited on the surface of the seafloor Spent drilling fluids Water based drilling fluids 5, 005 bbl/well Discharged to sea through disposal caisson after 30:1 dilution with
seawater Cuttings from water based intervals (does not include MLC and 36-inch section) Cuttings coated with water based drilling muds 3,505 bbl/well Discharged to sea through disposal caisson after 30:1 dilution with
seawater Sanitary waste Treated human body waste from toilets 27 bbl/day Treated sanitary wastewater to be discharged to water through disposal caisson (based on 124 people at a rate of 9 gal/person/day) Domestic waste Gray water (laundry, galley, lavatory) 83 bbl/day Discharged to water through disposal caisson (based on 124 people at a rate of 28 gal/person/day) Excess cement Cement slurry 50 bbl/we ll Discharged at seafloor during 30-in and 20-in casing cementing operations
Desalination unit brine
water Rejected water from watermaker unit 125 bbl/day Discharged to water through disposal caisson Deck drainage Uncontaminated fresh or
seawater 5 bbl/day Drain to oily water separator; uncontaminated water to be discharged to sea through disposal caisson, contaminated water stored in waste oil tank then transferred by boat to an approved treatment/disposal site Trash and debris Refuse generated during installation and production 300 bbl/month Trash and debris to be segregated and disposed of at an approved disposal facility Cooling water Seawater 45,000 bbl/day Discharged to water through a number of outlets Firewater Treated seawater 0 bbl/month No discharge except in the event of a fire Ballast water Uncontaminated seawater 620 bbl/day Discharged to water through disposal caisson Used oil Lube oil 100 bbl/year St ored onboard in waste oil tank; transferred to l ube cubes for transport by boat to an approved treatment/disposal site Hazardous waste Chemical products and general hazardous waste 10 bbl/well Stored onboard in approved container; transferred for transport2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 30 July 2009 15276-03-09-001A/09-011A Rev.1 TABLE 6.2-a Projected Generated Wastes During Drilling Season 2010– Crackerjack Prospect

Type of Waste Composition Total Projected Amount Treatment, Storage, and Disposal

by boat to an approved treatment/disposal site Bilge water Oily seawater and freshwater 1000 bbl/well Treated in oily water separator, uncontaminated water discharged to sea through disposal caisson, oily water stored onboard, transferred for transport by boat to an approved treatment/disposal site
BOP fluid water + ≤ 3% Stack Magic Eco-F additive + ≤ 25% Stack Glycol (MEG) 42 bbl/well Discharged subsea at BOP

b) Projected Ocean Discharges

The types and quantities of wastes that are expected to be generated on the Discoverer during the offshore exploration drilling program at the Crackerjack Prospect and discharged into the sea are listed in Table 6.2-b with the expected rates of discharge. This information has been submitted to the EPA with a NOI application for authorization to discharge the wastes under NPDES General Permit AKG-28-0000. A copy of the NOI is provided in Appendix B. The projected wastes and amounts listed in Table 6.2-b are applicable only to the Discoverer. Discharges from drilling support vessels will be made pursuant to the MARPOL standards and requirements. The projected generated waste values were calculated based on empirical information and past experien ce; actual ocean discharges may differ.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 31 July 2009 15276-03-09-001A/09-011A Rev.1 TABLE 6.2-b Types and Estimated Volume Ocean Discharges During Drilling Season 2010– Crackerjack Prospect

Type of Waste Total Amount to be Discharged Discharge Rate* Discharge Method Drill cuttings (from MLC and 36-inch section) 3,160 bbl/well (cuttings only; no drilling muds used) 632 bbl/day Deposited on the surfac e of the seafloor

Spent drilling fluids 5,005 bbl/well spent mud plus mud in tanks (if multiple wells drilled per season, water based muds will be transferred to and used at the next well) 156 bbl/day (including discharge of excess water based drilling fluid at end of the drilling season) Discharged to sea through disposal caisson after 30:1 dilution with seawater

Cuttings from water based intervals (does not include MLC and 36-inch section) 3,505 bbl/well 110 bbl/day Discharged to sea through disposal caisson after 30:1 dilution with seawater

Sanitary waste 1,000 bbl/well 27 bbl/day Treated in marine sanitary device prior to discharge to meet NPDES limits (based on 124 people at 9 gal/person/day) Domestic waste 3,071 bbl/well 83 bbl/day Discharged to water through the disposal caisson (based on 124 people at 28 gal/person/day)

Note: all food waste to be incinerated
Excess cement 50 bbl/well Two occasions at 1 bbl/min Discharged at seafloor during 30-inch and 20-inch cementing operations

Desalination unit brine water 4,625 bbl/well 125 bbl/day Discharged to water through disposal caisson Deck drainage 185 bbl/well 5 bbl/day (dependent on rainfall) Drains to the oily water separator. Uncontaminated water id discharged through the disposal caisson; contaminated water is stored in a waste oil tank then transferred by boat to an approved treatment/disposal site. Cooling water 1,665,000 bbl/well 45,000 bbl/da y Discharged to water through a number of outlets Firewater 0 0 bbl/month No routine firewater system testing anticipated Ballast water 22,940 bbl/well 620 bbl/day Discharged to sea through disposal caisson Bilge water 1000 bbl/well 27 bbl/day Treated in oily water separator, uncontaminated water discharged to sea through disposal caisson, oily water stored onboard, transferred for transport by boat to an approved disposal site BOP fluid 42 bbl/well (6 tests; 7 bbl per test) 7 bbl/day Discharged subsea at BOP when testing BOP

* assumes 5 days to complete the MLC and 36-inch section; 32 days to complete the remainder of the well2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 32 July 2009 15276-03-09-001A/09-011A Rev.1 6.3 Southwest Shoebill Prospect

a) Projected Generated Wastes

The type, composition, and amount of solid and liquid wastes expected to be generated on the Discoverer during the planned exploration drilling program at th e SW Shoebill Prospect are listed below in Table 6.3-a, along with the storage and disposal methods . The volumes were calculated based on empirical information and past experience.

TABLE 6.3-a Projected Generated Wastes During Drilli ng Season 2010– Southwest Shoebill Prospect

Type of Waste Composition Total Projected Amount Treatment, Storage, and Disposal Drill cuttings (from MLC and 36-inch section) Drill cuttings; no drilling muds used 3,310 bbl/well Deposited on the surface of the seafloor

Spent drilling fluids Water based drilling fluids 4, 730 bbl/well Discharged to sea through disposal caisson after 30:1 dilution with
seawater Cuttings from water based intervals (does not include MLC and 36-inch section) Cuttings coated with water based drilling muds 3,230 bbl/well Discharged to sea through disposal caisson after 30:1 dilution with
seawater

Sanitary waste Treated human body waste from toilets 27 bbl/day Treated sanitary wastewater to be discharged to water through disposal caisson (based on 124 people at a rate of 9 gal/person/day) Domestic waste Gray water (laundry, galley, lavatory) 83 bbl/day Discharged to water through disposal caisson (based on 124 people at a rate of 28 gal/person/day) Excess cement Cement slurry 50 bbl/we ll Discharged at seafloor during 30-in and 20-in casing cementing operations
Desalination unit brine water Rejected water from watermaker unit 125 bbl/day Discharged to water through disposal caisson Deck drainage Uncontaminated fresh or
seawater 5 bbl/day Drain to oily water separator; uncontaminated water to be discharged to sea through disposal caisson, contaminated water stored in waste oil tank then transferred by boat to an approved treatment/disposal site Trash and debris Refuse generated during installation and production 300 bbl/month Trash and debris to be segregated and disposed of at an approved disposal facility Cooling water Seawater 45,000 bbl/day Discharged to water through a number of outlets
Firewater Treated seawater 0 bbl/month No discharge except in the event of a fire
Ballast water Uncontaminated seawater 620 bbl/day Discharged to water through disposal caisson Used oil Lube oil 100 bbl/year Stor ed onboard in waste oil tank; transferred to lube cubes for transport by boat to an approved treatment/disposal site2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 33 July 2009 15276-03-09-001A/09-011A Rev.1 TABLE 6.3-a Projected Generated Wastes During Drilli ng Season 2010– Southwest Shoebill Prospect

Type of Waste Composition Total Projected Amount Treatment, Storage, and Disposal Hazardous waste Chemical products and general hazardous waste 10 bbl/well Stored onboard in approved container; transferred for transport by boat to an approved treatment/disposal site Bilge water Oily seawater and freshwater 1000 bbl/well Treated in oily water separator, uncontaminated water discharged to sea through disposal caisson, oily water stored onboard, transferred for transport by boat to an approved treatment/disposal site
BOP fluid water + ≤ 3% Stack Magic Eco-F additive + ≤ 25% Stack Glycol (MEG) 42 bbl/well Discharged subsea at BOP2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 34 July 2009 15276-03-09-001A/09-011A Rev.1 b) Projected Ocean Discharges

The types and quantities of wastes that are expected to be generated on the Discoverer by the offshore exploration drilling program at the SW Shoebill Prospect and discharged into the sea are listed in Table 6.3-b with the expected rates of discharge. This information has been submitted to the EPA with a NOI application for authorization to discharge the wastes under NPDES General Permit AKG-28-0000. A copy of the NOI is provided in Appendix B. The projected wastes and amounts listed in Table 6.3-b are applicable only to the Discoverer. Discharges from drilling support vessels will be made pursuant MARPOL standards and requirements. The projected generated waste values were calculated based on empirical information and past experien ce; actual ocean discharges may differ.

TABLE 6.3-b Types and Estimated Volume Ocean Discharges During Drilling Season 2010– Southwest Shoebill Prospect

Type of Waste Total Amount to be Discharged Discharge Rate* Discharge Method Drill cuttings (from MLC and 36-inch section) 3,310 bbl/well (cuttings only; no drilling muds used) 662 bbl/day (for approx. 5 days) Deposited on the surfac e of the seafloor

Spent drilling fluids 4,730 bbl/well spent mud plus mud in tanks (if multiple wells drilled per season, water based muds will be transferred to and used at the next well) 148 bbl/ day (including discharge of excess water based drilling fluid at end of the drilling season) Discharged to sea through disposal caisson after 30:1 dilution with seawater

Cuttings from water based intervals (does not include MLC and 36-inch section) 3,230 bbl/well 101 bbl/day Discharged to sea through disposal caisson after 30:1 dilution with seawater

Sanitary waste 1,000 bbl/well 27 bbl/day Treated in marine sanitary device prior to discharge to meet NPDES limits (based on 124 people at 9 gal/person/day) Domestic waste 3,071 bbl/well 83 bbl/day Discharged to water through the disposal caisson (based on 124 people at 28 gal/person/day)

Note: all food waste to be incinerated
Excess cement 50 bbl/well Two occasions at 1 bbl/min Discharged at seafloor during 30-inch and 20-inch cementing operations

Desalination unit brine water 4,625 bbl/well 125 bbl/day Discharged to water through disposal caisson Deck drainage 185 bbl/well 5 bbl/day (dependent on rainfall) Drains to the oily water separator. Uncontaminated water id discharged through the disposal caisson; contaminated water is stored in a waste oil tank then transferred by boat to an approved treatment/disposal site. Cooling water 1,665,000 bbl/well 45,000 bbl/da y Discharged to water through a number of outlets Firewater 0 0 bbl/month No routine firewater system testing anticipated Ballast water 22,940 bbl/well 620 bbl/day Discharged to sea through disposal caisson Bilge water 1000 bbl/well 27 bbl/day Treated in oily water separator, uncontaminated water discharged to sea through disposal caisson, oily water stored onboard, transferred for transport2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 35 July 2009 15276-03-09-001A/09-011A Rev.1 TABLE 6.3-b Types and Estimated Volume Ocean Discharges During Drilling Season 2010– Southwest Shoebill Prospect

Type of Waste Total Amount to be Discharged Discharge Rate* Discharge Method by boat to an approved disposal site BOP fluid 42 bbl/well (6 tests; 7 bbl per test) 7 bbl/day Discharged subsea at BOP when testing BOP

6.4 NPDES Permit

All discharges from the Discoverer during the exploration drilling progr am (as itemized above in Tables 6.1-b, 6.2-b and 6.3-b) will be made in accord ance with the EPA NPDES program through the General Permit AKG-28-0000, which is valid until midnight June 26, 2011. Shell’s NOI for coverage under this permit is in Appendix B. A flow diagram for the Discoverer , is provided in NOI. Schematics for oily waste separator systems, sewage and gray water treatment systems are provided below in Figures 6.4-1
and 6.4-2.

Figure 6.4-1 Sewage and Gray Water Treatment System on the Discoverer2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 36 July 2009 15276-03-09-001A/09-011A Rev.1 Figure 6.4-2 Oily Waste Separator System on the Discoverer2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 37 July 2009 15276-03-09-001A/09-011A Rev.1 A list of the components that may be added to the drilling fluid are provided in Table 6.4-1. This component list and the respective volumes have been designed for various drilling depth from the mudline cellar to total depth for all wells.

TABLE 6.4-1 Drilling Fluid Components and Load Out List for the Chukchi Sea Exploration Drilling Program Component Description/Function Unit Size Package Total Usage (packages) Total Weight

(lb) Barite Weighting agent 100 lb Sack 22,000 2,200,000 Gel Bentonite viscosifier 100 lb Sack 1,200 120,000 Caustic soda Sodium hydroxide, ph control 50 lb Sack 200 10,000 Soda ash Sodium carbonate, for raising ph 50 lb Sack 250 12,500 Bicarbonate Sodium bicarbonate, ph control 50 lb Sack 200 10,000 Duovis Polysaccharide bioplymer 25 lb Sack 450 11,250

Phpa Partially hydrolyzed polyacrylamide polymer 50 lb Sack 800 40,000 Tackle (alcomer 74) Modified acrylic polymer 50 lb Sack 100 5,000 Poly pac r Polyanionic cellulose, reduce filtration rate 50 lb Sack 100 5,000 Poly pac ul Polyanionic cellulose, reduce filtration rate 50 lb Sack 500 25,000 Sp-101 Sodium polyacrylate copolymer 50 lb Sack 300 15,000 Tannathin Oxidized lignite, 50 lb Sack 200 10,000 Citric acid Alkalinity control 50 lb Sack 100 5,000 Myacide Biocide 5 gal Can 200 10,000 Contingency Salt Sodium chloride 100 lb Sack 5,000 500,000 Gelex Polyacrylate/polyacrylamide, viscosifier 2 lb Sack 50 100 Defoam-X Polyglycol, reduce foaming in fluids 5 gal Can 90 4,500 Nut plug (asst) Ground nut shells, for lost circulation 50 lb Sack 200 8,000 Mi seal Lost circulation 40 lb Sack 200 8,000 Mix ii (asst) Blended calcium carbonate & polymers 25 lb Sack 200 5,000 Desco cf Organic thinner 50 lb Sack 144 7,200 Spersene CF Chrome lignosulfonate, deflocculant 50 lb Sack None 0 Sapp Sodium acid pyrophosphate, thinner 50 lb Sack 90 4,500 Lime Calcium hydroxide 50 lb Sack 80 4,000 Durogel Sepiolite clay, viscosifier, filtration reducer 50 lb Sack 600 30,000

Notes: Does not include barite to be loaded on support vessels.

Drilling support vessels in excess of 300 gross registered tons or having a ballast capacity of 2133 gal (8

m 3 ) or greater must acquire authorization to dischar ge under the Vessel General Permit for Discharges Incidental to the Normal Operation of Comme rcial Vessels and Large Recreational Vessels. Authorizations to discharge under this vessel ge neral permit for discharges incidental to normal operations will be undertaken by the vessel owner and/ or operator and is not a part of Shell’s required permit and authorization application submittals.

6.5 Modeling Report

All requested NPDES permitted discharges will be carried out in federal waters of the OCS. No mixing zones or zones of deposit are being requested and no modeling was conducted in s upport of such requests. Shell has carried out modeling of th e expected discharges of drill cuttings and drilling fluids for impact assessment purposes. The results of this modeli ng effort are discussed in the EIA (Appendix F).2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 38 July 2009 15276-03-09-001A/09-011A Rev.1 6.6 Cooling Water Intake

A saltwater service system supplies the Discoverer’s requirement for saltwater, including that for drilling operations. The system is primarily used to suppl y cooling water to equipment heat exchangers. A piping flow diagram for Discoverer , is provided with the NOI in Appendix B.

The saltwater service system consists of two saltwat er pumps (Aurora 5-483-11C), one flare-burner spray pump, four sea-suctions (each with strainer having holes 5mm in diameter), and associated distribution piping. Screen mesh sizes on the water intakes, wh ich have been reduced to minimize entrainment of larger fish eggs and larvae, are provided below in Table 6.6-1.

TABLE 6.6-1 Screen Mesh Size on Water Intakes on the Discoverer

Sea-suction Screen Mesh Size Pumproom Sea Suction 0.2 in (5.0 mm) diameter holes in plate Lower Engine Room Sea Suction 0.2 in (5.0 mm) diameter holes in plate Upper Engine Room Sea Suction 0.2 in (5.0 mm) diameter holes in plate
Generator Room Sea Suction 0.2 in (5.0 mm) diameter holes in plate

The calculated velocity of intake water across the screens is approximately 40 ft/minute (min) (20 cm/second).

6.7 Disposal Caisson

The disposal caisson runs vertically through the sp onson from the main deck level to the base of the sponson. The sponson is an exterior reinforced claddi ng on the hull to provide ice resistance. It is hollow
and extends from the main deck level to well below th e water line. Waste streams are collected aboard the drillship to a point on the main deck near the mud room. A 15-in. diameter pipe exits the hull, turns downwards and is connected to the top of the disposal caisson.

The disposal caisson is a 15-in diameter pipe welded into the sponson top and bottom (such that the inside of the sponson remains dry). The bottom of the sponson is 5.6 ft (1.7 m) above the keel depth. The disposal caisson is not equippe d with a "float" valve; it is an open pipe. Since it remains open to the sea at all times, the disposal caisson is cons tantly filled with water. This cai sson is not equipped with a "float" valve; it is merely an open conduit to the sea thr ough which most waste streams are disposed below sea
level.

With the bottom of the sponson 5.6 ft above the keel , the base of the disposal caisson while drilling is 25.2 ft - 5.6 ft = 19.6 ft (6.0 m) below mean sea level. Because of heav e, the water level inside the caisson is constantly changing.

6.8 Desalination Unit BrineWater

The watermaker operates via evaporation/condensati on of seawater. The remaining stream has slightly higher concentrations of all dissolved solids. Thus, the stream is seawater with more salt, hardness and all other dissolved components.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 39 July 2009 15276-03-09-001A/09-011A Rev.1 SECTION 7.0 AIR EMISSIONS INFORMATION

The air quality information provided herein is based on the drillship and associat ed support vessels, which include an ice management vessel, and anchor hand ling vessel, a materials s upply vessel, and Oil Spill Response (OSR) vessels. Shell submitted a majo r new source review Prevention of Significant Deterioration (NSR/PSD) applica tion to EPA Region 10 on 10 December 2008 and a revised application on 23 February 2009. Responses to additional EPA requ ests for information were submitted to MMS on 18 May and 29 May 2009. Shell has provided MMS with these documents, and the MMS should refer to these documents for additional information on the projected emissions, how emissions were calculated, and how impacts were modeled. Shell has proposed several emission reduction measures and owner-requested enforceable limits in the applicatio n including burning ultra-low sulfur diesel fuel; and installing diesel particulate filters, catalytic diesel particulate filters, and selective catalytic reduction (SCR) controls on the drillship emission units. Shell believes these emission reduction measures will satisfy the best available control technology (BACT) componen t of PSD permitting and expects EP A to incorporate these measures as enforceable permit limitations. Additional em ission reduction measures may be identified and incorporated into the PSD permit by EPA during th eir permit review and approval process. The actual drilling window from 4 July to 31 October is approximately 119 days, therefore the 168-days used for projected air emissions is a worst case calculation.

Shell’s PSD application includes emis sion unit spreadsheets that describe all of the source units of the drillship and support vessels; and an analysis of poten tial impacts to air quality based on the emissions and source descriptions. These are summarized below.

a) Projected Emissions

Sources : The Discoverer emission units are listed in Table 7.a- 1 and consist of engines for electric generation, pneumatic compression and hydraulic compression, engines for movement of materials (cranes), heaters, and an incinerator primarily for domestic purposes. The primary emission units of the ancillary vessels are the propulsion engines.

Projected Peak Hourly Emissions [30 CFR 250.218(a)(1)(i)] : Projected peak hourly emissions from the emission sources are provided below in Table 7.a-2.

Total Annual Emissions [30 CFR 250. 218(a)(1)(ii)] and Emissions over the Duration of the Exploration Drilling Program [30 CFR 250.218(a)(1)(iii)] : Emissions for all sources associated with the Discoverer are estimated as potentials to emit (PTE) . Total projected annual PTEs for the Discoverer emission sources, and for the associated vessels, are provided in Table 7.a-3 by pollutant. Because the planned exploration drilling program is a one-year program , the annual PTEs also represent the PTEs for the duration of the proposed exploration activities.

Frequency and Duration of Emissions [30 CFR 250.218( a)(1)(iv)] and Basis for Calculation of Emissions [30 CFR 250.218(a)(2)] : Total projected annual PTEs by pollutant for the Discoverer sources and for the associated vessels, are provided in Table 7.a-3. These PTEs are based on a maximum 168- day drilling season. The actual drilling window from July 4 to Oct ober 31 is approximately 119 days, therefore the 168-days used for projected air emissions is a worst case calculation. Emissions for all emission units
associated with the Discoverer are estimated as PTEs, which are the emissions assuming continuous operation at capacity for the entire drilling season per y ear, unless limited by owner-requested restriction. Proposed owner-requested restrictions are provided in Table 7.a.4. These restrictions and the following
text summarize the basis for the calculation of the PTEs. The emissions for the associated vessels are estimated at 150 percent of expected use. Discoverer emissions are estimated without the propulsion engines operating (drilling and propulsion are exclus ive). The maximum length of drilling per hole is 842010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 40 July 2009 15276-03-09-001A/09-011A Rev.1 days and per season is 168 days of drilling per cale ndar year. The emergency and backup engines are only used during emergencies and main tenance of paired engines. Fuel quality for the vessels will have a sulfur content equal to or less than 0.19 weight percent. Fuel quality for the Discoverer will have a sulfur content equal to or less than 0.0015 weight percent.

TABLE 7.a-1 Description of Discoverer Drilling Vessel Emission Units and Associated Fleet

Unit ID Unit Description Make/Model Rating Max fuel consumption

[mBtu/hr])
FD-1 Generator Engine Cat / D399 1,325 Hp 6.91

FD-2 Generator Engine Cat / D399 1,325 Hp 6.91

FD-3 Generator Engine Cat / D399 1,325 Hp 6.91

FD-4 Generator Engine Cat / D399 1,325 Hp 6.91

FD-5 Generator Engine Cat / D399 1,325 Hp 6.91

FD-6 Generator Engine Cat / D399 1,325 Hp 6.91

FD-7* Propulsion Engine MI / 6UEC65 7,200 Hp 0.0

FD-8* Emergency Generator Caterpillar / 3304 131 Hp 0.3 FD-9 MLC Compressor Caterpillar C – 15 540 Hp 3.6

FD-10 MLC Compressor Caterpillar C – 15 540 Hp 3.6

FD-11* MLC Compressor Caterpillar C – 15 540 Hp 3.6

FD-12 HPP Engine Detroit/8V71 250 Hp 2

FD-13 HPP Engine Detroit/8V71 250 Hp 2

FD-14 Port Deck Crane Cat / D343 365 Hp 2.8

FD-15 Starboard Deck Crane Cat / D343 365 Hp 2.8

FD-16 Cementing Unit Detroit / 8V-71N 335 Hp 2.6

FD-17 Cementing Unit Detroit / 8V-71N 335 Hp 2.6

FD-18 Cementing Unit GM 3-71 147 Hp 1.1

FD-19** Logging Winch Detroit / 4-71N 128 Hp 1.0

FD-20** Logging Winch 4024TF270 36 kW 0.3

FD-21 Heat Boiler Clayton 200 Boiler 7.97 mBtu/hr 8.0

FD-22 Heat Boiler Clayton 200 Boiler 7.97 mBtu/hr 8.0

FD-23 Incinerator TeamTec/GS500C 276 lb/hr - FD-31 Resupply Ship docked - - - 4.1

89.7

Associated Fleet

Ice Management Fleet - - - - Diesel Engines - - - 377.28

Incinerators - (2)154 lb/hr Total Ice Management Fleet - - - 377..28 Resupply Ship In Transit 44.41

OSR Fleet OSR Main Ship Total 52.32

OSR Work Boats Total 12.85

Total OSR Fleet 65.18

486.86

576.57

Notes:

*Not used during drilling ** Logging wi nch operation combined with cementing units2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 41 July 2009 15276-03-09-001A/09-011A Rev.1

TABLE 7.a-2 Projected Peak Hourly Emissions of Discoverer Drilling Vessel Emission Units and Associated Fleet

Maximum Emissions (lb/hr)

Unit ID Unit Description PM 10 PM 2.5 NO x SO 2 CO VOC Lead

FD-1 Generator Engine 0.20 0.20 0.77 1.10E-02 0.28 0.04 2.01E-04

FD-2 Generator Engine 0.20 0.20 0.77 1.10E-02 0.28 0.04 2.01E-04

FD-3 Generator Engine 0.20 0.20 0.77 1.10E-02 0.28 0.04 2.01E-04

FD-4 Generator Engine 0.20 0.20 0.77 1.10E-02 0.28 0.04 2.01E-04

FD-5 Generator Engine 0.20 0.20 0.77 1.10E-02 0.28 0.04 2.01E-04

FD-6 Generator Engine 0.20 0.20 0.77 1.10E-02 0.28 0.04 2.01E-04

FD-7* Propulsion Engine 0.00 0.00 0.00 0.00E+00 0.00 0.00 0.00E+00

FD-8* Emergency Generator 0.21 0.21 1.09 4.88E+04 0.60 0.11 8.86E-06 FD-9 MLC Compressor 0.18 0.18 3.55 5.71E-03 3.11 3.55 1.04E-04

FD-10 MLC Compressor 0.18 0.18 3.55 5.71E-03 3.11 3.55 1.04E-04

FD-11* MLC Compressor 0.18 0.18 3.55 5.71E-03 3.11 3.55 1.04E-04

FD-12 HPP Engine 0.10 0.10 5.41 3.11E-03 0.16 0.08 5.66E-05

FD-13 HPP Engine 0.10 0.10 5.41 3.11E-03 0.16 0.08 5.66E-05

FD-14 Port Deck Crane 0.04 0.04 6.20 4.41E-03 0.13 0.04 8.02E-05

FD-15 Starboard Deck Crane 0.04 0.04 6.20 4.41E-03 0.13 0.04 8.02E-05

FD-16 Cementing Unit 0.21 0.21 8.66 4.17E-03 0.48 0.15 7.58E-05

FD-17 Cementing Unit 0.21 0.21 8.66 4.17E-03 0.48 0.15 7.58E-05

FD-18 Cementing Unit 0.09 0.09 3.80 1.83E-03 0.21 0.07 3.33E-05

FD-19** Logging Winch 0.08 0.08 3.31 1.59E-03 0.18 0.06 2.90E-05

FD-20** Logging Winch 7.14E-03 7.14E-03 0.595 5.37E-04 0.0437 0.0595 9.76E-06

FD-21 Heat Boiler 0.19 0.19 1.60 1.27E-02 0.62 0.01 7.17E-05

FD-22 Heat Boiler 0.19 0.19 1.60 1.27E-02 0.62 0.01 7.17E-05

FD-23 Incinerator 1.13 0.97 0.69 0.35 4.28 0.41 0.03

FD-31 Resupply Ship docked 1.27 1.27 18.03 0.83 3.88 1.43 1.19E-04

5.60 5.44 86.54 1.31 22.98 13.57 3.17E-02 Ice Management Fleet Diesel Engines 93.99 83.00 2,216.84 82.85 296.43 53.20 1.09E-02

Incinerators 2.05 1.40 0.46 0.39 46.20 15.40 3.28E-02 Total Ice Management Fleet 96.04 84.40 2,217.31 83.23 342.63 68.60 4.37E-02 Resupply Ship In Transit 20.04 16.07 265.11 9.75 34.89 6.26 1.29E-03

OSR Fleet OSR Main Ship Total 10.47 8.60 229.00 11.04 39.39 17.61 1.48E-02

OSR Work Boats Total 0.38 0.38 19.54 2.60 0.85 0.40 3.73E-04

Total OSR Fleet 10.85 8.98 248.54 13.64 40.25 18.01 1.52E-02

126.93 109.46 2,730.96 106.62 417.78 92.88 6.02E-02

132.53 114.89 2,817.50 107.93 440.75 106.45 9.19E-02

Notes:

* Not used during drilling ** Logging winch operation combined with cementing units2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 42 July 2009 15276-03-09-001A/09-011A Rev.1 TABLE 7.a-3 Projected Annual and Duration of Activity Potentials to Emit for the Discoverer Emission Units and Associated Fleet

Unit ID Unit Description Maximum Emissions (tons/year)

PM 10 PM 2.5 NO x SO 2 CO VOC Lead
FD-1 Generator Engine 0.40 0.40 1.56 0.022 0.56 0.07 4.04E-04
FD-2 Generator Engine 0.40 0.40 1.56 0.022 0.56 0.07 4.04E-04
FD-3 Generator Engine 0.40 0.40 1.56 0.022 0.56 0.07 4.04E-04
FD-4 Generator Engine 0.40 0.40 1.56 0.022 0.56 0.07 4.04E-04
FD-5 Generator Engine 0.40 0.40 1.56 0.022 0.56 0.07 4.04E-04
FD-6 Generator Engine 0.40 0.40 1.56 0.022 0.56 0.07 4.04E-04
FD-7* Propulsion Engine 0.00 0.00 0.00 0.00 0.00 0.00 0.00E+00
FD-8* Emergency Generator 0.0255 0.0255 0.013 5.85E-06 7.16E-03 1.34E-03 1.06E-07 FD-9 MLC Compressor 0.13 0.13 2.69 4.32E-03 2.35 2.69 7.85E-05
FD-10 MLC Compressor 0.13 0.13 2.69 0.00 2.35 2.69 7.85E-05
FD-11* MLC Compressor 0.00 0.00 0.00 0.00 0.00 0.00 0.00E+00
FD-12 HPP Engine 0.08 0.08 4.09 2.35E-03 0.12 0.06 4.28E-05
FD-13 HPP Engine 0.08 0.08 4.09 2.35E-03 0.12 0.06 4.28E-05
FD-14 Port Deck Crane 0.03 0.03 4.68 3.33E-03 0.10 0.03 6.06E-05
FD-15 Starboard Deck C 0.03 0.03 4.68 3.33E-03 0.10 0.03 6.06E-05
FD-16 Cementing Unit 0.13 0.13 5.24 2.52E-03 0.29 0.09 4.59E-05
FD-17 Cementing Unit 0.13 0.13 5.24 2.52E-03 0.29 0.09 4.59E-05
FD-18 Cementing Unit 0.06 0.06 2.30 1.11E-03 0.13 0.04 2.01E-05
FD-19** Logging Winch 0.00 0.00 0.00 0.00 0.00 0.00 0.00E+00
FD-20** Logging Winch 0.00 0.00 0.00 0.00 0.00 0.00 0.00E+00
FD-21 Heat Boiler 0.38 0.38 3.23 2.56E-02 1.24 0.02 1.45E-04
FD-22 Heat Boiler 0.38 0.38 3.23 2.56E-02 1.24 0.02 1.45E-04
FD-23 Incinerator 0.53 0.45 0.32 0.16 1.99 0.19 1.36E-02
FD-31 Resupply Ship d kd 0.03 0.03 0.43 0.02 0.09 0.03 2.85E-06
4.50 4.42 52.28 0.39 13.78 6.48 1.68E-02 Ice Management Fleet Diesel Engines 189 167 1,698 167 598 107 2.21E-02

Incinerators 4.13 2.83 0.93 0.78 93.14 31.05 6.61E-02 Total Ice Management Fleet 194 170 1,699 168 691 138 8.82E-02 Resupply Ship In Transit 0.32 0.26 4.24 0.16 0.56 0.10 2.06E-05

OSR Fleet OSR Main Ship Total 10.62 8.47 169.83 7.79 55.33 19.61 2.79E-02

OSR Work Boats Total 0.77 0.77 39.39 5.23 1.72 0.80 7.51E-04

Total OSR Fleet 11 9 209 13 57 20 2.86E-02

205 180 1,913 181 748 159 1.17E-01

210 184 1,965 181 762 165 1.34E-01

Notes:

* Not used during drilling ** Logging winch operation combined with cementing units2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 43 July 2009 15276-03-09-001A/09-011A Rev. 1 TABLE 7.a-4 Proposed Owner-Requested Restrictions

Compliance Condition Restriction How Calculated How Documented
Operational Restrictions

Season maximum drilling duration 168 days/season 168 days/season x 24 hr/day = 4,032 hrs/season First anchoring attached to last anchor removed, by clock

MLC compressors maximum use per

season 63 days/season 63 day/season x 24 hr/day x 2 engines x 26.9 gal/hr-engine= 81,346 gal/season Demonstrated using fuel consumption – dipstick on the combined MLC

compressor consumption at day fuel tank
HPUs maximum use per

season 63 days/ season 63 day/season x 24 hr/day x 2 engines x 250hp/engine x 0.415 lb/hphr ÷ 7.08 lb/gal=44,338 gal/season Demonstrated using fuel consumption – dipstick on the combined HPU consumption at day fuel tank

Generator combined production maximum 71% 71% x 6 engines x 1,325 hp x kW/1.340hp= 4,212
kW Demonstrated by power meter - combined

Cementing & Logging units combined maximum 30% per day (of cementing) 30% x (335 hp x 2 engines + 147 hp) x 0.415 lb/hp-hr x 24 hr/day ÷ 7.08 lb/gal = 345 gal/day Demonstrated using fuel consumption – dipstick on the combined cementing/logging consumption at day fuel tank

Crane units combined maximum 38% per season Max Fuel Consumption 63,661 gal/season Demonstrated using fuel consumption – dipstick on the combined crane consumption at day fuel tank

Discoverer Incinerator limit 1,525 lb/trash per day - -

Discoverer Incinerator PM 2.5 limited to 7 lb/ton - Demonstrated by initial stack test

Discoverer Incinerator PM 10 limited to 8.2 lb/ton - Demonstrated by initial stack test

Discoverer Incinerator SO 2 limited to 2.5 lb/ton - Demonstrated by initial stack test

Sulfur content on all stationary source engines on drilling vessel 0.0015% by weight - Supplier documentation

Sulfur content on all ships except the Discoverer 0.19% by weight - Supplier documentation

Ice management fleet fuel restriction while < 25 miles from drill site 1699 tons of NO x /season Fuel consumption (gallons) x stack test determined NO x emission factor (tons NO x per gallon fuel) Demonstrated using fuel consumption – dipstick on both vessels measured daily2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 44 July 2009 15276-03-09-001A/09-011A Rev. 1 TABLE 7.a-4 Proposed Owner-Requested Restrictions

Compliance Condition Restriction How Calculated How Documented

Anchor handler fuel restriction while < 25 miles from drill site 849 tons of NO x /

season Fuel consumption (gallons) x stack test determined NO x emission factor (tons NO x per gallon fuel) Demonstrated using fuel consumption - dipstick on anchor handler measured daily

Ice management fleet capacity hourly PM 2.5 restriction 84.4 lb PM 2.5 / hour (Propulsion engine power (kW) capacity (80% of design rating) x
PM 2.5 emission factor (lb/kWh)) + (boiler design rate (btu/hr) x
PM 2.5 emission factor (lb/Btu)) x 24 hours + incinerator capacity (lb/hr) x PM 2.5 emission factor (lb PM 2.5 /lb waste) Propulsion emission factor by stack test, boiler and incinerator emission factors from this workbook. Compliance calculated prior to startup

Anchor handler capacity hourly PM 2.5 restriction 42.2 lb PM 2.5 / hour (Propulsion engine power (kW) capacity (80% of design rating) x
PM 2.5 emission factor (lb/kWh)) + (boiler design rate (btu/hr) x
PM 2.5 emission factor (lb/Btu)) x 24 hours + incinerator capacity (lb/hr) x

PM 2.5 emission factor (lb
PM 2.5 /lb waste) Propulsion emission factor by stack test, boiler and incinerator emission factors from this workbook. Compliance calculated prior to startup

Ice management fleet capacity hourly PM 10 restriction 96.0 lb PM 10 / hour (Propulsion engine power (kW) capacity (80% of design rating) x
PM 10 emission factor (lb/kWh)) + (boiler design rate (btu/hr) x
PM 10 emission factor (lb/Btu)) x 24 hours + incinerator capacity (lb/hr) x PM 10 emission factor (lb PM 10 /lb waste) Propulsion emission factor by stack test, boiler and incinerator emission factors from this workbook. Compliance calculated prior to startup

Anchor handler capacity hourly PM 10 restriction 48.0 lb PM 10 / hour (Propulsion engine power (kW) capacity (80% of design rating) x
PM 10 emission factor (lb/kWh)) + (boiler design rate (btu/hr) x PM 10 emission factor (lb/Btu)) x 24 hours + incinerator capacity (lb/hr) x

PM 10 emission factor (lb
PM 10 / lb waste) Propulsion emission factor by stack test, boiler and incinerator emission factors from this workbook. Compliance calculated prior to startup

Resupply ship while docked limited to 12 hr/day - -2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 45 July 2009 15276-03-09-001A/09-011A Rev. 1 TABLE 7.a-4 Proposed Owner-Requested Restrictions

Compliance Condition Restriction How Calculated How Documented
Resupply ship while docked generation limited to equivalent of 1 engine at: 100% 1 engine x 292 hp x 100% ÷ 1.340 hp/kW x 12 hr/day = 2,615 kW-hr /day Demonstrated by energy monitoring of two engines output combined (kW-hr / day)
OSR Main Ship propulsion limited to equivalent of 1 engine
at: 50% 1 engine x 2,710 hp x

50% ÷ 1.340 hp/kW x

24 hr/day = 24,269

kW-hr /day Demonstrated by energy monitoring of two engines output combined (kW-hr / day)

OSR Main Ship generation limited to equivalent of 1 engine
at: 100% 1 engine x 1285 hp x 100% ÷ 1.340 hp/kW x24 hr/day = 23,015 kWhr /day Demonstrated by energy monitoring of two engines output combined (kW-hr /day)

b) Emission Reduction Measures

Shell is implementing a number of mitigative measur es to reduce the amounts of emissions, including:

 Limiting the drilling to 168 days per season

 Primary generators on the Discoverer will be retrofitted with sel ective catalytic reduction devices
to reduce NO

x emissions to under 0.5 grams/kilowatt-hour (g/kW-hr), and catalytic oxidation devices to reduce CO by at least 80 percent, VOCs by at least 70 percent, and PM10 by at least 50 percent

 All other engines on Discoverer will either be Tier 3 (low emissions) or will be retrofitted with catalytic Diesel Particulate Filters devices to reduce CO, VOCs, and HAPs by at least 90 percent and fine particulate matter by at least 85 percent

 Ultra-low sulfur content (0.0015%) fuel will be used by the Discoverer and low-sulfur content (0.19%) by the support vessels to reduce SO 2 emissions

 Limiting combined generator usage to 71 percent of combined engine capacity

 Limiting the MLC compressors to the equivalent emissions of 2 of the 3 operating at capacity for 63 days

 Limiting the cranes to the equivalent emissions of both cranes operating at capacity for 63 days

per season

 Limiting daily cementing and logging to the equi valent emissions of 30 percent of combined cementing engine capacity

 Limiting incinerator use to 1,525 lb/day

c) Processes, Equipment, Fuels, and Combustibles

The processes of the Discoverer are focused on the generation of electrical, compressed air, and hydraulic energy for operation of the drill. All others are seco ndary and related to general purpose heating, transfer of materials about the deck, pumping of cement, incine ration primarily of domestic waste, and other small emission source. All stationary source engines on the Discoverer will be fueled by diesel with sulfur2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 46 July 2009 15276-03-09-001A/09-011A Rev. 1 content at or below 0.0015 weight percent. The asso ciated vessels will be fuel ed by diesel with sulfur content at or below 0.19 weight percent.

d) Distance to Shore

Minimum distance from shoreline for a drill site will be 60 statute miles (97 km) in 2010.

e) Impact Evaluation for Non-Exempt Drilling Units

As required by 30 CFR 250.218(e), the following describes how Shell’s program complies with the requirements of 30 CFR 250.303. The drillship an d associated support vessels are exempt using the exemption formula found at 30 CFR 250.303(d). M odeled concentrations do not exceed significance concentrations identified in 30 CFR 250.303(e) for all pollutants.

Shell is applying for a PSD permit from the EPA, a nd BACT has been applied to all pollutants. The BACT is described in Shell’s air permit applicati on (Preconstruction Permit Application for the Frontier Discoverer Drill Vessel in Chukchi Sea, beyond the 25 mile Alaska Seaward Boundary), prepared by Air Sciences Inc. Impacts are estimated using dispersi on modeling procedures provided by EPA Region 10.

f) Modeling Report

Results of the modeling and impact analysis are provided in Shell’s air permit application and are summarized below in Table 7.f-1. The EPA-accep table dispersion modeling indicates that the NAAQS and PSD increments will be met at and beyond the hull of the Discoverer

.

TABLE 7.f-1 Summary of Maximum Estimated Concentrations

Pollutant Averaging

Time NAAQS 1
( μ g/m 3 ) Screening

Model Max. Impact Plus Background 2
( μ g/m 3 ) PSD Class II

Increment

( μ g/m 3 ) Screening

Model Max. Impact No Background 3
( μ g/m 3 ) Nitrogen Dioxide (NO 2 ) Annual 100 24.0 25 20.8

Particulate Matter (PM 2.5 ) 24-hour 35 34.3 NA 25.6

Annual 15 3.7 NA 17

Particulate Matter (PM 10 ) 24-hour 150 36.8 30 28.2

Annual 50 5.8 17 1.9

Sulfur Dioxide (SO 2 ) 3-hour 1,300 67.7 512 74.0

24-hour 365 38.2 91 28.0

Annual 80 2.1 20 2.1

Carbon Monoxide (CO) 1-hour 40,000 1,429.3 NA 391.2
8-hour 10,000 879.2 NA 352

1 National Ambient Air Quality Standards

2 Maximum modeled impacts plus background c oncentrations are compared to the NAAQS.

3 Maximum modeled impacts only (no background concentra tions included) are compared to the PSD Increments. NA = not applicable2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 47 July 2009 15276-03-09-001A/09-011A Rev. 1 SECTION 8.0 OIL AND HAZARDOUS SUBSTANCES SPILL INFORMATION

a) Oil Spill Response Planning

Shell has prepared the Chukchi Sea Regional Exploration ODPCP as a fundamental component of the planned exploration drilling program (submitted as part of this EP as a separate document). Despite the very low likelihood of a large oil spill event, Shell has designed a response program based upon a regional capability of responding to a range of sp ill volumes, from small operational spills up to and including a Worst Case Discharge (WCD) from an exploration well blowout. Shell’s program is developed to fully satisfy the response planning require ments of the State of Alaska and federal oil spill planning regulations. The ODPCP presents specific information on the response program that includes a description of personnel and equipment mobilization, th e incident management te am organization, and the strategies and tactics used to implement effect ive and sustained spill containment and recovery operations.

Shell is committed to conducting safe and environmentall y responsible operations in the Chukchi Sea. To achieve this goal, oil spill prevention is a primar y priority in all aspects of operations. Prevention practices will include personnel training programs and adherence to strict procedures and management practices to prohibit spills. Shell’s Chukchi Sea Regional Exploration Program ODPCP emphasizes the prevention of oil pollution by employing the best control mechanisms for blowout prevention and fuel transfer, and by implementing mandatory programs for personnel training. All project personnel, including employees and contractors, involved in o il spill contingency response would receive discharge prevention and response training as described in th e ODPCP. Training drills also would be conducted periodically to familiarize pers onnel with on-site equipment, proper deployment techniques, and maintenance procedures.

b) Location of primary oil spill equipment base and staging area

A dedicated oil spill response vessel (OSRV) possessi ng sufficient onboard storage capacity to provide containment, recovery, and storage for the in itial 24-hour operational peri od (12,690 bbl [1,951 m 3 ]) will be staged in the vicinity of the drillship when drillin g into potential liquid hydrocarbon bearing zones. An Arctic Oil Storage Tanker (OST) also will be staged so that it will arrive at the recovery site within 24 hours of departure from its staging location. The OST will possess a minimum liquid storage capacity of 287,100 bbl (45,645 m 3 ), sufficient capacity to store all recove red liquids (oil and emulsified oil/water) from a 30-day blowout. At hour 24, the anchor handler, Tor Viking, or a similar vessel, with a minimum storage capacity of 3,200 bbl (509 m 3 ), will be available to relieve the OSRV to lighter its recovered
fluids to the OST. The OSRV and anchor handler will work in conjunction to sustain containment and skimming operations and transfer re covered fluids to the OST for the duration of the response.

An ice-strengthened Oil Spill Response Barge (OSRB) w ith skimming capability, with an associated tug, will be located in the nearshore zone and possess capacity to mobilize prior to earliest projected time oil
could arrive in the Chukchi nearshore zone. The OSRB would possess storage capacity of 18,636 bbl (2,963 m 3 ) for recovered liquids. It will also carry response equipment, including a 47-ft (14-m) skimming vessel, 34-ft (10-m) workboats, mini-barges, boom and duplex skimming units for nearshore recovery and possibly support nearshore protection. The OSRB will carry designated response personnel and will mobilize to recovery areas, de ploy equipment and begin operations.

c) Name(s) of spill removal organization(s) for both equipment and personnel

Alaska Clean Seas (ACS) is Shell’s primary response action contractor for the Chukchi Sea spill response program. ACS would lead the spill response effort s in the offshore, nearshore, and shoreline environments. ACS’s response personnel and oil spill response equipment would be maintained on2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 48 July 2009 15276-03-09-001A/09-011A Rev. 1 standby while critical drilling operations into liquid hydrocarbon bearing zones are underway and provide offshore, nearshore, and shoreline response operations in the unlikely event of an actual oil spill incident. Additionally, ACS provides program oversight, spill management team support, response training, and additional responders through Auxilia ry Contract Response Teams (ACRT), North Slope Spill Response Team (NSSRT), and Village Response Teams (VRTs).

Shell provides dedicated response vessels, skimmers , and equipment for the nearshore and offshore operations. Response activities will be conducted using Shell or ACS t actics as defined in the Shell’s Beaufort and Chukchi Seas Regional Tactics Manual and/or ACS’s Technical Manual , or otherwise as
defined in the ODPCP.

d) Calculated volume of worst case di scharge scenario [30 CFR 254.26(a)]

The calculated volume of a WCD scenario is provided in Table 8.d-1.

TABLE 8.d-1 A Calculated Volume of a Worst Case Discharge

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

Total Worst Case Discharge (Daily Volume X 30-day Duration of Blowout) 165,000 30 CFR 254.47(b)

Total Storage Capacity Requirements (165,000 x 1.54) +

(165,000 x 20%) = 287,100 ADEC Guidance

Notes: AAC = Alaska Administrative Code ADEC = Alaska Department of Environmental Conservation CFR = Code of Federal Regulations

e) Description of worst case discharge scenario

Under the requirements of the MMS, the plan mu st include a WCD scenario. For exploration or development drilling operations, the WCD scenario is equal to the daily volume possible from an uncontrolled blowout for period of 30 days. The WCD sc enario also was developed to address the ADEC regulations (18 Alaska Administrative Code [AAC] 75. 434) that require the Response Planning Standard volume to be 5500 bbl (874 m 3 ) of oil per day (bopd) for an exploration facility for fifteen (15) days duration. In order to address MMS and ADEC juri sdiction, the total WCD planning volume was based upon MMS’ planning requirement for a 30-day blowout using ADEC’s 5,500 bopd, resulting in a WCD scenario volume of 165,000 bbl (26,233 m 3 ) of oil during the 30 days. For storage purposes, an emulsion factor of 1.54 and a percentage of free water (20 pe rcent) have been added to the initial WCD of 165,000 bbl [(165,000 x 1.54 = 254,100) + (165,000 x 0.20 = 33,000) = 287,100] for a total storage volume of 287,100 bbl (45,645 m 3 ). The entire WCD scenario can be found within Section 1.6.13 of the ODPCP.

f) Modeling Report

The WCD scenario is based upon a spill simulation model of a 5,500 bopd well blowout at the seafloor (or mudline) in the Burger Prospect at Latitude 71  16’ 37.2”, Longitude 163  19’ 48.0”, the site of the historical Burger well (SWEPI OCS-Y-1413 #1), in a pproximately 138-144 ft (42 - 44 m) of water. Modeling of the oil plume trajectory was conducted by Applied Science Associates, Inc. (ASA), using historical wind data and the MMS hydrodynamic o cean-ice current model. The ASA trajectory model2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 49 July 2009 15276-03-09-001A/09-011A Rev. 1 includes algorithms for spreading, evaporation, emulsi fication, and entrainment, all of which are input parameters based on the properties of an Alaska North Slope crude oil with an API gravity of 30.6°.

The ASA’s OILMAP software was us ed to run the trajectory model based on environmental conditions including predominate winds and currents. Oil on th e ocean’s surface is assumed to move as the sum of vectors: surface currents plus 3.5 percent of the wind speed in the downwind direction. Oil plume migration is driven by ocean currents and prevailing winds for the 30-day durati on of this scenario. Wind data used for the trajectory modeling were collected by Shell from 22 locations in the Chukchi Sea during June through November for the years 1980, 1982, and 1983. Data from these three years were used for stochastic modeling. Wind data for the period of August 7 to September 6 was used in the trajectory modeling.

Based upon the collected data, the offshore winds origin ated from the northeast to southeast 54 percent of the time and the northwest to southwest 23 percent of the time during the June through November period. Three predominant wind directions had a measured freque ncy of occurrence greater than 10 percent of the time originating from the northeast (NE), east-north east (ENE) and east (E) based upon the 16 cardinal compass directions. These three wind directions on av erage occurred at the following frequencies for the June through November period:

 ENE wind = 14.6 percent frequency

 NE wind = 13.8 percent frequency

 E wind = 13.0 percent frequency

The trajectory simulation uses a subsea blowout risi ng through the water column and surfacing above the well location. The trajectory simulation moves and spreads the oil under the influence of local winds measured at the closest station for the August 7 to September 6 time period and the MMS ocean-current
information.

The trajectory analysis revealed that the oil plume would move away from shorelines in a southwesterly direction. From Day 1 through Day 3, the oil moveme nt is directed by winds predominantly from the NE and the predicted current. Through Day 12, the oil move ment is to the southwest away from land. If not intercepted by containment and recovery operations, oil is predicted to begin drifting to the northnortheast (NNE) and toward shorelines by Day 14. If unr ecovered, the earliest oil is predicted to potential contact with shorelines is Day 25 in the area be tween Peard Bay and Kasegaluk Lagoon (Figure 1.b-1). Following Day 25, oil would continue drifting to the NE toward open ocean north of land.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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Shell Gulf of Mexico Inc. 51 July 2009 15276-03-09-001A/09-011A Rev. 1 SECTION 9.0 ALASKA OUTER CONTINENTAL SHELF PLANNING INFORMATION

a) Emergency Plan

The following emergency plans and documentation re garding spill prevention and response actions are
included in the ODPCP that will be submitted to MMS as a separate document, concurrent with this EP:

 Response Action Plan

 Emergency Action Checklist

 Reporting and Notification

 Safety

 Communications

 Deployment Strategies

 Response Strategies

 Non-mechanical Response Options

 Prevention Plan

 Prevention Inspection & Maintenance Program

 Bulk Storage Containers

 Command System

 Best Available Technology

b) Critical Operations and Curtailment Procedures

See Attachment 9.1 for a description of the proposed COCP and Attachment 9.2 for a description of the proposed IMP. These plans are complementary documen ts that address the methods by which Shell will cease, limit, or not initiate specific critical opera tions due to environmenta l conditions that may be encountered at the exploratory drill site. However, the scope of the IMP is limited to approaching hazardous ice and its potential eff ects on drilling operations and the Discoverer safety. A detailed COCP and IMP will be submitted with Application for Pe rmit to Drill (APDs) before drilling operations are
initiated at the drill sites.

c) Well Control Plan

An outline of Shell’s well control plan is provided in Attachment 9.3. Well control is the process of maintaining hydrostatic pressure in the drilled wellbor e in a manner that prevents gas or fluids from underground reservoirs escaping from the we llbore in an uncontrolled manner.

d) Fuel Transfer Plan

Shell has prepared a Fuel Transfer Plan that covers activities with its planned exploration drilling program in the Chukchi Sea. A copy of the plan is provided in Attachment 9.4. The Fuel Transfer Plan outlines the procedures used to transfer fuel from v essel-to-vessel, drillship-to-vessel, and dock-to-vessel.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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## Attachment 9.1

Critical Operations and Curtailment Plan
Chukchi Sea 20102010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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Shell Gulf of Mexico Inc. 55 July 2009 15276-03-09-001A/09-011A Rev. 1 Critical Operations and Curtailment Plan
Chukchi Sea 2010

Introduction

The primary purpose of this COCP is to minimize the likelihood of an incident while occupying drill sites in the Chukchi Sea to protect personnel, equipment a nd the environment. Prior experience in the mid1980’s reveals that drilling operations can be interrupted for a variety of reasons. Some factors affecting
curtailment include:

 Adverse sea ice movement, weather conditions, sea states, and other environmental conditions that add risk to ongoing operations

 Time requirements for bringing support vessels to b ear on a particular issue, especially oil spill response equipment

 Loss of ice management vessels due to mechanical malfunction or assignment of the vessel to another area for some reason (rescue, supply/logistics support, etc.)

 Communication loss between vessels and between vessels and the shorebase

This plan identifies certain drilling activities designate d as critical operations and details plans to delay, limit or cease these operations when hazards devel op with the potential to harm personnel, damage vessels, equipment or the well, or result in a spill that could adversely impact the environment. This COCP establishes a decision-making process with clear lines of authority, responsibility, and accountability for successfully handling critical operations.

A companion plan to the COCP is the IMP, which d eals with ice alert levels, well suspension operations, mooring recovery, and well reentry activities associated w ith ice hazards in the Chukchi Sea. No critical operation will be started or continued, if already in progress, until the time required to perform the task is properly determined under the circumstances and that time is deemed to be less than the time available for safe operations before a serious hazard develops.

This COCP satisfies 30 CFR 250.417 (e) as required for a “floating drilling unit contingency plan for moving off location in an emergency situation.” No c ontingency plan is expected to cover all conceivable situations and circumstances. This plan is not intended to be a substitu te for good judgment and experience in dealing with the unexpected situation.

Critical Operations

Certain drilling operations are more likely than others to result in conditions that could lead to a well
control incident or other incident that could result in harm to people, assets or the environment. This is particularly so when subsurface formations capable of flowing formation fluids into the wellbore are exposed, or when the well has been pressured by outside means.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 56 July 2009 15276-03-09-001A/09-011A Rev. 1 Planned Critical Operations

These operations are those that can reasonably be expected to occur during the planned 2010 drilling program in the Chukchi Sea. Planned critical operations include, but are not limited to:

 Drilling into a zone capable of flowing oil and/or gas

 Conducting certain procedures in a well where zo nes capable of flowing oil and/or gas are exposed or are anticipated of becoming exposed such as:

– Continuing to drill after a well-related event (e.g. a kick)

– Coring (whole or sidewall cores)

– Pulling the drill string out of the hole

– Wireline logging in the open hole

– Running casing, circulating and cementing

– Conducting well control operations (e.g., circulating a kick out of the hole)

Not all of these planned critical operations will n ecessarily be conducted on each drill site during the drilling campaign. Data collection and testing re quirements will vary from drill site to drill site depending on previous results from offsets and th e defined exploration objectives for each drill site.

Unplanned Critical Operations

Several operations are not planned in the normal course of drilling exploration drill sites, but could be required. If these operations increase the risk of harm under the circumstances existing at the time, they could be curtailed. Such operations could include:

 Fishing for lost items in the well

 Cutting and pulling casing/milling casing window

 Open hole sidetracking

 Perforating

 Well completion work

 Remedial well work

 Formation stimulation

Other Potentially Critical Operations

These are operations that could be considered critic al depending on the well status and conditions at the
time:

 Moving back over a drill site after an emergency evacuation

 Reentering a suspended or temporarily abandoned well

 Anchor line tensioning

 Accidental or unintentional riser disconnecting

 Unintentional oil or fuel spill

 Heavy load lifting and handling during resupply activities

 Refueling

 Shipboard fire

Should these conditions be encountered, operations may be curtailed while dealing with them using safe methods and procedures. Again, good judgment is the key for dealing with such situations.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 57 July 2009 15276-03-09-001A/09-011A Rev. 1 Circumstance/Conditions Requiring Curtailment

Several situations may exist under which critical drilli ng operations may be term inated, limited, or not commenced. These are listed and discussed briefly below:

Severe Weather

Wind and sea states can affect vessel motion (e.g., h eel, pitch, roll, and heave) beyond safe operating limits and/or create conditions that make certain opera tions unsafe. Wind and currents can also result in
ice movement that creates an unsafe condition for the vessel.

The Discoverer is equipped with a turret-mounted mooring system that allows the bow of the vessel to be turned into the wind while the mooring system, bl owout preventor (BOP) and marine riser system maintain a constant orientation with respect to the seafloor. This reduces hull exposure to maximum wave features which, in turn, reduces heel, pitch, a nd roll. This feature also provides the minimum hull cross-section exposure to ice that may be driven by wind and currents toward the vessel. Because of hull configuration, heave may be reduced as well due to compensating sea conditions (e.g., roll or chop from another direction).

Conditions for curtailment activities will depend on the performance of the drillship in the open water of the Chukchi Sea. The drillship behavior will be thoroughly analyzed upon mooring on the first drill site, and it will be reevaluated as needed during drilling oper ations. Thresholds will be established for weather
and sea conditions that will control:

 Equipment preparation to curtail operations

 Ceasing drilling

 Hanging off drill string

 Disconnecting riser

 Moving drillship off the drill site

Sea Ice

Ice conditions that impact drillship station-keeping limitations (e.g., maximum horizontal displacement off well center) or endanger the vessel hull will lead to curtailment of critical operations. Ice Alert Levels outlined in the IMP define remaining time available fo r action before the arrival of hazardous ice. This limits the time available for certain operations. If there is insufficient time to complete a critical operation, or if a routine operation becomes critical before the arrival of the ice hazard, curtailment will be required.

Sea Spray

Freezing precipitation or sea spray on the vessel can affect the Vertical Center of Gravity and possibly destabilize the drillship. Wind exacerbates the situa tion by increasing ice accumulations on the windward side of the drillship. Such ice loading could lead to curtailment of critical operations. Prediction of ice loading under adverse conditions is required to de termine whether certain operations can begin or
continue before this hazard becomes acute.

Unavailability of Materials, Personnel, and Equipment

Curtailment of critical operations may involve any of the following, or combinations thereof:

 Limited availability and/or capability of cr itical oil containment and cleanup equipment2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 58 July 2009 15276-03-09-001A/09-011A Rev. 1  Increase in oil spill contro l system response time

 A lack of trained personnel or equipment fo r conducting a particular critical operation

 Insufficient supply of drilling mud materials at th e drill site for emergency well control purposes

 Transportation for personnel, supplies and oil spill containment and cleanup equipment is not readily available

 Well control equipment, marine safety systems, fire detection, fire fighting or any other health, safety, security, and environment (HSSE) critical systems that are inoperable or do not meet
minimum standards

 Loss of ice support vessel(s)

 The absence of critical information and/or communications (e.g., ice data, weather forecasts, logistics)

Well Control

Critical operations, other than efforts to restore prim ary well control, will not be undertaken during a well control event (e.g., drilling will cease pending circulati on of a kick out of the hole and adjusting mud density to prevent further kicks from entering the wellbore).

Time Requirements

The time required to cease operations, secure the well, ma ke the drillship ready to move off the site, and recover moorings is discussed for ice hazards in th e IMP. Similar time estimates must be made for crucial operations to determine the margin available for dealing with all hazards including approaching
hazardous ice.

Secure Time (ST)

This is defined as the time, in hours, required for crews to cease drilling operations and to temporarily abandon the well in a way that prevents leakage of hydrocarbons into the water column, regardless of how long the well will be suspended before op erations can resume in the future.

ST varies and depends on the type of operation in progr ess at the time drilling is suspended. For example, if drilling is in a zone capable of producing hydro carbons, the time required to pull out of the hole with the drillstring must be tempered by the maximum pipe speed to avoid swabbing a kick into the wellbore. It is also impacted by the method selected for susp ending the well. If plugs are to be set, either mechanical or spotted cement slurries, ST will be greater than if the drillstring is dropped in the hole or the pipe is severed using the blind/shear rams (gen erally considered to be the worst case scenario).

Methods for suspending the well are detailed in the IMP. Regardless of which technique is selected, estimates of the time required to suspend the well ar e experienced-based and must be conservative to
allow for unforeseen circumstances. The Shell Dril ling Foreman is responsible for estimating ST and providing it to the Offshore Installation Manager (OIM).

Move-off Time (MT)

MT is defined as the time, in hours, required to di sconnect from the subsea BOP, recover the riser and lower marine riser package (LMRP), safely store all items aboard the vessel, recover moorings, and make the vessel ready to evacuate the site.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 59 July 2009 15276-03-09-001A/09-011A Rev. 1 MT, like ST, varies considerably depending on a number of circumstances including sea state, weather conditions, the type of hazard involved, and the method selected for mooring recovery. Horizontal displacement of the drillship from the wellbore centerline may complicate release of the LMRP. Inadequate time available for recovering anchors usi ng conventional means may re quire activation of rig anchor releases (RARs) or allowing anchor wires to spool off winches. These methods are also detailed
in the IMP.

The Frontier Marine Supervisor is responsible fo r estimating MT and providing it to the OIM. MT estimates, like ST estimates, must be conservative allowing for uncertainties.

Total Time (T-Time)

T-Time is the sum of ST and MT, and it is defined as the time required, in hours, to cease operations and be ready to move off the drill site.

Hazard Time (HT)

HT is the time, in hours, until the arrival of the ha zard, regardless of type, at the drill site. The IMP outlines how the arrival of ice hazards are predic ted based on observations of ice features by Ice Specialists on support vessels and the Ice Observer on the drillship combined with ice and weather predictions provided by Shell’s Ice and W eather Advisory Center in Anchorage.

Other hazards discussed above are predicted using a variety of sources including the Ice and Weather Advisory Center, MMOs, and observation of sea, weathe r, and spray ice conditions aboard the vessel, and other information. The early arrival of the hazard at the vessel should be anticipated. Observation and reporting frequency from all sources must increase as HT decreases to ensure that appropriate measures can be employed at the drill site to protect people, equipment, and the environment. Mathematically, TTime must always be less than HT.

Curtailment Decision Process

The decision process for dealing with ice hazards is addressed in the IMP. The decision process for dealing with emergencies is in the drillship operations procedure, a copy of which is kept on the drillship for reference. In every case, the MMS will be include d in the process and will be kept informed of all operations, alerts, and decisions through verbal communications and written reports.

Key Personnel

The following personnel have a significant role in de termining when and how curtailment of crucial operations is to be undertaken:

 OIM

 Shell Drilling Foreman

 Frontier Marine Supervisor

 Frontier Drilling Supervisor

 Ice Advisor

Together, this group constitutes the Vessel Management Team (VMT). This team ensures that all inputs from various data sources are considered in making a decision to curtail operations. Defining certain drilling operations as critical operations and curtailing these critical operations in the face of approaching2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 60 July 2009 15276-03-09-001A/09-011A Rev. 1 hazards rests primarily with the Shell Drilling Foreman with inputs from the Shell Drilling Engineers, Shell Drilling Superintendent and Well Delivery Manager.

Curtailment Decision Protocol

The curtailment decision process is su mmarized in the following steps:

 The Shell Drilling Foreman will anticipate operations and, with advice on hazard type, severity and arrival time, will determine which operations on the drill site will be defined as Critical Operations. He will then estimate the time to be gin such operations if they are not already in

progress.

 The Shell Drilling Foreman, with the concurrence of the Shell Drilling Superintendent, will determine what operations will be curtailed. This decision will incorporate input from the VMT
and will have the concurrence of the OIM.

 A suspension procedure will be selected by the Shell Drilling Foreman and approved by the Shell Drilling Superintendent. The Shell Drilling Supe rintendent will document the procedure and submit it for approval to the MMS RS/FO. The Shell Drilling Foreman will estimate ST and provide it to the OIM and VMT.

 The Shell Drilling Foreman will estimate ST and provide to the OIM and VMT.

 The Frontier Marine Supervisor will determine the move-out procedure. An estimate of MT will be made and provided to the OIM and VMT.

 The well will be suspended and the drillship made ready to move out as the hazard continues to be observed. The OIM will ultimately make the decision to move the vessel to a safe location until the hazard has passed. The decision to move b ack to the drill site will be made jointly by the VMT with the concurrence of the OIM and upon approval of the MMS RS/FO.

 The decision to execute an emergency well suspensi on due to an unanticipated acute hazard (e.g., well control incident, shipboard fire) and the pro cedure selected to do so (e.g., drop drillstring, cut the drillpipe) will be made by the Shell Drilling Foreman. Once the well is suspended, the Frontier Marine Supervisor will make the drills hip ready to move, if necessary, with the concurrence of the OIM. The MMS Field Repres entative, the Shell Drilling Superintendent, and the MMS RS/FO will be notified as soon as practicab le after the vessel has been made safe.

Training

All personnel will be made aware of their roles and responsibilities described within this COCP through a training program to be taught before the vessels are on site. All persons with a key position in the COCP will be provided a copy of this document, and traini ng will be provided by Shell prior to deployment. This training will include a table-top exercise that will be carried out prior to initiating operations in the
Chukchi Sea.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 61 July 2009 15276-03-09-001A/09-011A Rev. 1 

## Attachment 9.2

Ice Management Plan Outline
Chukchi Sea 20102010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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Shell Gulf of Mexico Inc. 63 July 2009 15276-03-09-001A/09-011A Rev. 1 Ice Management Plan Outline
Chukchi Sea 2010

Introduction

The following is a summary of Shell’s IMP for its planned drilling program in the Chukchi Sea during
2010. A detailed IMP will be subm itted along with APDs for drill sites and will contain current information pertinent to the drilling program at the time of submission.

The purpose of the IMP is to define methodologies neces sary to identify, monitor, and mitigate ice-related hazards that might be encountered during drilling ope rations in the Chukchi Sea. It ensures an appropriate phased response to current or anticipated i ce hazards at the drill site. If ice conditions become severe it may not be prudent or practical to keep the drilling vessel moored at the site. When this occurs, techniques have been developed to suspend drilli ng operations, secure the well, recover mooring equipment, and move the drilling vessel to a safe area until the hazard is past.

No contingency plan can anticipate all conditions a nd circumstances, and this IMP is not expected to cover all possible situations that could occur. Ho wever, it does contain firm guidelines for dealing with most ice-related hazards. Sound ju dgment and discretion by management are the best protection for vessels and crews in mitigating these hazards.

The IMP and the COCP are complementary plans with similar structures. The IMP is limited to approaching hazardous ice and its potential effects on drilling operations and drilling vessel safety.

Ice Detection and Monitoring

Shell’s IMP relies heavily on the observations and expe rience of its Ice Specialists and Ice Advisors, a group of arctic-seasoned mariners whose sole duty is to provide critical information and advise drilling vessel supervisors and the drilling vessel master about any and all ice-related threats. These observers
and advisors will be stationed on the drillship, the ice management vessel and the anchor handler.

Ice and weather forecasting is provided by Shell’s Ice and Weather Advisory Center. This center is continuously manned by experienced personnel who rely on number of data sources for ice forecasting and tracking including:

 Radarsat and Envisat data – satellites with Sy nthetic Aperture Radar providing all-weather imagery of ice conditions with very high resolution

 Moderate Resolution Imaging Spectroradiometer – a satellite providing lower resolution visual and near infrared imagery

 Aerial reconnaissance – provided by specially deployed fixed wing or rotary wing aircraft for confirmation of ice conditions and position

 Reports from Ice Specialists on the ice manageme nt vessel and anchor handler and from the Ice Observer on the drillship

 Incidental ice data provided by commercial ships transiting the area

 Information from the National Oceanographic a nd Atmospheric Administration ice centers and the University of Colorado

Ice Alert Levels and Actions

Ice alerts are linked to the time predicted for an ice f eature to drift to the drill site, the time required to secure the well, and the time required to make the drilli ng vessel ready to move off the site if it becomes necessary to do so. Actions and responsibilities of va rious managers involved w ith operations depend on
the ice alert level.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 64 July 2009 15276-03-09-001A/09-011A Rev. 1 Definitions

Hazardous Ice – any ice feature that is considered a threat to the continued safe operation of the drilling vessel

Ice Alert Level – a color-coded hazard category that depends on the time necessary to secure the well and to prepare the drilling vessel to move to a place of safety in the face of a confirmed ice
incursion

HT – the time, in hours, until a h azardous ice feature reaches the drill site

ST – the time, in hours, required to cease drilling oper ations and to temporarily abandon the well in a way that prevents leakage of hydrocarbons into the water column, regardless of the time required to resume operations in the future

MT – the time, in hours, required to disconnect from the well and pull the riser, recover moorings, and secure all equipment on the drilling vessel so that it can be moved to a place of safety

T-Time – the sum of ST and MT; the total time , in hours, required from cessation of drilling operations until the drillship vessel is re ady to move off the drill site

Ice Alert Levels

The following table defines each of the five Ice Alert Level categories:

ALERT
LEVEL TIME CALCULATION ACTION

Green (HT – T-Time) greater than 24 hrs Normal operations

Yellow (HT – T-Time) 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 Limit 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 drilling vessel to a safe location

Personnel and Responsibilities

Definitions

Ice Advisor – arctic-seasoned mariner with experience in ice responsible for coordinating and disseminating ice information to personnel responsible for drilling and marine operations on the drillship vessel; rotates with Ice Observer to ensure continuous ice information handling

Ice Observer – assists Ice Advisor and makes near drillship visual ice observations and reports accordingly; rotates with Ice Advisor to ensure continuous ice information handling

Ice Specialist – Shell’s representative on ice management vessel and anchor handler responsible for reporting ice observations and reporting these to the Ice Advisor along with time estimate for
arrival of ice at drill site2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 65 July 2009 15276-03-09-001A/09-011A Rev. 1 Ice Management Vessel Master – captain/master of ice management vessel or anchor handler responsible for mitigating ice features that are or could become hazardous to the drillship and other vessels; receives instructions for such operations from the OIM

OIM - Offshore Installation Manager or Person-in-C harge of the drillship, master of the vessel with ultimate responsibility under maritime law for the safety of the drillship and its crew; responsible for moving the drillship to a safe site an d for returning it to the drill site when the ice hazard has passed

Marine Supervisor – Frontier employee responsible fo r marine operations on the drillship including mooring, ballasting, and safely opera ting the vessel under a variety of conditions; responsible for estimating the time required to move off the drill site after the well is secure (MT)

Drilling Supervisor – Frontier employee responsible for supervising drilling crews and support personnel operating the drillship a nd other equipment required for drilling operations; works with Shell Drilling Foreman in securing the well in the event of an impending ice hazard

Shell Drilling Foreman – the senior Shell manager aboard th e drillship responsible for overseeing drilling and other drill site operations; the Ons ite Incident Commander for spill or well control response; responsible for ordering suspen sion of drilling operations, securing the well and estimating the time required to do both (ST); also responsible for well re covery operations when the drillship returns.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 66 July 2009 15276-03-09-001A/09-011A Rev. 1 Organization Chart The following chart depicts the organization of key personnel in the execution of the IMP aboard the drillship:

Well Suspension and Re-entry Procedures

The Shell Drilling Foreman, with the assistance of Sh ell’s Drilling Engineers, is tasked with preparing procedures for suspending the well in the face of an impending ice hazard and fo r re-entering the well when the threat has passed. All procedures will be reviewed and approved by the MMS RS/FO or his designated representative. The following list includes, but is not limited to, well procedures that will safely seal the well during the period when the ice h azard interrupts drilling operations and will allow reentry with minimal risk to the drilling vessel or personnel.

Suspension Procedures

Suspending the well must be performed using MMS-a pproved procedures that ensure that the well cannot leak during the time the well is suspended. It s hould be understood that weather and ice conditions may not permit well re-entry until a subsequent year’s drilling season, so the well may have to remain suspended for several months if not a year or more. The following are some of the procedures that can be used to secure and suspend a well:

Plugging – setting mechanical and/or cement plugs in portions of the well with heavy kill-weight mud in the remainder of the wellbore to provide a long lasting seal preventing the migration of
fluids from a reservoir into other zones or into th e water column. Sometimes, this method is used to permanently abandon the well wh en the objectives have been fulfilled, but it is desired to leave
the well such that it can be re-entered in the futu re. Recovery of the entire BOP stack is possible OIM Drillship

Frontier Marine Supervisor Frontier Drilling Supervisor Shell Drilling
Foreman Ice Advisor/ Ice
Observer

Drilling
Crewmembers Marine
Crewmembers Ice Specialists

Ice Management Vessel
Masters2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 67 July 2009 15276-03-09-001A/09-011A Rev. 1 in this scenario; however, if the well is only par tially plugged, the drillstr ing is often suspended and the lower portion of the BOP stack is left over the hole.

Drillpipe hang-off – the preferred means by which to su spend a well for a temporary suspension of drilling activities. This requires locating the drillpipe within the cased hole section, and inserting a special sub in the top of the string that seats in the wellhead bowl section. Drillstring weight is transferred to the hang-off sub, then the pipe above is disengaged and withdrawn from the wellbore. Hang-off normally occurs after a hydrostatic plug or mechanical plug has been set to secure and isolate potentially pressured formation in tervals. In the alternative, the drillpipe can be suspended using a packer that is set in the upper portion of the well. The portion of the string above this “storm packer” is then withdrawn a nd the blind/shear rams are closed to provide a secondary seal.

Pull out of hole – withdrawing the drillstring from the well and then securing the well by closing the BOP’s blind/shear rams to provide a secure seal. It is common to set one or more hydrostatic fluid pills (e.g., heavy weight mud, high-viscosity mud, barite plugs, etc.) or mechanical plugs to secure and isolate all potentially pressured formation in tervals prior to this operation. It is usually preferred to leave some drillpipe suspended for well control purposes to f acilitate re-entering the well when the drilling vessel returns.

Shearing the drillpipe – mechanically severing the pipe using the BOP’s blind/shear rams and for immediate pipe withdrawal from the riser followe d by releasing the LMRP and pulling the riser. This is generally considered a last resort since the top of the drillpipe remaining in the hole is damaged and it is not practical to pump flui d down the pipe for well control purposes.

Dropping the drillpipe – releasing the string and allowing it to fall in the hole without cutting the string. This procedure does not leave a damaged to p to the drillstring remaining in the hole, so recovery of the pipe is simplified. The blind/sh ear rams in the subsea BOP stack provide the seal along with any heavy mud volumes that were placed in the well prior to dropping the string.

Re-Entry Procedure

The decision to move back to the drill site after the ice hazard has passed requires working through the same alert levels and using similar decision-making procedures as those employed for evacuating the drill site but in reverse sequence. The decision to return to the drill s ite is dependent on high quality ice forecasts and experienced marine and drilling personne l who are able to assess the various parameters properly and determine the practicality of the decisi on with due dispatch. Th e sequence followed depends on the following:

 Maximum expected wellbore pressure below the BOP rams (if any)

 Isolation and control of potentia l trapped pressure between pipe and blind/shear rams (if any)

 The potential of a packer or plug release

 Difficulties involved in reconnecting to the drillstring left in the hole

 Circulating kill weight fluid upon re-establishing a circulation path

 Conducting a flow check after opening the wellbore

Re-entry of the well can only proceed when it is sa fe to do so and with the concurrence of the MMS RS/FO or his designated representative.

The following procedure is generally followed once the drillship is back over the hole and moored correctly:

 Guidelines are reinstalled to the guidepost tops. A diver or remotely operated vehicle is jumped to inspect the top of the BOP stack and the H-4 connector for damage.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 68 July 2009 15276-03-09-001A/09-011A Rev. 1  The LMRP and riser are run. The H-4 connector is engaged and locked.

 Communication with the BOP is re-established and the stack is checked for proper operation. If the well was suspended using a hang-off sub, th e BOP stack can be pressure tested against the sub. If a storm packer, other mechanical plug, or cement plugs were used to suspend the well, a test plug can be run and seated below the BOP stack allowing it to be pressure tested. Other suspension methods (i.e., shearing or dropping the drillstring) may require other methods of testing the BOP stack.

 The Shell Drilling Foreman, working with Sh ell Drilling Engineers and the Shell Drilling Superintendent, will prepare a re-entry procedur e and submit it for approval to the MMS RS/FO taking into account how the well was suspended. The integrity of all drilling systems, surface and subsea, must be confirmed before re-establis hing communication with the wellbore below the
BOP.

 The procedures for returning and re-entering the well are to be documented for submission and approval by the MMS.

 Continue with normal drilling operations.

 Resume ice-monitoring protocols, determine the current Ice Alert Level and re-institute normal ice management procedures.

Mooring System Recovery

Following are procedures to recover the mooring system in response to a hazardous ice event. Detailed procedures are contained in the marine operations manuals for the drillship and support vessels. Support vessels will receive mooring system recovery instructions from the master of the drillship. There are three primary options for marine mooring release. They vary from a routine release involving common anchor recovery methods and time requirements to a very short period of time for emergency release and drive off. The use of any of these options is dete rmined by the severity of the emergency and adverse conditions that could impact the vessel.

Conventional Anchor Recovery – retrieving all anchors using the anchor handling vessel. Anchors and mooring lines are handed back to the drillship in a normal manner. This recovery technique leaves all mooring equipment intact for later deployment when the drillship returns to re-enter the well and it is the recommended practi ce under most situations. The time required for the recovery sequence is greater than the other procedures available, however.

RAR Activation – acoustically activating a device that releases the anchor allowing the remaining mooring lines to be winched back aboard the drilling vessel leaving the anchors “cold stored” until they can be retrieved. This procedure provides a very short departure time in the event of an imminent ice threat to the drillship.

Running Anchor Wire Off Winches – similar to the RAR activation, this procedure involves spooling the mooring lines off the winches leav ing the entire mooring equipment set on the seafloor for later recovery. This contingency is employed when there is insufficient time to conventionally recover the mooring system and/or th e RARs fail to function. This is used when
the ice threat is imminent and there are no othe r means for releasing the drillship vessel from its moorings.

The selection of a specific release option and th e execution of the procedure depends on the time available before the ice hazard approaches the drillshi p. The Marine Supervisor is tasked with the procedure selection and execution with the concurre nce of the OIM. Clearly, the well must be secure and the riser disconnected before the drillship can be released.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 69 July 2009 15276-03-09-001A/09-011A Rev. 1 Training

All personnel will be made aware of their roles and responsibilities within this IMP through a training session each year upon deployment to the drill site. This training will include a Table Top Exercise, which will be executed prior to beginning operations. The exercise will provide exposure to and testing of communications, well suspension and mooring rec overy procedures, management decision-making system and well re-entry procedures. Highlights of the training session, including worker attendance, times, subjects covered and feedback will be captured for future training sessions.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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## Attachment 9.3

Well Control Plan Outline
Chukchi Sea 20102010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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### Chukchi Sea 2010

Well control is the process of maintaining hydrosta tic pressure in the drilled wellbore in a manner that prevents gas or fluids from underground reservoirs es caping from the wellbore in an uncontrolled manner.

Shell believes that no single operational error or equi pment failure should lead to loss of well control. Therefore, Shell will apply the following layers of prevention and response to avoid well control issues:

 Layer I - includes proper well construction, risk id entification, training, scheduled tests and drills on the rig (e.g., BOP tests, pit drills, and trip drills), all of which build a strong foundation for problem avoidance.

 Layer II - includes early kick detection and timel y implementation of kick response procedures. Continuous monitoring including the use of comput erized pit volume monitoring, return flowrate detection, returned drilling fluid analysis and da ta sharing with Shell’s Real Time Operations Center provide early kick detection. When a kick is detected, the general response is to immediately shut down the pumps, perform a flow ch eck, shut in the well, and kill the flow using one of several methods that prevent the situa tion from escalating into a blowout (an uncontrolled flow to the surface).

 Layer III - involves the use of mechanical barriers, including, but not limited to, blowout preventers, casing, and cement. Testing and insp ections are performed to ensure competency.

 Layer IV - incorporates relief well drilling and blowout kill operations that would be implemented if all other kick control methods fail.

In the unlikely event that well control is lost d espite these precautions, Shell will immediately mobilize specialized emergency response person nel and equipment to the site. She ll will also consult a well control specialist such as Wild Well Control for the interven tion and prompt action to resolve the emergency.

Surface Control Options

If well control is lost, every effort will be made to regain well control using dynamic surface control measures. Historically, these measures of regaining c ontrol have been rapid and effective. However, uncontrolled flow at the surface presents a safety hazard. Safety procedures are employed to protect personnel, the environment, and e quipment. A site assessment is c onducted, safe access and work plans are created, and uncontrolled fluids are diverted for collection to create a safe environment to minimize
releases to the environment.

Although the specific surface control methods used will depend on the situation, potential mechanical surface control methods include the following:

 Induced natural bridging (or plugging) of the well

 Pumping mud, plugging material, and/or special fluids down the well to kill it

 Replacing failed equipment if control w as lost due to equipment malfunction2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 74 July 2009 15276-03-09-001A/09-011A Rev. 1 Relief Well

In the scenario developed for a blowout, the Discoverer will attempt to stop the blowout by pumping mud and/or some other specially formulated fluid down the hole. Should these efforts fail, the Discoverer will pull away to a drill site upwind and upcurrent from the blowout location and initiate relief well drilling operations. As a precautionary measure, relief well prep aration operations are initiated in parallel with surface or subsurface control methods being employed on the blowout well. Unless it is damaged, the
Discoverer can commence relief well drilling if intervention measures are unsuccessful.

The general strategy for killing a blowout using a relief well is to drill a specially designed well to intersect the blowout well at some point along its path , usually near the top of the source reservoir. Then, kill weight fluid is pumped from the relief well into the original wellbore at sufficient rates to stop formation fluids from flowing bringing the blowout well under control. Finally, both wells are properly plugged and abandoned using pro cedures approved by the MMS.

A relief well in this situation would not have a MLC and the Discoverer would be stocked with a second BOP stack, wellhead, casing, drillpipe, mud materials, a nd cement in sufficient quantities to at least start the relief well. Additional materials and supplies will be mobilized quickly to ensure that there are no delays in drilling the relief well and killing the bl owout. A detailed Relief Well Design is submitted to MMS as part of the Application for Permit to Drill for each planned exploration well.

Shell, MMS Operator Number 02117, is of sound financ ial strength and reliability and has demonstrated OSFR according to 30 CFR 253 for the facilities planned in the EP. This financia l reliability ensures that Shell has the capability to deal with all emergency situ ations such as blowout control including relief well drilling and kill operations if such an unlikely event should occur.

Relief Well Location and Timing

The optimum location for a relief well depends on several factors, including the depth and direction of the intercept point, personnel safety, and weather conditions. The location of the relief well is selected so that it can be drilled in the most efficient manner practicable.

The estimated total duration from the start of a bl owout to well killing through a relief well would be approximately 16 days for an 8,000 ft TVD blowout well and would be approximately 18 days for a 9,000 ft TVD blowout well depending on the depth of the inte rcept point. Often, relief wells intercept a deep blowout at some point above the TVD depending on flowrates, reservoir pressures and fluid types (oil, gas or salt water).

In general, all available resources are quickly accessed and funneled into drilling the relief well and killing the blowout as quickly as possible. Resupply of critical supplies and equipment, mobilization of specialized equipment and assignment of drilling personne l and well control specialists occurs rapidly in this emergency situation. Normal time require ments for planning and scheduling activities are compressed and deliveries are expedited. All reasonable and safe measures are employed to kill the blowout as quickly as possible.

Blowout Well Ignition

The decision to ignite a blowout will be made only after assessing the probability of implementing a successful surface control, reviewing potential safety hazards, addressing pertinent environmental considerations and obtaining necessar y agency approvals. Placing human safety as the highest priority, Shell will consider the feasibility and benefits of ig niting the blowout after all personnel, equipment, and2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 75 July 2009 15276-03-09-001A/09-011A Rev. 1 vessels have been located at a safe distance from the surfacing oil and gas. Ignition and sustained combustion of vapors from the surfacing gas and o il could potentially result in a safer working environment for relief well operators and for r esponders attempting to contain and recover oil downstream of the blowout. This decision may or may not result in the loss of the drillship; some subsea
blowouts have been allowed to burn on the surface to consume dangerous vapors and to reduce the volume of oil escaping from the area especially when th is oil could threaten relief well drilling operations.

Blowout Well Intervention

Many wells bridge over naturally within 24-48 hours of blowing out. The flowrate from other wells may drop over a few days due to near wellbore depletion or formation subsidence. In these situations it may be possible to re-enter the blowout well and use conventi onal well kill methods to regain control and secure the well against further flows. If this is possible, the Discoverer will move back over the blowout well when it is safe to do so, re-attach the LMRP and riser to the BOP remaining on the well, test all equipment to ensure its integrity, and run tools and e quipment into the blowout wellbore to affect a final
kill.

Often, the wellbore is damaged by the blowout to th e extent that it is no longer usable and permanent
abandonment is indicated. The decision to continue drilling operations or plug the well after such an intervention will be made in conjunction with the MM S. Drilling may proceed only if doing so would not introduce the risk of a subsequent blowout from the damaged wellbore.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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## Attachment 9.4

Fuel Transfer Plan2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 78 July 2009 15276-03-09-001A/09-011A Rev. 1 

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Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 1 of 21

The controlled version of this “contro lling document” resides online in Livelink® . Printed copies are UNCONTROLLED.Printed copies of this document areUNCONTROLLED. Destroy(RECYCLE)after use. 

## OPERATIONS STANDARD/PROCEDURE/GUIDELINE

DRAFT

Approval Approved for the Alaska Asset:

Shell Exploration & Production Company Signature Date

Kate Miner

Dwight Johnston

Rick Fox

Peter Slaiby

* Note * Original signed copy of this procedure is filed

Effective 1 April 2010

Compliance

1 April 2010

Expires Remains in effect until superceded or revised

Custodian Logistics Department, Alaska VentureShell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 2 of 21

The controlled version of this “contro lling document” resides online in Livelink® . Printed copies are UNCONTROLLED.Printed copies of this document areUNCONTROLLED. Destroy(RECYCLE)after use. Author Craddock-Melin, J. Lynn; Marine Contracts Manager, Alaska

ReviewersShell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 3 of 21

The controlled version of this “contro lling document” resides online in Livelink® . Printed copies are UNCONTROLLED.Printed copies of this document areUNCONTROLLED. Destroy(RECYCLE)after use. 

# Table of Contents

1. Introduction

1.1. Purpose 1.2. Applicability
1.3. Contingency Response Team
1.4. References
1.5. Responsibility
1.6. Exemptions

2. Fuel Transfer Operations

2.1. Applicability
2.2. Timing
2.3. Scheduling/Notification
2.4. Preparation Spill Response Equipment Booming Equipment
2.5. Planning
2.6. Termination of Fuel Transfer Operations
2.7. Ice Conditions
2.8. Completion of Fuel Transfer Operations
2.9. Declaration of Inspection

3. Appendices

3.1. Appendix A: Notification of Planned Fuel Transfer Operation Form
3.2. Appendix B: Advance Notification to U.S. Coast Guard – Offshore Fuel Transfer Operation
Form 3.3. Appendix C: Declaration of Inspection Form
3.4. Appendix D: Declaration of Inspection Form for CRT
3.5. Appendix E: Contact InformationShell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 4 of 21

The controlled version of this “contro lling document” resides online in Livelink® . Printed copies are UNCONTROLLED.Printed copies of this document areUNCONTROLLED. Destroy(RECYCLE)after use. 1. Introduction

1.1. Purpose

This document establishes special operating criteria to ensure that fuel transfers between vesselto-vessel, vessel-to-MODU and dock-to-vessel conduc ted as part of EPW’s operations in the Alaskan Venture fully comply with port stat e regulations as well as Minerals Management Service (MMS) requirements, including the use of booming vessels engaged in fuel oil transfer operations. This document will be applicable to EPW operations in Canadian waters as well as any other fuel transfer operations in Alaskan waters.

As fuel transfer operations present an elevated risk of fuel spills and potential environmental damage, it is imperative that transfer opera tions are conducted safely and that adequate response equipment is in place to provide for containment and recovery of any spilled fuel.

The MMS Lease Stipulations for Oil and Gas L ease Sale 193 in the Chukchi Sea (February 6, 2008) include the following provision:

Stipulation No. 6 - Pre-Booming Requirements for Fuel Transfers . Fuel transfers (excluding gasoline transfers) of 100 barrels or more will req uire pre-booming of the fuel barge(s). The fuel barge must be surrounded by an oil-sp ill-containment boom during the entire transfer operation to help reduce any adverse effects from a fuel spill. The lessee’s oil-spill-contingency plans must in clude procedures for the pre-transfer booming of the fuel barge(s).

1.2. Applicability

This document will be applicable to all EPW v essels operating in the Chukchi Sea, US Beaufort
Sea and the Canadian Beaufort Sea as well as an y other fuel transfer operations involving EPW
contracted vessels in Alaskan waters.

1.3. Contingency Response Team (CRT)

The Contingency Response Team (CRT) is an EPW assemblage of vessel and oil spill response assets including specifically trained individuals. This team will attend all fuel transfers that occur
in the Chukchi and Beaufort Seas when the MODU is operating in the Chukchi or Beaufort Seas. This team will provi de appropriate material a nd manpower as required by this document and their operating procedures.

When a vessel is engaged in fuel transfer operati ons in areas other than the Chukchi and Beaufort Seas but within the Alaskan Venture, the appropr iate local, state and federal fuel transfer regulations are followed with the addition that all vessels receiving or transferring fuel oil will be pre-boomed by the local facilities.Shell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 5 of 21

The controlled version of this “contro lling document” resides online in Livelink® . Printed copies are UNCONTROLLED.Printed copies of this document areUNCONTROLLED. Destroy(RECYCLE)after use. For all fuel oil transfers with in the Alaskan Venture, booming equipment shall be deployed as required by this document.

1.4. References

All vessels are subject to the appropriate port state control regulations for fuel oil transfers.

Fuel Transfer Operations will comply with

1.4.1. EP2005-0262, Manage Logistics – Marine Logistics HSE
1.4.2. EP2005-0262-SP-04; Bulk Transfer Operations
1.4.3. EP2005-0262-SP-05; Bulk Loading Hoses
1.4.4. OPS0011 – Marine Transportation Standard
1.4.5. OPS0011 – PR06 – Bulk Transfer Requirements (attached)
1.4.6. OPS0011 – TO.02 – Manual of Pe rmitted Operations (attached)
1.4.7. OPS0055 – Lifting and Hoisting Standard
1.4.8. 33CFR155 – Oil or Hazardous Material Pollution Prevention Regulations
1.4.9. 33CFR156 – Oil or Hazardous Material Transfer Operations
1.4.10. 46CFR35 – Tank Vessel Regulations
1.4.11. Ship to Ship transfer Guide
1.4.12. ISGOTT
1.4.13. Contingency Response Team Procedures

1.5. Responsibility

1.5.1. Primary - Logistics supervision shall be respons ible for assuring that this document is provided and that operators are instructed to use this document prior to Fuel Transfer and Pre-Booming operations.

1.5.2. Secondary - Vessel operators are required to perf orm Fuel Transfer and Pre-Booming
Procedures in concurrence with this document.

1.6. Exemptions

Certain vessels will be exempt from pre-booming due to the nature of the vessel’s operation. Vessels exempt from pre-booming are required to have booming material in the immediate vicinity of the fuel transfer operation. Examples of vessels exempt from pre-booming are:Shell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 6 of 21

The controlled version of this “contro lling document” resides online in Livelink® . Printed copies are UNCONTROLLED.Printed copies of this document areUNCONTROLLED. Destroy(RECYCLE)after use. 1.6.1. Fueling of small work boats (e.g. 34 feet a nd 47 feet boats) or fast response boats (e.g. zodiacs) either while they are out of the water or while they are stored on a barge, oil spill response vessel (OSRV), or other vessel,

1.6.2. Vessels that are actively conducting 3D seism ic acquisition (e.g. Gilavar and her escort vessels) while underway with streamers deployedShell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 7 of 21

The controlled version of this “contro lling document” resides online in Livelink® . Printed copies are UNCONTROLLED.Printed copies of this document areUNCONTROLLED. Destroy(RECYCLE)after use. 2. Fuel Transfer Operations

2.1. Fuel transfer operations will follow Bulk Transfer Requirements (OPS0011 – PR06).

2.2. For vessels operating in the Chukchi and Beaufort Seas, the scheduling of fuel transfer operations shall be initiated by the receiving vessel or MODU to EPW’s SIMOPS Coordinator at least 24
hours in advance.

2.3. Scheduling/Notification

2.3.1. The Simultaneous Operations (SIMOPS) Coordinator shall:

2.3.1.1. Consider the proposed fuel transfer in th e context of other planned operations and vessels in the area of operations,
2.3.1.2. Review the weather forecast and ensure the forecasted weather is favorable for conducting a fuel transfer operation (Reference OPS0011-TO.02),
2.3.1.3. Coordinate with Logistics Coordinator (Location TBD) the scheduling of the fuel transfer, if applicable,
2.3.1.4. Notify the Shell focal points and vessel masters on related vessels and/or rigs involved in the planned fuel transfer. See the “Notification of Planned Fuel Transfer Operation” form in Appendix A of this manual, and
2.3.1.5. Notify Shell Contingency Response Coor dinator (Appendix E) of the planned involved fuel transfer,
2.3.1.6. Notify receiving vessels,
2.3.1.7. Notify the USCG Captain of the Port Western Alaska at least four (4) hours in advance of all planned fuel transfers, (See Appendix B: Advance Notification to U.S. Coast Guard - Offshore Fuel Transfer Operation form.),
2.3.1.8. Complete the Notification of Planned Fuel Transfer Operation form (in Appendix A). Maintain file of completed forms.

2.4. Preparation for Fuel Transfers :

2.4.1. At any time a fuel transfer is scheduled between two EPW contracted vessels, the CRT will be on scene to perform contingency response duties. Fuel transfers that occur in the
Chukchi or Beaufort Seas will consist of th ree operational entities: the transferring vessel, the receiving vessel and the contingency response team.

2.4.2. If a transfer is scheduled between an EPW contracted vessel and another party not contracted to EPW, the non-EPW vessel or facility will provide oil spill response equipment, including containment boom, as per appropriate port state regulations.

2.4.3. Prior to commencement of fueling operations the following measures shall be taken by
into account:

Delivery and Receiving vessel :Shell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 8 of 21

The controlled version of this “contro lling document” resides online in Livelink® . Printed copies are UNCONTROLLED.Printed copies of this document areUNCONTROLLED. Destroy(RECYCLE)after use. 2.4.3.1. Ensure all applicable fuel transfer e quipment and procedures specified in 33 CFR 155 and 156 are complied with and the Declaration of Inspection (DOI) (copy in Appendix C) is signed.

2.4.3.2. Verify all pollution prevention equipment is in place, as per Vessel’s Shipboard Oil Pollution Emergency Plan (SOPEP).

2.4.3.3. Ensure fuel containment boom, anchors and spill response vessels are deployed
as needed.

2.4.3.4. Ensure communications are established between the transfer and receiving
vessels.

2.4.3.5. Correct couplings have been identified for the product(s) to be transferred.

2.4.3.6. Hoses comply with EP2005-0262-SP-05.

2.4.3.7. Slings and lifting points are visually ch ecked and replaced if required (reference OPS0055).

2.4.3.8. Ensure hoses are lifted as per OPS0011.

2.4.3.9. All manifold valves are in good condition.

2.4.3.10. Ensure the person in charge of the operation performs no other duties.

Contingency Response Team:
2.4.3.11. Confirm that the prevailing weather conditions (sea state, ice, and winds will not prevent the deployment of spill containment boom and oil recovery vessels from carrying out an effective response in the event of a spill.

2.4.3.12. Ensure oil containment boom, anchors a nd spill response vessels are deployed as per the applicable boom deployment diagrams provided on the following pages.

2.4.3.13. Ensure communications are established w ith response team vessel personnel as well as the transfer and receiving vessels.

2.4.4. Spill Response Equipment :

When a fuel transfer occurs in the Chukchi and US Beaufort Seas and the Shell Contingency Response Group is on station, the following equi pment and conditions shall be considered required:Shell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 9 of 21

The controlled version of this “contro lling document” resides online in Livelink® . Printed copies are UNCONTROLLED.Printed copies of this document areUNCONTROLLED. Destroy(RECYCLE)after use. 2.4.4.1. The boom deployed shall be suitable for use in the conditions as per the OPA 90 regulations.

2.4.5. Booming Requirements :

2.4.5.1. The oil containment boom shall be placed in a configuration as indicated in configuration 1 or 2.

2.4.5.2. Configuration 1, where the boom is deployed downstream of the transfer operation, will be utilized when:

2.4.5.2.1. The vessels are not moored to one another, or
2.4.5.2.2. When a vessel is required due to specific circumstances to keep the propeller turning while engaged in the fuel transfer operations.

2.4.5.3. Configuration 1 will be utilized as per the CRT’s operations manual which will
include

: 2.4.5.3.1. Distance boom will be deployed from the vessels ( the boom should not be any closer than 20 feet to the closest vessel),
2.4.5.3.2. Type of boom,
2.4.5.3.3. Appropriate boom for the sea and weather conditions
2.4.5.3.4. Management of boom (workboat, anchors, maneuvering, etc)
2.4.5.3.5. Workboats will standby during the entire transfer operation, monitor the boom configuration, perform minor ice management as necessary and monitor for any product that may enter the water.

2.4.5.4. Configuration 2, where the boom is deployed forward and aft of the manifold between the vessels, will be utilized when:

2.4.5.4.1. The vessels are moored to one another, or
2.4.5.4.2. When a vessel is moored at a dock or facility.

2.4.5.5. Configuration 2 will be utilized as per the CRT’s operations manual which will
include:

2.4.5.5.1. Type of boom,
2.4.5.5.2. Management of boom (workboat, anchors, maneuvering, etc.)
2.4.5.5.3. Workboats will standby during the entire transfer operation, monitor the boom configuration, perform minor ice management as necessary and monitor for any product that may enter the water.

2.5. Planning for Fuel Transfer:Shell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 10 of 21

The controlled version of this “contro lling document” resides online in Livelink® . Printed copies are UNCONTROLLED.Printed copies of this document areUNCONTROLLED. Destroy(RECYCLE)after use. When preparing plan for transfer, due regard shoul d be given to ensure that adequate stability is
maintained.

2.5.1. The transfer operation should be planned and agreed in writing between the two (or three) parties and, where applicable, should include information on the following:

2.5.1.1. Quantity and type of each fuel to be transferred,

2.5.1.2. Number of pumps to be used and maximum pressure,

2.5.1.3. Initial and maximum topping off rates,

2.5.1.4. Notice period of rate change communicated,

2.5.1.5. Normal stopping and emergency shutdown procedures,

2.5.1.6. Emergency and spill containment procedures,

2.5.1.7. Watch or shift change arrangements,

2.5.1.8. Critical stages of operations,

2.5.1.9. Local or government rules that may apply (MMS for EPW contracted vessel),

2.5.1.10. Material Safety Data Sheet,

2.5.1.11. Coordination of plans for cargo hose connection, monitoring, draining and
disconnection.

2.5.2. Flow rates for various phases of the transfer operation will be discussed and agreed upon prior to beginning transfer operation. If varia tions in transfer rate become necessary, the receiving vessel shall advise the discharging vessel or facility of its requirements. Similarly, the discharging vessel or facility shall inform the receiving vessel of any variations in flow rates due to its operations.

2.5.3. The receiving vessel will confirm that he will not load any tank to more than 90 percent capacity.

2.5.4. Throughout the transfer, the transfer rate w ill be checked and compared between the two vessels and/or facilities. A log shall be kept.

2.6. Ice Conditions :

The vessels involved in the fuel transfer will pay particular attention to ice in the vicinity (OPS0011-TO.02). If necessary, the vessel will ma neuver for ice. It may be necessary toShell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 11 of 21

The controlled version of this “contro lling document” resides online in Livelink® . Printed copies are UNCONTROLLED.Printed copies of this document areUNCONTROLLED. Destroy(RECYCLE)after use. release one end of the boom should ice approach. Should this occur, the fuel transfer operations would be temporarily halted when the boom is released and resume once the boom has been redeployed.

Determining movement of hazardous ice within 3 hours of the fuel transfer operation is essential. Thus if ice is closing in on a vessel’s location and the Master deems it to be hazardous, the transfer operations will be halted. A vessel may steam away to extend the arrival
of the ice at the vessel.

If the ice is static (not moving), it is not cons idered hazardous. The containment boom should be able to be or remain deployed with no inte rference from the ice. Therefore, the transfer operations may continue.

2.7. Termination of Transfer

Any party involved in the fuel transfer operation may stop the fuel transfer operation for safety or
environmental reasons.

Fuel transfers should be immediately halted if lo ss of containment occurs or any of the other following situations develop:

2.7.1. A leaking pipe or hose is discovered,

2.7.2. If the containment boom is deployed, the presence of ice requires releasing the boom, preventing effective immediate spill containment,

2.7.3. Vessel moorings (spring and/or breast lines) fail or are not adequately securing the vessels,

2.7.4. Shifting of the transfer vessels locations due to wind or current that cause the containment boom to be compromised,

2.7.5. Increase in other safety or environmental risk factors that become elevated to an unsafe
level

2.8. Completion of Transfer

In accordance with previously agreed procedur es, after completion of cargo transfer the following operations should be carried out:

2.8.1. All hoses should be drained into the agreed upon tank,

2.8.2. Hoses should be disconnected and securely blanked,

2.8.3. Cargo manifolds should be securely blanked,Shell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 12 of 21

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the dock.

2.9. A copy of the Declaration of Inspection (DOI) co mpleted by the Person in Charge for the delivery vessel and the Person in Charge for the receiving vessel prior to the fuel transfer shall be retained by both the delivering and receiving vessels. When the DOI provided in Appendix B is used a copy of the document shall also be provided to the spill response team.

A vessel may use their Company’s Safety Manage ment System DOI as long as the DOI includes all sections included in the attached DOI (Appendix C).

If a contracted vessel and/or fuelling facility ut ilize their safety management systems’ DOI, then the CRT shall complete Appendix E. This doc ument must be addressed and signed by all participating parties.Shell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 13 of 21

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Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 14 of 21

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Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 15 of 21

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## Notification of Planned Fuel Transfer Operation

Proposed Date and Time of Fu el Transfer: ________________

Receiving Vessel: _______________

_____________________________
Delivery Vessel: ________________

______________________________
Estimated Quantity of Fue l: ________________gals

Location: ____________

_____________________

Weather Forecast:

________________________ ______________________ ____________________

________________________________ ________________________________

Notifications:

Shell Contingency Response Coor dinator: _____________________

Date and Time 

## Delivery Vessel: _____________________

Date and Time 

## Receiving Vessel: _____________________

Date and Time Note: U.S. Coast Guard Captain of the Port Western Alaska (4 hrs advance notice) PH: (907) 271-6700,
or fax Advance Notification to U. S. Coast Guard - Offshore Fuel Transfer Operation form (Appendix B)

__________________________ ___________________ _____________________ Notification Date and Time Method: Fax or Call USCG Point of contact

Instructions: This Notification Form is to be co mpleted by the SIMOPS Coordinator, who maintains a file of completed forms.Shell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 16 of 21

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## APPENDIX B

Advance Notification to U.S. Coast Guard

Offshore Fuel Transfer Operation

U.S. Coast Guard: PH: (907) 271-6700 Fax (907) 271-6751

TO: USCG SECTOR WESTERN ALASKA, ANCHORAGE ALASKA ATTN: PREVENTION DEPARTMENT

ADVANCE NOTICE OF FUEL TRANSFER IN ACCORDANCE WITH 33 CFR 156.118

Shell is required by 33 CFR 156.118 to provide Advance Notice not less than four hours prior to a fuel transfer taking place between a supply vessel and receiving vessel or drill rig in Alaskan Waters.

Accordingly, be advised that a fuel transfer is scheduled to take place between the following vessels in the Chukchi or Beaufort Seas as follows:

Date Estimated Time Vessels Involved Location

Notice of transfer submitted by:

Name __________________________ Phone No: ___________________________

e-mail: _____________________________Shell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 17 of 21

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## APPENDIX C
DECLARATION OF INSPECTION This document should be completed prior to the transfer of fuel to ensure MMS stipulation 6 of the Oil and Gas Lease Sa le 193 and USCG Regulations in 46 CFR 35
and 33 CFR 155 and 156.

DATE RECEIVING VESSEL SUPPLYING VESSEL LOCATION

FUEL TO BE TRANSFERRED: Quantity : ________ Type of Oil: ___________

I, _____________________, the pers on in charge of the receiving vessel for the transfer of fuel oil in bulk certify I have personally inspected this vessel with respect to th e requirements in 46 CFR 35 and 33 CFR 155 and 156 and that opposite each of the applicable items below I have indi cated whether the vessel complies with all pertinent regulations by initialing the check off list below.

I, _____________________, the person in charge of the supplying vessel for the transfer of fuel oil in bulk certify I have personally inspected this vessel wi th respect to the requirements below set forth in 46 CFR 35 and 33 CFR 155 and 156 and that opposite each of the applicable items belo w I have indicated whether the vessel complies with all pertinent regulations by initialing the check off list below.

Regulation

Citation Description Supply Vessel Receiving Vessel

46 CFR 35.35- 30(b)(1) Warnings displayed (bravo flag; red lights)

46 CFR 35.35- 30(b)(2) No unauthorized repair work in progress (spark producing or hot work)

46 CFR 35.35- 30(b)(3) Flanged connections have minimum of 4 bolts; fixed or portable containment in place

46 CFR 35.35- 30(b)(4) Cargo connections made to receiving vessel and transferring vessel manifold

46 CFR 35.35- 30(b)(5) No fires or open flames present on deck or in adjacent compartment

46 CFR 35.35- 30(b)(7) Sea valves connected to cargo piping secured

46 CFR 35.35-

30(b)(8)(9) Boiler and galley fires if any safely maintained

46 CFR 35.35- 30(b)(10) (11) Safe smoking areas designated

46 CFR 35.35-

30(b)(12) Inert gas system being operated, if applicable

46 CFR 35.35-

30(b)(13) Individual vessel response plans reviewed

46 CFR 33 CFR

156.120(a) Moorings are adequate for all expected conditions

46 CFR 33 CFR

156.120(b) Hoses have adequate operating envelopes for theShell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 18 of 21

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33 CFR 156.120(c) Each hose is supported to prevent kinking or other damage to the hose and strain on its coupling.

33 CFR 156.120(d) Each part of the transfer system is aligned properly

33 CFR 156.120(e) Each part of the transfer system not necessary for the transfer operation is securely blanked or shut off;
33 CFR 156.120(f) The end of each hose that is not connected for the transfer of fuel is blanked off using the closure devices required by §§154.520 and 155.805 of 33
CFR

33 CFR 156.120(g) The transfer system is attached to a fixed connection
on both vessels

33 CFR 156.120(h) Each overboard discharge or sea suction valve that is connected to the vessel's transfer or cargo tank system is sealed or lashed in the closed position;
33 CFR 156.120(i) Each transfer hose has no unrepaired loose covers, kinks, bulges, soft spots, or any other defect which would permit the discharge of fuel through the hose material and no gouges, cuts, or slashes that penetrate the first layer of hose reinforcement
33 CFR 156.120(j) Each hose in use meets 33 CFR 154.500 and
154.510

33 CFR 156.120(k) Each connection meets 33 CFR156.130;

33 CFR 156.120(n) The discharge containment required by 33 CFR 155.310, and 155.320 as applicable, is in place and periodically drained to provide the required capacity;

33 CFR 156.120(o) Each drain and scupper is cl osed by the mechanical means required by 33 CFR155.310;

33 CFR 156.120(p) All connections in the transfer system are leak free;

33 CFR 156.120(q) The communications required by 33 CFR154.560 and 155.785 are in place with procedures
established and understood.
33 CFR 156.120(r) The emergency means of shutdown required by 33 CFR 155.780 is in position and operable;

33 CFR 156.120(s) There is a person in charge on each transferring and receiving vessel

** 33 CFR
156.120 and MMS The person in charge of transfer operations on the transferring vessel, the person in charge of transfer operations on the receiving vessel and the person in charge of the oil spill response agree to begin theShell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 19 of 21

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33 CFR 156.120(y) Adequate lighting, including Vessel manifold areas, is provided.

*** MMS Communications (2 way) systems tested and ready

*** MMS Receiving or delivering vessel boomed

*** MMS Boom tending capabilities present and ready to respond

*** MMS Contingency Response Group Contacted and on standby

*** MMS Ice conditions do not present an impediment to cleanup operations

*** MMS Wind and sea conditions do not present an impediment to cleanup operations

Date and Time of Fueling Operation: Date : ________Start Time: _______Completed: ________

Persons in Charge

______________________________________ __________________________________ Printed Name – Supply Vessel PIC Printed Name – Receiving Vessel PIC

______________________________________ __________________________________ Signature SignatureShell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 20 of 21

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## APPENDIX D

Date and Time of Fueling Operation: Date: _____________Start Time: __________Completed: ____________

Persons in Charge

______________________________________ ________________________________________ Printed Name – Supply Vessel/Terminal PIC Printed Name – Receiving Vessel PIC

______________________________________ ________________________________________ Signature Signature

Contingency Response Coordinator

______________________________________ Printed Name – Supply Vessel/Terminal PIC

______________________________________ Signature DECLARATION OF INSPECTION – Additional Requirements – Contingency Response Team This document should be completed prior to the transfer of fuel to ensure MMS stipulation 6 of the Oil and Gas Lease Sale 193 a nd USCG Regulations
in 46 CFR 35 and 33 CFR 155 and 156.
DATE RECEIVING VESSEL SUPPLYING VESSEL/TERMINAL LOCATION

FUEL TO BE TRANSFERRED: Quantity: ____________ Type of Oil: _______________

I, _________________________, the person in charge of the receiving vessel for the transfer of fuel oil in bulk certify I have personally inspected this vessel with respect to the requirements in 46 CFR 35 and 33 CFR 155 and 156 and that opposite each of the applicable items belo w I have indicated whether the vessel complies with all pertinent re gulations by initialing the check off list below.

I, _________________________, the person in charge of the supplyin g vessel/terminal for the transf er of fuel oil in bulk certif y I have personally inspected this vessel/terminal with respect to the requirements below set fort h in 46 CFR 35 and 33 CFR 155 and 156 and that op posite each of the applicable items below I have indicated whether the vessel/termin al complies with all pertinent regulations by initialing the c heck off list below.

Regulation

Citation Description Supply Vessel /
Terminal Receiving
Vessel
*** MMS Communications (2 way) systems tested and ready

*** MMS Receiving and / or delivering vessel boomed

*** MMS Boom tending capabilities present and ready to respond

*** MMS SIMOPS Coordinator Contacted and CRT on standby

*** MMS Ice conditions do not present an impediment to cleanup operations

*** MMS Wind and sea conditions do not present an impediment to cleanup operationsShell Exploration & Production Company Number:

Operations Procedure Custodian: Alaska Logistics

ALASKA FUEL TRANSFER -
OPERATING CONDITION AND
PROCEDURE Revision: 1 Effective: 1 April 2010

Printed: 1 June 2009 Page 21 of 21

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## APPENDIX E

Contact Information

Title Organization Phone Number
Fax Number Email
Captain of the Port,
Western Alaska USCG (907) 271-6700 (907) 271-6751 D17-PF-ANCCDOMSOANC@uscg.mil

Logistics Coordinator
- Deadhorse Shell (907) 980-5146 John.Maketa@shell.com

Logistics Terminal - Manager Shell 907-646-7168 Jack.Wallis@shell.com
Contingency Response Coordinator Shell (907) 382-7003 (907) 319-2500 Mark.Broton@shell.com

SIMOPS Coordinator Shell (907) 382-6974 (907) 644-7479 Howard.l.Hill@shell.com Richard.Seltz@shell.com2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 100 July 2009 15276-03-09-001A/09-011A Rev. 1 

## THIS PAGE
INTENTIONALLY
LEFT BLANK2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 101 July 2009 15276-03-09-001A/09-011A Rev. 1 SECTION 10.0 ENVIRONMENTAL MONITORING

a) Monitoring Systems

The Discoverer will be equipped with the following monitoring equipment:

 Radar: Furuno Model FAR2837S

 Satellite Navigation Receiver: Simrad GN 33 Global Positioning System Navigator

 Gyro Compass: Simrad GC 80

 Magnetic Compass: C&P Standard Reflecta 3

 Echo Sounder, fathometer: Furuno FE-700

 Roll and Pitch Monitors: Inclinometers

 Anemometer: Observator OMC-160

 Meteorological Thermometer:Observator OMC-406

 Meteorological barometer: Observator OMC-506

An air quality permit application has been submitted to the EPA for air emissions authorization. The
Discoverer air emissions will be monitored in complian ce with the subsequent air permit conditions.

NOI applications to operate under NPDES Genera l Permit AKG-28-0000 will be submitted to the EPA
for the Discoverer (Appendix B). The Discoverer will have the required waste monitoring equipment onboard to monitor and report the discharges as required by the permit.

b) Incidental Takes

Applications have been submitted concurrently with the EP for the following MMPA authorizations:

 Incidental Harassment Authorization (IHA) from NMFS – Non-lethal, Incidental Take of Whales and Seals (Appendix C)

 Letter of Authorization (LOA) from USFWS – Non- lethal, Incidental and Intentional Take of Polar Bear and Pacific Walrus (Appendix E)

During the planned drilling program, the Discoverer and support vessels will each have MMOs onboard
to observe for marine mammals and record all obser vations. Complete details of the MMO program are presented in the 4MP submitted in support of the NMFS IHA application.

Species for which an incidental harassment authorization is sought are:

 Mysticetes: bowhead, fin, gray, humpback and minke whales

 Odontocetes: beluga, narwhal, k iller whale, and harbor porpoise

 Pinnipeds: bearded, ribbon, ringed, and spotted seals

Potential impacts to these species are discussed in de tail in the EIA (Appendix F). Any impacts to whales and seals from the planned exploration drilling program w ould be temporary and result in only short-term disturbance or displacement. From a historical persp ective, the temporary activity of offshore exploration2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 102 July 2009 15276-03-09-001A/09-011A Rev. 1 drilling and associated support vessel activities, collectiv ely and individually, have not resulted in impacts of biological significance to marine mammals of the Arc tic, or interference with the subsistence harvest of those marine mammals by the residents of the communities along the Beaufort and Chukchi Seas.

The numbers of marine mammals that may pot entially be exposed to sound levels of > 160 decibels (dB)
rms and > 120 dB rms generated by drilling or ice mana gement are summarized in Table 10.b-1 and discussed in the IHA (Appendix C). Many animals e xposed to sound levels near 120 dB rms would not react to those sound levels, particularly pinnipeds, and exposure to this sound level should not be considered as “takes by harassment”. Even for sp ecies that may change their behavior or alter their migration route, those changes are likely to be with in the normal range of activities for the animals and may not rise to the level of “taking” based on guida nce in NMFS (2001). Animals that divert around the activity at the lower sound levels would not approach close enough that they would alter their behavior to the degree that they would be “taken by harassment.” The actual number of animals that will be “taken” lies somewhere between the number exposed to ≥ 120 and ≥ 160 dB rms.

These represent small takes based on their effect (tem porary behavioral effects) and the proportion of the population that would be affected. For example, an estimated maximum of 10 bowheads may be exposed
to sounds ≥ 160 dB re 1 μPa rms equaling <1 percent of the population. An even smaller percentage of seal populations in the Chukchi Sea would be exposed to underwater sounds in excess of 160 dB. In regard to the subsistence harvest of bowhead whal e, as a consequence of Shell’s planned mitigation measures (see Section 12.0) any effects on the bowh ead whale as a subsistence resource also will be negligible.

The LOA application (Appendix E) provides an ou tline of the 2010 drilling activities and includes an updated, drilling program-specific bear and walrus plan titled: Polar Bear, Pacific Walrus and Grizzly Bear Avoidance and Encounter/Interaction Plan, Be aufort Sea, Alaska, 2010 Exploration Program. The LOA application does not require the inclusion of take estimates for polar bears or Pacific walrus.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 103 July 2009 15276-03-09-001A/09-011A Rev. 1 TABLE 10.b-1 Number of Potential Exposures of Marine Mammals to Re ceived Sound Levels in the Water of >120 dB rms and (>160 dB rms) during Shell’s Planned Exploration Drilling Activiti es in the Chukchi Sea, Alaska, (July–October) 2010.

Species Number of Exposures to Soun d Levels > 120 dB and (>160 dB)

Summer Fall Total
Average Maximum Average Maximum Average Maximum

Beluga 4 (1) 15 (5) 8 (5) 34 (20) 12 (6) 48 (24)
Narwhal 0 (0) 0 (0) 0 (0) 0 (0) 0 (0) 5 (5)
Killer whale 0 (0) 0 (0) 0 (0) 0 (0) 0 (0) 5 (5)
Harbor porpoise 10 (3) 22 (7) 2 (1) 5 (3) 11 (4) 27 (10)
Bowhead whale 1 (0) 5 (2) 1 (0) 4 (3) 2 (1) 10 (5)
Fin whale 0 (0) 1 (0) 0 (0) 0 (0) 0 (0) 5 (5)
Gray whale 10 (3) 148 (47) 11 (7) 44 26 48 (18) 193 (73)
Humpback whale 0 (0) 1 (0) 0 (0) 0 (0) 0 (0) 5 (5)
Minke whale 0 (0) 1 (0) 0 (0) 0 (0) 0 (0) 5 (5)
Bearded seal 52 (16) 85 (27) 12 (7) 20 (12) 64 (24) 105 (39)
Ribbon seal 0 (0) 1 (0) 0 (0) 0 (0) 0 (0) 5 (5)
Ringed seal 1,489 (474) 2,319 (738) 239 (141) 406 (240) 1,728 (615) 2,726 (978)
Spotted seal 30 (9) 119 (38) 5 (3) 19 (11) 35 (12) 138 (49)

Note: Arbitrary estimates have been included in the Total (Max) column to account for chance encounters or where greater numbe rs may be encountered than calculations suggested. Not all marine mammals will change their behavior when exposed to these sound levels2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 104 July 2009 15276-03-09-001A/09-011A Rev. 1 

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Shell Gulf of Mexico Inc. 105 July 2009 15276-03-09-001A/09-011A Rev. 1 SECTION 11.0 LEASE STIPULATIONS INFORMATION

The source for the italicized text below is the OC S Chukchi Sea Planning Area Oil and Gas Lease Sale
193.

Stipulation No. 1 - Protection of Biological Resources

If previously unidentified biological populations or habitats that may require additional protection are identified in the lease area by the Regional Superv isor, Field Operations (RS/FO), the RS/FO may require the lessee to conduct biological surveys to determine the extent and composition of such biological populations or habitats. The RS/FO shall give written no tification to the lessee of the RS/FO’s decision to require such surveys.

Based on any surveys that the RS/FO may require of th e lessee or on other information available to the RS/FO on special biological resources, the RS/FO may require the lessee to:

1) Relocate the site of operations; 2) Establish to the satisfaction of the RS/FO, on the basis of a site-specific survey, either that such operations will not have a significant adverse effect upon the resource identified or that a special biological resource does not exist; 3) Operate during those periods of time, as establis hed by the RS/FO, that do not adversely affect the biological resources; and/or 4) Modify operations to ensure that significant biological populations or habitats deserving protection are not adversely affected.

If any area of biological significance should be discovered during the conduct of any operations on the lease, the lessee shall immediatel y report such findings to the RS/F O and make every reasonable effort to preserve and protect the biological resource from damage until the RS/FO has given the lessee direction with respect to its protection.

The lessee shall submit all data obtained in the c ourse of biological surveys to the RS/FO with the locational information for drilling or other activity. The lessee may take no action that might affect the biological populations or habitats surveyed until the RS/FO provides written directions to the lessee with regard to permissible actions.

Shell Proposed Actions

The MMS has not requested that Shell conduct any biol ogical resource surveys in the area of the planned drill sites. No areas of special biological significance have been identified within or near the EP blocks.

In addition to the shallow hazard surveys, which pr ovide detailed information on the seafloor sediments and relief, Shell conducted or partic ipated in the funding or in the facilitation of several types of environmental studies in and near the prospects in 2008 to gather baseline data regarding resources in the project area. These studies included coastline survey s to assess the relative environmental sensitivity of Chukchi Sea coastline segments, walrus tagging a nd monitoring studies, seal tagging and monitoring studies, bird and marine mammal surveys, assessme nts of the benthic invertebrate communities, oceanographic studies, and sediment quality assessments at the planned drill sites. The results of the marine mammal and bird surveys are summa rized in the EIA in Appendix F.

These studies also indicated that there are no areas of sp ecial biological significance in the vicinity of the drill sites. Video reconnaissance surveys were conducted at historical drill sites at Burger and2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 106 July 2009 15276-03-09-001A/09-011A Rev. 1 Crackerjack in 1989, and the results were submitted to MMS at that time. These surveys also found a relatively flat and featureless seafloor with a silty su bstrate and a benthic fauna typical of the Lease Sale 193 Area (Finney 1989; Boudreau 1989).

Stipulation No. 2 - Orientation Program

The lessee shall include in any exploration plan (EP) or developmen t and production plan (DPP)
submitted under 30 CFR 250.2 11 and 250.241 a proposed orientation program fo r all personnel involved in exploration or development and production activ ities (including personnel of the lessee’s agents, contractors, and subcontractors) for review and approv al by the RS/FO. The program shall be designed in sufficient detail to inform individuals working on the project of specific types of environmental, social,
and cultural concerns that relate to the sale and adjacent areas. The program shall address the importance of not disturbing archaeological and biological resources and habitats, including endangered species, fisheries, bird coloni es, and marine mammals and provide guidance on how to avoid disturbance. This guidance will include the produc tion and distribution of information cards on endangered and/or threatened species in the sale area . The program shall be designed to increase the sensitivity and understanding of personnel to community va lues, customs, and lifestyles in areas in which such personnel will be operating. The orientation pr ogram shall also include information concerning avoidance of conflicts with subsiste nce activities and pertinent mitigation.

The program shall be attended at least once a year by all personnel involved in onsite exploration or development and production activities (including personnel of the lessee’s agents, contractors, and subcontractors) and all supervisory and managerial p ersonnel involved in lea se activities of the lessee and its agents, contractors, and subcontractors.

The lessee shall maintain a record of all personnel who attend the program onsite for so long as the site is active, not to exceed 5 years. This record sha ll include the name and date(s) of attendance of each
attendee.

Shell Proposed Actions:

Shell has developed and is currently implementi ng an approved orientation program for Shell and contractor personnel involved in Shell’s Alaska Ve nture exploration drilling program that was approved by the Alaska OCS Region of the MMS RS/FO on 15 February 2007. The orientation program will be resubmitted to the MMS for approval prior to or w ith the applications for Permits to Drill.

All Shell and contractor personnel involved in field exploration ac tivities will attend the orientation training annually. All other Shell and contractor personnel will attend the progr am at least once at the time they join the team. Shell will maintain a record , not to exceed 5 years, of all personnel who attend the program, including relevant attendee and program information.

Shell has designed a specific program that addresses e nvironmental, social, and cultural concerns related to the project area. The program is designed to increase sensitivity and unde rstanding by Shell and its contractors of community values, customs, and lifest yles in the area they will be working, and how to
avoid conflicts with subsistence activities. The program stresses the importance of not disturbing archaeological and biological resources and habitats , including endangered species, fisheries, bird colonies, and marine mammals and provid es guidance on how to avoid disturbance.

Shell’s Cultural Awareness Program addresses the following:

 Alaska Native Ethnic Breakdown2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 107 July 2009 15276-03-09-001A/09-011A Rev. 1  Brief history of land claims

 Formation of regional corporations, and region within which Shell is working

 History of the North Slope

 Cultural diversity

 Comparison of cultural values of Alaska Natives v. non-Natives

 Patterns of language

 Communication skills and body language

 Guidelines on cultural artifacts

 Local community values and customs

 Whaling

Shell has further developed an HSSE Aware ness Program, which addresses the following:

 Shell’s HSSE Commitment

 Intervention policy

 Journey Management requirements

 Personal Protective Equipment requirements

 General Alaska Venture Hazards, such as earthquakes and volcanoes

 Medical emergencies

 Security

 North Slope Safety requirements

 Shell Alaska Venture Standards and Procedures

– Cold Climate Work Standard

– Firearms Use in Wildlife Confrontations

– Procedure for Vessel-to-Vessel Personnel Transfers

 Incident Reporting

 Environmental Awareness

– Endangered Species Act (ESA) – Major Provisions

– Endangered and threatened species

– Marine Mammal Protection Act of 1972 (MMPA)

– Marine mammal interactions

– Sensitive Habitats on the North Slope

– Wildlife interactions

– Prohibited activities of hunting, trapping and fishing

– Environmental requirements, for air, spills and waste

– Environmental training

Stipulation No. 3 - Transportation of Hydrocarbons

Pipelines will be required: (a) if pipeline rights-of-way can be determined and obtained; (b) if laying such pipelines is technologically fe asible and environmentally preferable; and (c) if, in the opinion of the2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 108 July 2009 15276-03-09-001A/09-011A Rev. 1 lessor, pipelines can be laid without net social loss, taking into account any incremental costs of pipelines over alternative methods of transportation and any incremental benefits in the form of increased environmental protection or reduced multiple-use con flicts. The lessor specifica lly reserves the right to require that any pipeline used for transporting produc tion to shore be placed in certain designated management areas. In selecting the means of transportation, consideration will be given to recommendations of any Federal, State, and local governments and industry.

Following the development of sufficient pipeline c apacity, no crude oil producti on will be transported by surface vessel from offshore production sites, except in the case of an emergency. Determinations as to emergency conditions and appropriate responses to these conditions will be made by the RS/FO.

Shell Proposed Action:

Not applicable to the activiti es described in this EP.

Stipulation No. 4 - Industry Site-Specific Bowhead Whale Monitoring Program

A lessee proposing to conduct exploration operations , including ancillary seismic surveys, on a lease within the blocks identified below during the periods of subsistence use related to bowhead whales, beluga whales, ice seals, walrus, and polar bears will be required to conduct a site-specific monitoring program approved by the RS/FO; unless, based on the size, timing, duration, and scope of the proposed operations, the RS/FO, in consultation with appropriate agencies and co-management organizations, determines that a monitoring program is not n ecessary. Organizations currently recognized by the National Marine Fisheries Service (NMFS) and the U. S. Fish and Wildlife Service (USFWS) for the comanagement of the marine mammals resources are the Alaska Eskimo Whaling Commission, the Alaska Beluga Whale Committee, the Alaska Eskimo Walrus Commission, the Ice Seal Commission, and the Nanuk Commission. The RS/FO will provide the appropriate agencies and co -management organizations a minimum of 30 calendar days, but no longer than 60 calendar days to review and comment on a proposed monitoring program prior to Minerals Management Service (MMS) approval. The monitoring program must be approved each year before exp loratory drilling operations can be commenced.

The monitoring program will be desi gned to assess when bo whead and beluga whales, ice seals, walrus, and polar bears are present in the vicinity of lease operations and the extent of behavioral effects on these marine mammals due to these operations. In d esigning the program, the lessee must consider the potential scope and extent of effects that the type of operation could have on these marine mammals. Experiences relayed by subsistence hunters indicate that, depending on the type of operations, some whales demonstrate avoidance behavior at distances of up to 35 miles. The program must also provide for the following:

1) Recording and reporting information on sightin g of the marine mammals of concern and the extent of behavioral effects due to operations; 2) Coordinating the monitoring logistics beforehand with the MMS Bowhead Whale Aerial Survey Project (BWASP) and other mandated aerial monitoring programs; 3) Inviting a local representative to be determ ined by consensus of the appropriate comanagement organizations to participate as an observer in the monitoring program; 4) Submitting daily monitoring results to the RS/FO; 5) Submitting a draft report on the results of the mon itoring program to the RS/FO within 90 days following the completion of the operation. The RS /FO will distribute this draft report to the appropriate agencies and co-management organizations; 6) Allowing 30 days for independent peer review of the draft monitoring report; and2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 109 July 2009 15276-03-09-001A/09-011A Rev. 1 7) Submitting a final report on the results of the m onitoring program to the RS/FO within 30 days after the completion of the independent peer review. The final report will include a discussion of the results of the peer review of the draft report. The RS/FO will distribute this report to the appropriate agencies and co-management organizations.

The RS/FO may extend the report review and subm ittal timelines if the RS/F O determines such an extension is warranted to accommodate extenuating circumstances.

The lessee will be required to fund an independent p eer review of a proposed monitoring plan and the draft report on the results of the monitoring program for bowhead whales. The lessee may be required to fund an independent peer review of a proposed monitori ng plan and the draft report on the results of the monitoring program for other co-managed marine ma mmal resources. This peer review will consist of independent reviewers who have knowledge and experi ence in statistics, monitoring marine mammal behavior, the type and extent of the proposed opera tions, and an awareness of traditional knowledge. The peer reviewers will be selected by the RS/FO from experts recommende d by the appropriate agencies and co-management resource organizations. The results of these peer reviews will be provided to the RS/FO for consideration in final MMS approval of the mon itoring program and the final report, with copies to the appropriate agencies and co-management organizations.

In the event the lessee is seeking a Letter of Authoriz ation (LOA) or Incidental Harassment Authorization (IHA) for incidental take from NMFS and/or FWS, the monitoring program and review process required under the LOA or IHA may satisfy the requirements of this stipulation. The l essee must advise the RS/FO when it is seeking an LOA or IHA in lieu of meeting th e requirements of this st ipulation and provide the RS/FO with copies of all pertinent submittals and resulting correspondence. The RS/FO will coordinate
with the NMFS and/or FWS and w ill advise the lessee if the LOA or IHA will meet these requirements.

The MMS, NMFS, and FWS will establish procedures to coordinate results from site-specific surveys required by this stipulation and the LOA’s or IH A’s to determine if further modification to lease operations are necessary.

This stipulation applies to the following blocks:

NR02-06, Chukchi Sea: 6624, 6625, 6674, 6675, 6723-6725, 6773-6775, 6822, 6823, 6872

NR03-02, Posey: 6872, 6873, 6918-6923, 6967-6973, 7016-7023, 7063-7073, 7112-7123

NR03-03, Colbert 6674, 6723, 6724, 6771-6774, 6820-6824, 6869-6874, 6918-6924, 6966-6974, 7015-7024, 7064-7074, 7113-7124

NR03-04, Solivik Island 6011-6023, 6060-6073, 6109-6122, 6157-6171, 6206-6219, 6255-6268, 6305-6317, 6354-6365, 6403-6414, 6453-6462, 6502-6511, 6552-6560, 6601-6609, 6651-6658, 6701-6707, 6751-6756, 6801-6805, 6851-6854, 6901-6903, 6951, 6952, 7001

NR03-05, Point Lay West 6014-6024, 6062-6073, 6111-6122, 6160-6171, 6209-6221, 6258-6269, 6307-6317, 6356-6365, 6406-6414, 6455-6462, 6503-6510, 6552-6558, 6602-6606, 6652-6655, 6702, 67032010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 110 July 2009 15276-03-09-001A/09-011A Rev. 1 NR04-01, Hanna Shoal 6223, 6267-6273, 6315-6323, 6363-6373, 6411-6423, 6459-6473, 6507-6523, 6556-6573, 6605-6623, 6654-6671, 6703-6721, 6752-6771, 6801-6819, 6851-6868, 6901-6916, 6951-6964, 7001-7010, 7051-7059, 7101-7107

NR04-02, Barrow 6003-6022, 6052-6068, 6102-6118, 6151-6164, 6201-6214, 6251-6262, 6301-6312, 6351-6359, 6401-6409, 6451-6456, 6501-6506, 6551, 6552, 6601, 6602

NR04-03, Wainwright 6002-6006, 6052, 6053

NS04-08, (Unnamed) 6816-6822, 6861-6872, 6910-6922, 6958-6972, 7007-7022, 7055-7072, 7104-7122

This stipulation applies during the time periods for subsistence-harvesting described below for each community.

Subsistence Whaling and Marine Mammal Hunting Activities by Community

Barrow : Spring bowhead whaling occurs from April to June; Barrow hunters hunt from ice leads from Point Barrow southwestward along the Chukchi Sea coas t to the Skull Cliff area. Fall whaling occurs from August to October in an area extending from appr oximately 10 miles west of Barrow to the east side of Dease Inlet. Beluga whaling occurs from April to June in the spring leads between Point Barrow and Skull Cliff; later in the season, belugas are hunted in open water around the barrier islands off Elson Lagoon. Walrus are harvested from June to September from west of Barrow southwestward to Peard Bay. Polar bear are hunted from October to June generally in the same vicinity u sed to hunt walrus. Seal hunting occurs mostly in winter, but some open water sealing is done from the Chukchi coastline east as far as Dease Inlet and Admiralty Bay in the Beaufort Sea.

Wainwright : Bowhead whaling occurs from April to June in the spring leads offshore of Wainwright, with whaling camps sometimes as fa r as 10 to 15 miles from shore. Wainwright hunters hunt beluga whales in the spring lead system from April to June but only if no bowheads are in the area. Later in the summer, from July to August, belu gas can be hunted along the coas tal lagoon systems. Walrus hunting occurs from July to August at the southern edge of the retreating pack ice. From August to September, walrus can be hunted at local haulouts with the foca l area from Milliktagvik north to Point Franklin. Polar bear hunting occurs primarily in the fall and winter around Icy Cape, at the headland from Point Belcher to Point Franklin, and at Seahorse Island.

Point Lay : Because Point Lay’s location renders it unsuita ble for bowhead whaling, beluga whaling is the primary whaling pursuit. Beluga whales are harvested from the middle of June to the middle of July. The hunt is concentrated in Naokak and Kukpowru k Passes south of Point Lay where hunters use boats to herd the whales into the shallow waters of Kasegaluk Lagoon where they are hunted. If the July hunt is unsuccessful, hunters can travel as far north as Utukok Pass and as far south as Cape Beaufort in search of whales. When ice conditions are favorable, Poin t Lay residents hunt walrus from June to August along the entire length of Kasegaluk Lagoon, south of Icy Cape , and as far as 20 miles offshore. Polar bear are hunted from September to April along the coast, rarely more than 2 miles offshore.

Point Hope : Bowhead whales are hunted from March to June from whaling camps along the ice edge south and southeast of the point. The pack-ice lead is rarely more than 6 to 7 miles offshore. Beluga2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 111 July 2009 15276-03-09-001A/09-011A Rev. 1 whales are harvested from March to June in the same area used fo r the bowhead whale hunt. Beluga whales can also be hunted in the open water later in the summer from July to August near the southern shore of Point Hope close to the beaches, as well as areas north of the point as far as Cape Dyer. Walruses are harvested from May to July along the s outhern shore of the point from Point Hope to Akoviknak Lagoon. Point Hope residents hunt po lar bears primarily from January to April and occasionally from October to January in the area sout h of the point and as far out as 10 miles from shore.

This stipulation will remain in effect until terminati on or modification by the Department of the Interior after consultation with appropriate agencies.

Shell Proposed Actions:

Although none of the blocks listed in this stipulatio n are included in those planned for exploration drilling in Shell’s 2010 EP, Shell will voluntarily submit to the MMS a site-specific marine mammal monitoring program (4MP) in support of its application for an IHA (Appendix C). Shell plans to be an active participant in future NMFS Open Water meetings and an active participant in the independent review of the monitoring plan and reports generated for future activities. Shell assumes that the 4MP in support of the IHA application and the review process required under the IHA will satisfy the requirements of this stipulation. The 4MP is located in Appendix D.

Shell intends to use contractors based in the North Slope Borough (NSB), who will in turn provide job opportunities to local residents, including recruitmen t and training of SAs and MMOs. A summary of key components of the program is presented below.

Marine Mammal Observers Vessel-based monitoring for marine mammals will be done throughout the period of drilling operations to comply with expected provisions in the IHA and L OA that Shell receives. Those provisions will be implemented during the drilling program by a team of trained MMOs. The presence of MMOs onboard drilling and support vessels will be a core component of compliance with the 4MP. The MMOs will be responsible for collecting basic da ta on observations of marine mamma ls and for implementing mitigation measures including vessel avoidance measures and factored into decisions concerning operational shutdown. The observations made by MMOs serve as the primary basis for estimation of impacts to
marine mammals. Because their ranks include re presentatives of the Alaska Native community, the MMOs also serve as an important means of providing lo cal hire and local oversight of the monitoring program. MMOs will be stationed on the drillship, ice management vessel, anchor handler and other drilling support vessels engaged in transit to and be tween drill sites, drilling, and other operational and
intermittent activities to monitor for marine mammals.

Aerial Survey Program With agreement from hunters in the coastal villages, aerial surveys of coastal areas to approximately 20 mi (32 km) offshore between Point Hope and Point Ba rrow will begin in early- to mid- July and will continue until drilling operations in the Chukchi Sea ar e completed. The objectives of the aerial survey
are to collect data on the distribution and abundance of marine mammals in co astal areas of the eastern Chukchi Sea; and to collect and report data on the distribution, numbers, orie ntation and behavior of marine mammals, particularly beluga whales, near traditional hunting areas in the eastern Chukchi Sea.

Acoustic Recorders A combination of acoustic recorder technologies will be employed to document the distribution of marine mammals; the distribution of marine mammals in relation to activities; to add clarity to the characterization of exploration drilling sound le vels, character, and propagation; and to document2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 112 July 2009 15276-03-09-001A/09-011A Rev. 1 presence of marine mammals in subsistence hunting areas. This will be accomplished by deploying several acoustic recorder buoys in a wide area surrounding the planned locations.

Sound Modeling Sound modeling will be co nducted during the exploration-drilling program in the Chukchi Sea.

Sound Source Verification Field measurement sound propagation profiles of vessels and the drillship will be conducted during different operational modes, so as to determine tho se activities that produce the greatest opportunities for mitigation.

Additional Studies Shell plans to participate in additional studies of marine resources in the Chukchi Sea in an effort to gain an understanding of baseline conditions and the distributio n of critical resources, to gain an understanding of interactions between industry activities and marine resources, and to contribute to the understanding of resource status and conservation/management needs. The list of potential studies and monitoring projects
includes:

 Benthic biota survey

 Pinniped distribution and response to industry activities

 Participation in, and funding of, walr us and ringed seal tagging studies

 Collection of subsistence use of coastal and o ffshore waters though a system of Subsistence
Advisors

 Bird and Marine Mammal Surveys

 Benthic community monitoring

Stipulation No. 5 - Lease Sale 193 Conflict Avoidance Mechanisms to Protect Subsistence Whaling and other Subsistence-Harvesting Activities

Exploration and development and pr oduction operations shall be conduc ted in a manner that prevents unreasonable conflicts between the oil and gas indus try and subsistence activities. This stipulation applies to exploration, development, and production operations on a lease within the blocks identified below during periods of subsistence use related to bowhead whales, beluga whales, ice seals, walruses, and polar bears. The stipulation also applies to supp ort activities, such as vessel and aircraft traffic, that
traverse the blocks listed below or Fe deral waters landward of the sale during periods of subsistence use regardless of lease location. Transit for human safety emergency situations shall not require adherence to this stipulation.

This stipulation applies to the following blocks:

NR02-06, Chukchi Sea: 6624, 6625, 6674, 6675, 6723-6725, 6773-6775, 6822, 6823, 6872

NR03-02, Posey: 6872, 6873, 6918-6923, 6967-6973, 7016-7023, 7063-7073, 7112-7123

NR03-03, Colbert 6674, 6723, 6724, 6771-6774, 6820-6824, 6869-6874, 6918-6924, 6966-6974, 7015-7024, 7064-7074, 7113-71242010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 113 July 2009 15276-03-09-001A/09-011A Rev. 1 NR03-04, Solivik Island 6011-6023, 6060-6073, 6109-6122, 6157-6171, 6206-6219, 6255-6268, 6305-6317, 6354-6365, 6403-6414, 6453-6462, 6502-6511, 6552-6560, 6601-6609, 6651-6658, 6701-6707, 6751-6756, 6801-6805, 6851-6854, 6901-6903, 6951, 6952, 7001

NR03-05, Point Lay West 6014-6024, 6062-6073, 6111-6122, 6160-6171, 6209-6221, 6258-6269, 6307-6317, 6356-6365, 6406-6414, 6455-6462, 6503-6510, 6552-6558, 6602-6606, 6652-6655, 6702, 6703

NR04-01, Hanna Shoal 6223, 6267-6273, 6315-6323, 6363-6373, 6411-6423, 6459-6473, 6507-6523, 6556-6573, 6605-6623, 6654-6671, 6703-6721, 6752-6771, 6801-6819, 6851-6868, 6901-6916, 6951-6964, 7001-7010, 7051-7059, 7101-7107

NR04-02, Barrow 6003-6022, 6052-6068, 6102-6118, 6151-6164, 6201-6214, 6251-6262, 6301-6312, 6351-6359, 6401-6409, 6451-6456, 6501-6506, 6551, 6552, 6601, 6602

NR04-03, Wainwright 6002-6006, 6052, 6053

NS04-08, (Unnamed) 6816-6822, 6861-6872, 6910-6922, 6958-6972, 7007-7022, 7055-7072, 7104-7122

Prior to submitting an exploration plan or developme nt and production plan (inc luding associated oilspill response plans) to the MMS for activities propo sed during subsistence-use critical times and locations described below for bowhead whale and oth er marine mammals, the lessee shall consult with the North Slope Borough, and with directly affected subsistence communities (Ba rrow, Point Lay, Point Hope, or Wainwright) and co-manageme nt organizations to discuss potential conflicts with the siting, timing, and methods of proposed operations and safeguards or miti gating measures that could be implemented by the operator to prevent unreasonable conflicts. Organizations currently recognized by the NMFS and the USFWS for the co-management of the marine mammals res ources are the Alaska Eskimo Whaling Commission, the Alaska Beluga Whale Committee, the Alaska Eskimo Walrus Commission, the Ice Seal Commission, and the Nanuuq Commission. Through this consultation, the lessee shall make every reasonable ef fort, including such mechanisms as a conflict avoidance agreement, to assure that exploration, development, and producti on activities are compatible with whaling and other marine mammal subsistence hunting activities and w ill not result in unreasonable interference with
subsistence harvests.

A discussion of resolutions reached during this cons ultation process and plans fo r continued consultation shall be included in the exploration plan or the development and production pl an. In particular, the lessee shall show in the plan how its activities, in co mbination with other activ ities in the area, will be scheduled and located to prevent un reasonable conflicts with subsistence activities. The lessee shall also include a discussion of multiple or simultaneous operations, such as ice management and seismic activities, that can be expected to occur during operations in order to mo re accurately assess the potential for any cumulative affects. Communities, individuals, and other entities who were involved in the consultation shall be identified in the plan. The RS/FO shall send a copy of the exploration plan or development and production plan (including associated oil-spill response plans) to the directly affected communities and the appropriate co-management organizati ons at the time the plans are submitted to the2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 114 July 2009 15276-03-09-001A/09-011A Rev. 1 MMS to allow concurrent review and comment as par t of the plan approval process. In the event no agreement is reached between the parties, the lessee, NMFS, USFW S, the appropriate co-management organizations, and any communities that could be direc tly affected by the proposed activity may request that the RS/FO assemble a group consisting of repres entatives from the parties to specifically address the conflict and attempt to resolve the issues. The RS/F O will invite appropriate parties to a meeting if the RS/FO determines such a meeting is warranted and relevant before making a final determination on the adequacy of the measures taken to p revent unreasonable conflicts with subsistence harvests. The lessee shall notify the RS/FO of all c oncerns expressed by subsistence hunters during operations and of steps
taken to address such concerns. Activities on a lea se may be restricted if the RS/FO determines it is necessary to prevent unreasonable conflicts with loca l subsistence hunting activities. In enforcing this stipulation, the RS/FO will work with other agencies and the public to assure that potential conflicts are identified and efforts are taken to avoid these conflicts. Subsistence- harvesting activities occur generally in the areas and time periods listed below.

Subsistence Whaling and Marine Mammal Hunting Activities by Community

Barrow : Spring bowhead whaling occurs from April to June; Barrow hunters hunt from Ice leads from Point Barrow southwestward along the Chu kchi Sea coast to the Skull Cliff area; fall whaling occurs from August to October in an area extending from approximately 10 miles west of Barrow to the east side of Dea se Inlet. Beluga whaling occurs from April to June in the spring leads between Point Barrow and Skull Cliff; later in the season, belugas are hunted in open water around the barrier islands off Elson Lagoon. Walrus are harvested from June to September from west of Barrow southwestward to Peard Bay. Polar bear are hunted from October to June generally in the same vicinity used to hunt walruses. Seal hunting occurs mostly in winter, but some open-water sealing is done from the Chu kchi coastline east as far as Dease Inlet and Admiralty Bay in the Beaufort Sea.

Wainwright : Bowhead whaling occurs from April to June in the spring leads offshore of Wainwright, with whaling camps sometimes as far as 10 to 15 miles from shore. Wainwright hunters hunt beluga whales in the spring lead system from April to June but only if no bowheads
are in the area. Later in the summer, from July to August, belugas can be hunted along the coastal lagoon systems. Walrus hunting occurs from July to August at the southern edge of the retreating pack ice. From August to September, walr uses can be hunted at local haulouts with the focal area from Milliktagvik north to Point Fran klin. Polar bear hunting occurs primarily in the fall and winter around Icy Cape, at the headland from Point Belcher to Point Franklin, and at
Seahorse Island.

Point Lay : Because Point Lay’s location renders it unsuitable for bowhead whaling, beluga whaling is the primary whaling pursuit. Beluga w hales are harvested from the middle of June to the middle of July. The hunt is concentrated in Naokak and Kukpowruk Passes south of Point Lay where hunters use boats to herd the whales in to the shallow waters of Kasegaluk Lagoon where they are hunted. If the July hunt is unsucces sful, hunters can travel as far north as Utukok Pass and as far south as Cape Beaufort in search of whales. When ice conditions are favorable, Point Lay residents hunt walruses from June to August along the entire length of Kasegaluk Lagoon, south of Icy Cape, and as far as 20 miles offshore. Polar bears are hunted from September to April along the coast, rarely more than 2 miles offshore.

Point Hope : Bowhead whales are hunted from March to June from whaling camps along the ice edge south and southeast of the point. The pack-ice lead is rarely more than 6 to 7 miles offshore. Beluga whales are harvested from Marc h to June in the same area used for the bowhead whale hunt. Beluga whales can also be h unted in the open water later in the summer2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 115 July 2009 15276-03-09-001A/09-011A Rev. 1 from July to August near the southern shore of Po int Hope close to the beaches, as well as areas north of the point as far as Cape Dyer. Wa lruses are harvested from May to July along the southern shore of the point from Point Hope to Akoviknak Lagoon. Point Hope residents hunt polar bears primarily from Janua ry to April and occasionally from October to January in the area south of the point and as far out as 10 miles from shore

Shell Proposed Actions:

Shell has actively engaged the NSB, Northwest Ar ctic Borough (NWAB), and affected subsistence communities of Barrow, Point Hope, Point Lay, Wain wright, Kivalina and Kotzebue and co-management organizations, including the Alaska Eskimo Whaling Commission (AWEC), to discuss potential conflicts between planned oil and gas activities and subsistence use activities. Shell’s EP lease blocks do not lie within the stipulation area, but Shell has voluntarily complied with the stipulation.

Plan of Cooperation

Shell began consulting with affected subsistence comm unities, stakeholders and federal, state, and local agencies in 2006 and prepared a POC for its Chukchi Sea open water activities (3D seismic activities and vessel transit) in November 2007. Shell continued with these consultations th rough 2008 and into 2009. Although a POC is not required by this Stipulation for any of the leases proposed in this EP, Shell will voluntarily continue to engage with subsistence stake holders to build on its past efforts to inform and engage the communities that could be affected by e xploration activities in the Chukchi Sea. It is also noted that a POC is required for an IHA from th e NMFS and USFWS. Shell met with the public and community leaders in January-April 2009 specifically to discuss the planned 2010 exploration drilling program in the Chukchi Sea, and to hear their concer ns. Shell has prepared a written POC that describes when and where the meetings were held, what wa s presented by Shell, the comments received, and Shell’s responses to these comments. The POC also identifies mitigation measures that Shell has prepared in response to these concerns. A copy of the POC is attached in Appendix I. The dates and locations of the meetings, along with the persons Shell met with, are listed below in Table 11.0-1

TABLE 11.0-1 Dates and Locations of Meetings Held Regarding t he 2010 Chukchi Sea Exploration Drilling Program for Development of the POC

2009 Meeting Location Meeting Attendees – Position

12-13 January Barrow Harry Brower - Whaling Capt ain, AEWC Chairman and Assistant Director of the NSB Wildlife Department Edward Itta - Whaling Capt ain and Mayor of the NSB Eugene Brower - Whaling Captain, AS RC Board Member and President of the NSB Assembly Anthony Edwardsen - Whaling C aptain and President of UIC Andy Mack - NSB Assistant to the Mayor Harold Curran - NSB Chief Administrative Officer Robert Suydam - NSB Wildlif e Department Biologist Cheryl Rosa - NSB Wildlife Department Research Biologist Craig George - NSB Wildlife Department Biologist 21 January Anchorage MMS 21 January Point Hope Steve Oommittuk - Mayor of Point Hope 21 January Barrow Charlie Hopson - Whaling Captain Representative, LCMF member, and AEWC alternate in Barrow Adeline Hopson – NSB Assembly Member 21 January Barrow Ray Koonuk - AEWC Commissioner and Point Hope Whaling Captain 21 January Barrow George Edwardsen - ICAS President Juanita Smith - ICAS Natural Resource Director2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 116 July 2009 15276-03-09-001A/09-011A Rev. 1

27 January Kotzebue Jackie Hill - Maniilaq Association Representative 27 January Kotzebue Martha Whiting – Mayor of the NWAB 27 January Kotzebue Chuck Greene, EJ Doll Garoutte, Walter Sampson, Gladys Pungowiyi - NANA Representatives 28 January Kaktovik Carla Sims - Kaktovik Vice Mayor 2 February Barrow NSB Assembly Workshop 2 February Barrow Plan of Cooperation Public Meeting 3 February Barrow Janice Meadows - AEWC Executive Director 3 February Barrow Vera Williams - Native Village of Barrow Realty Director Joseph Sage - Native Village of Barrow Wildlife Director 5 February Barrow Joseph Kaleak - AEWC Commissioner 5 February Kaktovik Whaling Captain Association and AEWC Representatives 5 February Kaktovik Plan of Cooperation Public Meeting 4-5 March Anchorage AEWC 2009 CAA Negotiations

24 March Point Hope Plan of Cooperation Public Meeting 25 March Kotzebue Plan of Cooperation Public Meeting 25 March Kotzebue NSB/NWAB Joint Planning Commission Meeting 26 March Wainwright Plan of Cooperation Public Meeting 2 April Barrow ICAS Monthly Meeting 6-8 April Anchorage Open Water Meeting 20 April Barrow Native Village of Barrow Meeting 22 April Point Lay Plan of Cooperation Public Meeting 23 April Kivalina Plan of Cooperation Public Meeting
Notes: AEWC = Alaska Eskimo Whaling Commission ASRC = Arctic Slope Regional Corporation ICAS = Iñupiat Community of the Arctic Slope LCMF = LCMF Incorporated. A subsidiary of Ukpeagvik Iñupiat Corporation NSB = North Slope Borough NWAB = Northwest Arctic Borough UIC = Ukpeagvik Iñupiat Corporation
Marine Mammal Co-Management Groups

Shell has facilitated quarterly meetings with the co-management groups including the Alaska Eskimo Whaling Commission (AEWC), Alaska Beluga Whale Committee, the Alaska Eskimo Walrus Commission, the Ice Seal Commission, and the Alaska Nanuuq Commission beginning in June 2006, continuing in June, September, and December 2007, and February, March, Ma y, June, and November 2008. Shell plans to continue these meetings to discuss potential conflicts that could arise with the siting, timing, and method of planned operations and mitigation measures regarding the planned 2010 exploration drilling activities. Shell also attends the Open Water Meetings held annually, which include the co-management groups AEWC, NMFS, MMS, USFW S, and other industry participants. Shell attended the Open Water Meeting for 2009, held in April 2009.

Stipulation No. 6 - Pre-Booming Requirements for Fuel Transfers

Fuel transfers (excluding gasoline transfers) of 100 barrels or more will require pre-booming of the fuel barge(s). The fuel barge must be surrounded by an oil-spill-containment boom during the entire transfer operation to help reduce any adverse effects from a fu el spill. The lessee’s oil-spill-response plans must include procedures for the pre-transfer booming of the fuel barge(s)

.

Shell Proposed Action:

A copy of Shell’s Fuel Transfer Plan (Alaska Fuel Operating Condition and Standard) is provided in
Attachment 9.4. Additional details for fuel tran sfers are provided in Appendix D of the Chukchi Sea Regional ODPCP. Under Shell’s procedures all v essel-to-vessel, vessel-to-drillship, and dock-to-vessel transfers of fuel will be pre-boomed during the 2010 season.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 117 July 2009 15276-03-09-001A/09-011A Rev. 1 Stipulation No. 7 - Lighting of Lease Structures to Minimize Effects to Spectacled and Steller’s
Eider

This stipulation will minimize the likelihood that spectacled and Steller’s eiders will strike drilling structures or vessels. The stipula tion also provides additional protection to eiders within the blocks listed below and Federal waters landward of the sale area , including the Ledyard Bay Critical Habitat Area, during times when eiders are present.

(A) General conditions: The following conditions apply to all exploration activities.

(1) An EP must include a plan for recording and repor ting bird strikes. All bird collisions (with vessels, aircraft, or drilling structures) shall be documented and reported within 3 days to MMS. Minimum information will include species, date /time, location, weather, identification of the vessel, and aircraft or drilling structure involved and its operational status when the strike occurred. Bird photographs are not required, but would be helpful in verifying species. Lessees
are advised that the USFWS does not recommend r ecovery or transport of dead or injured birds due to avian influenza concerns.

(2) The following conditions apply to operati ons conducted in support of exploratory and delineation drilling.

(a) Surface vessels (e.g., boats, barges) asso ciated with exploration and delineation drilling operations should avoid operating w ithin or traversing the listed blocks or
Federal waters between the listed blocks and th e coastline between April 15 and June 10, to the maximum extent practicable. If surfa ce vessels must traverse this area during this period, the surface vessel op erator will have ready access to wildlife hazing equipment (including at least three Breco buoys or simila r devices) and personnel trained in its use; hazing equipment may located onboard the vessel or on a nearby oil spill response vessel, or in Point Lay or Wainwright. Lessees are required to provide information regarding their operations within the area upon request of MMS. The MMS may request information regarding number of vessels and th eir dates of operation within the area.

(b) Except for emergencies or human/navigatio n safety, surface vessels associated with exploration and delineation drilling operations w ill avoid travel within the Ledyard Bay Critical Habitat Area between July 1 and Novem ber 15. Vessel travel within the Ledyard Bay Critical Habitat Area for emergencies or human/navigation safety shall be reported
within 24 hours to MMS.

(c) Aircraft supporting drilling operations will avoid operating below 1,500 feet above
sea level over the listed blocks or Federa l waters between the listed blocks and the coastline between April 15 and June 10, or the Ledyard Bay Critical Habitat Area between July 1 and November 15, to the maximum extent practicable. If weather prevents attaining this altitude, aircraft will use pre-designated flight routes. Predesignated flight routes will be establis hed by the lessee and MMS, in collaboration with the USFWS, during review of the EP. R oute or altitude deviations for emergencies or human safety shall be re ported within 24 hours to MMS.

(B) Lighting Protocols. The following lighting requirements apply to activities conducted between April 15 and November 15 of each year.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 118 July 2009 15276-03-09-001A/09-011A Rev. 1 (1) Drilling Structures: Lessees must adhere to lighting requi rements for all exploration or delineation drilling structures so as to minimize th e likelihood that migrating marine and coastal
birds will strike these structures. Lessees are required to implem ent lighting requirements aimed at minimizing the radiation of light outward from exploration or delineation drilling structures to minimize the likelihood that birds will strike t hose structures. These requirements establish a coordinated process for a performance-based obj ective rather than pre-de termined prescriptive requirements. The performance-based objective is to minimize the radiation of light outward from exploration/delineation stru ctures while operating on a lease or if staged within nearshore Federal waters pending lease deployment.

Measures to be considered include but need not be limited to the following:

 Shading and/or light fixture placement to direct light inward and downward to living and work structures while minimizing light radiating upward and outward;

 Types of lights;

 Adjustment of the number and intensity of lights as needed during specific activities;

 Dark paint colors for selected surfaces;

 Low-reflecting finishes or coverings for selected surfaces; and

 Facility or equipment configuration.

Lessees are encouraged to consider other techni cal, operational, and m anagement approaches that could be applied to their specific facilities and operations to reduce outward light radiation. Lessees must provide MMS with a written statement of measures that will be or have been taken to meet the lighting objective, and must submit th is information with an EP when it is submitted for regulatory review and approval pursuant to 30 CFR 250.203.

(2) Support Vessels: Surface support vessels will minimize the use of high-intensity work lights, especially when traversing the listed blocks and fe deral waters between the listed blocks and the coastline. Exterior lights will be used only as necessary to illuminate ac tive, on-deck work areas during periods of darkness or inclement weather (s uch as rain or fog), otherwise they will be turned off. Interior lights and lights used during navigation could remain on for safety.

For the purpose of this stipulation, the listed blocks are as follows:

NR02-06, Chukchi Sea: 6624, 6625, 6674, 6675, 6723-6725, 6773-6775, 6822, 6823, 6872

NR03-02, Posey: 6872, 6873, 6918-6923, 6967-6973, 7016-7023, 7063-7073, 7112-7123

NR03-03, Colbert 6674, 6723, 6724, 6771-6774, 6820-6824, 6869-6874, 6918-6924, 6966-6974, 7015-7024, 7064-7074, 7113-7124

NR03-04, Solivik Island 6011-6023, 6060-6073, 6109-6122, 6157-6171, 6206-6219, 6255-6268, 6305-6317, 6354-6365, 6403-6414, 6453-6462, 6502-6511, 6552-6560, 6601-6609, 6651-6658, 6701-6707, 6751-6756, 6801-6805, 6851-6854, 6901-6903, 6951, 6952, 70012010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 119 July 2009 15276-03-09-001A/09-011A Rev. 1 NR03-05, Point Lay West 6014-6024, 6062-6073, 6111-6122, 6160-6171, 6209-6221, 6258-6269, 6307-6317, 6356-6365, 6406-6414, 6455-6462, 6503-6510, 6552-6558, 6602-6606, 6652-6655, 6702, 6703

NR04-01, Hanna Shoal 6223, 6267-6273, 6315-6323, 6363-6373, 6411-6423, 6459-6473, 6507-6523, 6556-6573, 6605-6623, 6654-6671, 6703-6721, 6752-6771, 6801-6819, 6851-6868, 6901-6916, 6951-6964, 7001-7010, 7051-7059, 7101-7107

NR04-02, Barrow 6003-6022, 6052-6068, 6102-6118, 6151-6164, 6201-6214, 6251-6262, 6301-6312, 6351-6359, 6401-6409, 6451-6456, 6501-6506, 6551, 6552, 6601, 6602

NR04-03, Wainwright 6002-6006, 6052, 6053

NS04-08, (Unnamed) 6816-6822, 6861-6872, 6910-6922, 6958-6972, 7007-7022, 7055-7072, 7104-7122

Nothing in this stipulation is intended to redu ce personnel safety or preven t compliance with other regulatory requirements (e.g., U.S. Coast Guar d (USCG) or Occupational Safety and Health Administration) for marking or lighting of equipment and work areas.

Shell Proposed Actions:

Lease Stipulation No. 7 is not applicable to Shell’ s exploration program as planned as the EP blocks and drill sites are not within the stipulation area. The ri sk of Shell’s exploration drilling program having an effect on marine birds, especially Steller’s and spect acled eiders, due to collisions, is minimal because drilling would occur after the spring migration of most of these species, and more than 60 statute mi (97 km) offshore where the bird presence relatively low. However, Shell has considered the stipulation and voluntarily developed a Bird Strike Avoidance and Li ghting Plan that covers the planned exploration drilling program in the Chukchi Sea in 2010. In de velopment of the plan, Shell considered all the measures identified for consideration in the stipul ation, and selected the most proven and practical
measures to minimize the likelihood that marine birds will strike the drillship or support vessels. Shell’s plan includes:

 Bird strike monitoring, which will include r ecording and reporting bird, strikes for the collection of information on bird strikes and light ing configuration. This information can be
used to better understand methods to reduce bird strikes.

 Avian monitoring including visual observations a nd radar assessments to determine bird use of the prospect areas during the drilling period.

 Installing shading and directing some drillshi p lights inward and downward to living and work structures to minimize the amount of light radiating from the drillship.

 Lighting modifications including replacing some lights on the drillship with ClearSky light technology where applicable to reduce the amount of red light output.

 Minimizing the use of high-intensity work lights on support vessels.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 120 July 2009 15276-03-09-001A/09-011A Rev. 1  Restricting aircraft and vessel traffic including restrictions on travel routes and flight
altitudes.

In addition, Shell plans to conduct both visual and radar assessments of the numbers and species of birds around the drill sites during the operations, and investigate the reactions of the birds to the vessels. This
data should aid in the assessment of risk for future programs and provide some indication of the efficacy of the mitigation measures. A copy of the plan is provided in Appendix J2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 121 July 2009 15276-03-09-001A/09-011A Rev. 1 SECTION 12.0 ENVIRONMENTAL MITIGATION MEASURE INFORMATION

a) Permits and Authorizations

The General Information section (Section 2.0) identi fies the permits and authorizations required for the planned exploration drilling program. Shell will work within the mitigation measures written into these permits and authorizations, and ther efore will be working within all regulatory requirements. In addition to the permits and authorizations, Shell has met with marine mammal co-management groups, including the AEWC and Whaling Captains Associations, a nd NSB and NWAB community members, to discuss their concerns regarding marine mammal subsistence resources including the bowhead whale, beluga whale, walrus, ice seal, and polar bear.

b) Protected Species

Species that occur within the northeastern Chukchi Sea and are listed under the ESA as either threatened or endangered are listed below in Table 12.b-1. The Kit tlitz’s murrelet is included in the table only as a candidate species.

TABLE 12.b-1 Species Found in the Northeastern Chukchi Sea that are Protected under the Endangered Species Act.

Common Name Scientific Name ESA Status Extralimital (Yes/No)
Spectacled eider Somateria fischeri Threatened No
Steller’s eider Polysticta stelleri Threatened No
Kittlitz’s murrelet Brachyramphus brevirostris Candidate No
Polar bear Ursus maritimus Threatened No
Bowhead whale Balaena mysticetus Endangered No
Fin whale Balaenoptera physalus Endangered Yes Humpback whale Megaptera novaeangliae Endangered Yes

TABLE 12.b-2 Marine Mammals Found in the Northeastern Chukchi Sea that are Protected under t he Marine Mammal Protection Act.

Common Name Scientific Name ESA Status Extralimital (Yes/No)

Beluga whale Delphinapterus leucas Not listed No
Narwhal Monodon monoceros Not listed No
Killer whale Orcinus orca Not listed No Harbor Porpoise Phocoena phocoena Not listed No
Bowhead whale Balaena mysticetus Endangered No Gray whale Eschrichtius robustus Not listed Yes
Fin whale Balaenoptera physalus Endangered Yes
Minke whale Balaenoptera acutorostrata Not listed Yes Humpback whale Megaptera novaeangliae Endangered Yes
Bearded seal Erignathus barbatus In review for listing No Spotted seal Phoca largha In review for listing No Ringed seal Phoca hispida In review for listing No
Ribbon Seal Histriophoca fasciata Not listed No
Polar bear Ursus maritimus Threatened No

The planned exploration drilling program will likely involve the non-lethal incidental take of marine mammals. Shell is applying to NMFS for an IHA for the incidental take of whales and seals, and to
USFWS for an LOA for the non-lethal incidental and in tentional take of polar bears and Pacific walrus. Copies of the IHA and LOA applications are provi ded in Appendix C and E respectively. The IHA application contains a marine ma mmal mitigation and monitoring plan. The LOA application contains a2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 122 July 2009 15276-03-09-001A/09-011A Rev. 1 bear and walrus avoidance and human encounter / inte raction plan. Shell has also developed and will implement a Bird Strike Avoidance and Lighting Pl an (Appendix J). All three of these documents describe mitigation measures that Shell will implement to minimize any effects on protected species. The authorizations may also contain added mitigation measure s to help avoid or minimize incidental takes. A summary of mitigation measures that will be undertaken by Shell is provided below. The measures are annotated where they were developed partly or entirel y with the intent of avoiding or minimizing impacts on protected species.

c) Mitigation Measures

Subsistence

 Communication Plan for avoiding conflicts with subsistence users

 Collaboration and communication with Whaling Associations

 A POC with the affected communities and appropriate marine mammal commission(s).

 Subsistence Advisors based in Barrow, Wainwri ght, Point Lay, Point Hope, Kaktovik, Nuiqsut, Kivalina, Shishmaref, and Savoonga for consu ltation and guidance during the drilling season

 Community Liaisons in Barrow and Point Hope

 Aircraft will fly at an altitude of 1,500 ft (457 m) or higher except during takeoff, landing, low cloud ceilings, and during emergency situations

 The drillship and associated vessels will not enter the Chukchi Sea until on or about July 1 which
will minimize effects on subsistence hunts

 Inupiat Communicators will be aboard the drilling and key support vessels to provide
communication with subsistence hunters

Marine Mammals (protected species)

 Marine mammal observers on the Discoverer and support vessels

 A Marine Mammal Monitoring and Mitigation Plan protocol (4MP)

 Aircraft will fly at an altitude of 1,500 ft (457 m) or higher except during takeoff, landing, low cloud ceilings, and during emergency situations. Ai rcraft will not operate below 1,500 ft (457 m) unless the aircraft is engaged in marine mammal m onitoring, approaching, landing or taking off, or unless engaged in providing assistance to a wh aler or other subsiste nce hunter or in poor weather (low ceilings) or any other emergency situ ations. Aircraft engaged in marine mammal monitoring will not operate below 1,500 ft (457 m) in areas of active whaling; such areas to be identified through communications with the Co mmunications and Call Centers (Com Centers).

 Aircraft will not get closer than 1,500 ft (457 m) of groups of whales

 Aircraft and vessels will not operate within 0.5 mi (800 m) of walrus or polar bears when
observed on land or ice

 When within 900 ft (274 m) of marine ma mmals, vessels will reduce speed, avoid separating members from a group and avoid multiple changes of direction

 Vessel speed to be reduced during inclement weat her conditions in order to avoid collisions with
marine mammals2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 123 July 2009 15276-03-09-001A/09-011A Rev. 1  The drillship and associated vessels will not enter the Chukchi Sea until on or about July 1 which
will minimize effects on marine mammals

 Vessels underway will alter course to avoid impacts to marine mammals including possible collisions, stampeding, and exclusion from access to critical resources

 Shell will consult with regulatory agencies in th e event of any unavoidable interactions with marine mammals in order to achieve the most protective resolution

Birds (focused on protected species – eiders)

 Some lighting on the drillship will be replaced with ClearSky lighting that minimizes the
disorientation and attraction of birds associated w ith light and reduces probability of bird strikes

 Shading and minimizing the use of high intensit y lights on support vessels that minimizes the
disorientation and attraction of birds associated w ith light, and reduces probability of bird strikes

 Aircraft will fly at an altitude of 1,500 ft ( 457 m)or higher except during takeoff, landing, low cloud ceilings, and during emergency situations

 The drillship and associated vessels will not enter the Chukchi Sea until on or about July 1 which will minimize effects on marine birds that frequent open leads

Drilling Transit and Operations; Oil Spill Response

 Drilling muds will be recycled (used from one well to the next) to the extent practicable based on operational considerations (e.g., wh ether mud properties have deterior ated to the point where they cannot be used further), to reduce discharges fro m the operations. At the end of the season, excess water based fluids, approximately 1500 bbl , will be pre-diluted to a 30:1 ratio with seawater and then discharged.

 Drilling muds to be chilled to mitigate any pote ntial permafrost thawing around the drill pipe

 To minimize impacts on marine mammals and subsistence hunting activities, vessels that can safely travel outside of the polynya zone will do so, unless it is necessary to break ice (as opposed to managing ice by pushing it out of the way) or if sea state conditions require an alternative route. Shell will notify the local communities of any change in the transit route through the Com Centers. In all cases, vessel tran sits will follow a route that allows for the highest degree of safety regarding ice conditions and sea states.

 The transit route will avoid known fragile ecosystems and critical habitat areas

 Ice management around the Discoverer will involve redirecting, rather than breaking, ice floes while the floes are well away from the drill site

 Critical operations will not be started if the a rrival of potential hazards (ice floe, inclement weather, etc.) is less than the time available to complete the critical operation, suspend the well and make ready to evacuate

 OSR vessels on standby during drilling into liquid hydrocarbon bearing zones

 Real time ice and weather forecasting

Air Emissions

 Primary generators on the Discoverer retrofitted with selective catalytic reduction devices to
reduce NO

x emissions to under 0.5 g/kW-hr, and cat alytic oxidation devices to reduce CO by 80 percent, VOCs by 70 percent, and PM 10 by at least 50 percent2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 124 July 2009 15276-03-09-001A/09-011A Rev. 1  All other engines on Discoverer will either be Tier 3 (low emissions) or will be retrofitted with catalytic Diesel Particulate Filters to reduce devices to reduce CO, VOCs, and HAPs by at least 80 percent and fine particulate matter by at least 85 percent

 Ultra-low sulfur content (0.0015 percent) fuel will be used by the Discoverer and low-sulfur content (0.19 percent) fuel will be used by the support vessels to reduce SO2 emissions

 Limiting combined generator usage to 80 percent of combined engine capacity

 Limiting the MLC compressors, Units FD-9 th rough FD-11, to 2 of the 3 while the Discoverer is occupying a drill site

 Limiting daily cementing, logging, and cranes to 30 percent of combined engine capacity

 Limiting incinerator use to 1,525 lb/day2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 125 July 2009 15276-03-09-001A/09-011A Rev. 1 SECTION 13.0 SUPPORT VESSELS AND AIRCRAFT INFORMATION

a) Shell 2010 Chukchi Sea Drilling Vessels and Aircraft List

 Frontier Discoverer drillship

 M/V Vladimir Ignatjuk (or similar) ice management vessel,

 Tor Viking (or similar) anchor handler

 Offshore supply boat for resupply of drillship with drilling materials

 Shallow water landing craft for lightering, genera l supplies, shorebase access, and crew changes

 M/V Nanuq (or similar) OSRV

 Arctic Endeavor (with work boats) and Point Class Tug OSRB

 Affinity (or similar vessel) OST

 Helicopter (1 for search and rescue)

 Helicopter (1 for crew rotations)

 Fixed wing aircraft (1) for crew transport

 Fixed wing aircraft (1) for MMO flights

Vessels

The drillship Discoverer will be supported by an ice management vessel, an anchor handler, an offshore supply boat, a shallow water landing craft, and an OSR vessel. Specifications are provided in Table 13.a1 and 13.a-2 for some vessels that could be used. Some of the actual vessels to be used are not yet contracted and may be the vessels listed below or sim ilar vessels. Photographs of some of these vessels are provided below with brief descrip tions of their function and use.

TABLE 13.a-1 Specifications of Support Vessels

Specification Vladimir Ignatjuk 1 Tor Viking 1 Shallow Water Landing Craft 1 Offshore Supply Boat 1

Length 289 ft (88.02 m) 275 ft (83.7 m) 165 ft (50.3 m) 280 ft (85.3 m)

Width 57 ft (17.5 m) 59 ft (18.0 m) 38 ft (11.6 m) 60 ft (18.3 m)

Draft 27 ft (8.3 m) 20 ft (6.0 m) 10 ft (3.0 m) 19. ft (5.9 m)

Accommodations 34 berths 23 berths 22 berths 29 berths

Maximum Speed 16 knots (30 km/hr) 16 knots (30 km/hr) 16 knots 15 knots

Fuel Storage 11,070 bbl (1,760 m 3 ) 7,484 bbl (1,190 cu m) 667 bbl (106 m 3 ) 7,028 bbl (1,117 m 3 )

Notes: 1 or similar vessel

The Motor Vessel (M/V) Vladimir Ignatjuk (Photograph 13.1), or a similar vessel, will serve an ice management vessel in support of the Discoverer . This vessel will enter and exit the Chukchi Sea with the
Discoverer and will remain at a location approximately 3- 25 mi (5-40 km) upwind and upcurrent of the drillship when not in use. Any ice management would be expected to occur within 3-12 mi (5-19 km) of the drillship.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 126 July 2009 15276-03-09-001A/09-011A Rev. 1 Photograph 13.1 M/V Vladimir Ignatjuk

The M/V Tor Viking (Tor Viking) or a similar vessel will serve as the primary anchor handling vessel.
The vessel will enter and exit the Chukchi Sea with the Discoverer and will remain in the area of the drillship at all times. The Tor Viking is depicted below in Photograph 13.2.

Photograph 13.2 M/V Tor Viking

The drilling operations will require the transfer of some supplies between the shorebase and the drillship and support vessels. A Chukchi Sea supply vessel sim ilar to the vessel pictured in Photograph 13.3 will provide support to the 2010 exploration activities.

Photograph 13.3 Typical Shallow Water Landing Craft2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 127 July 2009 15276-03-09-001A/09-011A Rev. 1 The planned exploration drilling operations will require a supply boat to resupply the Discoverer with drilling materials and supplies and fuel. This vessel is not under contract yet, but is expected to be a typical offshore supply boat similar to the vessel depicted in Photograph 13.4.

Photograph 13.4 Offshore Supply Boat

Oil Spill Response Vessels

The OSR vessels include a dedicated OSRV and an OSRB, both of which have associated smaller workboats, an OST, and small boats located at the s horebase. The OSRV will be dedicated to Chukchi Sea operations and remain in the vicinity of the drillship when drilling into liquid hydrocarbon zones, with the OSRB staged nearshore a nd the OST staged to respond as needed to a discharge. The OSRV and tanker are expected to be the M/V Nanuq (Nanuq) and the Affinity, respectively, or similar vessels. Specifications for these vessels are provided below in Table 13.a-2. Photographs and descriptions of the Nanuq , OSRB and the Affinity are also provided.

TABLE 13.a-2 Specifications of the Major Oil Spill Response Vessels

Specification OSRV
( Nanuq ) OSRB
( Arctic Endeavor Barge ) OST
( Affinity )

Barge Tug

Length 301 ft (91.9 m) 205 ft (62.5 m) 90 ft (27.4 m) 748 ft (228 m)
Width 60 ft (18.3 m) 90 ft (27.4 m) 32 ft (9.8 m) 106 ft (32.3 m)
Fuel Storage 6,867 bbl -- 1,428 bbl 7,028 bbl
Liquid Storage 12,690 bbl 18,636 bbl -- 513,000 bbl

Accommodations 41 -- 6 25
Maximum Speed 16 knots -- 5 knots 15 knots Workboats (3) 34 ft work boats (1) 47 ft (14 m) skim boats (3) 34 ft (10 m) work boats (4) mini-barges -- --2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 128 July 2009 15276-03-09-001A/09-011A Rev. 1 The Nanuq (Photograph 13.5) or similar vessel will be stag ed in the vicinity of the drill site.

Photograph 13.5 M/V Nanuq

The Affinity (Photograph 13.6) or vessel with similar liquid st orage capacity will be staged in the vicinity
of the Chukchi Sea drill site so that it will arrive at a recovery site, if needed, within 24 hours of departure from their staging location. The purpose of the Affinity will be to provide a place to store large volumes of recovered crude oil, emul sions and free water. The Affinity has capacity beyond the storage volume for the maximum recovered oil and other liquids from th e maximum 30-day worst case discharge and may be used to assist refueling the Discoverer and support vessels, if necessary.

Photograph 13.6 Affinity

An OSRB such as the Arctic Endeavor (Photograph 13.7) or similar vessel and a Point Class tug will be staged in the nearshore zone. The OSRB will have stor age capacity for recovered liquids in the event of a spill, and would carry onboard response equipment th at includes a 47-ft (14-m) skimming vessels, 34-ft (10-m) workboats, mini-barges, boom and duplex skimming units for nearshore recovery.

Photograph 13.7 OSRB and Tug2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 129 July 2009 15276-03-09-001A/09-011A Rev. 1 Aircraft

Offshore operations will be serviced by helicopters op erated out of onshore support base locations. The helicopters are not yet contracted. An Agusta AW139 helicopter or EC 225 capable of transporting 10 to 12 persons, will be used to transport crews betwee n the onshore support base and the drillship. The helicopters will also be used to haul small amounts of food, materials, equipment, and waste between vessels and the shorebase. The flight corridor over the onshore and nearshore areas are indicated on Figure 13.e-2. Shell will have a second helicopter fo r Search and Rescue (SAR). This helicopter is expected to be a Sikorski 61 or similar model. Th is aircraft will stay grounded at a shorebase location except during training drills, emergencies, and other non-routine events.

A fixed wing propeller or turboprop aircraft, such as Saab 30-seat or Beechcraft 19-seat, will be used to routinely transport crews, materials, and equipmen t between the shorebase and hub airports such as Barrow or Fairbanks. A fixed wing aircraft, DeHa villand Twin Otter (DHC-6), will be used for MMO flights.

Fuel Storage Information and Frequency of Trips

The drillship, ice management vessel, anchor handling vessel, and OSRV ( Nanuq ), will meet at Dutch Harbor for supplies and fuel in mid-June 2010. The se vessels will depart Dutch Harbor around June 25 for the Chukchi Sea, crossing the Bering Strait and entering the Chukchi Sea on or about July 1. The supply boat and the OST will enter the Chukchi Sea on or about July 1 and join the Discoverer at the drill site prior to or just after the mooring of the drillshi p. The OSRB is stationed at West Dock at Prudhoe Bay and will be mobilized before drilling into liqui d hydrocarbon bearing zon es commences. The OSRB and associated tug will remain in the nearshore zone throughout Chukchi Sea exploration drilling operations. Drilling will cease on or before Octobe r 31 and the drillship and support vessels will leave
the Chukchi Sea.

The drillship will be supported by an ice management vessel such as the Vladimir Ignatjuk or similar vessel, an anchor-handling vessel, such as the Tor Viking or similar vessel, and an offshore supply boat. The drillship and support vessels cannot carry all the fuel they require for the entire drilling season. The OST will bring sufficient extra fuel in its tanks to support the drillship and support vessels for additional wells. Refueling of the Discoverer will be accomplished with the offshore supply boat using the fuel stored on the OST. Shell has prepared and will im plement the procedures d escribed in Shell’s Fuel Transfer Plan (Attachment 9.4) during all refu eling efforts. Workboats located on the OSRB and onshore
will be used to shuttle OSR crews between the shorebase and the OSRB for OSR training and drills. The expected frequencies of trips the above-referenced ma rine vessels would make during the planned drilling program are listed below in Table 13.a-3.

The SAR helicopter will be stationed in Barrow. The crew change helicopter will either be stationed in Wainwright or stationed in Barrow and relocated to Wainwright each day, where it will transport offshore crews and scientists between the Wainwright shoreb ase and the drillship. The crews will be transported between Wainwright and Anchorage using the fixed wing aircraft. The expected frequencies of trips the above referenced aircraft would make during the pl anned drilling program are listed below in Table 13.a3.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 130 July 2009 15276-03-09-001A/09-011A Rev. 1 TABLE 13.a-3 Fuel Storage Capacity and Trip Information for Support Vessels and Aircraft

Vessel Type Maximum Fuel Tank Storage Capacity Trip Frequency or Duration

Marine Vessels (or similar) Vladimir Ignatjuk – ice management 11,070 bbl 1,760 m 3 Will remain generally upwind of the Discoverer from 3-25 miles away throughout the 2010 Chukchi exploration drilling program Tor Viking -A nchor handling and ice management vessel 7,494 bbl 1,190 m 3 Stays in the area of Discoverer throughout drilling season

Offshore supply boat 7,028 bbl 1,117 m 3 2-4 round trips for resupply between drillship and Dutch Harbor during the drilling season Up to 5 refuel trips between OST and drillship during drilling season

Shallow water landing craft 667 bbl 106 m 3 Three round trips / week between Wainwright shorebase and support vessels during drilling season Three round trips / week between Wainwright shorebase & OSRB in July & August for OSR training & drills OSRVs (or similar)

OSRV 6,867 bbl 1,092 m 3 Stays in vicinity of the drillship throughout the drilling season
OSR work boats 7 bbl
1.1 m 3 12 round trips / week for 2 months for OSR drills & training – between Wainwright shorebase and OSRB OSRB 1,428 bbl (tug)
227 m 3 Will be located in the nearshore zone throughout the 2010 Chukchi exploration drilling program OST 513,000 bbl 81,560 m 3 Will be staged such that it can be on location winthin 24 hours Aircraft (or similar) (1) Saab (30 seats) or Beechcraft (B 1900) (19 seats) fixed-wing or similar – transport from shorebase to regional jet service 9 bbl 1.4 m 3 5 trips / week between Wainwright and Anchorage

(1) Helicopter - Agusta AW 139 or EC225 – for crew rotation & groceries/supply 18 bbl

2.9 m 3 7 round trips/ week Barrow to Wainwright
Approximately 30 trips/ month between the shorebase and prospects
(1) Helicopter Sikorski 61 or similar – search-andrescue 18 bbl 2.9 m 3 Stationed in Barrow – 40 hr/week for proficiency training & trips made in emergency2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 131 July 2009 15276-03-09-001A/09-011A Rev. 1 b) Air Emissions

Projected air emissions from support vessels are indicat ed below in Table 13.b-1 and discussed in detail in the air quality permit application.

TABLE 13.b-1 Projected Annual Air Emissions from the Support Vessels A ssociated with the Drillship Discoverer for the Chukchi Sea Exploration Drilling Program

Vessels PM 10

PM 25

NO x SO 2 CO VOC Lead Ice Management
ICE engines 189 167 1698 167 647 107 0.0221

Incinerators 4.13 2.83 0. 35 0.78 93.14 31.05 0.0661

Total 193.13 169.83 1698.35 167.78 740.14 138.05 0.0882
Resupply Vessel 0.03 0.03 0. 43 0.02 0.09 0.03 0.000

OSR Vessels 11 9 209 13 58 20 0.0286

All Vessels 205 179 1908 181 798 159 0.010

Notes:

Ice Management Vessels includes the ice management vessel and anchor-handler2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 132 July 2009 15276-03-09-001A/09-011A Rev. 1 c) Drilling Fluids and Chemical Products Transportation

The Discoverer will be preloaded with drilling fluids and other chemicals to be used for the drilling of a single well before it is mobilized to the prospects at the start of each drilling season. Drilling fluids will be recycled to the extent practicable based on ope rational considerations (e.g., whether mud properties have deteriorated to the point where they cannot be used further) and used for subsequent wells during the same drilling season. Any required additional drilli ng fluid components will be transported to the drillship from a storage area in Dutch Harbor via the offshore supply boat. Quantities to be on the
Discoverer at loadout are listed below in Table 13.c-1.

TABLE 13.c-1 Drilling Fluid Loadout for the Discoverer for the Chukchi Sea Exploration Drilling Program

Component Description Unit Size (lb) Package Total Usage

(lb) Total Weight (lb)

Barite Weighting agent 100 lb Sack 22,000 2,200,000

Gel Bentonite viscosifier 100 lb Sack 1,200 120,000

Caustic Soda Sodium hydroxide, pH control 50 lb Sack 200 10,000

Soda Ash Sodium carbonate, for raising pH 50 lb Sack 250 12,500

Bicarbonate Sodium bicarbonate, pH control 50 lb Sack 200 10,000 XC/XCD Polymer Xanthan gum, bioplymer 25 lb Sack 450 11,250

PHPA partially hydrolyzed polyacrylamide 50 lb Sack 800 40,000 Tackle (Alcomer 74) Modified acrylic polymer 50 lb Sack 100 5,000 Poly Pac R Polyanionic cellulose, reduce filtration rate 50 lb Sack 100 5,000 Poly Pac UL Polyanionic cellulose, reduce filtration rate 50 lb Sack 500 25,000 SP-101 Sodium polyacrylate cpolymer 50 lb Sack 300 15,000 Resinex Lignosulfonate polymer, filtrate reducer 50 lb Sack none 0 Tannathin Oxidized lignite, 50 lb Sack 200 10,000 Citric Acid Alkalinity control 50 lb Sack 100 5,000 Myacide biocide 5 gal Can 200 10,000 Contingency

Salt Sodium chloride 100 lb Sack 5,000 500,000

Gelex Polyacrylate/polyacrylamide, viscosifier 2 lb Sack 50 100

Defoam-X Polyglycol, reduce foaming in fluids 5 gal Can 90 4,500 Nut Plug (ASST) Ground nut shells, for lost circulation 50 lb Sack 200 8,000

MI Seal Lost circulation 40 lb Sack 200 8,000 MIX II (ASST) Blended calcium carbonate & polymers 25 lb Sack 200 5,000

DESCO CF Organic thinner 50 lb Sack 144 7,200 SAPP Sodium acid pyrophosphate, thinner 50 lb Sack 90 4,500 Lime Calcium hydroxide 50 lb Sack 80 4,000 Durogel Sepiolite clay, viscosifier, filtration reducer 50 lb Sack 600 30,000

Notes: Does not include barite on support vessels2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 133 July 2009 15276-03-09-001A/09-011A Rev. 1 d) Solid and Liquid Wastes Transportation

An incinerator will be onboard the Discoverer and will be used to dispose of combustibles. Authorized wastes will be discharged to the sea under an NPDES permit. The remaining wastes will be transported out of the Chukchi Sea by the supply boat and dispo sed of at a permitted and regulated facility. Food
wastes associated with the Discoverer will be incinera ted. Descriptions of the transportation methods and a brief description of the composition, quantities, and destination(s) of solid and liquid wastes to be transported by vessel from the Discoverer are provided below in Table 13.d-1.

TABLE 13.d-1 Transportation of Wastes
Type of Waste Amount Rate Transportation Method Disposal Location

Waste lube oil and glycol 40 bbl/well 1.2 bbl/day Stored in lube cubes, transferred by boat then truck to approved treatment/disposal site Phillips Services, Anchorage, AK

Chemical products and general hazardous
waste 10 bbl/well 0.3 bbl/day Stored in approved hazardous materials containers, then transferred to boat then truck to approved treatment/disposal site Phillips Services, Anchorage, AK

Trash and debris (nonrecyclables and recyclables) 300 bbl/well 10 bbl/day Stored in suitable bins then transferred by boat then truck to approved treatment/disposal site Phillips Services, Anchorage, AK

e) Vicinity Map and Travel Routes

Figure 13.e-1 depicts the locations of planned explora tion activities relative to the shoreline and shorebase and the primary route of the drillship and routes of support vessels when entering and exiting the Chukchi Sea and accessing the prospects. The route sma ller support vessels would follow to access the shorebase are also shown. The flight corridors that helicopter s would take between the shorebase and the prospects are indicated in Figure 13.e-2. The planned use of Wainwright is only for 2010 exploration drilling operations. Its use in 2010 does not necessarily re flect Shell’s planned shorebase operations in the
extended term.

f) Aircraft Waste Transportation

No drilling wastes will be transported via aircraft.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 134 July 2009 15276-03-09-001A/09-011A Rev. 1 Figure 13.e-1 Marine Vessel Routes2010 Outer Continental Shelf Leases Exploration PlanChukchi Sea, AlaskaShell Gulf of Mexico Inc. 135July 200915276-03-09-001A/09-011ARev. 1Figure 13.e-2 Flight Corridor2010 Outer Continental Shelf Leases Exploration PlanChukchi Sea, AlaskaShell Gulf of Mexico Inc. 136July 200915276-03-09-001A/09-011ARev. 1THIS PAGEINTENTIONALLYLEFT BLANK2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 137 July 2009 15276-03-09-001A/09-011A Rev. 1 SECTION 14.0 ONSHORE SUPPORT FACILITIES INFORMATION

a) General

Shell plans to temporarily establish aviation shorebase facilities potentially at two locations and use these facilities for the duration of the planned 2010 explor ation drilling program. Shorebase facilities for air support will be located in Barrow at the State-ow ned and operated Barrow Wiley Post Will Rogers Memorial Airport (Barrow Airport). A secondary avia tion shorebase may be established in the Village of Wainwright. The Barrow Airport has a 6,500 ft x 150 ft (1,980 m x 46 m) paved runway, hangar and service facilities, passenger terminal, and jet service. The Wainwright airstrip is gravel, 4,494 ft x 90 ft (1,370 m x 27 m), and maintained year round.

The SAR helicopter will be stationed and serviced in existing facilities at the Barrow airport. The crew change helicopter will be stationed either at the Barrow airport or the airstrip in the Village of Wainwright, pending on-going commercial arrangement s. A temporary hangar would be constructed on an existing pad at either location for housing the helic opter. Offshore crewmembers will be transported to shore either at Barrow or at Wainwright via helicopter. Those in Wainwright, if any, would then transport to Barrow or Anchorage using a fixed wing airplane. The helicopter would relocate from Wainwright to Barrow each morning and evening (if stationed at Ba rrow), or remain in Wainwright if the hangar is
constructed there.

Shell currently leases office space in Barrow and w ill continue to use these facilities during the 2010 exploration drilling program. Additional office space may be leased during 2010, but no other development of new facilities or expansion of exis ting facilities in Barrow is planned for 2010. Existing
accommodations such as hotels will be used as accommoda tions for the shorebase staff, which is expected to be approximately 6-7 persons.

Shorebase facilities for marine support will be temporarily established in the Village of Wainwright for the 2010 exploration drilling program. Community facilities in Wainwright include the city hall, police station, fire station, health clinic, community wate r and sewer systems, and airstrip. Shell will use the airstrip located in the Village of Wainwright, whic h is owned and operated by the North Slope Borough, for access by helicopters and fixed wing aircraft shuttling supplies and certain materials to the marine base. No expansions to the airstrip are planned; Shell may conduct improvements to the runway surface and conduct periodic maintenance throughout 2010. Th ere currently are no docks in Wainwright.

There are two earthen boat ramps (at the lagoon and at the lagoon entrance) connected to the village by gravel roads that would be used for marine access and support by shallow draft vessels. The primary ramp would be the lagoon ramp, and the primary use of the ramp would be to support OSR training. No new docks are planned for the 2010 exploration drilli ng program. Lift and hoi sting equipment (crane) would be installed near the ramp if feasible; an inv estigation into the need and feasibility of the hoisting equipment is currently underway. Lifting may be ac complished by forklifts and other smaller pieces of equipment.

Aviation and marine fuel will be stored in Wainwright to support the marine base, and a secure yard will be established for storage of oil spill response equipmen t and load staging for the marine vessels. Shell will use an existing 30,000-gallon (113 cubic meters [m 3 ]) tank for diesel and bring in three additional 50,000-gallon (189 m 3 ) tanks for aviation fuel. All four tanks will be inspected, certified, double-walled tanks on gravel pads, with secondary containment capa ble of holding 110 percent of the tank volume. If necessary, a camp will be established for a crew of 25-75 persons, which includes a small staff stationed at the location and accommodations for any crew members that are weathered-in. Existing2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 138 July 2009 15276-03-09-001A/09-011A Rev. 1 accommodations in the village will be used to the extent possible. Temporary accommodations will be established on developed land if required.

The shorebase in Wainwright will be used as a base in 2010 for shuttling materials and crew changes between land and the drillship, and the shorebase and the OSR vessels. Marine access will be accomplished by a relatively shallow draft landing vessel and OSR workboats. Descriptions of these vessels and aircraft as well as estimates of the frequency of trips they are likely to make are provided in
Section 13.0.

b) Air Emissions

Shell will lease existing facilities in Wainwright a nd Barrow for the shorebase and auxiliary support facilities. Any incremental increases in air emissions associated with Shell’s activities at the shorebase facilities, including air emissions associated with ai rcraft emissions, will be minimal and temporary.

c) Unusual Solid and Liquid Wastes

There will not be any unusual solid or liquid wast es generated at the shorebase facility. Any wastes generated will be disposed of in the Wainwright landfill operated by the NSB.

d) Waste Disposal

Table 14.d-1 identifies the waste streams anticipated to be generated by the exploration drilling program that will be transported to shore for disposal.

TABLE 14.d-1 Shorebase Waste Disposal Facilities, Wast e Type, Amount, Rate, and Disposal Method

Name/Location of Facility Type of Waste Amount Rate Disposal Method

Philips Services Anchorage, AK Non-hazardous trash and debris oily rags & filters,
etc. 300 bbl/month 10 bbl/day Land-farmed and/or incinerated

Philips Services Anchorage, AK Paint, solvents, unused chemicals, batteries, lamps, etc 10 bbl/well 0.3 bbl/day Hazardous waste disposal in Class 1 injection well or approved TDS Philips Services Anchorage, AK Used oil & glycol 40 bbl/well 1.2 bbl/day Land-farmed and/or incinerated2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 139 July 2009 15276-03-09-001A/09-011A Rev. 1 SECTION 15.0 COASTAL ZONE MANAGEMENT ACT

Attachment 15.1 is the Coastal Project Qu estionnaire and Certification Statement.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 140 July 2009 15276-03-09-001A/09-011A Rev. 1 

## THIS PAGE
INTENTIONALLY
LEFT BLANK2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 141 July 2009 15276-03-09-001A/09-011A Rev. 1 

## Attachment 15.1

Alaska Coastal Management Program Coastal Project Questionnaire & Certification Statement2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 142 July 2009 15276-03-09-001A/09-011A Rev. 1 

## THIS PAGE
INTENTIONALLY
LEFT BLANK2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 143 July 2009 15276-03-09-001A/09-011A Rev. 1 State of Alaska, Department of Natural Resources, Division of Coastal & Ocean Management



# Coastal Project Questionnaire and Certification Statement

The Coastal Project Questionnaire (CPQ) is a diagnostic tool that will identify the state and federal permit requirements for your project that are subject to a c onsistency review. You must answer all questions. If you answer “Yes” to any of the questions, please call that specific department for further instructions to avoid delay in processing your application . You can find an agency contact list
online at http://alaskacoast.state.ak.us/Contacts/PRCregcont.html

.

A complete project packet includes accurate ma ps and plan drawings at scales large eno ugh to show details, copies of your state and federal permit applications, your answers to this questionnaire, and a complete consistency evaluation. DCOM will notify you w ithin 21 days of receipt if the packet is incomple te and what information is still required.

For additional information or assistance, you may call or email the Juneau Project Review at (907) 465-2142, or the Anchorage Project Review at (907) 269-7478

. This CPQ document contains numerous hyperlinks (underlined text that has a connection to an internet web page) and is best viewed on-line. Additional instructions are available at http://www.alaskacoast.state.ak.us/Projects/pcpq.html

 APPLICANT INFORMATION

1. Shell Gulf of Mexico Inc.
Name of Applicant 3601 C Street, Suite 1000

Address Anchorage, Alaska 99503
City/State/Zip 907-770-3700
Daytime Phone 907-770-3636 Susan.Childs@shell.com

Fax Number E-mail Address 2. Steve Ellsworth
Agent (or responsible party if other than applicant) 3601 C Street, Suite 1000

Address Anchorage, Alaska 99503
City/State/Zip 907-771-7205
Daytime Phone 907-770-3636 steve.ellsworth@shell.com

Fax Number E-mail Address

 PROJECT INFORMATION Yes No 1. This activity is a: new project modification or addition to an existing project 2. If this is a modification or an addition, do you currently have any State, federal or local approvals for this activity? NOTE: Approval means any form of authorization. If "yes," please list below: Approval Type Approval # Issuance Date Expiration Date MMS Exploration Plan

NMFS IHA

USACE NWP 8

USEPA Air Quality

USEPA NPDES GP AKG-28-0000

USFWS LOA 3. If this is a modification, was this original project re viewed for consistency with the Alaska Coastal Management

Program? ......................................................................................................................

....................................................... Previous ACMP I.D. Number: (example: AK 0706-05AA or ID2004-0505JJ)

Previous Project Name: Previous Project Applicant:2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 144 July 2009 15276-03-09-001A/09-011A Rev. 1  PROJECT DESCRIPTION

Attach a complete and detailed narrative description of your ne w project or of your modification/addition including ALL associated facilities and changes to the current land or water use (if not already attached as part of an agency application). Clearly delineate the project boundaries and all property owners, including owners of adjacent land, on the site plan. The scale of the maps and plan drawings must be large enough to show pertinent details. Identify your proposed footprint or disturbed area. If this project is a modification to an approved project, identify existin g facilities and proposed changes on the site plan.

Proposed starting date for project: on or about July 4, 2010 Proposed ending date for project: October 31, 2010.

 PROJECT LOCATION and LAND OWNERSHIP Yes No
4. Describe/identify the project location on a map (Including near est community, the name of th e nearest land feature or body of water, and other legal description such as a survey or lot number.).
Township Range Section Meridian

Latitude/Longitude 71 degrees / 171 degrees (specify Decimal Degrees or Degrees, Minutes, Seconds) USGS Quad Map Chukchi OCS Planning Area See attached project area map showing Shell leases and leases covered in the Exploration Plan.
5. The project is located on: State land or water* Federal land Private land Municipal land (Check all that apply) Mental Health Trust land University of Alaska land Contact the applicable landowner(s) to obtain necessary authorization. State land ownership can be verified using Alaska Mapper

. *State land can be uplands, tidelands or submerged lands to 3 miles offshore

. 6. Is the project within or as sociated with the Trans Alaska Pipeline co rridor? ..................................................

....................

 COASTAL DISTRICT Yes No

7. Is the project located in a coastal district ? ..........................................................................................................................

If yes, identify the applicab le coastal district(s) North Slope Borough review and contact them to ensure your project conforms with district policies and zoning requirements. Coastal districts are a municipality or borough, home rule or first class city, second class municipality with planning pow ers, or coastal resource service area. A coastal district is a participant in the State's consistency review process. Early interaction with the district can benefit you significantly; please contact the district representative listed on the contact list at http://www.alaskacoast.state.ak.us/Contacts/PRCregcont.html

 DEPARTMENT OF NATURAL RESOURCES (DNR) APPROVALS
DNR DIVISION OF MINING, LAND & WATER - LAND SECTION Yes No 1. Is the proposed project on State- owned land or water or will you need to cross State-owned land for access? (NOTE: State land includes the land below the ordinary high water line of navigable streams, rivers and lakes, and in marine waters, below the mean high tide line seaward for three miles. State land does not include Alaska Mental Health Trust Land or University of Alaska Land.)

.................................................................................................... 2. If you answered yes to the question above, indicate the person you contacted at the appropriate Division of Mining,

Land and Water regional office for information.
a) Name/date of Contact: b) Is an application required for the proposed ac tivity? ......................................................................

............................... c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation: Shore-based facilities under third party contractor permits.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 145 July 2009 15276-03-09-001A/09-011A Rev. 1 DNR DIVISION OF MINING, LAND & WATER - MATERIALS SECTION Yes No 3. Do you plan to dredge or otherwise excavate or remove materials such as rock, sand, gravel, peat, or overburden from

any land regardless of ownership?

................ a) Location of excavation site if different than the project site:

Township Range Section Meridian

4. At any one site (regardless of land ownership), do you plan any of the following? Excavate five or more acres over a year’s time Excavate 50,000 cubic yards or more of materials (rock, sand, gravel, soil, peat, over burden, etc.) over a year’s
time Have a cumulative, un-reclaimed, excavated area of five or more acres 5. Do you plan to place fill or excavated material on State-owned land?

a) Location of fill or material disposal site if different than the project site:

Township Range Section Meridian 6. If you answered yes to any question above, in dicate the person you contact ed at the appropriate Division of Mining,

Land and Water regional office for information.
a) Name/date of Contact: b) Is an application required for the proposed ac tivity? ......................................................................

................................ c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation:

DNR DIVISION OF MINING, LAND & WATER - MINING SECTION Yes No 7. Do you plan to mine for locatable minerals such as silver, gold, or copper? ....

.............. ................ .............. ..................... 8. Do you plan to explore for or extract coal? ................................................................................

........................................ 9. If you answered yes to any question above, in dicate the person you contact ed at the appropriate Division of Mining,

Land and Water regional office for information.
a) Name/date of Contact: b) Is an application required for the proposed ac tivity? ......................................................................

................................ c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation:

DNR DIVISION OF MINING, LAND & WATER - WATER SECTION Yes No 10. Will this project or development divert, impound, withdraw , or use any fresh water (regardless of land ownership)? (NOTE: If you know of other water users who withdraw from the same source or any potential conflicts affecting this use of water, contact the Water Section. If you are obtaining wa ter exclusively from either an exi sting Public Water Supply or f

rom a rainwater catchment system, you are not required to contact the DNR Water Section regional office.)

......................

a) Check all points-of-withdrawal or water sources that apply Public Water system (name):
Stream or Lake (name):

Well Rain catchment system

Other: b) Intended use(s) of water:
c) Amount (maximum daily, not average, in gallons per day): d) Is the point of water w ithdrawal on property you ow n? ............................................................................. 11. Do you plan to build or alter a dam (regardless of land ownership)? .......................................................

........................... 12. If you answered yes to any question above, indi cate the person you contact ed at the appropriate Division of Mining,
Land and Water regional office for information.
a) Name/date of Contact:2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 146 July 2009 15276-03-09-001A/09-011A Rev. 1

b) Is an application required for the proposed ac tivity? ......................................................................

................................. c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation:

DNR DIVISION OF FORESTRY Yes No 13. Does your operation meet both of the following criteria on any land, regardless of ownership? a) The project will commercially harvest timber on 10 or more acres, or commercially harvest timber that intersects,

encompasses, or borders on surface waters, and b) The project involves one or more of the following: site preparation, thinning, slash treatment, construction and

maintenance of roads associated with a commercial timber harvest, or any ot her activity leading to or connected to a commercial timber harvest operation................................................................................................................

...... 14. If you answered yes to any question above, indi cate the person you contacted at the appropriate Division of Forestry regional office for information.
a) Name/date of Contact: b) Is an application required for the proposed ac tivity? ......................................................................

................................ c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation:

DNR DIVISION OF OIL & GAS Yes No 15. a) Will you be exploring for or producin g oil and/or gas? ......

............................................. ........................ b) Will you conduct surface use ac tivities on/within an oil and ga s lease or unit ? ...........................

................... If yes, please specify: Federal OCS Chukchi Sale 193 Oil and Gas Leases

16. Do you plan to drill a geothermal well (re gardless of land owners hip)? ..............................

............................ 17. If you answered yes to any question above, indi cate the person you contact ed at the appropriate Division of Oil & Gas
office for information.
a) Name/date of Contact: Not applicable for federal OCS lease activities

b) Is an application required for the proposed activity? .............................................................................. c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation: Federal MMS Jurisdiction - Exploration Plan Approval
Visit the Division of Oil & Gas website for application forms and additional information.

DNR OFFICE OF HISTORY & ARCHAEOLOGY Yes No 18. Will you investigate, remove, or impact historical, archae ological or paleontological resources (anything over 50 years old) on State-owned land refer to EIA, Section 16 of Exploration Plan 19. If you answered yes to the question above , indicate the person you contacted at the State Historic Pr eservation Office
for information.
a) Name/date of Contact:

DNR DIVISION OF GEOLOGICAL & GEOPHYSICAL SURVEYS Yes No 20. Is the proposed project locat ed within a natural hazard area designated by a coastal distri ct in the approved district plan? ........................................................................................................................................ a) If “yes”, describe the measures you will take in the siting, design, construction, and operation of the proposed activity to protect public safety, services, and the environment from potential damage caused by the designated natural hazard(s)* *See the attached coastal consistency evaluation section on Natural Hazards for more detailed information. Exploration is outside of the coastal zone and co astal districts and not in any known hazard area.

21. If “YES” and you have contacted someone, pl ease indicate the person you contacted at the Division of Geological and Geophysical Surveys or the coastal district for information.
a) Name/date of Contact:2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 147 July 2009 15276-03-09-001A/09-011A Rev. 1 DNR DIVISION OF PARKS & OUTDOOR RECREATION Yes No 22. Is the proposed project lo cated in a unit of the Alaska State Park Syst em including navigable waters, tidelands or submerged lands to three miles offshore? .............................................................................................. 23. If you answered yes to any question above, indi cate the person you contacted at the appropriate DNR Division of Parks
& Recreation office for information.
a) Name/date of Contact: b) Is an application required for the proposed activity? .............................................................................. c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation:

DNR OFFICE OF HABITAT MANAGEMENT & PERMITTING Yes No 24. Will you work in, remove water or material from, or place anything in, a stream, river or lake ? (NOTE: This includes work or activities below the ordinary high water mark or on ice, in the active fl ood plain, on islands, in or on the face of the banks, or, for streams entering or flowing through tidelands, above the l evel of mean lower low tide. If the proposed project is located within a special flood hazard area, a municipal floodplain development permit may be required. Contact the affected city or borough planning department for additional information and a floodplain determination.)

............................................................................................................................. a) If yes, name of waterbody: 25. If you answered yes to any question above, in dicate the person you contact ed at the appropriate Division of Habitat Management and Permitting office for information.
a) Name/date of Contact: b) Is an application required for the proposed activity? .............................................................................. c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation:

DNR APPROVALS List the Department of Natural Resources permits or authorizations required for your project below: Types of project approvals or permits needed. Date application submitted

 DEPARTMENT OF FISH AND GAME (DFG) APPROVALS Yes No 1. Is your project located in a designated State Game Re fuge, Critical Habitat Area or State Game Sanctuary? ............... 2. Does your project include co nstruction/operation of a salm on hatchery? ............

................................. ............ 3. Does your project affect, or is it related to, a previously permitted sa lmon hatchery?

.......................................... 4. Does your project include construction of an aquatic farm? ........................

.................................... ............ 5. If you answered yes to any questions abov e, indicate the person you contacted at the Department of Fish and Game for

information.
a) Name/date of Contact: b) Is an application required for th e proposed activity? ...........................................................................

.

c) If “YES” then submit a signed copy of the completed app lication to the DCOM. If “No” , explain why an application

isn’t required. Explanation:2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 148 July 2009 15276-03-09-001A/09-011A Rev. 1 DFG APPROVALS List the Department of Fish and Game permits or authorizations required for your project below: Types of project approvals or permits needed. Date application submitted

 DEPARTMENT OF ENVIRONMENTAL CONSERVATION (DEC) APPROVALS

DEC DIVISION OF WATER Yes No 1 a) Will a discharge of non-domestic wastewater to lands, waters, or the subsurface of the state occur? (NOTE: Nondomestic wastewater includes wastewater from commercial or industrial facilities, excavation projects, wastewater from man-made containers or containment areas, or any other non-domestic wastewater disposal activities see 18 AAC 72.990 for definitions.)

......................................................................................................... b) Will a discharge of domestic wastewater or septage to lands, waters or the su bsurface of the state occur? (see 18 AAC 72.990 for definitions.)

........................................................................................................... c) Will the wastewater disposal activity require a mixing zo ne or zone of deposit to meet Water Quality Standards

(WQS)? (Many disposal activities require a mixing zone to meet WQS, contact DEC if unsure. ) .......................... d) Will the project include a stormwater co llection/discharge syst em? .....................

....................................... e) Will the project include placing fill in wetlands? .........

................................................ ......................... f) Is the surrounding area inundated with wa ter at any time of the year? .......................................................... g) Do you intend to construct, install, modify or use any part of a domestic or non-domestic wastewater treatment or

disposal system? ........................................................................................................................ 2. Does your project qualify for a general permit fo r wastewater? ............................................................

... 3. If you answered yes to any questions above, indicate th e person you contacted at the DEC-Division of Water for
information.
a) Name/date of Contact: b) Is an application required for the proposed activity? .............................................................................. c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation: EPA NPDES General Permit AKG-28-0000, Notice of Intent

DEC DIVISION OF ENVIRONMENTAL HEALTH Yes No 4 a) Will your project result in construction, modification, or operation of a facility for solid waste disposal? (NOTE: Solid waste means drilling wastes, household garbage, refuse, sludge, construction or demolition wastes, industrial solid waste, asbestos, and other discarded, abandoned, or unwanted solid or semi-solid material, whether or not subject to decomposition, originating from any source. Disposal means placement of solid waste on land.)

......... . b) Will your project result in treatment of solid waste at the site? (Examples of treatment methods include, but are not

limited to: incineration, open burning, baling, and composting.)

............................................................... c) Will your project resu lt in storage or transf er of solid waste at the site? ............

........................ ................... d) Will the project result in storage of more than 50 tons of materials for reuse, recycling, or resource recovery? ......... e) Will any sewage solids or biosolids be di sposed of or land-applied to the site? (NOTE: Sewage solids include wastes

that have been removed from a wastewater treatment plant system, such as a septic tank lagoon dredge, or wastewater treatment sludge that contain no free liquids. Biosolids are the solid, semi- solid or liquid residues produced during the treatment of domestic septage in a tr eatment works which are land applied for beneficial use.)

.. 5. Will your project require application of oil, pestic ides, and/or any other broa dcast chemicals? ............................... 6. Does your project qualify for a general permit for solid waste?

............ ............. ........... ............. ........... .... 7. If you answered yes to any question abov e, indicate the person you contacted at the DEC- Division of Environmental

Health for information.
a) Name/date of Contact: b) Is an application required for the proposed activity? .............................................................................. c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation: Use existing permitted facilities.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 149 July 2009 15276-03-09-001A/09-011A Rev. 1 DEC DIVISION OF AIR QUALITY Yes No
8 a) Will you have an asphalt plant designed to process no less than five tons per hour of product? ...........................

b) Will you have a thermal remediation unit with a rated capacity of at least five tons per hours of untreated material? .. c) Will you have a rock crusher w ith a rated capacity of at least fi ve tons per hour ? ........................

.................... d) Will you have one or more incinerators with a cumulative rated capacity of 1,000 pounds or more per hour? ........... e) Will you have a coal preparatio n plant? ....................................

.................................... ..................... f) Will you have a Port of Anchorage st ationary source? ...

................................................ ......................... g) Will you have a facility with the potential to emit no less th an 100 tons per year of any regulated air contaminant?..... h) Will you have a facility with the poten tial to emit no less than 10 tons per y ear of any hazardous air contaminant or

25 tons per year of all hazardous air contaminants?.........

............... .............. ................ ............ .......... ............................ i) Will you be constructing a new st ationary source with a potential to emit greater than: .................................... 15 tons per year (tpy) of PM-10 40 tpy of nitrogen oxides 40 tpy of sulfur dioxide 0.6 tpy of lead; or 100 tpy of CO within 10 km of a nonattainment area j) Will you be commencing construction, or (if not already authorized under 18 AAC 50 ) relocating a portable oil and gas operation? (answer “yes” unless you will comply with an exis ting operating permit devel oped for the portable oil and gas operation at the permitted location; or you will operate as allowed under AS 46.14.275 without an operating permit)

......................................................................................................................................... k) Will you be commencing construction or (if not already authorized under 18 AAC 50) relocating an emission unit

with a rated capacity of 10 million Btu or more per hour in a sulfur dioxide special protection area established under
18 AAC 50.025? ........................................................................................................................ l) Will you be commencing a physical change to or a change in the method of construction of an existing stationary

source with a potential to emit an air polluta nt greater than an amount listed in g) that will cause for that pollutant an emission increase (calculated at your discretion) as either an increase in potential to emit that is greater than: 10 tpy of PM-10 10 tpy of sulfur dioxide 10 tpy of nitrogen oxides; or 100 tpy of CO within 10 km of a nonattainment area; or

actual emissions and a net emissions increase greater than: 10 tpy of PM-10 10 tpy of sulfur dioxide 10 tpy of nitrogen oxides; or 100 tpy of CO within 10 km of a nonattainment area m) Will you be commencing construction or making a major m odification of a Prevention of Significant Deterioration

stationary source under 18 AAC 50.306?

............................................................................................ n) Will you be commencing construction or making a major modification of a nonattainment area major stationary

source under 18 AAC 50.311?

......................................................................................................... o) Will you be commencing construction or reconstructing a major stationary source under 18 AAC 50.316, for

hazardous air pollutants? Definition of Re gulated Air Pollutants can be found at http://www.epa.gov/ttn/oarpg/t5/memoranda/rapdef.pdf

.................................................................................................. 9. If you answered yes to any questions a bove, indicate the person you contacted at the DEC- Division of Air Quality for

information.
a) Name/date of Contact: b) Is an application required for th e proposed activity? .............................................................................. b) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an
application isn’t required. Explanation: EP A Jurisdiction for OCS Oil and Gas Drilling Project EPA has jurisdiction of the OCS oil and gas project. Shell Gulf of Mexico Inc. (Shell) is applying for a preconstruction permit from EPA Region 10 for the operation of the Discoverer drillship and associated vessels in the Chukchi Sea more than the 25 mi (40 km) offshore of Alaska under the OCS permitting rules (40 CFR 55).2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 150 July 2009 15276-03-09-001A/09-011A Rev. 1 DEC DIVISION OF SPILL PREVENTION AND RESPONSE Yes No 10 a) Will your project involve the operatio n of waterborne tank vessels or oil barges that carry crude or non crude oil as bulk cargo, or the transfer of oil or other petroleum products to or from such a vessel or a pipeline system? ............. b) Will your project require or include onshore or offshore oil facilities with an effective aggregate storage capacity of

greater than 5,000 barrels of crude oil or greater than 10,000 barrels of non -crude oil? ...................................... c) Will you operate facilities on land or water for expl oration or production of hydrocarbons?

............................... 11. If you answered yes to any questions above, indicate the person you contacted at the DEC-Division of Spill Prevention and Response office for information.
a) Name/date of Contact: b) Is a plan required for the proposed activity? .............................................................................. c) If “YES” then submit a signed copy of the completed Oil Discharge Prevention & Contingency Plan to the DCOM.

If “No”, explain why an application isn’t required. Explanation: MMS Oil Spill Response Plan

DEC APPROVALS List the Department of Environmental Conservation permits or authorizations required for your project below : Types of plan approvals or permits needed Date application submitted

ACMP Review participant

 FEDERAL APPROVALS U.S. ARMY CORPS OF ENGINEERS (USACE) Yes No 1. Will you discharge dredged and/or fill ma terial or perform dredging activities in wa ters of the U.S? Section 404 of the

Clean Water Act requires that a Department of the Army permit be obtained for the placement or discharge of dredged
and/or fill material into waters of the U.S., including wetlands (33 U.S.C. 1344). (Your application to the USACE would also serve as application for DEC Water Quality Certification.)

............... 2. Will you place fill or structures or perf orm work in waters of the U.S? Secti on 10 of the Rivers and Harbors Act of 1899 requires that a Department of the Army permit be obtained for structures or work in or affecting navigable waters of the U.S. (33 U.S.C. 403) (Waters of the U.S. include marine waters s ubject to the ebb and flow of the tide, rivers, streams, lakes tributaries, and wetlands

. If you are not certain whether your pr oposed project is located within a wetland, contact the USACE Regulatory Division to request a wetlands determination. For additional information about the Regulatory Program, visit www.poa.usace.army.mil/reg )

............................................... 3. If you answered yes to the question abov e, indicate the person you contacted at the US Army Corps of Engineers for

information.
a) Name/date of Contact: Alyssa Starrett
b) Is an application required for th e proposed activity? .............................................................................. c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation: PCN for NWP#8 attached Appendix G of EP.

BUREAU OF LAND MANAGEMENT (BLM) Yes No 4. Is the proposed project located on BLM land, or will you need to cros s BLM land for access? ... 5. If you answered yes to the question above, indicate the person you contacted at the Bureau of Land Management for
information.
a) Name/date of Contact: b) Is an application required for th e proposed activity? .............................................................................. c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation:

U.S. COAST GUARD (USCG) Yes No
6 a) Do you plan to construct a bridge or causeway over tidal (ocean) waters, or navigable rivers, streams or lakes? .........

b) Does your project involv e building an access to an island? ...................................................................... c) Do you plan to site, construct, or operate a deepwater port? .....................................................................2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 151 July 2009 15276-03-09-001A/09-011A Rev. 1 7. If you answered yes to any question above, indi cate the person you contacted at the appropriate US Coast Guard office

for information.
a) Name/date of Contact: b) Is an application required for th e proposed activity? .............................................................................. c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation:

U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA) Yes No
8 a) Will the proposed project have a disc harge to any waters?

............................................. ...........................

b) Will you dispose of sewage sludge? ....................................

.................................... ......................... c) Will construction of your project expose 1 or more acres of soil? (NOTE: This applies to the total amount of land

disturbed, even if disturbance is distributed over more than one season, and also applies to areas that are part of a larger common plan of development or sale.)

....................................... d) Is your project an industrial facility that will have stormwater discharge directly related to manufacturing,

processing, or raw materials storage areas at an industrial plant? If you answered yes to c) or d), your project may require an NPDES Stormwater permit ............................................................... 9. If you answered yes to any question above, indicate the person you contacted at the US Environmental Protection

Agency for information.
a) Name/date of Contact: Sonia Porter
b) Is an application required for th e proposed activity? .............................................................................. c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation: Copy of Notice of Intent to be covered under NPDES General Permit AKG 280000 is
attached as Appendix B of EP.

FEDERAL AVIATION ADMINISTRATION (FAA ) Yes No
10 a) Is your project located within five miles of any public airport? .............................. b) Will you have a waste discharge that is likely to decay within 5, 000 feet of any public airport?

........................... 11. If you answered yes to the question ab ove, indicate the person you contacted at the Federal Aviation Administration
for information.
a) Name/date of Contact:

FEDERAL ENERGY REGULATORY COMMISSION (FERC) Yes No
12 a) Does the project include any of the following:

.................................................................................... 1) a non-federal hydroelectric project on any navigable body of water 2) locating a hydro project on federal land (including transmission lines) 3) using surplus water from any federal government dam for a hydro project b) Does the project include construction and operation, or abandonment of interstate natural gas pipeline facilities under

sections 7 (b) and (c) of the Natural Gas Act (NGA)? .............................................................................. c) Does the project include construction and operation of na tural gas or liquefied natural gas importation or exportation

facilities under section 3 of the NG A? .................

............... ............... ............... ............... ........... ..................................... d) Does the project include construction for physical inte rconnection of electric transmission facilities under section

202 (b) of the FPA?

.......................................................................................................................... 13. If you answered yes to any question above, indi cate the person you contacted at the appropriate Federal Energy Regulatory Commission office for information.
a) Name/date of Contact: b) Is an application required for th e proposed activity? .............................................................................. c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation:

U.S. FOREST SERVICE (USFS) Yes No
14 a) Does the proposed pr oject involve construction on USFS land? ................................................................. b) Does the proposed project involve the crossing of USFS land with a water line? .............................................2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 152 July 2009 15276-03-09-001A/09-011A Rev. 1

c) The current list of Forest Service permits that require ACMP consistency review are online at http://alaskacoast.state.ak.us/Clawhome/handbook/pdf/11_AAC_110.pdf in Article 4, 11 AAC 110.400, pages 28-30. Does your proposed project include any of Forest Service authorizations found on pages 28-30 of the ACMP
Handbook? .............................................................................................................................. 15. If you answered yes to any question ab ove, indicate the pers on you contacted at United States Forest Service for
information.
a) Name/date of Contact: b) Is an application required for th e proposed activity? .............................................................................. c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation:

U.S. FISH AND WILDLIFE SERVICE (USFWS) Yes No
16 a) Is your proposed project on land ma naged by the USFWS? ...................................................................... b) Does your project require a Right of Way from the USFWS under 50 C.F.R. 29 and 50 C.F.R 36? .............................. 17. If you answered yes to any question above, indicate the pers on you contacted at the US Fish and Wildlife Service for
information.
a) Name/date of Contact: b) Is an application required for th e proposed activity? .............................................................................. c) If “YES” then submit a signed copy of the completed application to the DCOM. If “No”, explain why an application

isn’t required. Explanation:

OTHER FEDERAL AGENCY APPROVALS Yes No 18 a) Other Federal agencies with authorizations reviewab le under the Alaska Coastal Management Program are posted
online at http://alaskacoast.state.ak.us/Clawhome/handbook/pdf/11_AAC_110.pdf in Article 4, 11 AAC 110.400, pages 28-30. Does your proposed project include any of the Federal agency authorizations found on pages 28-30 of
the ACMP Handbook?

.................................................................................................................. b) If yes, which federal authorizations? ............................ MMS OCS Exploration Plan Approval

................................ 19. Have you applied for any other federal permits or authorizations?

................................................................. Agency Approval Type Date Submitted MMS EP May 2009
MMS APD To be submitted MMS Oil Spill Response Plan ODPCP May 2009 NMFS MMPA IHA May 2009 USFWS MMPA LOA May 2009 US EPA Air Quality PSD December 2008 USACE NWP No.8 May 2009 Note: The Coastal Project Questionnaire (CPQ) identifies state and federal permits subject to a consistency review. You may need additional permits from other agencies or the affected city and boroug h government to proceed with your activity. Attach the documentation requested under the Project Description.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 153 July 2009 15276-03-09-001A/09-011A Rev. 1 ACMP Consistency Evaluation & Certification Statement

Pursuant to 11 AAC 112.215 (a)(1)(c), the applicant shall submit an evaluation of how the proposed project is consistent with the statewide standards at 11 AAC 112.200 - 11 AAC 112.990 and with the applicable district enforceable policies, sufficient to support the consistency cer tification. Evaluate your project against each section of the state standards and applicable distri ct enforceable policies using the template below or by submitting a narrative description in letter or report form. District enfo rceable policies are availabl e on the ACMP website at http://www.alaskacoast.state.ak.us . Definitions of key terms can be found at: 11 AAC 110.990

, 11 AAC 112.990 and 11 AAC 114.990

.

If you need more space for an adequate explanation of any of the applicable standards, please attach additional pages to the end of this document. Be sure to include references to the specific sections and subsections that you are evaluating

.

STATEWIDE STANDARDS 11 AAC 112.200. Coastal Development
Standard: (a) In planning for and approving development in or adjacent to coastal waters, districts and state agencies shall manage coastal land and water uses in such a manner that those uses that are economically or physically dependent on a coastal location are given higher priority when compared to uses that do not economically or ph ysically require a coastal location. (b) Districts and state agencies shall give , in the following order, priority to (1) water-dependent uses and activities; (2) water-related uses and activities; and (3) uses and activities that are neither water-depe ndent nor water-related for which there is no practicable inland alternative to meet th e public need for the use or activity. (c) The placement of structures and the discharge of dredged or fill material into coastal water must, at a minimum, comply with the standards contained in 33 CFR Parts 320 - 323 , revised as of July 1,
2003.

Evaluation : (a) How is your project economically or physical ly dependent on a coastal location? Why are you proposing to place the project at the selected location? Shell proposes to conduct the planned exploration drilling program on its OCS leases obtai ned from the MMS during Lease Sale 193. Shell selected these leases based on their po tential for holding oil and gas resources. (b) Evaluation of development priority. (1) How is the proposed project water-dependent? Explain . Exploration drilling on offshore OCS
leases. (2) How is the proposed project water-related? Explain. Exploration drilling on offshore OCS
leases. (3) If the proposed project is neither water-depende nt nor water-related, please explain why there is not a practicable inland alternative that meets th e public need for the use or activity. Explain

. (c) DCOM defers to the United States Corps of Engi neers (USACE) to interpre t compliance with the referenced standards. If you plan to discharge or fill waters of the US, have you applied to the Corps of Engineers for the appropriate authorization?
USACE authorization under Nationwide Permit # 8 OCS Oil and Gas Structures requested. No fill discharges to the waters of the United States are proposed.

11 AAC 112.210. Natural hazard areas.
Standard: (a) In addition to those identified in 11 AAC 112.990 , the department, or a district in a district plan, may designate other natural processes or adverse cond itions that present a threat to life or property in
the coastal area as natural hazards. Such designations must provide the scientific basis for designating the natural process or adverse condition as a natural hazard in the coastal area, along with supporting2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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scientific evidence for the designation. (b) Areas likely to be affected by the occurren ce of a natural hazard may be designated as natural hazard areas by a state agency or, under 11 AAC 114.250(b), by a district. (c) Development in a natural hazard area may not be found consistent unless the applicant has taken appropriate measures in the siting, design, constr uction, and operation of the proposed activity to protect public safety, services, and the environment from potential damage caused by known natural
hazards. (d) For purposes of (c) of this section, "appropria te measures in the siting, design, construction, and operation of the proposed activity" means those measu res that, in the judgment of the coordinating agency, in consultation with the department’s division of geological and geophysical surveys, the Department of Community and Economic Developmen t as state coordinating agency for the National Flood Insurance Program under 44 C.F.R. 60.25, and other local and state agencies with expertise, (1) satisfy relevant codes and safety standards; or (2) in the absence of such codes and standards; (A) the project plans are approved by an engineer who is registered in the state and has engineering experience concerning the specific natural hazard; or (B) the level of risk presented by the design of the project is low and appropriately addressed by the project plans.

Evaluation : (a) Describe the natural hazards designated in the dist rict plan as they affect this site. Not applicable, the NSB Coastal District does not have approved designated natural hazard areas. (b) Describe how the proposed project is designe d to accommodate the designated hazards. How will you use site design and operate the proposed activ ity to protect public safety, services and the environment from potential damaged caused by k nown natural hazards? Not applicable, without designated hazards areas

. (d)(1) Describe the measures you will take to meet relevant codes and safety standards in the siting, design, construction and operation of the proposed activity. Compliance with applicable regulatory approvals, and USCG and Occupa tional Safety and Health Administration requirements. (d)(2)(A) If your project is located in an area without codes and safety standards, how is your project engineered for the specific natural hazard? Give the name of the appropriately qualified registered engineer who will approve the plans for protecti ng public safety, services, and the environment from damage caused by hazards OR (d)(2)(B) If the level of risk presented by the design of the project is low, how do the project plans and project design address the potential natural hazard? Not applicable.

11 AAC 112.220. Coastal access.
Standard: Districts and state agencies shall ensure that proj ects maintain and, where appropriate, increase public access to, from, and along coastal water.

Evaluation : Please explain how the proposed project will mainta in and, where appropriate, increase public access to, from and along coastal water. The planned explor ation drilling is approximately 60 -130 statute miles offshore in an area not frequented by the pub lic. Public access to coastal areas are not expected to increase, decrease, or be affected by planned activities.

11 AAC 112.230. Energy facilities.
Standard: (a) The siting and approval of major energy facilities by districts and state agencies must be based, to
the extent practicable , on the following standards: (1) site facilities so as to minimize adverse environmental and social effects while satisfying2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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industrial requirements; (2) site facilities so as to be compatible with existing and subsequent adjacent uses and projected community needs; (3) consolidate facilities; (4) consider the concurrent use of facilities for public or economic reasons; (5) cooperate with landowners, de velopers, and federal agencies in the development of facilities; (6) select sites with sufficient acreage to a llow for reasonable expansion of facilities; (7) site facilities where existing infrastructure, in cluding roads, docks, and airstrips, is capable of satisfying industrial requirements; (8) select harbors and shipping routes with least exposure to reefs, shoals, drift ice, and other obstructions; (9) encourage the use of vessel traffic c ontrol and collision avoidance systems; (10) select sites where development will require mi nimal site clearing, dredging, and construction; (11) site facilities so as to minimize the probability , along shipping routes, of spills or other forms of contamination that would affect fishing grounds, spawning grounds, and other biologically productive or vulnerable habitats, including marine mammal rookeries and hauling out grounds and waterfowl nesting areas; (12) site facilities so that design and construc tion of those facilities and support infrastructures in
coastal areas will allow for the free passage and movement of fish a nd wildlife with due consideration for historic migratory patterns; (13) site facilities so that areas of particular scen ic, recreational, environmental, or cultural value, identified in district plans, will be protected; (14) site facilities in areas of least biological productivity, diversity, and vulnerability and where effluents and spills can be controlled or contained; (15) site facilities where winds and air currents di sperse airborne emissions that cannot be captured before escape into the atmosphere; (16) site facilities so that associated vessel opera tions or activities will not result in overcrowded
harbors or interfere with fishi ng operations and equipment. (b) The uses authorized by the i ssuance of state and federal leases, easements, contracts, rights-ofway, or permits for mineral and petroleum resource extraction are uses of state concern

.

Evaluation : (a) If this standard applies to your project, pl ease describe in detail how the proposed project is designed to meet each applicable section of this standard: (1) Shell is proposing to explore for economic accumulations of hydrocarbon resources located on OCS Chukchi Sea Sale 193 leases located greater than 60 statute miles (97 km) offshore, and seaward of the Polynya Zone and OCS Sale 193 lease Stipulations 4, 5 marine (mammal subsistence hunt) and Stipulation 7 (sensitive eide r habitat) boundaries. Seasonal drilling would occur generally July through October of 2010 us ing the drillship Frontier Discoverer and support vessels. Project equipment and operations are designed to avoid and minimize negative environmental effects governed by compliance wi th environmental laws and regulatory project approvals.

Potential social effects of the project related to the siting of the wells are minimized considering the
distance from shoreline and avoidance of NSB delin eated coastal community subsistence use areas. Pursuant to the Marine Mammal Protection Act, Sh ell is submitting an application to the National Marine Fisheries Service (NMFS) for an Incide ntal Harassment Authorization (IHA) for whales and seals, and an application for a Letter of Author ization to USFWS for incidental and intentional takes of polar bears and Pacific walrus to suppor t offshore operations. The authorizations include
measures to avoid and minimize social effects through conflict avoidance mechanisms and a NMFS
Incidental Harassment Authorization Mari ne Mammal Monitoring and Mitigation Plan.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 156 July 2009 15276-03-09-001A/09-011A Rev. 1 (2) The planned exploration dr illing program is on federal OCS oil and gas leases designated for resource exploration and development. Projected community needs include subsistence conflict avoidance, commercial enterprise and employment and social investment opportunities.

(3) Facility consolidation opportunities include mari ne and aviation logistics coordination, ice alert and management coordination, vessel resupply and fueling operations, scientific and drilling program baseline data collection support, third party shore base support facilities, communication and call centers, spill prevention and respon se equipment staging and crew changeouts.

(4) Concurrent use of facilities is described in (3) above. (5) The planned exploration dr illing program is temporary and seas onal. Drilling operations will
be conducted in consultation a nd coordination with landowners, developers, and under federal agency approvals.

(6) The project area is not constrained for future expansion.

(7) The exploration program is temporary and seasonal, located on federal OCS leases with no industrial infrastructure. Existing infrastructure and facilities located in Barrow, and Wainwright are available to provide operational and logistic support.

(8) No harbors are planned for the exploration progr am that targets resource assessment located in
OCS waters. Shallow hazards and site clearance approvals from MMS will ensure the planned exploration drilling program is conducted in areas cleared of seafloor obstructions. Drift ice will be actively managed by ice-management vessels as necessary to protect worker safety, equipment and the potential hydrocarbon resources.

(9) Vessel traffic will be coordinated through the use of industry-established communication centers and through normal U.S. Coast Guard and indu stry marine vessel communication protocols. Collision avoidance systems include the use of shipboard Global Pos itioning System (GPS) tracking and radar systems, with Automated Iden tification Devices (AID) devices installed on the Frontier Discoverer and support vessels.

(10) This is a planned explor ation drilling program with tem porary and seasonal operations, not a development program. There will be minimal sub sea bed excavation for mud line cellars at drilling locations. Mudline cellars are designed to pr otect wellhead casing and blowout preventers from potential ice scour events. Vessel anchoring syst ems installed during operations will be removed upon completion of each well. Permanent facilities will be limited to the surface casing and drill pipe after well abandonment.

(11) The planned exploration drilling program will be conducted with appropriate spill prevention and response strategies and equipment av ailable to protect marine resources.

(12) The drilling activities are not located in coastal waters as defined by 11 AAC 112.990.(6).)

(13) The planned exploration drilling program will be conducted in a manner that protects these

resources.

(14) Shell is proposing to dr ill exploration wells on OCS Chukchi Sea Sale 193 leases located greater than 60 statute miles (97 km) offshore seaward of the Sale 193 Stipulations 4 and5 (marine mammal subsistence hunt) and Sti pulation 7 (sensitive eider habitat boundaries), and the Polynya Zone. The drilling program would be conducted in a manner that c ontrols wastewater effluents under the parameters and federal and Alaska water quality standards of NPDES AKG-28-00002010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 157 July 2009 15276-03-09-001A/09-011A Rev. 1 General Permit issued by EPA. Spill prevention st rategies are designed to avoid and minimize the release of hydrocarbons and other contaminants. In the event of a spill, response equipment will be available and deployed to control the release a nd foster product recovery and proper disposal in accordance with an approved Oil Spill Response Pl an, also referred to as an Oil Discharge Prevention Contingency Plan (ODPCP).

(15) Offshore winds and air currents of the project area are sufficient to disperse airborne emissions that cannot be captured. The program will be conducted in compliance with EPA air quality regulatory requirements.

(16) The planned program will not result in the overcrowding of ha rbors. The planned exploration drilling program will not interfere with fishing operations and equipment.

(b) List the authorizations for state and federal leases, easements, contracts, rights-of-way, water rights, or permits for mineral and petroleum resour ce extraction you have applied for or received. MMS Exploration Plan, Oil Spill Response Pl an, l; EPA NPDES General Permit AKG-28-0000, Air Quality Construction Permit; NMFS Incident al Harassment Authorization for Whales and Seals; USFWS Letter of Authorization for Polar Bear and Pacific Walrus; USACE Nationwide
Permit 8.

11 AAC 112.240. Utility routes and facilities.
Standard: (a) Utility routes and facilities must be site d inland from beaches and shorelines unless (1) the route or facility is water-dependent or water related; or (2) no practicable inland alternative exists to meet the public need for the route or facility. (b) Utility routes and facilities along the coast must avoid, minimize, or mitigate (1) alterations in surface and gr ound water drainage patterns; (2) disruption in known or reasonably foreseeable wildlife transit; (3) blockage of existing or traditional access.

Evaluation : (a) If the proposed utility route or facility is site d adjacent to beaches or shorelines, explain how the route or facility is water dependent water rela ted or why no practical inland alternative exits. Not applicable. (b) If the proposed utility route or facility is s ited along the coast, explain how you will avoid, minimize or mitigate: (1) alterations in surface and gr ound water drainage patterns; Not applicable. (2) disruption in known or reasonably foreseeable wildlife transit; Not applicable. (3) blockage of existing or traditional access. Not applicable.

11 AAC 112.250. Timber harvest and processing.
Standard:
AS 41.17 (Forest Resources and Practices Act) and the re gulations adopted unde r that chapter with respect to the harvest and processing of timber are incorporated into the program and constitute the components of the program with respect to those purposes.

Evaluation : Does your activity invol ve harvesting or processing of timber? Yes No X2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 158 July 2009 15276-03-09-001A/09-011A Rev. 1

If yes, please explain how your proposed project meets the standards of the State Forest Resources and
Practices Act.

11 AAC 112.260. Sand and gravel extraction.
Standard: Sand and gravel may be extracted from coastal waters, intertidal areas, barrier islands, and spits if there is no practicable alternative to coastal extrac tion that will meet the public need for the sand or gravel.

Evaluation : If your proposed project includes extracting sand or gravel from coastal waters , intertidal areas, barrier islands or spits, please explain why there is no practi cable alternative to coastal extraction that meets the public need for sand or gravel. Not applicable to exploration drill site.

11 AAC 112.270. Subsistence.
Standard: (a) A project within a subsiste nce use area designated by the department or under 11 AAC 114.250(g) must avoid or minimize impacts to subsistence uses of coastal resources. (b) For a project within a subsistence use ar ea designated under 11 AAC 114.250(g), the applicant shall submit an analysis or evaluation of reasonably foreseeable adverse impacts of the project on subsistence use as part of (1) a consistency review packet submitted under 11 AAC 110.215; and (2) a consistency evaluation under 15 C.F.R. 930.39, 15 C.F.R. 930.58, or 15 C.F.R. 930.76. (c) Repealed 10/29//2004, Register 172. (d) Except in nonsubsistence areas identified u nder AS 16.05.258, the department may, after consultation with the appropriate di strict, federally recognized Indian tribes, Native corporations, and other appropriate persons or groups, designate areas in which a subs istence use is an important use of coastal resources as demonstrated by local usage. (e) For purposes of this section, "federally reco gnized Indian tribe," "local usage", and "Native corporation" have the meani ngs given in 11 AAC 114.990.

Evaluation : (a) Is your proposed project located within a subs istence use area designated by a coastal district?

Yes No X If yes, please describe how the proposed project is designed to “avoid or minimize impacts to
subsistence uses of
coastal resources:”

Because there is not a current approved NSB coastal di strict plan in place, there are no coastal districtdesignated subsistence use areas. However, as requi red by NMFS and USFWS regulations, Shell held POC meetings with various indi viduals and groups from the affected communities. Through POC meetings, Shell has adopted mitigation measures de signed to avoid and/or minimize unreasonable conflicts with subsistence hunting activities or subsistence resources. These measures include:

 To minimize impacts on marine mammals and subsistence hunting activities, the drillship and support vessels will transit through the Chukchi Sea along a route that lies offshore of the polynya zone. In the event the transit outside of the polynya zone results in Shell having to break ice (as opposed to managing ice by pushing it out of the way), the drillship and support vessels will enter into the polynya zone far enough so that Ice breaking is not necessary. If it is necessary to move into the polynya zone, Shell will notify the local communities of the change in the transit route through the Com Centers.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 159 July 2009 15276-03-09-001A/09-011A Rev. 1  Shell has developed a Communication Plan a nd will implement the plan before initiating exploration drilling operations to coordinate activities with local subsistence users as well as Village Whaling Associations in order to mini mize the risk of inte rfering with subsistence hunting activities, and keep current as to th e timing and status of the bowhead whale migration, as well as the timing and status of other subsistence hunts. The Communication Plan includes procedures for coordination with Communication and Call Centers to be located in coastal villages along the Chukchi and Beau fort Seas during Shell's proposed activities in
2010.

 Shell will employ local Subsistence Advisors from the Beaufort and Chukchi Sea villages to provide consultation and guidance regarding th e whale migration and subsistence hunt. There
will be a total of nine subsistence adviso r-liaison positions, one per village, to work approximately 8-hours per day and 40-hour week s through 2010. The subsistence advisor will use local knowledge (Traditional Knowledge) to ga ther data on subsistence lifestyle within the community and to advise in ways to minimi ze and mitigate potential negative impacts to subsistence resources during the drilling season. Responsibilities include reporting any
subsistence concerns or conflic ts; coordinating with subsisten ce users; reporting subsistencerelated comments, concerns, and information; a nd advising how to avoid subsistence conflicts.
A subsistence advisor handbook w ill be developed prior to the operational season to specify position work tasks in more detail.

 Shell will recycle drilling muds (e.g., use t hose muds on multiple wells), to the extent practicable based on operational considerations (e .g., mud properties have deteriorated to the point where they cannot be used further), to reduce discharges from its operations. At the end of the season excess water base fluid, approximately 1500 bbl (238 cu m), will be pre-diluted to a 30: 1 ratio with seawater and then discharged.

 Shell will also implement flight restrictions prohibiting aircraft from flying within 1,000 ft (300 m) of marine mammals or below 1,500 ft (457 m) altitude (except during takeoffs and landings or in emergency situ ations) while over land or sea.

Marine Mammals

 Marine mammal observers on the Discoverer and support vessels; see Marine Mammal Monitoring and Mitigation Plan.

 A Marine Mammal Monitoring protocol.

 Aircraft shall not operate below 1,500 ft (457 m) unless the aircraft is engaged in marine mammal monitoring, approaching, landing or taking off, or unless engaged in providing assistance to a whaler or in poor weather (low ceilings) or any other emergency situations. Aircraft engaged in marine mammal monitoring shall not operate below 1500 ft (457 m) in areas of active whaling; such areas to be id entified through communications with the ComCenters. Except for airplanes engaged in ma rine mammal monitoring, aircraft shall use a flight path that keeps the aircraft at least 5 mi (8 km) inland until the aircraft is directly south of its offshore destination, then at that point it shall fly directly north to its destination

 Aircraft will not get closer than 50 0 yards (457 m) of groups of whales.

 Aircraft and vessels will not operate within 0.5 mi (0.8 m) of walruses or polar bears when
observed on land or ice.

 When within 300 yards (274 m) of marine mammals, vessels will reduce speed, avoid separating members from a group and avoid multiple changes of direction.

 Vessel speed to be reduced during inclement we ather conditions in order to avoid collisions
with marine mammals.

Birds

 Lighting on the drillship will be shaded or replaced as appropriate to re duce the possibility of a bird collision with the drillship.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 160 July 2009 15276-03-09-001A/09-011A Rev. 1 Drilling Transit and Opera tions; Oil Spill Response

 Shell will recycle drilling muds (e.g., use those muds on multiple wells), to the extent practicable based on operational considerations (e .g., mud properties have deteriorated to the point where they cannot be used further), to reduce discharges from its operations. At the end of the season excess water base fluid, approximate ly 1500 bbl (238 cu m), will be pre-diluted to a 30: 1 ratio with seawater and then discharged.

 Drilling muds to be chilled to mitigate any potential permafrost thawing or thermal dissociation of any methane hydrates encountered during drilling.

 To minimize impacts on marine mammals and subsistence hunting activities, the drillship and support vessels traversing north through the Be ring Strait will transit through the Chukchi Sea along a route that allows for the highest degr ee of safety regarding ice conditions and sea states. Those vessels that can safely travel outsi de of the polynya zone will do so unless it is necessary to break ice (as opposed to managing ice by pushing it out of the way). In this case those vessels will move into the polynya zone fa r enough so that ice breaking is not necessary. If it is necessary for any vessel to move into the polynya zone, Shell will notify the local communities of the change in the transit route through the Com Centers.

 The transit route will avoid known fragile ecosystems and critical habitat areas.

 The Discoverer and support vessels will not enter the Chukchi Sea until after July I which will minimize effects on marine mammals and birds that frequent open leads and minimize effects on spring bowhead whale hunting.

 Ice management will involve preferentially redir ecting, rather than breaking, ice floes while the floes are well away from the drill site.

 Critical operations will not be started if potentia l hazards (ice floe, inclement weather, etc.) are in the vicinity and there is not sufficient tim e to complete the critical operation before the
arrival ofthe hazard atthe drill site.

 OSR vessels on standby at all times when drilling in to zones containing oil to ensure that oil spill response capability is available, if needed.

 Real time ice and weather forecasting.

(b) If your project is located in a subsistence u se area designated by the coastal district, provide an analysis or evaluation of its reasonably foreseeab le adverse impacts to the subsistence uses.

The planned drilling program may have some level of disturbance on subsistence species such as bowhead whales, beluga whales, and seals. Sound associated with drilling activities varies considerably with ongoing operations, location, a nd environmental factors. In addition, marine mammal responses to drilling sound are variable. Nonetheless, the great concern expressed by residents on the North Slope of Alaska of the effects of drilling sound on the success of subsistence hunts is noted (MMS 2003).

The main sources of disturbance to marine mammals associated with the drilling program will be from aircraft, the drillship, and support vessels. These types of equipment emit low-frequency sound energy that may evoke marine mammal avoidance behavi or. It is often difficult to separate the effects of visual and acoustic disturbance; therefore, these are discussed as one below. Impacts from sound energy associated with well drilling, ice manageme nt, and vessel traffic could cause some temporary avoidance of the immediate area of a vessel by marine mammals, but these effects would be minor, short term, and localized. The potential impacts of program air emissions are expected to be negligible. Oil spills could potentially impact marine mammals. A large oil spill, such as a crude oil release from a blowout, is extremely rare and not considered a reasonably foreseeable impact of this EP. Small spills, such as releases of fuel, could aff ect marine mammals, but any impacts would affect only a small percentage of the total species popula tion for all marine mammals, if any, and fleeting because of the limited duration of spills of this si ze. Any potential effects from diesel or oil spills2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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would be mitigated by the swift implementation of Shell’s comprehensive oil spill response plan.

Impacts to subsistence may be direct or indirect a nd include those which affect the subsistence user’s
activities or affect the subsistence resources. Re ductions in subsistence resources and changes in subsistence resource distribution may impact s ubsistence users and their activities (MMS 2008).

Our analyses indicate sound energy and physical disturbance can cause cumulative effects on subsistence resources and harvests without the impl ementation of appropriate mitigation measures. However, MMS has determined that, with the mitigation measures required by lease stipulations, an MMS-approved POC, and the NMFS IHAs, such effect s would be reduced to moderate (MMS 2008).

Shell’s prospects are located 60 statute mi (96 km) to 126 statute mi (187 km) offshore of the coastline
in the OCS. Review of available information on subsistence use areas (Figures 3.11.7-3 through 3.11.7-18 of Appendix F of the EP) indicates that all of Shell’s proposed well locations are far offshore (seaward) of all identified subsistence use areas for the villages of Barrow, Wainwright, Point Lay, and Point Hope by at least 30 statute mi. It is therefore unlikely that offshore operations (drilling and ice management) will have any direct or indirect impacts on subsistence activities. Potential indirect impacts from offshore operations on subsistence resources may occur, for example, from support aircraft. Any such indirect impacts, howev er, are expected to be negligible, temporary and localized. These potential direct and indirect impact s on subsistence are discussed below by resource.

(c) No response required.

(d) If your project is not located in a designated s ubsistence use area, please describe any subsistence uses of coastal resources within the project area. Please be advised that subsistence use areas may be designated by the department during a review.

The vast majority of subsistence hunting and fishing activities by local residents occurs much closer to shore than Shell’s planned exploration drilling activ ities. The closest planned drillsite is 64 mi (106 km) from the shoreline and 78 mi (126 km) from Wainwright, the closest village. Subsistence vegetation gathering along the Chukchi Coast is fairly limited (MMS 1990).

Bowhead Hunting For Barrow residents, spring whaling takes place from ice leads from Point Barrow southwestward along the Chukchi Sea coast to the Skull Cliff ar ea. Fall bowhead whaling occurs from August to October in an area that extends 10 statute mi (16 km ) west of Barrow to 30 statute mi (48 km) north of Barrow, and southeast 30 statute mi (48 km) off Cooper Island with an eastern boundary on the east side of Dease Inlet. Occasionally, bowhead wh ale hunting may extend east as far as Smith Bay and Cape Halkett.

Wainwright spring bowhead whale hunting occurs from Ap ril to June in leads offshore of Wainwright. Whaling camps are sometimes located 10 to 15 mi (16 to 24 km) from shore.

Residents of Point Lay have not hunted bowhead wh ales in the recent past, but have been selected by the International Whaling Commission to receive a bowhead whale quota in 2009. In a more distant past, Point Lay hunters traveled to Barrow, Wainwri ght, or Point Hope to participate in the bowhead
whale harvest activities.

Point hope residents hunt bowhead from March to June from whaling camps along the ice edge south and southeast of Point Hope (Figure 3.7.11-14 in Ap pendix F of the EP). The pack-ice lead is rarely more than 6 - 7 mi (10 - 11 km) offshore (MMS 2007b).2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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Beluga Hunting The Barrow spring beluga hunt occurs from April to June in the spring leads between Point arrow and Skull Cliff. Later in the spring, whalers in Barrow hunt belugas in open water around the barrier islands off Elson Lagoon, generally within 10 mi ( 16 km) (See Figure 3.11.7-4 in Appendix F of the EP).

The Wainwright beluga whale hunt takes place in the spring lead system from April to June, but this hunt only occurs if no bowheads are in the area. Wainwright hunters also hunt belugas later in the summer from July to August along the coastal lagoon systems – generally less than 10 mi (16 km)
from shore.

Point Lay residents harvest beluga from the middle of June to the middle of July. The hunting area is concentrated in Naokak and Kukpowruk Passes south of Point Lay (Figure 3.11.7-11 in Appendix F of the EP). Hunters use boats to herd the whales in to the shallow waters of Kasegaluk Lagoon where the belugas are harvested. If the July beluga hunt is unsuccessful, Point Lay hunters may travel as far north as Utukok Pass and as far south as Cape Beaufo rt in search of beluga whales (MMS 2007b).

Point Hope residents take part in two beluga whal e hunts a year. The first hunt occurs from late March through June. This hunt co incides geographically and temporally with the bowhead whale hunt – along the ice edge south and southeast of Point Hope, rarely more than 6 - 7 mi (10 - 11 km) offshore. The second beluga hunt occurs later in the summer, from July to August. During this second hunt, Point Hope residents hunt beluga whales in the open water near the southern shore of Point Hope close to the beaches, as well as north of Point Hope as far as Cape Dyer (Figure 3.11.7- 15in Appendix F of the EP, MMS 2007b). This second hunt occurs within 10 mi (16 km) of shore.

Walrus Hunting Barrow residents hunt walrus in early summer to early fall, June to September, from west of Barrow southwestward to Peard Bay, generally within 35 mi (56 km) of shore (Figure 3.11.7-3 in Appendix F of the EP).

Wainwright residents hunt walrus fro m July to August at the southern edge of the retreating pack ice – generally within 45 mi (72.4 km) from shore. Fr om August to September they may hunt walrus at local haul-outs, with the main area being from Mil liktagvik north to Point Franklin. Icy Cape is a
known walrus haulout location and subsistence hunti ng ground near Wainwright (Figure 3.11.7-9 in Appendix F of the EP).

Point Lay residents hunt walrus from June to Augus t – depending on favorable ice conditions – along the entire length of Kasegaluk Lagoon, south of Icy Cape, and as far as 20 mi (32 km) offshore (AESRTS 2009).

Point Hope residents hunt walrus from May to Ju ly along the southern shore from Point Hope to Akoviknak Lagoon (MMS 2007b). Walrus hunting genera lly occurs within 20 mi (32 km) of shore.

Seal Hunting For Barrow residents, seal hunting occurs primarily in winter, with some open-water sealing along the
Chukchi coastline and in the Beaufort Sea as far east as Dease Inlet and Admiralty Bay, generally within 30 mi (48 km) from shore (Figure 3.11.7-3 in Appendix F of the EP).

Wainwright residents hunt seal usually from May through September, as far south as Kuchaurak Creek, south of Point Lay, and north to Peard Ba y. These activities generally occur within 45 mi (72.4 km) from shore.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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Point Lay residents hunt ringed and bearded seals year-round. They hunt these ringed seals approximately 20 mi (32 km) north of Point Lay and bearded seals, 30 mi (48 km) north of Point Lay. Generally, these activities occur within 25 mi (40 km) of shore.

Point Hope residents hunt seal through most of the year, with the general exception of September and October. These activities generally occur from south of Point Hope, near Ogotoruk Creek north of Cape Lisburne near Ayugatak Lagoon a nd within 20 mi (32 km) of shore.

Polar Bear Hunting Barrow residents hunt polar bear during the fall and winter – October to June – in the same areas
where walrus are hunted - from west of Barrow southw estward to Peard Bay, within 35 mi (56 km) of
shore.

Wainwright polar bear subsistence hunts occur in the fall and winter around Icy Cape, at the headland
from Point Belcher to Point Fra nklin, and at Seahorse Island.

Point Hope residents hunt polar bear from January to April, and occasionally from October to January (MMS 2007b). Residents hunt these mammals in the area south of the point, as far out as 10 mi (16 km) from shore in the same region where seal are hunted (MMS 2007b).

Bird Hunting Barrow residents hunt common eider, king eider, spectacl ed eider, Steller’s eider, mallard, long-tailed duck, northern pintail, scoter, brant, Canada g eese, snow geese, white fr onted geese, tundra swan, crane, loons, red-throated loon, and ptarmi gan (Johnson and Daigneault 2008; NSB 2005, ADF&G 2008). Barrow residents also hunt for migratory birds along the Chukchi Sea coast. Migratory bird hunting areas in the Chukchi Sea extend southwest along the coast to Skull Cliffs located 45 statute mi (72 km) from Barrow and southeast along the Beaufort Sea coast to Dease Inlet (Figure 3.11.7-5 in Appendix F of the EP).

Wainwright residents harvest common eider, king ei der, spectacled eider, Steller’s eider, mallard, long-tailed duck, northern pintail, scoter, brant, Canada geese, snow geese, white fronted geese, Pacific loon, and ptarmigan (Johnson and Daigne ault 2008, ADF&G 2008). Wainwright residents hunt migratory birds north along the coast to Skull Cliff, south along the coast to Kasegaluk Lagoon and inland along the Kuk River.

Point Lay residents harvest eider (unidentified by species in the data set), long-tailed duck, northern pintail, brant, Canada geese, murre, and ptarmi gan, and collect bird eggs (Johnson and Daigneault 2008, ADF&G 2008). Residents living in Point Lay s ubsistence hunt for migratory birds north along the coast to Icy Cape and South along the coast into Ledyard Bay. These activities generally occur within 20 mi (32 km) from shore and inland.

Fishing Barrow residents fish all five species of Pacific salmon: chum, coho, chinook, pink and sockeye. Fish harvested include smelt, arctic cod, arctic cisco, arctic flounder, Pacific tom cod, sculpin, burbot, arctic char, lake trout, grayling, pike, broad whitefi sh, bull head white fish, Bering cisco, least cisco, humpback whitefish, and round white fish (Johns on and Daigneault 2008, AES-RTS 2009). These activities generally occur less than 5 mi (8 km) of shore and also inland.

Wainwright residents subsistence fish for chum sal mon, Chinook salmon, pink salmon, smelt, capelin (grunion), rainbow smelt, Pacific tom cod, flounder, sculpin, burbot, char, lake trout, grayling, pike, broad whitefish, Bering cisco, least cisco, hum pback whitefish, and r ound whitefish (Johnson and2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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Daigneault 2008). These activities generally occur along the shore and inland.

Point Lay residents fish chum salmon, king salmon, smelt, tomcod, trout, grayling, humpback whitefish, and blue cod primarily to supplement th eir diet (Johnson and Daigneault 2008). These activities generally occur along the shore and inland.

Point Hope residents harvest fish in the open wa ter during summer months, as well as under ice in the fall and winter. (NSB 2005). Craig and Halderson (1986) reported large runs of chum and pink salmon in rivers south of Point Hope. Pink salmon and, to a lesser degree, chum salmon, occur with any regularity in nine drainages north of Point Hope and presumably maintain small populations in several of the northern drainages; most occurring in streams along the Chuk chi Sea coast west of Barrow (MMS 2007b).

(e) No response required.

11 AAC 112.280. Transportation routes and facilities.
Standard: Transportation routes and facilities must avoid, minimize, or mitigate (1) alterations in surface and gr ound water drainage patterns; (2) disruption in known or reasonably foreseeable wildlife transit; and (3) blockage of existing or traditional access.

Evaluation : If your proposed project includes transportation routes or facilities, describe how it avoids, minimizes, or mitigates (1) alterations in surface and ground water drainage patterns; Not applicable.

(2) disruption in known or reasonably foreseeable wildlife transit; and The program will not disrupt terrestrial wildlife transit, and marine operations would avoid, minimize, and mitigate wildlife transit through the use of a Marine Mammal Observer (M MO) program designed to guide vessel transit through the project area while avoiding or mini mizing disruptions and deflections of marine
mammals. (3) blockage of existing or traditional access. Ex isting or traditional access will not be blocked.

11 AAC 112.300. Habitats.
Standard: (a) Habitats in the coastal area that are subject to the program are (1) offshore areas; (2) estuaries; (3) wetlands; (4) tideflats; (5) rocky islands and sea cliffs; (6) barrier islands and lagoons; (7) exposed high-energy coasts; (8) rivers, streams, and lakes and the active flood plains and riparian management areas of those rivers, streams, and lakes; and (9) important habitat. (b) The following standards apply to the management of the habitats identified in (a) of this section: (1) offshore areas must be managed to avoid, minimize, or mitigate significant adverse impacts to competing uses such as commercial, recreational, or s ubsistence fishing, to the extent that those uses are determined to be in competition with the proposed use;2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

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(2) estuaries must be managed to avoid, minimize, or mitigate significant adverse impacts to (A) adequate water flow and natura l water circulation patterns; and (B) competing uses such as commercial, recreational, or subsistence fishing, to the extent that those uses are determined to be in comp etition with the proposed use; (3) wetlands must be managed to avoid, minimize, or mitigate significant adverse impacts to water flow and natural drainage patterns; (4) tideflats must be managed to avoid, mini mize, or mitigate significant adverse impacts to (A) water flow and natura l drainage patterns; and (B) competing uses such as commercial, recreational, or subsistence uses, to the extent that those uses are determined to be in compe tition with the proposed use; (5) rocky islands and sea cliffs must be managed to (A) avoid, minimize, or mitigate significant adverse impacts to habitat used by coastal species; and (B) avoid the introduction of competing or destructive species and predators; (6) barrier islands and lagoons mu st be managed to avoid, minimize, or mitigate significant adverse impacts (A) to flows of sediments and water; (B) from the alteration or redirection of wave energy or marine currents that would lead to the filling in of lagoons or the erosio n of barrier islands; and (C) from activities that would decrease the use of barrier islands by coastal species, including polar bears and nesting birds; (7) exposed high-energy coasts must be managed to avoid, minimize, or mitigate significant adverse impacts (A) to the mix and transport of sediments; and (B) from redirection of transport processes and wave energy; (8) rivers, streams, and lakes must be managed to avoid, minimize, or mitigate significant adverse impacts to (A) natural water flow; (B) active floodplains; and (C) natural vegetation within riparian management areas; and (9) important habitat (A) designated under 11 AAC 114.250(h) must be ma naged for the special productivity of the habitat
in accordance with district enforceable policies adopted under 11 AAC 114.270(g); or (B) identified under (c)(1)(B) or (C) of this section must be managed to avoid, minimize, or mitigate significant adverse impacts to the special productivity of the habitat. (c) For purposes of this section, (1) "important habitat" means habitats listed in (a )(1) – (8) of this section and other habitats in the
coastal area that are (A) designated under 11 AAC 114.250(h); (B) identified by the department as a habitat (i) the use of which has a direct and significant impact on coastal water; and (ii) that is shown by written scientific evidence to be biologically and significantly productive; or (C) identified as state game refuges, state game sanctuaries, state range areas, or fish and game critical habitat areas under AS 16.20; (2) "riparian management area" means the area along or around a waterbody within the following distances, measured from the outermost extent of the ordinary high water mark of the waterbody: (A) for the braided portions of a river or stre am, 500 feet on either side of the waterbody; (B) for split channel portions of a river or stre am, 200 feet on either side of the waterbody; (C) for single channel portions of a river or st ream, 100 feet on either side of the waterbody; (D) for a lake, 100 feet of the waterbody.

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by your proposed project.
Most activities associated with the proposed exploration drilling program will take place in prospects identified by Shell on oil and gas leases in Federal wa ters of the OCS more than 60 statute miles from the coastline of the Chukchi Sea. The only habitats within these locations, and within 60 statute miles of these locations, are offshore areas.

Temporary marine support shorebase facilities will be established in Wainwright, and air support
shorebase facilities will be established in Barrow and/or Wainwright. Habitat types near Wainwright include offshore areas, estuaries, wetlands, barri er islands and lagoons, exposed high energy coastlines, and rivers, streams, and lakes. Similar habitats are found in the Barrow area, but will not be affected as the air support shorebase facilities would be located on developed properties at the airport. Helicopter and fixed wing aircraft tr affic to and from Barrow would have no effect on habitats. Tide flats, and rocky islands and sea cliffs are also found along the coastline of the northeastern Chukchi Sea, but at great distances from Shell's prospects and not in proximity of the marine support shorebase facilities.

Other important habitats along the northeastern Chukc hi Sea, based on scientific reports concerning their biological significance, include Peard Bay, Ka segaluk Lagoon, Ledyard Bay, the Polynya Zone, and the Alaska Maritime National Wildlife Refuge (NWR). These important habitat areas are all located more than 40 mi from Shell's prospects, but are discussed below because of their regional importance.

(b) Describe how the proposed project avoids, mi nimizes, or mitigates impacts to each of the identified habitat(s) in section (a) above.

The proposed exploration drilling program includes the use of an ice-class dr illship, ice-management vessel, anchor handler, oil spill response vessels, and other support vessels and aircraft that will be operated in a manner that avoids, minimizes, a nd mitigates impacts to this offshore arctic environment. Up to three exploration wells will be drilled in July, August, Se ptember, and October. Potential environmental impacts associated with the proposed exploration program are evaluated in the Environmental Impact Analysis (EIA, Appendix F of the EP). Details of the project in the EP ODPCP, NPDES General Permit, NMFS IHA, and USFWS LOA present the avoidance, minimization, and mitigation mechanisms that wi ll be employed during operations. Additional mitigation measures are identified in Section 2.10 of the EIA and Section 12 (c) of the EP, and are
discussed where relevant in the evaluation below.

POTENTIAL FOR IMPACTS FROM OIL SPILLS

With regards to Shell’s proposed 2010 exploration drilling program, a large spill is regarded as too remote and speculative an occurrence to be consid ered reasonably foreseeable. The impacts of such
an event are therefore not addressed in this evaluati on or the EIA. Shell’s project is an exploration drilling program for up to three wells. No oil will be produced. No pipelines or other permanent
facilities will be constructed. All wells will be permanently plugged and abandoned in accordance with MMS requirements upon completion of drilling. MMS trajectory analyses (MMS 2007) indicate that even in the extraordinary event of a large oil spill, there is a minimal probability that hydrocarbons could reach coastal habitats.

Shell has determined through analysis of oil spill statistics that the only reasonably foreseeable release of liquid hydrocarbons would be a release of a small volume of refined product. A maximum most probable spill of this type was determined to be a 48 bbl spill of diesel. NOAA’s ADIOS2 model
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within three days, and modeling indicates that over 99 percent of a 48 bbl release of diesel would be evaporated or otherwise dispersed within 48 hrs. Additionally Shell has mitigation measures in place to avoid or minimize the potential effects of releases. Under Shell’s Fuel Transfer Plan, pre-booming will be conducted for all fuel transfers, and Shell will have onsite oil spill response equipment under its ODPCP. Given these factors, there is very little potential for impacts to offshore areas or coastal habitats from liquid hydrocarbon spills.

OFFSHORE AREAS

To ensure the project has minimal impacts to the surrounding habitat, fish, and wildlife of the area, Shell will implement mitigation measures designed to a void, minimize, or mitigate potential impacts. These mitigation measures are include d in the broad range of permits and plans required for the exploratory drilling program. Examples of these pl ans and permits, which are provided as part of the EP, include:

ODPCP – Under a plan to be approved by ADEC and MMS, oil spill response vessels will be in the project area and pre-booming practices will be in place in the event of an accidental discharge during refueling. Fuel Transfer Plan - Shell has prepar ed a fuel transfer plan (Attachment 9.4) that goes beyond the requirements of MMS stipulations and requires pr e-booming of all fuel transfers regardless of the quantity of fuel being transferred. NPDES General Permit – All discharges of drilling wastes, domestic and sanitary wastewaters, and other wastewaters from the drills hip will be discharged under the conditions of the General Permit AKG280000, which will mini mize any effects on water quality. Air Permit – Under a permit to be obtained from the EPA, emissions from vessels and machinery will be limited to levels that will not degrade air quality. Modeling indicates that air quality standards will be met at the edge of the dr illship well away from coastal habitat. Under this permit, Shell has made numerous modifications and applied numerous conditions, including installation of pollution control technology, use of ultra low sulfur fuel, and implementing operating limits, to minimize emissions from the Discove rer and support vessels, and ensure air quality standards are met at the edge of the drillship. IHA – As part of the application for an IHA from NMFS, Shell has prepared and will implement a Marine Mammal Mitigation and Mon itoring Plan (4MP, Appendix D). The 4MP requires that marine mammal observers will be used on the drillship and su pport vessels to ensure disturbances to marine mammals are minimized, and to record marine mammal observations. Mitigation measures in the 4MP include the following 1) aircraft will not operate within 500 yards of whale groups; 2) aircraft and vessels will not operate within 0.5 miles of walrus or polar bears observed on land or ice; 3) when within 300 yard s of marine mammals, vessels underway will reduce speed, avoid separating members of a group and avoi d multiple course changes; 4) vessels under way will reduce speed during inclement weather to avoid collisions with marine mammals. LOA – As part of the application for an LOA from USFWS, Shell has developed and will implement a Polar Bear, Walrus, and Grizzly Bear Avoidance and Human Encounter / Interaction Plan (Appendix E), which includes measures to minimize th e potential for, and impact associated with interaction with these species. These measures along with those in the above-reference 4MP, would minimize disturbances to polar bears and walrus. Marine mammal observers will record data to monitor any impacts and document polar bear and walrus observations. Bird Strike Avoidance Plan – Under the guidance of MMS and the USFWS, Shell voluntarily developed and will implement a Bird Strike Avoida nce Plan (Appendix J) to minimize the risk of birds striking vessels. The plan includes minimization of lighting on the drillship and support vessels and the use of green lighting on the drillship to reduce bird attraction / disorientation and avian
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Support vessels and helicopters may traverse nearshore areas. Any impacts would consist largely of behavioral disturbances to marine species, and would be temporary and minor. These temporary disturbances would not impact coastal habitats or co mpete with subsistence activities and resources.

Helicopter traffic between Barrow and Wainwr ight, and between shorebase facilities and the prospects, will either traverse inland or proceed dire ctly offshore to minimize disturbances to marine mammals and subsistence activities along the coast. Dist urbances from this level of aircraft traffic (1 flight/day) could result in some temporary disturbance of terrestrial and/or marine wildlife. All aircraft associated with Shell’s planned drilling program will fly at a minimum altitude of 1,500 ft, which is expected to avoid or minimize wildlife disturbances e ffects. Aircraft traffic will have only minor and temporary effects on wildlife no effect on habitats such as offshore areas.

Vessel traffic will disturb some birds and temporarily displace foraging and resting birds. Disturbance will be largely limited to the flushing of birds away from vessel pathways. Shell’s 2010 exploration drilling program in the Chukchi involves a drillship supported by an ice management vessel, an anchor handler, an OSR fleet, and vessels for tran sporting supplies. These vessels are would operate at slow speeds, generally 10 knots or less. As ves sels pass an area, birds would be expected to move some distance away and then soon after, continue on with foraging and resting. Most vessel traffic would take place offshore in the vicinity of the leases , which are more than 60 statute mi from shore where bird densities are relatively low. Disturba nces from offshore vessel traffic will be short term lasting only as long as the activity, and would occur at a relatively small geographic scale. Therefore,
disturbances from vessel traffic are not anticipated to result in bird mortality and will not affect birds on a population scale. Vessel traffic would have no effect on habitats such as offshore areas.

Most activities associated with the proposed exploration drilling progr am would take place in offshore areas over 60 statute mi offshore of the Chukchi Sea coastline. Up to three exploration wells will be drilled. Activities that could potentially affect hab itats in offshore areas include the mooring of the drillship with anchors, construction of mudline cellars (MLCs), and permitted discharges of drilling

wastes.

The MLCs are required and necessary to keep well components below the depth in the seafloor to which ice gouging can occur. Construction of thr ee MLCs would directly disturb about 0.03 ac (126

m 2 ) of seafloor, and some additional area indirectly through the deposition of excavated sediments. The MLCs will be left to be in-filled by the natural movement of seafloor sediments.

Each anchor, with a weight of about 15,430 lb would disturb about 2,124 ft 2 of seafloor. Given eight anchors on the drillship and up to three wells being drilled, mooring could result in disturbance of up
to 1.2 ac of seafloor. Disturbance to the seafloor would be ameliorated over time due to the natural movement of sediments on the seafloor from currents, storms, ice gouging, and sedimentation.

Discharges associated with the drilling program include drilling wastes (drill cuttings and drilling mud), (treated) sanitary and domestic wastewater s, deck drainage, cooling water, desalination wastewater, bilge water, and ballast water. All of these discharges will be conducted under the
limitations and conditions of the NPDES General Permit. With the exception of drilling wastes (discussed below), the effect of th ese discharges will be restricted to the water column and within an area of about 328 ft of the drillship or vessel. These discharges would have only minor effects on water quality lasting minutes or hours after the activity has ceased. Conditions of the NPDES permit will minimize any effects on water quality. Additi onally, Shell will incinerate all food wastes on the drillship, will not discharge any untreated sanita ry wastewaters, and will discharge no sanitary
wastewaters within three miles of the coastline.

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deposited on the seafloor. Modeling indicates that th e drilling of three wells could result in drilling wastes being deposited to depths of 0.4—1.6 inches over about 581 ft 2 of seafloor. These discharges are benign, with the major impact being the smotheri ng of benthic organisms. Modeling indicates that metal concentrations in the sediments may be elevat ed slightly within the area of deposition, but the
concentrations would remain with in the range generally considered to have little or no ecological impact. These activities would occur in water depths of 141-151 ft. No offshore habitats, such as kelp
beds or hard bottom have been identified within or n ear the prospects. Benthic habitats that would be disturbed are typical of this area of the mid-shelf of the Chukchi Sea. The seafloor is generally flat and featureless with the exception of some ice gouges th at have a relief of 6.0 ft or less. Based on baseline studies conducted in the Burger Prospect, be nthic invertebrate communities at the drill sites are believed to be typical of that described for much of the central Chukchi Sea. Benthos within the areas directly affected by MLC construction, moor ing, and drilling waste discharged may be destroyed due to mechanical destruction or smothering with di scharged materials. Re-colonization of these areas with a similar benthic invertebrate community co uld take a few to as many as 8-9 years. These impacts are considered to be minor because such a small area of the seafloor is being impacted, and the habitat is not of special importance. Effects of drilling waste discharges on the benthic habitats are being minimized by Shell’s plan to recycle drilling fl uids, using the same drilling fluids for all wells in a season, with bulk discharges only at the end of the drilling season.

Most activities associated with the proposed exploration program will take place on oil and gas leases
in the OCS more than 60 statute mi offshore. Th ere is little or no other known use of the prospects areas. Barge traffic is infrequent and generally occurs closer to shore. The proposed program will not compete with barge traffic. There is no commercia l fishing in the northeastern Chukchi Sea, and none is allowed per the current Arctic Fishery Management Plan. Recreational fisheries in offshore waters
of the Chukchi Sea are nonexistent. Subsistence ac tivities, particularly subsistence fishing, have not been documented within or near Shell’s prospects. The prospects are at least 60 statute mi offshore, 78 mi offshore from Wainwright and 92 mi from Po int Lay, the nearest communities. Review of published mapping of subsistence use areas indicat es the prospects are more than 30 mi from the nearest use area. Subsistence resources such as fish, birds, seals and whales, travel through the project area, and aircraft and vessels may transit over or th rough some subsistence use areas, in support of the program. Effects on subsistence resources would be la rgely limited to behavioral disturbance, would be minor and temporary, and would be minimized as indicated above.

ESTUARIES

There are no estuaries in Shell's prospects located in the OCS more than statute 60 statute mi from shore. Marine support shorebase facilities would be established in Wainwright, but will require no new land development. An existing gravel road an d an existing earthen boat ramp on the Wainwright Inlet, which is an estuary, would be used to ser vice offshore activities. Vessel loading and vessel traffic will be the only activities associated with the exploration drilling program that would occur in or along the estuary.

The vessel traffic would have no effect on water flow or natural drainage.

Wainwright Inlet is used for subsistence activiti es including fishing, hunting of waterfowl, and access to subsistence use areas upstream in the Kuk River. Vessel and aircraft traffic would have minor and temporary (if any) effects on subsistence fishing. Shell exploration drilling program includes a number of measures to minimize any effects on subs istence, as detailed above under 11 AAC 112.270 Subsistence and discussed at length in the EIA.

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No wetlands would be affected by the planned exploration drilling program, as most activities would
be conducted in offshore waters of the Chukchi Sea. Temporary shorebase facilities would be established in Barrow and Wainwright, but this would require no land development. Temporary
marine shorebase facilities would be established in Wa inwright and would also require no new land development or use of undeveloped land. Existing boat ramps and gravel roads would be utilized at the marine shorebase facilities. The proposed exploration drilling program would have no effect on water flow or natural drainage.

TIDEFLATS

There are no tideflats in Shell's prospects located in the OCS more than 60 statute mi from shore. Temporary marine support shorebase facilities would be established in Wainwright, but will require no new land development. An existing gravel road and an existing earthen boat ramp on the Wainwright Inlet, which is an estuary, would be used to service offshore ac tivities. Vessel loading and vessel traffic will be the only activities associ ated with the exploration drilling program that would occur in or along the estuary.

The vessel traffic would have no effect on water flow or natural drainage.

Wainwright Inlet is used for subsistence activiti es including fishing, hunting of waterfowl, and access to subsistence use areas upstream in the Kuk River. Vessel and aircraft traffic would have minor and temporary (if any) effects on subsistence fishing. Shell exploration drilling program includes a number of measures to minimize any effects on subs istence, as detailed above under 11 AAC 112.270 Subsistence and discussed at length in the EIA.

ROCKY ISLANDS AND SEA CLIFFS

There are no rocky islands or sea cliffs within She ll's prospects or near the marine shorebase facilities in Wainwright. Important sea cliffs are located in the Cape Thompson, Point Hope, Cape Lisburne area, where large numbers of cliff-nesting birds nest each year. These areas are located more than 155 mi from Shell's prospects and the marine shorebase facilities, and more than five miles from Shell’s
identified vessel and aircraft transit corridors. The proposed exploration drilling program would have no effect on rocky islands and sea cliffs.

BARRIER ISLANDS AND LAGOONS

Shell’s prospects are located more than 60 statute mi from any barrier islands or lagoons. Shell plans to establish shorebase facilities in Wainwright, which sits on the shores of the Chukchi Sea and the Kuk River lagoon or Wainwrigt Inlet. Vessel traffic supporting the drilling program would utilize existing earthen boat ramps in Wainwright on the la goon, and transit through the inlet to the Chukchi
Sea. Vessels would consist of a shallow-wate r landing craft and oil spill response work boats.

The vessel and aircraft traffic should ha ve little or no effect on lagoon habitats.

The proposed exploration drilling program would have no effect on the flow of sediments or water in the barrier island and lagoon habitats. No structures will be placed in the water in estuary habitat that would alter or redirect wave energy or marine curre nts that would lead to the filling in or the erosion of barrier islands. The drillship would be a floating, anchored vessel, located mo re than 60 statute mi
offshore and would have no effect on waves or currents.

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traffic corridors are no closer than 30 mi from any known bird nesting colonies. The routes have been selected to avoid coastal habitats, transiting eith er directly offshore from the coastal shorebase facilities, or transiting along a route that is at least five mi inland of the shoreline.

EXPOSED HIGH-ENERGY COASTS

No exposed high-energy coasts will be affected by the exploration drilling program, as most activities
will be conducted in offshore waters of the Chukchi Sea. Shorebase facilities will be established in Barrow and Wainwright, but this will require no land development. Exis ting boat ramps will be
utilized at marine shorebase facilities in Wainwr ight, but these ramps are located on the Kuk River lagoon.

RIVERS, STREAMS, AND LAKES

No rivers, streams, or lakes will be affected by the planned exploration drilling program, as most
activities will be conducted in offshore waters of the Chukchi Sea. Shorebase facilities will be established in Barrow and Wainwright, but th is will require no land development.

IMPORTANT HABITAT

Important habitats along the northeastern Chukc hi Sea include Peard Bay, Kasegaluk Lagoon, Ledyard Bay, Alaska Maritime NWR, and the Polynya Zone.

Distances from Shell prospects to identified sensitive biological resources and
habitats

Sensitive Area Distance to Nearest Drill Site in Statute Miles (km) Burger Crackerjack SW Shoebill Polynya Zone 40 (64) 80 (129) 92 (148) Ledyard Bay CHA 58 (93) 81 (130) 90 (145) Kasegaluk Lagoon 70 (113) 115 (185) 128 (206)
Alaska Maritime
NWR 68 (109) 114 (184) 127 (204) Peard Bay 100 (161) 162 (259) 184 (296)

Peard Bay is a productive area especially important to shorebirds, and has been identified as one of the most important areas for staging shorebirds in the U.S. Shell's prospects are located more than 100 mi from Peard Bay, and the predetermined aircraft tr affic corridor is more than five miles from the shoreline of Peard Bay. The proposed explora tion drilling should have no adverse impacts on the special productivity of these habitats.

Kasegaluk Lagoon has been identified as an area of im portance to marine mammals, including beluga whales, and staging waterfowl such as the Pacific blac k brant. For example, as much as 50 percent of the North American population of brant has been fo und to stage within the lagoon. Shell's prospects are located more than 70 mi from Kasegaluk Lagoon, and the predetermined aircraft traffic corridor is more than five miles from Kasegaluk Lagoon. Th e proposed exploration program should have no adverse impacts on the special productivity of the habitat.

Ledyard Bay is an especially productive area, and of importance to spectacled eiders, for which it has been designated Critical Habitat Area (CHA). MM S's Lease Sale 193 Stipulation No. 7 requires lessees to avoid vessel transit of the CHA July 1 - November 15, and aircraft overflights of the CHA at altitudes of < 1,500 ft during the same period. Sh ell's prospects are located more than 58 mi from2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 172 July 2009 15276-03-09-001A/09-011A Rev. 1

the Ledyard Bay CHA, and the predetermined aircraft traffic corridor is more than 53 mi from the Ledyard Bay CHA. Shell expects to have no operational vessel or aircraft traffic that is part of this EP, occur within or over the CHA. The propo sed exploration program should have no adverse impacts on the special productivity of these habitats.

Alaska Maritime NWR

The Alaska Maritime NWR was established to conserve marine mammals and seabird, and contains shoreline and coastal waters of large stretches of the northeastern Chukchi Sea. No parts of the NWR are closer than 68 mi from Shell's prospects, or closer than 53 mi from Shell's predetermined vessel and aircraft traffic corridors. The proposed e xploration program should have no adverse impacts on the special productivity of these habitats.

Polynya Zone

The polynya zone is an area of recurring spring l eads located between 1-30 miles offshore along much of the coastline of the northeastern Chukchi Sea. The area's biological importance as an important habitat is that it serves as the migration corridor and only ice fee habitat during the spring migration of
marine mammals and birds. Wildlife is concentr ated in these areas during their migrations, and are thought to be sensitive to disturbance based on the rest ricted nature of the habitat. Shell's prospects are located more than 40 mi from the Polynya Zone as designated by the MMS. Shell will avoid traversing any portion of the Polynya Zone when transiting the drillship and support vessels in or out of the Chukchi Sea, unless safety dictates otherwise.

Shell's predetermined vessel and aircraft tra ffic corridors traverse the Polynya Zone, which lies between the prospects and shorebase locations. Aircra ft and vessel traffic should have no effect on the habitat, but could disturb marine mammals and bi rds. Any such effects would be minimized by Shell's mitigation measures, which include minimum fli ght altitude of 1,500 ft for operational aircraft. The proposed and relatively infrequent vessel tra ffic between the marine support shorebase facilities
could disturb marine mammals and birds but would occur in July, August, September, and October, while the increased importance of the Polynya Zone occurs during the spring when ice-free water habitats are restricted. For these reasons, the pr oposed exploration program should have little or no adverse impacts on the special productivity of these habitats.

All of the above-discussed importanthabitats would be traversed by aerial overflights with a fixedwing aircraft as part of Shell's marine mammal mitigation and monitoring program, which collects important and needed distribution data on marine ma mmals in the area within 20 mi for the shoreline of the northeastern Chukchi Sea. Any disturbance to marine mammals and birds will be minimized by the infrequency of the flights (2x/week), and maintenance of a minimum altitude of 1,000 ft. If whales are observed in shallow waters such as lagoons and estuaries, the aircraft will climb to 10,000 ft to avoid disturbance. Given these mitigation measures the proposed marine mammal mitigation and monitoring overflights should have little or no adve rse impacts on the special productivity of these important habitats.

(c) No response required.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 173 July 2009 15276-03-09-001A/09-011A Rev. 1

11 AAC 112.310. Air, land and water quality
Standard: Not withstanding any other provision of this chapter, the statutes and regulations of the Department of Environmental Conservation with respect to the prot ection of air, land, and water quality identified in AS 46.40.040(b) are incorporated into the program an d, as administered by that department, constitute the exclusive components of the progr am with respect to those purposes.

Evaluation : No response required.

11 AAC 112.320. Historic, prehistoric, and archaeological resources.
Standard: (a) The department will designate areas of the coast al zone that are important to the study, understanding, or illustration of national, state, or local history or prehistory, including natural

processes. (b) A project within an area designated under (a) of this section shall comply with the applicable requirements of AS 41.35.010 – 41.35.240 and 11 AAC 16.010 – 11 AAC 16.900.

Evaluation : (a) Have you contacted the State Historic Preservation Office (SHPO) to see if your project is in a designated area of the coastal zone that is importa nt to the study, understanding, or illustration of national, state, or local history or pr ehistory, including natural processes? The offshore OCS project is not located in Alaska's designated coastal zone.

(b) If your project is within an area designated under (a) of this section, how will you comply with the applicable requirements in the statutes and regulations listed in (b)? Not applicable.
Affected Coastal District Enforceable Policies2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 174 July 2009 15276-03-09-001A/09-011A Rev. 1

Evaluate each applicable district enforceable policy using a format similar to the one you completed above for the State Standards. Di strict enforceable policies are available at http://alaskacoast.state.ak.us/. If you need more space for an adequate explanation of any of the applicable district enforceable po licies, please attach additional pages to the end of this document.

Applicable District Plan(s) The approved NSBCMP is not available for evaluation. Enforceable Policy:
Evaluation :

Enforceable Policy:
Evaluation :

Enforceable Policy:
Evaluation :



### Certification Statement

The information contained herein is true and complete to the best of my knowledge. I certify that the proposed activity complies with, and will be conducted in a manner cons istent with, the Alaska Coastal Management Program.

___________________________________________________ _____August 11, 2009 Signature of Applicant or Agent Date

Note: Federal agencies conducting an activity that will affect the coastal zone are required to submit a federal consistency de termination, per 15 CFR 930, Subpart C, ra ther than this certification statement. ACMP has developed a guide to assist federal agencies with this requirement. Contact ACMP to obtain a

copy.

This certification statement will not be complete until all required State and fede ral authorization requests have been submitted to the appropriate agencies.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 175 July 2009 15276-03-09-001A/09-011A Rev. 1 SECTION 16.0 ENVIRONMENTAL IMPACT ANALYSIS

Refer to Appendix F for the Environmental Impact Analysis.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 176 July 2009 15276-03-09-001A/09-011A Rev. 1 

## THIS PAGE
INTENTIONALLY
LEFT BLANK2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 177 July 2009 15276-03-09-001A/09-011A Rev. 1 SECTION 17.0 ADMINISTRATIVE

a) Exempted Information (public information copies only)

The following information is considered proprietary and has been removed from the public copies of the
EP:

 Drill sites and depths in the Form 137 OC S Plan Information Forms (Appendix A)

 All of Sections 3.1, 3.2, and 3.3 including

o Geologic descriptions (Sections 3.1.a, 3.2.a, and 3.3.a)

o Proposed surface location & bathymetry maps (Sections 3.1.b, 3.2.b, and 3.3.b)

o Proposed surface location & geologic structure ma ps (Sections 3.1.c, 3.2.c, and 3.3.c)

o Prospect 2D and 3D seismic lines (S ections 3.1.d, 3.2.d, and 3.3.d)

o Prospect 2D and 3D seismic lines – geologic cr oss section maps (Sections 3.1.e, 3.2.e, and 3.3.e)

o Stratigraphic column & time/depth tables (Sections 3.1.f, 3.2.f, and 3.3.f)

b) Bibliography

Appendix F, EIA has its own bibliography describing st udy reports, survey reports or other material used.

ASRC Energy Services. 2009. Subsistence Adviso r Program Summary, North Slope, Alaska. Report prepared by ASRC Energy Services, Anchorage, AK for Shell Exploration and Production Company, Houston, TX

AECOM, Inc. 2009. Wainwright near-term ambien t air quality monitoring program first quarter data report November 2008 through January 2009 final. U npublished report prepared by AECOM, Inc., for ConocoPhillips Alaska, Inc., Anchorage, Alaska.

Boudreau, B. 1989. Biological clearance for Bu rger and Crackerjack Prospects. U.S. Govt. Memorandum, from Regional Supervisor, Field Opera tions, Minerals Management Service, Alaska OCS Region to District Office Supervisor.

Brueggeman, J. in prep. Marine mammal surveys at the Klondike and Burger Prospects in the Chukchi Sea during the 2008 open water season. Report prep ared by Canyon Creek Consulting LLC, Seattle WA for ConocoPhillips Alaska, Inc. and Shell Explorat ion & Production Company, Anchorage, Alaska, 46

pp. Finney, H. 1989. Summary: Biological reconnai ssance, Burger Prospect, Sale 109, Chukchi Sea, Alaska. Unpublished Report submitted by H. Finn ey, Fugro-McClelland Marine Geosciences, Inc., Houston, Texas to Shell West ern E&P Inc., Houston Texas.

Fugro-McClelland Marine Geosciences, Inc. 1989. High-Resolution Geophysical Survey and Assessment of Potential Shallow Drilling Hazards , Burger Prospect, Chukchi Sea, Alaska. report prepared by Fugro-McClelland Marine Geosciences, Inc., Houston TX for Shell Western E&P, Inc., Houston, Texas.

Fugro Geoconsulting, Inc. 2009. Drill Site Cleara nce Letters, Proposed Drill Sites C & F Blocks 6764 OCS-Y-2280 & 6714 OCS-Y-2267, Chukchi Sea, Alaska. Prepared by Fugro Geoconsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

Gall, A. and R. Day. in prep. Distribution and ab undance of seabirds in the northeastern Chukchi Sea, 2008. Report prepared by ABR, Inc - Environm ental Research & Services, Fairbanks, AK for ConocoPhillips Alaska, Inc. and Shell Exploratio n & Production Company, Anchorage, Alaska, 46 pp.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 178 July 2009 15276-03-09-001A/09-011A Rev. 1 Geoscience Earth & Marine Services, Inc. 2009a. Shallow Hazards and Archeological Assessment, Burger J Drill Site Karo Block NR03-02 6912, Chukch i Sea, Alaska. Prepared by Geoscience Earth & Marine Services, Inc., Houston, TX for Sh ell Gulf of Mexico Inc., Houston, TX.

Geoscience Earth & Marine Services, Inc. 2009b. Shallow Hazards and Ar cheological Assessment, Crackerjack C Drill Site Karo Block NR03-01 6864, Chuk chi Sea, Alaska. Prepared by Geoscience Earth & Marine Services, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

Geoscience Earth & Marine Services, Inc. 2009c. Shallow Hazards and Archeological Assessment, SW
Shoebill “C” Drill Site Karo Block NR03-01 7007, Chukchi Sea, Alaska. Prepared by Geoscience Earth & Marine Services, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

Ireland, D., R. Rodrigues, D. W. Funk, W. Koski, and D. Hannay. 2009. Marine Mammal Monitoring and Mitigation during Open Water Seis mic Exploration by Shell Offshore Inc. in the Chukchi Sea, July– November 2008: 90–day report. LGL Draft Rep. P 1049–1. Rep. from LGL Alask a Research Associates, Inc., Anchorage, AK, LGL Ltd. Environmental Resear ch Associates, King City, Ont., King City, Ont., and JASCO Research Ltd., Victoria, BC, for Shell O ffshore Inc., Houston, TX, and Nat. Mar. Fish. Serv., Silver Spring, MD.

NMFS. 2001. Small takes of marine mammals incident al to specified activities; oil and gas exploration drilling activities in the Beaufort Sea/ Notice of issuance of an incidental harassment authorization. Fed. Regist. 66(26, 7 Feb.):9291-9298.

Northern Economics. 2009. Economic Analysis of Fu ture Offshore Oil and Gas Development: Beaufort Sea, Chukchi Sea, and North Aleutian Basin. Re port prepared by Northern Economics, Anchorage Alaska for Shell Exploration and Production, Houston, TX.

Sherwood, K.W., J.D. Craig, J. Scherr, P.O. Johns on, and L.W. Cooke. 2001. Undiscovered Oil and Gas
Resources of the U.S. Arctic Alaska Outer Continen tal Shelves (abs): American Association of Petroleum Geologists, Annual International Meeting, St. Petersburg, Russia, Abstracts with Programs, July 15 – 18, 2001, St. Petersburg, Russia.

Sound Enterprises and Associates, LLC. 2008. Sh ell Exploration and Production Company (SEPCO) Chukchi Village Interview Program . Report prepared by Sound Enterprises, LLC, Bainbridge, WA for Shell Exploration and Production Company Houston, TX.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. July 2009 15276-03-09-001A/09-011A Rev. 1 

## Appendix A

Outer Continental Shelf Pl an Information Forms (Form 137)2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. July 2009 15276-03-09-001A/09-011A Rev. 1 

## THIS PAGE
INTENTIONALLY
LEFT BLANK

## Appendix A

Outer Continental Shelf Plan I nformation Forms (Form 137)



# THE INFORMATION IN THIS SECTION CONTAINS CONFIDENTIAL/PROPRIETARY INFORMATION AND IS NOT

AVAILABLE IN THIS PUBLIC INFORMATION COPY OF THE

EXPLORATION PLAN.2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. July 2009 15276-03-09-001A/09-011A Rev. 1 

## Appendix B

National Pollutant Discharge Elimination System Permit Notice of Intent Application(s)2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. July 2009 15276-03-09-001A/09-011A Rev. 1 

## THIS PAGE
INTENTIONALLY
LEFT BLANKPermit No.:
AKG280000



### ATTACHMENT 1



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

APPLICANT ( Owner/Operator)
Owner Name: Shell Gulf of Mexico Inc. Operator Mailing
Address: 3601 C Street Telephone Number: 907-770-3700 Suite 1000 Operator Name: Shell Gulf of Mexico Inc. Anchorage, AK 99503 Telephone Number: 907-770-3700 

### FACILITY Facility Name: Frontier Discoverer Facility Mailing
Address: 3601 C Street
Contact Name: Susan Childs Suite 1000 Telephone Number: 907-770-3700 Anchorage, AK 99503 Beginning Date of Operation: July 4, 2010 Stationary
Facilities Latitude:

Expected Duration of Operation: 37 days per well site Longitude:

Facility Type (check applicable type) Jackup

Mobile Facilities Initial
Latitude: 71.310950 (NAD 83
Lease Block centerpoint location) Drill Ship
Semisubmersible Other (specify): Initial Longitude: -163.202497 (NAD 83
Lease Block centerpoint location) Submit a site map showing the exact location of facility and discharges associated with the project. Mobile facilities may designate an area where they may be operating and must include a map showing those areas and a description of operations within those areas. If the discharge is within 4000 meters of an environmentally sensitive area indicated by the permit, those areas and their distance from th e operation/discharge must be shown on the map. 

### RECEIVING WATER

Chukchi Sea Other ( specify ):

Beaufort Sea Supply confirmation with the U.S. Department of State and NOAA that the discharge is seaward of the inner boundary baseline, if applicable. 

### LOCATION OF DISCHARGE

MMS Lease Number 

### OCS-Y-2280 ADNR Lease Number 

### N/A

Block Number 

### Posey Area Block
6764 Block Number 

### N/A

Range of water depths below mean lower low water (MLLW) in the lease block: From: 

### 149' To: 

### 149'

Page 1 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Discharges ( check all that apply) 001 Drilling Mud and Cuttings Water Depth: 

### 149' 002 Deck Drainage Water Depth: 

### 149' 003 Sanitary Waste Water Depth: 

### 149'

004 Domestic Waste Water Depth: 

### 149'

005 Desalination Unit Waste Water Depth: 

### 149'

006 Blowout Preventer Fluid Water Depth: 

### 149'

007 Boiler Blowdown Water Depth: 008 Fire Control System Test Water Water Depth: 009 Non-Contact Cooling Water Water Depth: 

### 149'

010 Uncontaminated Ballast Water Water Depth: 

### 149' 011 Bilge Water Water Depth: 

### 149' 012 Excess Cement Slurry Water Depth: 

### 149' 013 Mud, Cuttings, Cement and Seafloor Water Depth: 

### 149'

014 Test Fluid Water Depth: Provide a brief description of the treatment process(es) and disposal practices (e.g., backhauled, reinjected, discharged, etc.) at the facility. See attached (Table 1) Provide a line drawing that shows flow of discharged wast e streams through the facility. Indicate intake sources, operations contributing to the effluent, and treatment units labeled to correspond to the discharges (001 – 014). Construct a flow balance on the line drawing by showing average flows between intakes, operations, treatment units, and outfalls. If a flow balance cannot be determined, provide a pictorial description of the nature and amount of any sources, and any collection or treatment measures. 

### Well Information

Well Name: 

### Burger Latitude: 

### 71.310950 (NAD 83
Lease Block centerpoint location)

Well Number: 

### C Longitude: 

### -163.202497 (NAD 83
Lease Block centerpoint location)

Beginning Drill Date: 

### July 4, 2010 Hole Diameter or Estimated Total Discharge
Volume: 

### 36" diameter at surface, reducing through 4 stages to 8.5" at depth Drilling Fluid

Category ( check all that apply ) Water-based

Group ( check all that apply ) Lignosulfonate

Oil-based Lime Synthetic-based Gyp Other ( specify ): Sea-waterSaltwater

Saturated Saltwater Nondispersed (Viscosifier/Polymer) PH/PA

Page 3 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Zone of Deposit Request ( applicable to those discharges within state of Alaska waters)

Are you requesting a Zone of Deposit from ADEC? Yes ( continue filling out
this section ) No ( skip this section and proceed to Special Conditions, below ) THE FOLLOWING INFORMATION MUST BE PROVIDED IF REQUESTING A ZONE OF DEPOSIT. The burden of proof for justifying a zone of deposit through demonstrating compliance with the requirements of 18 AAC 70.210 rests with the applicant.
Distance from shorelin e of discharge point (measured at M.L.L.W.): Average Mud density: Depth of discharge (measured at M.L.L.W.): Flow Rate:

Orientation of outfall to shoreline (e.g., perpendicular, 45 ° , parallel): Total Volume:

Orientation of outfall to water surface (e.g., perpendicular, 45 ° , parallel): Maximum current
and direction: If possible, provide salinity and temperatur e data from the receiving water surface to the depth of the discharge port or diffu ser. 

### Mixing Zone Request ( applicable to those discharges within state of Alaska waters)

Are you requesting a mixing zone from ADEC? Yes ( continue filling out
this section ) No ( skip this section and proceed to Special Conditions, below )

THE FOLLOWING INFORMATION MUST BE PROVIDED IF REQUESTING A MIXING ZONE. The burden of proof for justifying a mixing zone through demonstrating compliance with the requirements of 18 AAC 70.240 through 18 AAC 70.270 rests with the applicant.
Distance from shoreline of discharge point or first port of diffuser (meas ured at M.L.L.W.): Length of diffuser:

Depth of discharge port or diffuser (measured at M.L.L.W.): Diameter of port(s):

Orientation of diffuser to shoreline (e.g., perpendicular, 45 ° , parallel): Number of ports:

Maximum current: Port spacing:
USE OF RECEIVING WATER AT DISTANCE FROM DIFFUSER i.e., Supply for drinking water, Supply for agriculture including irrigation & stock water, Supply for a quaculture, Supply for industrial use, Contact recreation, Secondary recreation, Fish spawning, Harvesting and consumpti on of raw fish, or other aquatic life (Not needed if not requesting a mixing zone from ADEC):

If possible, provide salinity and temperatur e data from the receiving water surface to the depth of the discharge port or diffu ser.

Page 4 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Special Conditions ( provide justification for all that ar e not required, completed or provided)

Special Monitoring Required Not Required Justification:

Exploration Plans Attached Not Provided Justification: Submitted to MMS

Biological Surveys Attached Not Provided Justification: None required

Environmental Report(s) Attached Not Provided Justification: Submitted to MMS as part of the Exploration Plan

Drilling Fluid Plan Complete Not Complete Justification: In Preparation



### Certification I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the pe rson or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Signature: Date:

Printed Name: Susan Childs Title: Regulatory Affairs Manager 

### Mail Completed NOI to EPA and ADE C at the following addresses:

US EPA
1200 6 th Avenue, M/S OWW-130 Seattle, WA 98101 ADEC, Water Division
555 Cordova Street Anchorage, Alaska 99501

Page 5 of 5" "

"

" " "

" C h u k c h i S e a A r c t i c O c e a n

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National Petroleum Reserve - Alaska (NPR-A) Wainwright Barrow

Atqasuk

Point Lay

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AES-RTS: 09-011-002.mxd, 02/27/09, R00 

# r

SCALE:

NAD83, Alaska Albers Equal Area SCALE: FIGURE:

1 NOTICE OF INTENT AKG-28-0000 POSEY AREA BLOCK 6764 CHUKCHI SEA

0 40 80 20 Miles 

### SHE LL Shell OCS Lease Block

Posey Area Block 6764 Lease Sale 193 Area

National Petroleum Reserve - Alaska " Village ! ! ! RUSSIA

CANADA

P a c i f i c O c e a n A r c t i c O c e a n

B e r i n g

S e a G u l f o f A l a s k a Barrow Area Enlarged

Fairbanks

Anchorage 

# rTypes and Estimated Volume Ocean Discharges During Drilling Season 2010– Burger C Drill Site

Type of Waste Total Amount to be Discharged Discharge Rate* Discharge Method Drill cuttings (from MLC and 36-inch section) 3,070 bbl/well (cuttings only; no drilling muds used) 614 bbl/day (for approx. 5 days) Deposited on the surface of the seafloor

Spent drilling fluids 4,405 bbl/well spent mud plus mud in tanks (if multiple wells drilled per season, water based muds will be transferred to and used at the next well) 138 bbl/day (including discharge of
excess water based drilling fluid at end of the drilling season) Discharged to sea through disposal caisson after 30:1 dilution with
seawater

Cuttings from water based intervals (does not include MLC and 36-inch section) 2,905 bbl/well 91 bbl/day Discharged to sea through disposal caisson after 30:1 dilution with
seawater

Sanitary waste 1,000 bbl/well 27 bbl/day Treated in marine sanitary device prior to discharge to meet NPDES limits (based on 124 people at 9 gal/person/day) Domestic waste 3071 bbl/well 83 bbl/day Discharged to water through the disposal caisson (based on 124 people at 28 gal/person/day);all food waste to be incinerated Excess cement 50 bbl/well Two occasions at 1 bbl/min Discharged at seafloor during 30- inch and 20-inch cementing operations
Desalination unit brine water 4,625 bbl/well 125 bbl/day Discharged to water through disposal caisson Deck drainage 185 bbl/well 5 bbl/day (dependent on rainfall) Drains to the oily water separator. Uncontaminated water is discharged through the disposal caisson; contaminated water is stored in a waste oil tank then transferred by boat to an approved treatment/disposal site. Cooling water 1,665,000 bbl/well 45,000 bbl/day Discharged to water through a number of outlets
Firewater 0 0 bbl/day No routine firewater system testing anticipated Ballast water 22,940 bbl/well 620 bbl/day Discharged to sea through disposal caisson Bilge water 1000 bbl/well 27 bbl/day Treated in oily water separator, uncontaminated water discharged to sea through disposal caisson, oily water stored onboard, transferred for transport by boat to an approved treatment/disposal site BOP fluid 42 bbl/well (6 tests; 7 bbl per test) 7 bbl/day Discharged at the seafloor at the BOP

* assumes 5 days to complete the MLC and 36-inch section; 32 days to complete the remainder of the wellPermit No.:
AKG280000



### ATTACHMENT 1



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

APPLICANT ( Owner/Operator)
Owner Name: Shell Gulf of Mexico Inc. Operator Mailing
Address: 3601 C Street Telephone Number: 907-770-3700 Suite 1000 Operator Name: Shell Gulf of Mexico Inc. Anchorage, AK 99503 Telephone Number: 907-770-3700 

### FACILITY Facility Name: Frontier Discoverer Facility Mailing
Address: 3601 C Street
Contact Name: Susan Childs Suite 1000 Telephone Number: 907-770-3700 Anchorage, AK 99503 Beginning Date of Operation: July 4, 2010 Stationary
Facilities Latitude:

Expected Duration of Operation: 37 days per well site Longitude:

Facility Type (check applicable type) Jackup

Mobile Facilities Initial
Latitude: 71.338371 (NAD 83
Lease Block centerpoint location) Drill Ship
Semisubmersible Other (specify): Initial Longitude: -163.209988 (NAD 83
Lease Block centerpoint location) Submit a site map showing the exact location of facility and discharges associated with the project. Mobile facilities may designate an area where they may be operating and must include a map showing those areas and a description of operations within those areas. If the discharge is within 4000 meters of an environmentally sensitive area indicated by the permit, those areas and their distance from th e operation/discharge must be shown on the map. 

### RECEIVING WATER

Chukchi Sea Other ( specify ):

Beaufort Sea Supply confirmation with the U.S. Department of State and NOAA that the discharge is seaward of the inner boundary baseline, if applicable. 

### LOCATION OF DISCHARGE

MMS Lease Number 

### OCS-Y-2267 ADNR Lease Number 

### N/A

Block Number 

### Posey Area Block
6714 Block Number 

### N/A

Range of water depths below mean lower low water (MLLW) in the lease block: From: 

### 148' To: 

### 148'

Page 1 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Discharges ( check all that apply) 001 Drilling Mud and Cuttings Water Depth: 

### 148' 002 Deck Drainage Water Depth: 

### 148' 003 Sanitary Waste Water Depth: 

### 148'

004 Domestic Waste Water Depth: 

### 148'

005 Desalination Unit Waste Water Depth: 

### 148'

006 Blowout Preventer Fluid Water Depth: 

### 148'

007 Boiler Blowdown Water Depth: 008 Fire Control System Test Water Water Depth: 009 Non-Contact Cooling Water Water Depth: 

### 148'

010 Uncontaminated Ballast Water Water Depth: 

### 148' 011 Bilge Water Water Depth: 

### 148' 012 Excess Cement Slurry Water Depth: 

### 148' 013 Mud, Cuttings, Cement and Seafloor Water Depth: 

### 148'

014 Test Fluid Water Depth: Provide a brief description of the treatment process(es) and disposal practices (e.g., backhauled, reinjected, discharged, etc.) at the facility. See attached (Table 1) Provide a line drawing that shows flow of discharged wast e streams through the facility. Indicate intake sources, operations contributing to the effluent, and treatment units labeled to correspond to the discharges (001 – 014). Construct a flow balance on the line drawing by showing average flows between intakes, operations, treatment units, and outfalls. If a flow balance cannot be determined, provide a pictorial description of the nature and amount of any sources, and any collection or treatment measures. 

### Well Information

Well Name: 

### Burger Latitude: 

### 71.338371 (NAD 83
Lease Block centerpoint location)

Well Number: 

### F Longitude: 

### -163.209988 (NAD 83
Lease Block centerpoint location)

Beginning Drill Date: 

### July 4, 2010 Hole Diameter or Estimated Total Discharge
Volume: 

### 36" diameter at surface, reducing through 4 stages to 8.5" at depth Drilling Fluid

Category ( check all that apply ) Water-based

Group ( check all that apply ) Lignosulfonate

Oil-based Lime Synthetic-based Gyp Other ( specify ): Sea-waterSaltwater

Saturated Saltwater Nondispersed (Viscosifier/Polymer) PH/PA

Page 3 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Zone of Deposit Request ( applicable to those discharges within state of Alaska waters)

Are you requesting a Zone of Deposit from ADEC? Yes ( continue filling out
this section ) No ( skip this section and proceed to Special Conditions, below ) THE FOLLOWING INFORMATION MUST BE PROVIDED IF REQUESTING A ZONE OF DEPOSIT. The burden of proof for justifying a zone of deposit through demonstrating compliance with the requirements of 18 AAC 70.210 rests with the applicant.
Distance from shorelin e of discharge point (measured at M.L.L.W.): Average Mud density: Depth of discharge (measured at M.L.L.W.): Flow Rate:

Orientation of outfall to shoreline (e.g., perpendicular, 45 ° , parallel): Total Volume:

Orientation of outfall to water surface (e.g., perpendicular, 45 ° , parallel): Maximum current
and direction: If possible, provide salinity and temperatur e data from the receiving water surface to the depth of the discharge port or diffu ser. 

### Mixing Zone Request ( applicable to those discharges within state of Alaska waters)

Are you requesting a mixing zone from ADEC? Yes ( continue filling out
this section ) No ( skip this section and proceed to Special Conditions, below )

THE FOLLOWING INFORMATION MUST BE PROVIDED IF REQUESTING A MIXING ZONE. The burden of proof for justifying a mixing zone through demonstrating compliance with the requirements of 18 AAC 70.240 through 18 AAC 70.270 rests with the applicant.
Distance from shoreline of discharge point or first port of diffuser (meas ured at M.L.L.W.): Length of diffuser:

Depth of discharge port or diffuser (measured at M.L.L.W.): Diameter of port(s):

Orientation of diffuser to shoreline (e.g., perpendicular, 45 ° , parallel): Number of ports:

Maximum current: Port spacing:
USE OF RECEIVING WATER AT DISTANCE FROM DIFFUSER i.e., Supply for drinking water, Supply for agriculture including irrigation & stock water, Supply for a quaculture, Supply for industrial use, Contact recreation, Secondary recreation, Fish spawning, Harvesting and consumpti on of raw fish, or other aquatic life (Not needed if not requesting a mixing zone from ADEC):

If possible, provide salinity and temperatur e data from the receiving water surface to the depth of the discharge port or diffu ser.

Page 4 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Special Conditions ( provide justification for all that ar e not required, completed or provided)

Special Monitoring Required Not Required Justification:

Exploration Plans Attached Not Provided Justification: Submitted to MMS

Biological Surveys Attached Not Provided Justification: None required

Environmental Report(s) Attached Not Provided Justification: Submitted to MMS as part of the Exploration Plan

Drilling Fluid Plan Complete Not Complete Justification: In Preparation



### Certification I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the pe rson or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Signature: Date:

Printed Name: Susan Childs Title: Regulatory Affairs Manager 

### Mail Completed NOI to EPA and ADE C at the following addresses:

US EPA
1200 6 th Avenue, M/S OWW-130 Seattle, WA 98101 ADEC, Water Division
555 Cordova Street Anchorage, Alaska 99501

Page 5 of 5" "

"

" " "

" C h u k c h i S e a A r c t i c O c e a n

Icy Cape L e d y a r d B a y B e a u f o r t S e a

National Petroleum Reserve - Alaska (NPR-A) Wainwright Barrow

Atqasuk

Point Lay

Point Hope 155°W 160°W 165°W 170°W 175°W73°N72°N72°N71°N71°N70°N70°N69°N69°N68°N

AES-RTS: 09-011-003.mxd, 02/27/09, R00 

# r

SCALE:

NAD83, Alaska Albers Equal Area SCALE: FIGURE:

1 NOTICE OF INTENT AKG-28-0000 POSEY AREA BLOCK 6714 CHUKCHI SEA

0 40 80 20 Miles 

### SHE LL Shell OCS Lease Block

Posey Area Block 6714 Lease Sale 193 Area

National Petroleum Reserve - Alaska " Village ! ! ! RUSSIA

CANADA

P a c i f i c O c e a n A r c t i c O c e a n

B e r i n g

S e a G u l f o f A l a s k a Barrow Area Enlarged

Fairbanks

Anchorage 

# rTypes and Estimated Volume Ocean Discharges During Drilling Season 2010– Burger F Drill Site

Type of Waste Total Amount to be Discharged Discharge Rate* Discharge Method Drill cuttings (from MLC and 36-inch section) 3,070 bbl/well (cuttings only; no drilling muds used) 614 bbl/day (for approx. 5 days) Deposited on the surface of the seafloor

Spent drilling fluids 4,405 bbl/well spent mud plus mud in tanks (if multiple wells drilled per season, water based muds will be transferred to and used at the next well) 138 bbl/day (including discharge of
excess water based drilling fluid at end of the drilling season) Discharged to sea through disposal caisson after 30:1 dilution with
seawater

Cuttings from water based intervals (does not include MLC and 36-inch section) 2,905 bbl/well 91 bbl/day Discharged to sea through disposal caisson after 30:1 dilution with
seawater

Sanitary waste 1,000 bbl/well 27 bbl/day Treated in marine sanitary device prior to discharge to meet NPDES limits (based on 124 people at 9 gal/person/day) Domestic waste 3071 bbl/well 83 bbl/day Discharged to water through the disposal caisson (based on 124 people at 28 gal/person/day);all food waste to be incinerated Excess cement 50 bbl/well Two occasions at 1 bbl/min Discharged at seafloor during 30- inch and 20-inch cementing operations
Desalination unit brine water 4,625 bbl/well 125 bbl/day Discharged to water through disposal caisson Deck drainage 185 bbl/well 5 bbl/day (dependent on rainfall) Drains to the oily water separator. Uncontaminated water is discharged through the disposal caisson; contaminated water is stored in a waste oil tank then transferred by boat to an approved treatment/disposal site. Cooling water 1,665,000 bbl/well 45,000 bbl/day Discharged to water through a number of outlets
Firewater 0 0 bbl/day No routine firewater system testing anticipated Ballast water 22,940 bbl/well 620 bbl/day Discharged to sea through disposal caisson Bilge water 1000 bbl/well 27 bbl/day Treated in oily water separator, uncontaminated water discharged to sea through disposal caisson, oily water stored onboard, transferred for transport by boat to an approved treatment/disposal site BOP fluid 42 bbl/well (6 tests; 7 bbl per test) 7 bbl/day Discharged at the seafloor at the BOP

* assumes 5 days to complete the MLC and 36-inch section; 32 days to complete the remainder of the wellPermit No.:
AKG280000



### ATTACHMENT 1



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

APPLICANT ( Owner/Operator)
Owner Name: Shell Gulf of Mexico Inc. Operator Mailing
Address: 3601 C Street Telephone Number: 907-770-3700 Suite 1000 Operator Name: Shell Gulf of Mexico Inc. Anchorage, AK 99503 Telephone Number: 907-770-3700 

### FACILITY Facility Name: Frontier Discoverer Facility Mailing
Address: 3601 C Street
Contact Name: Susan Childs Suite 1000 Telephone Number: 907-770-3700 Anchorage, AK 99503 Beginning Date of Operation: July 4, 2010 Stationary
Facilities Latitude:

Expected Duration of Operation: 37 days per well site Longitude:

Facility Type (check applicable type) Jackup

Mobile Facilities Initial
Latitude: 71.173341 (NAD 83
Lease Block centerpoint location) Drill Ship
Semisubmersible Other (specify): Initial Longitude: -163.471812 NAD 83
Lease Block centerpoint location) Submit a site map showing the exact location of facility and discharges associated with the project. Mobile facilities may designate an area where they may be operating and must include a map showing those areas and a description of operations within those areas. If the discharge is within 4000 meters of an environmentally sensitive area indicated by the permit, those areas and their distance from th e operation/discharge must be shown on the map. 

### RECEIVING WATER

Chukchi Sea Other ( specify ):

Beaufort Sea Supply confirmation with the U.S. Department of State and NOAA that the discharge is seaward of the inner boundary baseline, if applicable. 

### LOCATION OF DISCHARGE

MMS Lease Number 

### OCS-Y-2321 ADNR Lease Number

Block Number 

### Posey Area Block
6912 Block Number

Range of water depths below mean lower low water (MLLW) in the lease block: From: 

### 144' To: 

### 144'

Page 1 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Discharges ( check all that apply) 001 Drilling Mud and Cuttings Water Depth: 

### 144' 002 Deck Drainage Water Depth: 

### 144' 003 Sanitary Waste Water Depth: 

### 144'

004 Domestic Waste Water Depth: 

### 144'

005 Desalination Unit Waste Water Depth: 

### 144'

006 Blowout Preventer Fluid Water Depth: 

### 144'

007 Boiler Blowdown Water Depth: 008 Fire Control System Test Water Water Depth: 009 Non-Contact Cooling Water Water Depth: 

### 144'

010 Uncontaminated Ballast Water Water Depth: 

### 144' 011 Bilge Water Water Depth: 

### 144' 012 Excess Cement Slurry Water Depth: 

### 144' 013 Mud, Cuttings, Cement and Seafloor Water Depth: 

### 144'

014 Test Fluid Water Depth: Provide a brief description of the treatment process(es) and disposal practices (e.g., backhauled, reinjected, discharged, etc.) at the facility. See attached (Table 1) Provide a line drawing that shows flow of discharged wast e streams through the facility. Indicate intake sources, operations contributing to the effluent, and treatment units labeled to correspond to the discharges (001 – 014). Construct a flow balance on the line drawing by showing average flows between intakes, operations, treatment units, and outfalls. If a flow balance cannot be determined, provide a pictorial description of the nature and amount of any sources, and any collection or treatment measures. 

### Well Information

Well Name: 

### Burger Latitude: 

### 71.173341 (NAD 83
Lease Block centerpoint location)

Well Number: 

### J Longitude: 

### -163.471812 NAD 83
Lease Block centerpoint location)

Beginning Drill Date: 

### July 4, 2010 Hole Diameter or Estimated Total Discharge
Volume: 

### 36" diameter at surface, reducing through 4 stages to 8.5" at depth Drilling Fluid

Category ( check all that apply ) Water-based

Group ( check all that apply ) Lignosulfonate

Oil-based Lime Synthetic-based Gyp Other ( specify ): Sea-waterSaltwater

Saturated Saltwater Nondispersed (Viscosifier/Polymer) PH/PA

Page 3 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Zone of Deposit Request ( applicable to those discharges within state of Alaska waters)

Are you requesting a Zone of Deposit from ADEC? Yes ( continue filling out
this section ) No ( skip this section and proceed to Special Conditions, below ) THE FOLLOWING INFORMATION MUST BE PROVIDED IF REQUESTING A ZONE OF DEPOSIT. The burden of proof for justifying a zone of deposit through demonstrating compliance with the requirements of 18 AAC 70.210 rests with the applicant.
Distance from shorelin e of discharge point (measured at M.L.L.W.): Average Mud density: Depth of discharge (measured at M.L.L.W.): Flow Rate:

Orientation of outfall to shoreline (e.g., perpendicular, 45 ° , parallel): Total Volume:

Orientation of outfall to water surface (e.g., perpendicular, 45 ° , parallel): Maximum current
and direction: If possible, provide salinity and temperatur e data from the receiving water surface to the depth of the discharge port or diffu ser. 

### Mixing Zone Request ( applicable to those discharges within state of Alaska waters)

Are you requesting a mixing zone from ADEC? Yes ( continue filling out
this section ) No ( skip this section and proceed to Special Conditions, below )

THE FOLLOWING INFORMATION MUST BE PROVIDED IF REQUESTING A MIXING ZONE. The burden of proof for justifying a mixing zone through demonstrating compliance with the requirements of 18 AAC 70.240 through 18 AAC 70.270 rests with the applicant.
Distance from shoreline of discharge point or first port of diffuser (meas ured at M.L.L.W.): Length of diffuser:

Depth of discharge port or diffuser (measured at M.L.L.W.): Diameter of port(s):

Orientation of diffuser to shoreline (e.g., perpendicular, 45 ° , parallel): Number of ports:

Maximum current: Port spacing:
USE OF RECEIVING WATER AT DISTANCE FROM DIFFUSER i.e., Supply for drinking water, Supply for agriculture including irrigation & stock water, Supply for a quaculture, Supply for industrial use, Contact recreation, Secondary recreation, Fish spawning, Harvesting and consumpti on of raw fish, or other aquatic life (Not needed if not requesting a mixing zone from ADEC):

If possible, provide salinity and temperatur e data from the receiving water surface to the depth of the discharge port or diffu ser.

Page 4 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Special Conditions ( provide justification for all that ar e not required, completed or provided)

Special Monitoring Required Not Required Justification:

Exploration Plans Attached Not Provided Justification: Submitted to MMS

Biological Surveys Attached Not Provided Justification: None required

Environmental Report(s) Attached Not Provided Justification: Submitted to MMS as part of the Exploration Plan

Drilling Fluid Plan Complete Not Complete Justification: In Preparation



### Certification I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the pe rson or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Signature: Date:

Printed Name: Susan Childs Title: Regulatory Affairs Manager 

### Mail Completed NOI to EPA and ADE C at the following addresses:

US EPA
1200 6 th Avenue, M/S OWW-130 Seattle, WA 98101 ADEC, Water Division
555 Cordova Street Anchorage, Alaska 99501

Page 5 of 5" "

"

" " "

" C h u k c h i S e a A r c t i c O c e a n

Icy Cape L e d y a r d B a y B e a u f o r t S e a

National Petroleum Reserve - Alaska (NPR-A) Wainwright Barrow

Atqasuk

Point Lay

Point Hope 155°W 160°W 165°W 170°W 175°W73°N72°N72°N71°N71°N70°N70°N69°N69°N68°N

AES-RTS: 09-011-004.mxd, 02/27/09, R00 

# r

SCALE:

NAD83, Alaska Albers Equal Area SCALE: FIGURE:

1 NOTICE OF INTENT AKG-28-0000 POSEY AREA BLOCK 6912 CHUKCHI SEA

0 40 80 20 Miles 

### SHE LL Shell OCS Lease Block

Posey Area Block 6912 Lease Sale 193 Area

National Petroleum Reserve - Alaska " Village ! ! ! RUSSIA

CANADA

P a c i f i c O c e a n A r c t i c O c e a n

B e r i n g

S e a G u l f o f A l a s k a Barrow Area Enlarged

Fairbanks

Anchorage 

# rTypes and Estimated Volume Ocean Discharges During Drilling Season 2010– Burger J Drill Site

Type of Waste Total Amount to be Discharged Discharge Rate* Discharge Method Drill cuttings (from MLC and 36-inch section) 3,070 bbl/well (cuttings only; no drilling muds used) 624 bbl/day (for approx. 5 days) Deposited on the surface of the seafloor

Spent drilling fluids 4,307 bbl/well spent mud plus mud in tanks (if multiple wells drilled per season, water based muds will be transferred to and used at the next well) 135 bbl/day (including discharge of
excess water based drilling fluid at end of the drilling season) Discharged to sea through disposal caisson after 30:1 dilution with
seawater

Cuttings from water based intervals (does not include MLC and 36-inch section) 2,807 bbl/well 88 bbl/day Discharged to sea through disposal caisson after 30:1 dilution with
seawater

Sanitary waste 1,000 bbl/well 27 bbl/day Treated in marine sanitary device prior to discharge to meet NPDES limits (based on 124 people at 9 gal/person/day) Domestic waste 3,071 bbl/well 83 bbl/day Discharged to water through the disposal caisson (based on 124 people at 28 gal/person/day)

Note: all food waste to be incinerated Excess cement 50 bbl/well Two occasions at 1 bbl/min Discharged at seafloor during 30- inch and 20-inch cementing operations
Desalination unit brine water 4,625 bbl/well 125 bbl/day Discharged to water through disposal caisson Deck drainage 185 bbl/well 5 bbl/day (dependent on rainfall) Drains to the oily water separator. Uncontaminated water id discharged through the disposal caisson; contaminated water is stored in a waste oil tank then transferred by boat to an approved treatment/disposal site. Cooling water 1,665,000 bbl/well 45,000 bbl/day Discharged to water through a number of outlets
Firewater 0 0 bbl/month No routine firewater system testing anticipated Ballast water 22,940 bbl/well 620 bbl/day Discharged to sea through disposal caisson Bilge water 1000 bbl/well 27 bbl/day Treated in oily water separator, uncontaminated water discharged to sea through disposal caisson, oily water stored onboard, transferred for transport by boat to an approved disposal site BOP fluid 42 bbl/well (6 tests; 7 bbl per test) 7 bbl/day Discharged subsea at BOP when testing BOP

* assumes 5 days to complete the MLC and 36-inch section; 32 days to complete the remainder of the wellPermit No.:
AKG280000



### ATTACHMENT 1



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

APPLICANT ( Owner/Operator)
Owner Name: Shell Gulf of Mexico Inc. Operator Mailing
Address: 3601 C Street Telephone Number: 907-770-3700 Suite 1000 Operator Name: Shell Gulf of Mexico Inc. Anchorage, AK 99503 Telephone Number: 907-770-3700 

### FACILITY Facility Name: Frontier Discoverer Facility Mailing
Address: 3601 C Street
Contact Name: Susan Childs Suite 1000 Telephone Number: 907-770-3700 Anchorage, AK 99503 Beginning Date of Operation: July 4, 2010 Stationary
Facilities Latitude:

Expected Duration of Operation: 37 days per well site Longitude:

Facility Type (check applicable type) Jackup

Mobile Facilities Initial
Latitude: 71.233034 (NAD 83
Lease Block centerpoint location) Drill Ship
Semisubmersible Other (specify): Initial Longitude: -166.236330 (NAD 83
Lease Block centerpoint location) Submit a site map showing the exact location of facility and discharges associated with the project. Mobile facilities may designate an area where they may be operating and must include a map showing those areas and a description of operations within those areas. If the discharge is within 4000 meters of an environmentally sensitive area indicated by the permit, those areas and their distance from th e operation/discharge must be shown on the map. 

### RECEIVING WATER

Chukchi Sea Other ( specify ):

Beaufort Sea Supply confirmation with the U.S. Department of State and NOAA that the discharge is seaward of the inner boundary baseline, if applicable. 

### LOCATION OF DISCHARGE

MMS Lease Number 

### OCS-Y- 2111 ADNR Lease Number 

### N/A

Block Number 

### Karo Area Block
6864 Block Number 

### N/A

Range of water depths below mean lower low water (MLLW) in the lease block: From: 

### 142' To: 

### 142'

Page 1 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Discharges ( check all that apply) 001 Drilling Mud and Cuttings Water Depth: 

### 142' 002 Deck Drainage Water Depth: 

### 142' 003 Sanitary Waste Water Depth: 

### 142'

004 Domestic Waste Water Depth: 

### 142'

005 Desalination Unit Waste Water Depth: 

### 142'

006 Blowout Preventer Fluid Water Depth: 

### 142'

007 Boiler Blowdown Water Depth: 008 Fire Control System Test Water Water Depth: 009 Non-Contact Cooling Water Water Depth: 

### 142'

010 Uncontaminated Ballast Water Water Depth: 

### 142' 011 Bilge Water Water Depth: 

### 142' 012 Excess Cement Slurry Water Depth: 

### 142' 013 Mud, Cuttings, Cement and Seafloor Water Depth: 

### 142'

014 Test Fluid Water Depth: Provide a brief description of the treatment process(es) and disposal practices (e.g., backhauled, reinjected, discharged, etc.) at the facility. See attached (Table 1) Provide a line drawing that shows flow of discharged wast e streams through the facility. Indicate intake sources, operations contributing to the effluent, and treatment units labeled to correspond to the discharges (001 – 014). Construct a flow balance on the line drawing by showing average flows between intakes, operations, treatment units, and outfalls. If a flow balance cannot be determined, provide a pictorial description of the nature and amount of any sources, and any collection or treatment measures. 

### Well Information

Well Name: 

### Crackerjack Latitude: 

### 71.233034 (NAD 83
Lease Block centerpoint location)

Well Number: 

### C Longitude: 

### -166.236330 (NAD 83
Lease Block centerpoint location)

Beginning Drill Date: 

### July 4, 2010 Hole Diameter or Estimated Total Discharge
Volume: 

### 36" diameter at surface, reducing through 4 stages to 8.5" at depth Drilling Fluid

Category ( check all that apply ) Water-based

Group ( check all that apply ) Lignosulfonate

Oil-based Lime Synthetic-based Gyp Other ( specify ): Sea-waterSaltwater

Saturated Saltwater Nondispersed (Viscosifier/Polymer) PH/PA

Page 3 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Zone of Deposit Request ( applicable to those discharges within state of Alaska waters)

Are you requesting a Zone of Deposit from ADEC? Yes ( continue filling out
this section ) No ( skip this section and proceed to Special Conditions, below ) THE FOLLOWING INFORMATION MUST BE PROVIDED IF REQUESTING A ZONE OF DEPOSIT. The burden of proof for justifying a zone of deposit through demonstrating compliance with the requirements of 18 AAC 70.210 rests with the applicant.
Distance from shorelin e of discharge point (measured at M.L.L.W.): Average Mud density: Depth of discharge (measured at M.L.L.W.): Flow Rate:

Orientation of outfall to shoreline (e.g., perpendicular, 45 ° , parallel): Total Volume:

Orientation of outfall to water surface (e.g., perpendicular, 45 ° , parallel): Maximum current
and direction: If possible, provide salinity and temperatur e data from the receiving water surface to the depth of the discharge port or diffu ser. 

### Mixing Zone Request ( applicable to those discharges within state of Alaska waters)

Are you requesting a mixing zone from ADEC? Yes ( continue filling out
this section ) No ( skip this section and proceed to Special Conditions, below )

THE FOLLOWING INFORMATION MUST BE PROVIDED IF REQUESTING A MIXING ZONE. The burden of proof for justifying a mixing zone through demonstrating compliance with the requirements of 18 AAC 70.240 through 18 AAC 70.270 rests with the applicant.
Distance from shoreline of discharge point or first port of diffuser (meas ured at M.L.L.W.): Length of diffuser:

Depth of discharge port or diffuser (measured at M.L.L.W.): Diameter of port(s):

Orientation of diffuser to shoreline (e.g., perpendicular, 45 ° , parallel): Number of ports:

Maximum current: Port spacing:
USE OF RECEIVING WATER AT DISTANCE FROM DIFFUSER i.e., Supply for drinking water, Supply for agriculture including irrigation & stock water, Supply for a quaculture, Supply for industrial use, Contact recreation, Secondary recreation, Fish spawning, Harvesting and consumpti on of raw fish, or other aquatic life (Not needed if not requesting a mixing zone from ADEC):

If possible, provide salinity and temperatur e data from the receiving water surface to the depth of the discharge port or diffu ser.

Page 4 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Special Conditions ( provide justification for all that ar e not required, completed or provided)

Special Monitoring Required Not Required Justification:

Exploration Plans Attached Not Provided Justification: Submitted to MMS

Biological Surveys Attached Not Provided Justification: None required

Environmental Report(s) Attached Not Provided Justification: Submitted to MMS as part of the Exploration Plan

Drilling Fluid Plan Complete Not Complete Justification: In Preparation



### Certification I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the pe rson or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Signature: Date:

Printed Name: Susan Childs Title: Regulatory Affairs Manager 

### Mail Completed NOI to EPA and ADE C at the following addresses:

US EPA
1200 6 th Avenue, M/S OWW-130 Seattle, WA 98101 ADEC, Water Division
555 Cordova Street Anchorage, Alaska 99501

Page 5 of 5" "

"

" " "

" C h u k c h i S e a A r c t i c O c e a n

Icy Cape L e d y a r d B a y B e a u f o r t S e a

National Petroleum Reserve - Alaska (NPR-A) Wainwright Barrow

Atqasuk

Point Lay

Point Hope 155°W 160°W 165°W 170°W 175°W73°N72°N72°N71°N71°N70°N70°N69°N69°N68°N

AES-RTS: 09-011-005.mxd, 02/27/09, R00 

# r

SCALE:

NAD83, Alaska Albers Equal Area SCALE: FIGURE:

1 NOTICE OF INTENT AKG-28-0000 KARO AREA BLOCK 6864 CHUKCHI SEA

0 40 80 20 Miles 

### SHE LL Shell OCS Lease Block

Karo Area Block 6864 Lease Sale 193 Area

National Petroleum Reserve - Alaska " Village ! ! ! RUSSIA

CANADA

P a c i f i c O c e a n A r c t i c O c e a n

B e r i n g

S e a G u l f o f A l a s k a Barrow Area Enlarged

Fairbanks

Anchorage 

# rTypes and Estimated Volume Ocean Discharges During Drilling Season 2010– Crackerjack Prospect

Type of Waste Total Amount to be Discharged Discharge Rate* Discharge Method Drill cuttings (from MLC and 36-inch section) 3,160 bbl/well (cuttings only; no drilling muds used) 632 bbl/hr (for approx. 5 days) Deposited on the surface of the seafloor

Spent drilling fluids 4,730bbl/well spent mud plus mud in tanks (if multiple wells drilled per season, water based muds will be transferred to and used at the next well) 147 bbl/day (including discharge of
excess water based drilling fluid at end of the drilling season) Discharged to sea through disposal caisson after 30:1 dilution with
seawater

Cuttings from water based intervals (does not include MLC and 36-inch section) 3,230 bbl/well 101 bbl/day Discharged to sea through disposal caisson after 30:1 dilution with
seawater

Sanitary waste 1,000 bbl/well 27 bbl/day Treated in marine sanitary device prior to discharge to meet NPDES limits (based on 124 people at 9 gal/person/day) Domestic waste 3,071 bbl/well 83 bbl/day Discharged to water through the disposal caisson (based on 124 people at 28 gal/person/day)

Note: all food waste to be incinerated Excess cement 50 bbl/well Two occasions at 1 bbl/min Discharged at seafloor during 30- inch and 20-inch cementing operations
Desalination unit brine water 4,625 bbl/well 125 bbl/day Discharged to water through disposal caisson Deck drainage 185 bbl/well 5 bbl/day (dependent on rainfall) Drains to the oily water separator. Uncontaminated water id discharged through the disposal caisson; contaminated water is stored in a waste oil tank then transferred by boat to an approved treatment/disposal site. Cooling water 1,665,000 bbl/well 45,000 bbl/day Discharged to water through a number of outlets
Firewater 0 0 bbl/month No routine firewater system testing anticipated Ballast water 22,940 bbl/well 620 bbl/day Discharged to sea through disposal caisson Bilge water 1000 bbl/well 27 bbl/day Treated in oily water separator, uncontaminated water discharged to sea through disposal caisson, oily water stored onboard, transferred for transport by boat to an approved disposal site BOP fluid 42 bbl/well (6 tests; 7 bbl per test) 7 bbl/day Discharged subsea at BOP when testing BOP

* assumes 5 days to complete the MLC and 36-inch section; 32 days to complete the remainder of the wellPermit No.:
AKG280000



### ATTACHMENT 1



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

APPLICANT ( Owner/Operator)
Owner Name: Shell Gulf of Mexico Inc. Operator Mailing
Address: 3601 C Street Telephone Number: 907-770-3700 Suite 1000 Operator Name: Shell Gulf of Mexico Inc. Anchorage, AK 99503 Telephone Number: 907-770-3700 

### FACILITY Facility Name: Frontier Discoverer Facility Mailing
Address: 3601 C Street
Contact Name: Susan Childs Suite 1000 Telephone Number: 907-770-3700 Anchorage, AK 99503 Beginning Date of Operation: July 4, 2010 Stationary
Facilities Latitude:

Expected Duration of Operation: 37 days per well site Longitude:

Facility Type (check applicable type) Jackup

Mobile Facilities Initial
Latitude: 71.073449 (NAD 83
Lease Block centerpoint location) Drill Ship
Semisubmersible Other (specify): Initial Longitude: -167.227247 (NAD 83
Lease Block centerpoint location) Submit a site map showing the exact location of facility and discharges associated with the project. Mobile facilities may designate an area where they may be operating and must include a map showing those areas and a description of operations within those areas. If the discharge is within 4000 meters of an environmentally sensitive area indicated by the permit, those areas and their distance from th e operation/discharge must be shown on the map. 

### RECEIVING WATER

Chukchi Sea Other ( specify ):

Beaufort Sea Supply confirmation with the U.S. Department of State and NOAA that the discharge is seaward of the inner boundary baseline, if applicable. 

### LOCATION OF DISCHARGE

MMS Lease Number 

### OCS-Y- 2142 ADNR Lease Number 

### N/A

Block Number 

### Karo Area Block
7007 Block Number 

### N/A

Range of water depths below mean lower low water (MLLW) in the lease block: From: 

### 149' To: 

### 149'

Page 1 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Discharges ( check all that apply) 001 Drilling Mud and Cuttings Water Depth: 

### 149' 002 Deck Drainage Water Depth: 

### 149' 003 Sanitary Waste Water Depth: 

### 149'

004 Domestic Waste Water Depth: 

### 149'

005 Desalination Unit Waste Water Depth: 

### 149'

006 Blowout Preventer Fluid Water Depth: 

### 149'

007 Boiler Blowdown Water Depth: 008 Fire Control System Test Water Water Depth: 009 Non-Contact Cooling Water Water Depth: 

### 149'

010 Uncontaminated Ballast Water Water Depth: 

### 149' 011 Bilge Water Water Depth: 

### 149' 012 Excess Cement Slurry Water Depth: 

### 149' 013 Mud, Cuttings, Cement and Seafloor Water Depth: 

### 149'

014 Test Fluid Water Depth: Provide a brief description of the treatment process(es) and disposal practices (e.g., backhauled, reinjected, discharged, etc.) at the facility. See attached (Table 1) Provide a line drawing that shows flow of discharged wast e streams through the facility. Indicate intake sources, operations contributing to the effluent, and treatment units labeled to correspond to the discharges (001 – 014). Construct a flow balance on the line drawing by showing average flows between intakes, operations, treatment units, and outfalls. If a flow balance cannot be determined, provide a pictorial description of the nature and amount of any sources, and any collection or treatment measures. 

### Well Information

Well Name: 

### SW Shoebill Latitude: 

### 71.073449 (NAD 83
Lease Block centerpoint location)

Well Number: 

### C Longitude: 

### -167.227247 (NAD 83
Lease Block centerpoint location)

Beginning Drill Date: 

### July 4, 2010 Hole Diameter or Estimated Total Discharge
Volume: 

### 36" diameter at surface, reducing through 4 stages to 8.5" at depth Drilling Fluid

Category ( check all that apply ) Water-based

Group ( check all that apply ) Lignosulfonate

Oil-based Lime Synthetic-based Gyp Other ( specify ): Sea-waterSaltwater

Saturated Saltwater Nondispersed (Viscosifier/Polymer) PH/PA

Page 3 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Zone of Deposit Request ( applicable to those discharges within state of Alaska waters)

Are you requesting a Zone of Deposit from ADEC? Yes ( continue filling out
this section ) No ( skip this section and proceed to Special Conditions, below ) THE FOLLOWING INFORMATION MUST BE PROVIDED IF REQUESTING A ZONE OF DEPOSIT. The burden of proof for justifying a zone of deposit through demonstrating compliance with the requirements of 18 AAC 70.210 rests with the applicant.
Distance from shorelin e of discharge point (measured at M.L.L.W.): Average Mud density: Depth of discharge (measured at M.L.L.W.): Flow Rate:

Orientation of outfall to shoreline (e.g., perpendicular, 45 ° , parallel): Total Volume:

Orientation of outfall to water surface (e.g., perpendicular, 45 ° , parallel): Maximum current
and direction: If possible, provide salinity and temperatur e data from the receiving water surface to the depth of the discharge port or diffu ser. 

### Mixing Zone Request ( applicable to those discharges within state of Alaska waters)

Are you requesting a mixing zone from ADEC? Yes ( continue filling out
this section ) No ( skip this section and proceed to Special Conditions, below )

THE FOLLOWING INFORMATION MUST BE PROVIDED IF REQUESTING A MIXING ZONE. The burden of proof for justifying a mixing zone through demonstrating compliance with the requirements of 18 AAC 70.240 through 18 AAC 70.270 rests with the applicant.
Distance from shoreline of discharge point or first port of diffuser (meas ured at M.L.L.W.): Length of diffuser:

Depth of discharge port or diffuser (measured at M.L.L.W.): Diameter of port(s):

Orientation of diffuser to shoreline (e.g., perpendicular, 45 ° , parallel): Number of ports:

Maximum current: Port spacing:
USE OF RECEIVING WATER AT DISTANCE FROM DIFFUSER i.e., Supply for drinking water, Supply for agriculture including irrigation & stock water, Supply for a quaculture, Supply for industrial use, Contact recreation, Secondary recreation, Fish spawning, Harvesting and consumpti on of raw fish, or other aquatic life (Not needed if not requesting a mixing zone from ADEC):

If possible, provide salinity and temperatur e data from the receiving water surface to the depth of the discharge port or diffu ser.

Page 4 of 5Attachment 1: NOI Inform ation Sheet Permit No.:
AKG280000



## NOTICE OF INTENT (NOI ) I N FORMATION SHEET

NPDES GENERAL PERMIT AKG280000
OIL AND GAS EXPLORATION FACILITIES
ON THE OUTER CONTINENTAL SHEL F AND CONTIGUOUS STATE WATERS

Special Conditions ( provide justification for all that ar e not required, completed or provided)

Special Monitoring Required Not Required Justification:

Exploration Plans Attached Not Provided Justification: Submitted to MMS

Biological Surveys Attached Not Provided Justification: None required

Environmental Report(s) Attached Not Provided Justification: Submitted to MMS as part of the Exploration Plan

Drilling Fluid Plan Complete Not Complete Justification: In Preparation



### Certification I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the pe rson or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Signature: Date:

Printed Name: Susan Childs Title: Regulatory Affairs Manager 

### Mail Completed NOI to EPA and ADE C at the following addresses:

US EPA
1200 6 th Avenue, M/S OWW-130 Seattle, WA 98101 ADEC, Water Division
555 Cordova Street Anchorage, Alaska 99501

Page 5 of 5" "

"

" " "

" C h u k c h i S e a A r c t i c O c e a n

Icy Cape L e d y a r d B a y B e a u f o r t S e a

National Petroleum Reserve - Alaska (NPR-A) Wainwright Barrow

Atqasuk

Point Lay

Point Hope 155°W 160°W 165°W 170°W 175°W73°N72°N72°N71°N71°N70°N70°N69°N69°N68°N

AES-RTS: 09-011-006.mxd, 02/27/09, R00 

# r

SCALE:

NAD83, Alaska Albers Equal Area SCALE: FIGURE:

1 NOTICE OF INTENT AKG-28-0000 KARO AREA BLOCK 7007 CHUKCHI SEA

0 40 80 20 Miles 

### SHE LL Shell OCS Lease Block

Karo Area Block 7007 Lease Sale 193 Area

National Petroleum Reserve - Alaska " Village ! ! ! RUSSIA

CANADA

P a c i f i c O c e a n A r c t i c O c e a n

B e r i n g

S e a G u l f o f A l a s k a Barrow Area Enlarged

Fairbanks

Anchorage 

# rProjected Generated Wastes During Drilling Season 2010– Southwest Shoebill Prospect

Type of Waste Composition Total Projected Amount Treatment, Storage, and Disposal Drill cuttings (from MLC and 36-inch section) Drill cuttings; no drilling muds used 3,310 bbl/well Deposited on the surface of the seafloor

Spent drilling fluids Water based drilling fluids 5,005 bbl/well Discharged to sea through disposal caisson after 30:1 dilution with
seawater Cuttings from water based intervals (does not include MLC and 36-inch section) Cuttings coated with water based drilling muds 3,505 bbl/well Discharged to sea through disposal caisson after 30:1 dilution with
seawater

Sanitary waste Treated human body waste from toilets 1,000 bbl/well Treated sanitary wastewater to be discharged to water through disposal caisson (based on 124 people at a rate of 9/gal/person/day) Domestic waste Gray water (laundry, galley, lavatory) 3071 bbl/well 83 bbl/day Discharged to water through disposal caisson (based on 124 people at a rate of 28 gal/person/day); food waste to be incinerated Excess cement Cement slurry 50 bbl/well Discharged at seafloor during 30-in and 20-in casing cementing operations
Desalination unit brine water Rejected water from watermaker unit 4625 bbl/well Discharged to water through disposal caisson Deck drainage Uncontaminated fresh or
seawater 185 bbl/well Drain to oily water separator; uncontaminated water to be discharged to sea through disposal caisson, contaminated water stored in waste oil tank then transferred by boat to an approved treatment/disposal site Trash and debris Refuse generated during installation and production 300 bbl/well Trash and debris to be segregated and disposed of at an approved disposal facility Cooling water Seawater 1,665,000 bbl/well Discharged to water through a number of outlets

Firewater Treated seawater 0 bbl/well No discharge except in the event of a fire Ballast water Uncontaminated seawater 22,940 bbl/well Discharged to water through disposal caisson
Used oil Lube oil 10 bbl/well Stored onboard in waste oil tank; transferred to lube cubes for transport by boat to an approved treatment/disposal site Hazardous waste Chemical products and general hazardous waste 10 bbl/well Stored onboard in approved container; transferred for transport by boat to an approved treatment/disposal site Bilge water Oily seawater and freshwater 1000 bbl/well Treated in oily water separator, uncontaminated water discharged to sea through disposal caisson, oily water stored onboard, transferred for transport by boat to an approved treatment/disposal site BOP fluid water, glycol 42 bbl/well Discharged subsea at BOP * assumes 5 days to complete the MLC and 36-inch section; 32 days to complete the remainder of the well