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 99503 
 

2010 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 & ABBREVIATIONS ........................................................................................................... v

CROSS-REFERENCE TO APPLICABLE 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 ............................................................... 19
 

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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 ................................................................................................. 47

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 discharge 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 SHELF 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 ....................... 108
 

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Stipulation No. 5 - Lease Sale 193 Conflict Avoidance Mechanisms to Protect Subsistence 

Whaling and other Subsistence-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 Applications Pending or Approved................................................................... 9 

TABLE 2.b-1 Drilling Fluid Type, Quantity and Discharge Rates ................................................... 10 

TABLE 6.1-a Projected Generated Wastes During 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 Water 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 ......................................................................................................... 41 
 

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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-Requested 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 ............................................................................ 125 

TABLE 13.a-2 Specifications of the Major Oil Spill Response Vessels .......................................... 127 

TABLE 13.a-3 Fuel Storage Capacity and Trip Information for Support Vessels and Aircraft ....... 130 

TABLE 13.b-1 Projected Annual Air Emissions from the Support Vessels Associated with the 

Drillship Discoverer for the Chukchi Sea Exploration Drilling Program ................ 131 

TABLE 13.c-1 Drilling Fluid Loadout for the Discoverer for the Chukchi Sea Exploration Drilling 

Program .................................................................................................................... 132 

TABLE 13.d-1 Transportation of Wastes .......................................................................................... 133 

TABLE 14.d-1 Shorebase Waste Disposal Facilities, Waste Type, Amount, Rate, and Disposal 

Method ..................................................................................................................... 138 

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 Fisheries 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 H2S 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, Alaska 
 

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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 

ft2

 square feet 

ft3

 cubic feet 

gal gallon(s) 

H2S hydrogen sulfide 

HAPs hazardous air pollutants 

HC hydrocarbon 

Hp horsepower 
 

2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska 

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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 

m2

 square meter(s) 

m3

 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 Interior, 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 

NOx 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 

PM10 particulate matter less than 10 microns 

PM2.5 particulate matter less than 2.5 microns 

POC Plan of Cooperation 
 

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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 

SO2 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 discharge 
 

2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska 

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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 required 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 required 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 information 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) 
 

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(e)(2) Oil spill financial responsibility 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 Section 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 charts 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 (H2S) 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) H2S 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 information Section 6.1a), 6.2a), 6.3a), & 

6.4a), 
 

2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska 

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(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 method 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 spills 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 oil 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 worst 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, 
 

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separate cover 

30 CFR 

250.220 

Alaska planning information Section 9.0 

(a) Emergency plans Section 9.0 a) 

(b) Critical operations and curtailment procedures Section 9.0 b) and 

Attachments 9.1 and 9.2 

30 CFR 

250.221 

Environmental monitoring information 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 products 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 environmental 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, oceanography, 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 indirect impacts Appendix F (Section 4.1) 

(c)(2) Analyze and potential cumulative impacts Appendix F (Section 4.2) 

(c)(3) Describe the potential impacts 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 7.0 

 
 

2010 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 Arctic 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 Authorization Section 10.0 b) and Appendix 

E 

 

U.S. Army Corps of Engineers 

33 CFR 325.1 Applications for permits Appendix G 

 

 
 

2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. xiv July 2009 

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2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska 

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 the exploration drilling activities Shell Gulf of Mexico Inc. (Shell) 

plans to conduct in 2010 in the Chukchi Sea Outer Continental Shelf (OCS), Alaska. 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). Shell 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 plans to drill exploration wells to total depth (TD) at 

three of these five possible drill sites in 2010 given favorable 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 hazards and archaeological evidence. Formal reports for 

each of these drill sites have been submitted to the U.S. Department of the Interior, Minerals Management 

Service (MMS) under separate cover. Each of these five 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 controlled by a complex interplay between actual ice 

conditions immediately prior to a rig move, ice forecasts, 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 these 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. Given 
 

2010 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 Prospect 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 Department 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 expects 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 after 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 other 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 (Burger, 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 locations of these drill sites are presented below in Table 

1.b-1. Surface and bottomhole coordinates, OCS Area name and block number, lease number, distance 

from block line, and other information for each of the drill sites are provided on the respective OCS Plan 

Information Forms (MMS Form-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

1Coordinates, m 

 X Y 

Latitude Longitude 

Burger C Posey 6764 OCS-Y-2280 563929.70 7912335.98 N71° 18' 17.2739" W163° 12' 45.9891" 

Burger F Posey 6714 OCS-Y-2267 564063.30 7915956.94 N71° 20' 13.9640" W163° 12' 21.7460" 

Burger J Posey 6912 OCS-Y-2321 555036.01 7897424.42 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 3 
2010 Outer Continental Shelf Leases Exploration Plan 

Shell Gulf of Mexico 3 15276-03-09-001A/09-011A Figure 1.b-1 Exploration Plan Location Map 
!

!

C

h

u

k

c

h

i

S

e

a

Crackerjack

SW Shoebill

C

NR03-01

(Karo)

NR03-03

(Unnamed)

C

7007

6864

-40m.

-50m.

-40m.

-40m.

-40m.

-40m.

-50

m.

r

AES-RTS: 09-011A-003.mxd, 08/27/09, R00

NAD83, Alaska Albers Equal Area

SCALE: FIGURE:

1.b-2

CRACKERJACK AND SW SHOEBILL

PROSPECTS LOCATION MAP

2010 Chukchi Sea Exploration Plan

0 2.5 5 10

Miles

! 2010 Drill Site SHELL

2010 Exploration Plan Block

Shell OCS Lease Block

Protraction Area Diagram Outline

Bathymetry (10m. interval)
!

!

!

C

h

u

k

c

h

i

S

e

a

Burger

NR03-02 J

(Posey)

NR03-04

(Solivik Island)

F

C

6912

6763

6713

6764

6714

-40m.

-40m.

-40m.

-40m.

r

AES-RTS: 09-011A-004.mxd, 08/27/09, R00

NAD83, Alaska Albers Equal Area

SCALE: FIGURE:

1.b-3

BURGER PROSPECT

LOCATION MAP

2010 Chukchi Sea Exploration Plan

0 2 4 8

Miles

! 2010 Drill Site SHELL

2010 Exploration Plan Block

Shell OCS Lease Block

Protraction Area Diagram Outline

Bathymetry (10m. interval)
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 identified 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 maximum anchor radius of 3,600 ft (1,100 m). The hull 

has been reinforced for ice resistance. 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 Shipyard, 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 m 
2010 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" diameter 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 system. The unit is fitted with Sonat Offshore Drilling patented roller turret mooring 

system giving the unit the ability to maintain favorable heading without an interruption of the drilling operations 

ANCHORS Stevpris New Generation 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, max 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 knots 
2010 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 Regulations (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 inflow detection and well control, monitoring for loss of circulation and 

seepage loss, and casing design will be the primary safety measures. Primary pollution prevention 

measures are the contaminated and non-contaminated drain 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 sites 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. These permits and authorizations will be submitted for 

planned wells to be drilled on the Burger, Crackerjack, and SW Shoebill Prospects in 2010. The number 

of wells that will be drilled will depend on ice conditions and the length of time available during the 

drilling season. Based on past experience and current planning, 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 Elimination 

System (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 6,505 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 operational considerations (e.g., whether mud properties have 

deteriorated to the point where they cannot be used further), 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 requiring lower drilling 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, fresh water, barite) 7,310 bbl 660 bbl/day 

Crackerjack Water-based (seawater, fresh water, barite) 8,510 bbl 660 bbl/day 

SW Shoebill Water-based (seawater, fresh 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 Shell Oil Company has the financial capacity 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 and has demonstrated oil spill financial responsibility 

(OSFR) according to 30 CFR 253 for the facilities planned in the EP. This financial reliability ensures 

that Shell has the capability to deal with all emergency situations such as blowout control including relief 

well drilling and kill operations if such an unlikely event should occur. 

This is a planned drilling program with temporary seasonal 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. Permanent 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 that accommodate 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, drillship mechanical conditions, or downhole conditions, 

among others. In order to facilitate a possible suspension 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 described in Section 8.0 and will be submitted to MMS as 

part of the Oil Discharge Prevention and Contingency 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 process of maintaining positive 

hydrostatic pressure in the drilled wellbore greater than 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 Manager, 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 

Shell Gulf of Mexico Inc. 12 July 2009 

15276-03-09-001A/09-011A Rev. 1

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2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska 

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, and 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 

Shell Gulf of Mexico Inc. 15 15276-03-09-001A/09-011A Figure 3.0-2 Historic Oil and Gas Exploration in the Chukchi Sea 
2010 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, and 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, and 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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2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska 

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SECTION 4.0 HYDROGEN SULFIDE INFORMATION 

a) Concentration 

During the historic 1989 – 1991 Chukchi exploration drilling program, no hydrogen sulfide (H2S) 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 H2S, related to the bacterial 

digestion of the XC polymer in the mud that was left inside the casing during an extended period of 

operational suspension, were recorded and are described below.

In early October, 1989, a string of 133⁄8-inch (in.) (34 centimeters [cm]) casing was set and cemented at 

5,516 ft (1,681 m) in the historical OCS-Y 1413 #1 (Burger) well. The cement was 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 displaced 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 hydrostatic 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 wellhead after pressure testing the wellhead hanger. The 

well remained in this configuration 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 the old mud reached the surface, a maximum H2S 

concentration of 30 parts per million (ppm) was detected at the shale shaker. As the new mud circulated 

to surface, the H2S concentration returned to zero. Once the H2S concentration returned to zero the 121⁄4-

in. (31 cm) bit then drilled through the cement plug and both check valves. It then proceeded to drill new 

formation on its way to the main objective target. 

It is concluded that the H2S was the byproduct of bacterial digestion of the polymer in the old mud 

contained within the 20-in. casing. There had been no H2S 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 H2S was recorded while drilling the remaining hole segments to the well’s 

final TD of 8,202 ft (2500 m). 

In October, 1990, the 133⁄8-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-in. (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 the floats along with the hydrostatic pressure from the 

mud column within the 133⁄8-in. (34 cm) casing, prevented formation fluids from entering the casing. In 

addition, an H2S 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 inside 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 133⁄8-in. (34 

cm) casing and the old mud was circulated out of the hole. The returned mud was monitored for H2S by a 

safety specialist and by mud loggers. When mud from approximately 4,000 ft (1,219 m) in the well 
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reached the surface, H2S in trace concentrations was released at the shakers. As the old mud was 

displaced with new mud, the H2S concentration fell to zero prior to drilling out the cement plug, and 

floats and into new formation. No other H2S 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 H2S in this well was the product of bacterial digestion of the XC polymer 

in the old mud. There was no H2S encountered while drilling the 171⁄2-in. (44.5 cm) hole and none was 

released into the mud during subsequent drilling. Apparently, the H2S scavenger was not completely 

successful in preventing the H2S, but the concentration was reduced from that seen in the Burger well 

after about the same on-bottom time. 

No H2S 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 H2S detected in these two wells was 

indeed the result of bacterial degradation of the polymer mud left in each hole for approximately 10 

months each and not from any geologic formation penetrated by either well. 

b) Classification

H2S is not expected in any hole segment in any exploration well planned in Shell’s 2010 exploration 

drilling program based on the absence of H2S in any previously drilled exploration well in the Chukchi 

Sea, the Beaufort Sea or the Canadian 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 “H2S 

unknown”. Shell has therefore prepared an H2S Contingency Plan and will install all equipment, provide 

required training and follow all emergency 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 “H2S absent” since none of the 

wells is projected to drill below the equivalent stratigraphic 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 H2S encountered while drilling the historic Burger well. All of the 

exploration wells planned for the 2010 drilling campaign would have similar total depths in the Kingak. 

Thus, if only the Burger Prospect drill sites were planned for 2010, the RF/SO could exempt the Burger 

Prospect from the provisions of 50 CFR 250.490. 

Similarly, at the Crackerjack Prospect drill site, the entire prospect could be classified by the RS/FO as 

H2S absent since the proposed drilling will stop above the Jurassic Unconformity. The Cenozoic, 

Cretaceous and Jurassic age equivalent stratigraphic section has been penetrated in nearby historical wells 

(the OCS-Y 1320 #1 Crackerjack Well, the OCS-Y 1482 #1 Klondike Well and the OCS-Y 1275 #1 

Popcorn Well) and all have confirmed the absence of H2S 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 “H2S unknown.” 

Since the latter would require compliance with the requirements of 50 CFR 250.490, Shell has prepared 

and will employ an H2S Contingency Plan. Ice or other conditions may require drilling the SW Shoebill 

Prospect instead of the Burger or Crackerjack exploration wells, so Shell will comply with the 

requirements of the H2S plan for all drilling operations in the Chukchi Sea in 2010. 
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c) Contingency Plan

An H2S Contingency Plan is provided in Appendix H. H2S-resistant tubular goods and wellheads have 

been selected for each proposed Chukchi Sea prospect 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 H2S 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 H2S in any of the five historic Chukchi Sea wells limits the ability to predict H2S 

concentrations necessary for preparing such a model, and there is no reliable analog reservoir on the 

North Slope containing H2S with which to compare the planned prospects. An assumed H2S 

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 H2S radii of exposure, would therefore be 

questionable. It is unlikely that an H2S release, even at maximum release flowrate and normal 

concentrations at the remote planned prospect sites 66-126 mi offshore could significantly impact the 

public on the northwest coast of Alaska due to expected diffusion and dispersion in the air column over 

such a long distance. 
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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 observed 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 surveys 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 studies in Kotzebue Sound with the Native Village of 

Kotzebue. Results of these studies are found on the internet at 

http://alaska.usgs.gov/science/biology/walrus/2008animation_Norseman.html and 

http://kotzebueira.org/current_projects2.html. 

Shell has also collected a large amount of information regarding marine mammals in the northeastern 

Chukchi Sea, including the area of Shell’s prospects, through its marine mammal monitoring program 

associated with seismic surveys. Data collected over the last three 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 five 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 archeological assessments have been submitted to MMS under separate cover. 

The results of the shallow hazard surveys are summarized in Section 3.1, 3.2, and 3.3. The results of the 

archeological assessments are discussed in Section 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 near the Crackerjack C drill site were identified as paleochannels. The margins of these types of geological features 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 the prevalence of ice gouging and other dynamic forces, 

Shell relocated the Crackerjack C drill site so that the paleo-channel margin would 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 possible presence of historic cultural resources such as 

shipwrecks. 

Shell also collected oceanographic information as part of the multi-faceted baseline study conducted at 

Burger in 2008 described above in Section 5 (a). Additionally, Shell: 
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 Deployed metrological buoy in the Chukchi Sea near 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 meteorological 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 (POC) 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 involve 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 communities 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 and issues to Shell. The SA speaks with other 

village members and documents subsistence information. 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-contact 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 attend 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 resources and habitats, including endangered species, 

fisheries, bird colonies, and marine mammals and provides guidance on how to avoid disturbance. 

Shell collected information on the use of coastal areas 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 Hope were interviewed. A report was prepared 

summarizing and mapping the results of these interviews. The report (ASRC Energy Services 2009) is 

attached as Appendix K. Results of these interviews were used in the preparation of the EIA 

(Appendix F). 
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While developing its ODPCP, Shell conducted interviews with residents of Barrow, Wainwright, Point 

Lay, and Point Hope to supplement existing formal environmental and resource data for the Chukchi Sea 

coastline. Data collected pertained to hunting, fishing, 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 Enterprises 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 Basin. The results (Northern Economics 2009) of the 

analysis have been presented to the MMS. 
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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 the surface of the seafloor 

Spent drilling fluids Water based drilling fluids 4,405bbl/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 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 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 + ≤3% Stack Magic 

Eco-F additive + ≤25% 

Stack Glycol (MEG) 

42 bbl/well Discharged subsea at BOP 
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b) Projected Ocean Discharges

Table 6.1-b lists the types of wastes, expected quantities, 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 information has been submitted to the Environmental Protection Agency 

(EPA) to support a Notice of Intent (NOI) application for authorization to discharge the wastes under 

National Pollutant Discharge Elimination System (NPDES) General Permit AKG-28-0000. A copy of the 

NOI is provided in Appendix B. The projected wastes and amounts listed in Table 6.1-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 generated 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 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 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 well 
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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/well 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 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 
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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 experience; actual ocean discharges may differ. 
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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 surface 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/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 well 
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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 the 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 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 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/well 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 Stored onboard in waste oil tank; 

transferred to lube cubes for 

transport by boat to an approved 

treatment/disposal site 
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TABLE 6.3-a 

Projected Generated Wastes During Drilling 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 BOP 
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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 experience; 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 surface 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/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 
2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska 

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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 program (as itemized above in Tables 

6.1-b, 6.2-b and 6.3-b) will be made in accordance 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 Discoverer 
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Figure 6.4-2 Oily Waste Separator System on the Discoverer
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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 

m3

) or greater must acquire authorization to discharge under the Vessel General Permit for Discharges 

Incidental to the Normal Operation of Commercial Vessels and Large Recreational Vessels. 

Authorizations to discharge under this vessel general 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 support of such requests. 

Shell has carried out modeling of the expected discharges of drill cuttings and drilling fluids for impact 

assessment purposes. The results of this modeling effort are discussed in the EIA (Appendix F). 
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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 supply 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 saltwater 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, which 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 sponson from the main deck level to the base of the 

sponson. The sponson is an exterior reinforced cladding on the hull to provide ice resistance. It is hollow 

and extends from the main deck level to well below the 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 equipped with a "float" valve; it is an open pipe. Since it remains open to the sea at 

all times, the disposal caisson is constantly filled with water. This caisson is not equipped with a "float" 

valve; it is merely an open conduit to the sea through 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 heave, the water level inside the caisson 

is constantly changing.

6.8 Desalination Unit BrineWater 

The watermaker operates via evaporation/condensation 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. 

 
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SECTION 7.0 AIR EMISSIONS INFORMATION 

The air quality information provided herein is based on the drillship and associated support vessels, which 

include an ice management vessel, and anchor handling vessel, a materials supply vessel, and Oil Spill 

Response (OSR) vessels. Shell submitted a major new source review Prevention of Significant 

Deterioration (NSR/PSD) application to EPA Region 10 on 10 December 2008 and a revised application on 

23 February 2009. Responses to additional EPA requests 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 application 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) component of PSD permitting and expects EPA to incorporate these measures 

as enforceable permit limitations. Additional emission reduction measures may be identified and 

incorporated into the PSD permit by EPA during their 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 emission unit spreadsheets that describe all of the source units of the 

drillship and support vessels; and an analysis of potential 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 October 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 year, 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 exclusive). The maximum length of drilling per hole is 84 
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days and per season is 168 days of drilling per calendar year. The emergency and backup engines are 

only used during emergencies and maintenance 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 winch operation combined with cementing units 
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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 PM10 PM2.5 NOx SO2 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 units 

 
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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) 

PM10 PM2.5 NOx SO2 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 units 
 

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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 250 

hp/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 

PM2.5 limited to 

7 lb/ton - Demonstrated by initial 

stack test

Discoverer Incinerator 

PM10 limited to

8.2 lb/ton - Demonstrated by initial 

stack test

Discoverer Incinerator 

SO2 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 NOx

/season

Fuel consumption 

(gallons) x stack test 

determined NOx

emission factor (tons 

NOx per gallon fuel)

Demonstrated using fuel 

consumption – dipstick 

on both vessels 

measured daily 
 

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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 NOx / 

season

Fuel consumption 

(gallons) x stack test 

determined NOx

emission factor (tons 

NOx per gallon fuel) 

Demonstrated using fuel 

consumption - dipstick 

on anchor handler 

measured daily 

Ice management fleet 

capacity hourly PM2.5 

restriction 

84.4 lb PM2.5 / hour (Propulsion engine 

power (kW) capacity 

(80% of design rating) x 

PM2.5 emission factor 

(lb/kWh)) + (boiler 

design rate (btu/hr) x 

PM2.5 emission factor 

(lb/Btu)) x 24 hours + 

incinerator capacity 

(lb/hr) x PM2.5 emission 

factor (lb PM2.5 /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 PM2.5 restriction

42.2 lb PM2.5 / hour (Propulsion engine 

power (kW) capacity 

(80% of design rating) x 

PM2.5 emission factor 

(lb/kWh)) + (boiler 

design rate (btu/hr) x 

PM2.5 emission factor 

(lb/Btu)) x 24 hours + 

incinerator capacity 

(lb/hr) x 

PM2.5 emission factor (lb 

PM2.5 /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 PM10

restriction

96.0 lb PM10 / hour (Propulsion engine 

power (kW) capacity 

(80% of design rating) x 

PM10 emission factor 

(lb/kWh)) + (boiler 

design rate (btu/hr) x 

PM10 emission factor 

(lb/Btu)) x 24 hours + 

incinerator capacity 

(lb/hr) x PM10 emission 

factor (lb PM10/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 PM10 restriction

48.0 lb PM10 / hour (Propulsion engine 

power (kW) capacity 

(80% of design rating) x 

PM10 emission factor 

(lb/kWh)) + 

(boiler design rate 

(btu/hr) x PM10 emission 

factor (lb/Btu)) x 24 

hours + incinerator 

capacity (lb/hr) x 

PM10 emission factor (lb 

PM10 / 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 - - 
 

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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 x 

24 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 measures to reduce the amounts of emissions, including: 

 

 Limiting the drilling to 168 days per season 

 Primary generators on the Discoverer will be retrofitted with selective catalytic reduction devices 

to reduce NOx 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 SO2 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 equivalent 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 secondary and related to general purpose heating, transfer 

of materials about the deck, pumping of cement, incineration primarily of domestic waste, and other small 

emission source. All stationary source engines on the Discoverer will be fueled by diesel with sulfur 
 

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content at or below 0.0015 weight percent. The associated vessels will be fueled 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 and associated support vessels are exempt using the 

exemption formula found at 30 CFR 250.303(d). Modeled 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, and BACT has been applied to all pollutants. The 

BACT is described in Shell’s air permit application (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 dispersion 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-acceptable 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 

NAAQS1

(μg/m3

) 

Screening 

Model Max. 

Impact Plus 

Background2

(μg/m3

) 

PSD Class II 

Increment 

(μg/m3) 

Screening 

Model Max. 

Impact No 

Background3

(μg/m3

) 

Nitrogen Dioxide 

(NO2) 

Annual 100 24.0 25 20.8 

Particulate Matter 

(PM2.5) 

24-hour 35 34.3 NA 25.6 

Annual 15 3.7 NA 17 

Particulate Matter 

(PM10) 

24-hour 150 36.8 30 28.2 

Annual 50 5.8 17 1.9 

Sulfur Dioxide 

(SO2) 

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 concentrations are compared to the NAAQS. 3

 Maximum modeled impacts only (no background concentrations included) are compared to the PSD Increments. 

NA = not applicable 
 

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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 spill 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 requirements 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, the incident management team organization, and the 

strategies and tactics used to implement effective and sustained spill containment and recovery 

operations. 

Shell is committed to conducting safe and environmentally responsible operations in the Chukchi Sea. To 

achieve this goal, oil spill prevention is a primary 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 oil spill contingency response would receive discharge 

prevention and response training as described in the ODPCP. Training drills also would be conducted 

periodically to familiarize personnel 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) possessing sufficient onboard storage capacity to provide 

containment, recovery, and storage for the initial 24-hour operational period (12,690 bbl [1,951 m3

]) will 

be staged in the vicinity of the drillship when drilling 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 m3

), sufficient capacity to store all recovered 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 m3

), 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 recovered fluids to the OST for the duration of the response. 

An ice-strengthened Oil Spill Response Barge (OSRB) with 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 m3

) 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, deploy 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 efforts in the offshore, nearshore, and shoreline 

environments. ACS’s response personnel and oil spill response equipment would be maintained on 
 

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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 Auxiliary 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 tactics 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 discharge 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 must 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 scenario 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 m3

) of oil per day (bopd) for an exploration facility for fifteen (15) days 

duration. In order to address MMS and ADEC jurisdiction, 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 m3

) of oil during the 30 days. For storage purposes, an emulsion 

factor of 1.54 and a percentage of free water (20 percent) 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 m3

). 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 approximately 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 ocean-ice current model. The ASA trajectory model 
 

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includes algorithms for spreading, evaporation, emulsification, 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 used to run the trajectory model based on environmental conditions 

including predominate winds and currents. Oil on the 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 duration 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 originated 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 frequency of occurrence greater than 10 percent of the 

time originating from the northeast (NE), east-northeast (ENE) and east (E) based upon the 16 cardinal 

compass directions. These three wind directions on average occurred at the following frequencies for the 

June through November period: 

 ENE wind = 14.6 percent frequency 

 NE wind = 13.8 percent frequency 

 E wind = 13.0 percent frequency 

The trajectory simulation uses a subsea blowout rising through the water column and surfacing above the 

well location. The trajectory simulation moves and spreads the oil under the influence of local winds 

measured at the closest station for the August 7 to September 6 time period and the MMS 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 movement is directed by winds predominantly from the NE 

and the predicted current. Through Day 12, the oil movement 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 unrecovered, the earliest oil is predicted to potential 

contact with shorelines is Day 25 in the area between 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. 
 

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SECTION 9.0 ALASKA OUTER CONTINENTAL SHELF PLANNING INFORMATION 

a) Emergency Plan

The following emergency plans and documentation regarding 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 documents that address the methods by which Shell will 

cease, limit, or not initiate specific critical operations due to environmental 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 effects on drilling operations and the Discoverer safety. A detailed COCP 

and IMP will be submitted with Application for Permit 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 wellbore in a manner that prevents gas or fluids from 

underground reservoirs escaping from the wellbore 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 vessel-to-vessel, drillship-to-vessel, and dock-to-vessel. 
 

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Attachment 9.1 

Critical Operations and Curtailment Plan 

Chukchi Sea 2010 
 

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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 and 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 bear 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 designated as critical operations and details plans to delay, 

limit or cease these operations when hazards develop 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 deals with ice alert levels, well suspension operations, 

mooring recovery, and well reentry activities associated with 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 contingency plan is expected to cover all conceivable 

situations and circumstances. This plan is not intended to be a substitute 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. 
 

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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 zones 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 necessarily be conducted on each drill site during the 

drilling campaign. Data collection and testing requirements will vary from drill site to drill site 

depending on previous results from offsets and the 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 critical 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. 
 

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Circumstance/Conditions Requiring Curtailment 

Several situations may exist under which critical drilling operations may be terminated, limited, or not 

commenced. These are listed and discussed briefly below: 

Severe Weather

Wind and sea states can affect vessel motion (e.g., heel, pitch, roll, and heave) beyond safe operating 

limits and/or create conditions that make certain operations 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, blowout 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, and 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 operations. 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 for 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 situation 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 determine 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 critical oil containment and cleanup equipment 
 

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 Increase in oil spill control system response time 

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

 Insufficient supply of drilling mud materials at the 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 primary well control, will not be undertaken during a well 

control event (e.g., drilling will cease pending circulation 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, make the drillship ready to move off the site, and 

recover moorings is discussed for ice hazards in the 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 operations can resume in the future. 

ST varies and depends on the type of operation in progress at the time drilling is suspended. For example, 

if drilling is in a zone capable of producing hydrocarbons, 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 suspending 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 (generally 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 are experienced-based and must be conservative to 

allow for unforeseen circumstances. The Shell Drilling 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 disconnect 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. 
 

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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 using conventional means may require 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 for 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 hazard, regardless of type, at the drill site. The IMP 

outlines how the arrival of ice hazards are predicted 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 Weather 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, weather, 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 included 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 determining 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 approaching 
 

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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 summarized 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 begin 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 Superintendent 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 back 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 suspension due to an unanticipated acute hazard (e.g., 

well control incident, shipboard fire) and the procedure 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 drillship ready to move, if necessary, with the 

concurrence of the OIM. The MMS Field Representative, the Shell Drilling Superintendent, and 

the MMS RS/FO will be notified as soon as practicable 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 training 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. 
 

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Attachment 9.2 

Ice Management Plan Outline 

Chukchi Sea 2010 
 

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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 submitted 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 necessary to identify, monitor, and mitigate ice-related 

hazards that might be encountered during drilling operations in the Chukchi Sea. It ensures an 

appropriate phased response to current or anticipated ice 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 drilling 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 and circumstances, and this IMP is not expected to 

cover all possible situations that could occur. However, it does contain firm guidelines for dealing with 

most ice-related hazards. Sound judgment 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 experience 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 Synthetic 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 management 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 and 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 feature to drift to the drill site, the time required to 

secure the well, and the time required to make the drilling vessel ready to move off the site if it becomes 

necessary to do so. Actions and responsibilities of various managers involved with operations depend on 

the ice alert level. 
 

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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 hazardous ice feature reaches the drill site 

ST – the time, in hours, required to cease drilling operations 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 ready 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 site 
 

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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-Charge 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 and for returning it to the drill site when the ice 

hazard has passed 

Marine Supervisor – Frontier employee responsible for marine operations on the drillship 

including mooring, ballasting, and safely operating 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 and 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 the drillship responsible for overseeing 

drilling and other drill site operations; the Onsite Incident Commander for spill or well control 

response; responsible for ordering suspension of drilling operations, securing the well and 

estimating the time required to do both (ST); also responsible for well recovery operations when 

the drillship returns. 
 

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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 Shell’s Drilling Engineers, is tasked with preparing 

procedures for suspending the well in the face of an impending ice hazard and for 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 hazard 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-approved procedures that ensure that the well cannot 

leak during the time the well is suspended. It should 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 the water column. Sometimes, this method is used 

to permanently abandon the well when the objectives have been fulfilled, but it is desired to leave 

the well such that it can be re-entered in the future. 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 

Masters 
 

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in this scenario; however, if the well is only partially plugged, the drillstring 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 suspend 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 intervals. 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 and 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 intervals prior to this operation. It is usually 

preferred to leave some drillpipe suspended for well control purposes to facilitate 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 followed 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 fluid 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 top to the drillstring remaining in the hole, so 

recovery of the pipe is simplified. The blind/shear 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 site is dependent on high quality ice 

forecasts and experienced marine and drilling personnel who are able to assess the various parameters 

properly and determine the practicality of the decision with due dispatch. The sequence followed depends 

on the following: 

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

 Isolation and control of potential 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 safe 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. 
 

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 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, the 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 Shell Drilling Engineers and the Shell Drilling 

Superintendent, will prepare a re-entry procedure 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-establishing 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 determined 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 practice 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 leaving 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 the RARs fail to function. This is used when 

the ice threat is imminent and there are no other means for releasing the drillship vessel from its 

moorings. 

The selection of a specific release option and the execution of the procedure depends on the time 

available before the ice hazard approaches the drillship. The Marine Supervisor is tasked with the 

procedure selection and execution with the concurrence of the OIM. Clearly, the well must be 

secure and the riser disconnected before the drillship can be released. 
 

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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 recovery 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. 
 

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Attachment 9.3 

Well Control Plan Outline 

Chukchi Sea 2010 
 

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Well Control Plan Outline 

Chukchi Sea 2010 

Well control is the process of maintaining hydrostatic pressure in the drilled wellbore in a manner that 

prevents gas or fluids from underground reservoirs escaping from the wellbore in an uncontrolled manner. 

Shell believes that no single operational error or equipment 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 identification, 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 timely implementation of kick response procedures. 

Continuous monitoring including the use of computerized pit volume monitoring, return flowrate 

detection, returned drilling fluid analysis and data 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 check, shut in the well, and kill the flow using 

one of several methods that prevent the situation 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 inspections 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 despite these precautions, Shell will immediately mobilize 

specialized emergency response personnel and equipment to the site. Shell will also consult a well control 

specialist such as Wild Well Control for the intervention 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 control 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 equipment. A site assessment is conducted, 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 was lost due to equipment malfunction 
 

2010 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 preparation 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 procedures 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, and 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 blowout. 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 financial strength and reliability and has demonstrated 

OSFR according to 30 CFR 253 for the facilities planned in the EP. This financial reliability ensures that 

Shell has the capability to deal with all emergency situations 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 blowout 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 intercept 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 personnel and well control specialists occurs rapidly in 

this emergency situation. Normal time requirements 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 necessary agency approvals. Placing human safety as the highest priority, 

Shell will consider the feasibility and benefits of igniting the blowout after all personnel, equipment, and 
 

2010 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 oil could potentially result in a safer working 

environment for relief well operators and for responders attempting to contain and recover oil 

downstream of the blowout. 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 this 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 conventional 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 equipment into the blowout wellbore to affect a final 

kill. 

Often, the wellbore is damaged by the blowout to the 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 MMS. 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 

Shell Gulf of Mexico Inc. 76 July 2009 

15276-03-09-001A/09-011A Rev. 1

THIS PAGE 

INTENTIONALLY 

LEFT BLANK 
 

2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. 77 July 2009 

15276-03-09-001A/09-011A Rev. 1

Attachment 9.4

Fuel Transfer Plan 
 

2010 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

THIS PAGE 

INTENTIONALLY 

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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 1 of 21

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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 Venture 
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 2 of 21

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Author 

Craddock-Melin, J. Lynn; Marine Contracts 

Manager, Alaska 

Reviewers 
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 3 of 21

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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 Information 
Shell Exploration & Production Company Number: 

 Operations Procedure Custodian: Alaska Logistics 

ALASKA FUEL TRANSFER - 

OPERATING CONDITION AND 

PROCEDURE 

Revision: 1 

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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 conducted as part of EPW’s operations in the 

Alaskan Venture fully comply with port state 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 operations 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 Lease 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 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 fuel spill. 

The lessee’s oil-spill-contingency plans must include procedures for the pre-transfer booming 

of the fuel barge(s).

1.2. Applicability 

This document will be applicable to all EPW vessels operating in the Chukchi Sea, US Beaufort 

Sea and the Canadian Beaufort Sea as well as any 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 provide appropriate material and manpower as required by this document and their 

operating procedures. 

When a vessel is engaged in fuel transfer operations in areas other than the Chukchi and Beaufort 

Seas but within the Alaskan Venture, the appropriate 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

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For all fuel oil transfers within 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 Permitted 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 responsible 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 perform 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 

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1.6.1. Fueling of small work boats (e.g. 34 feet and 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 seismic acquisition (e.g. Gilavar and her escort 

vessels) while underway with streamers deployed
Shell Exploration & Production Company Number: 

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OPERATING CONDITION AND 

PROCEDURE 

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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 the 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 Coordinator (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 three 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 

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2.4.3.1. Ensure all applicable fuel transfer equipment 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 checked 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 and 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 with 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 equipment and conditions shall be considered 

required:
Shell Exploration & Production Company Number: 

 Operations Procedure Custodian: Alaska Logistics 

ALASKA FUEL TRANSFER - 

OPERATING CONDITION AND 

PROCEDURE 

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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 

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When preparing plan for transfer, due regard should 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 variations 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 will 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 maneuver for ice. It may be necessary to 
Shell Exploration & Production Company Number: 

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OPERATING CONDITION AND 

PROCEDURE 

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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 considered hazardous. The containment boom should be 

able to be or remain deployed with no interference 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 loss 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 procedures, 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: 

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OPERATING CONDITION AND 

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2.8.4. Agreement between vessel and facility as to anticipated time of unmooring or departing 

the dock.

2.9. A copy of the Declaration of Inspection (DOI) completed 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 Management 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 utilize their safety management systems’ DOI, then 

the CRT shall complete Appendix E. This document must be addressed and signed by all 

participating parties. 
Shell Exploration & Production Company Number: 

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OPERATING CONDITION AND 

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Configuration 1 and 2 
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OPERATING CONDITION AND 

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APPENDIX A 

 

Notification of Planned Fuel Transfer Operation

Proposed Date and Time of Fuel Transfer: ________________ 

Receiving Vessel: ____________________________________________ 

Delivery Vessel: ______________________________________________ 

Estimated Quantity of Fuel: ________________gals 

Location: _________________________________ 

Weather Forecast: 

__________________________________________________________________

________________________________________________________________ 

Notifications: 

 Shell Contingency Response Coordinator: _____________________ 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 completed 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 Sale 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 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 below I have indicated 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 with 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 below 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 the 
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 18 of 21

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given conditions and perimeters 

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 closed 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 the 

 
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 19 of 21

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transfer operation; 

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 Signature 
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 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 and 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 below I have indicated 

whether the vessel complies with all pertinent regulations by initialing the check off list below. 

I, _________________________, the person in charge of the supplying vessel/terminal for the transfer of fuel oil in bulk certify I have personally 

inspected this vessel/terminal with 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 below I have indicated whether the vessel/terminal complies with all pertinent regulations by initialing the check 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 

operations 

 
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 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.com
 

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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 GN33 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 compliance with the subsequent air permit conditions. 

NOI applications to operate under NPDES General 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 observations. 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, killer whale, and harbor porpoise 

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

Potential impacts to these species are discussed in detail in the EIA (Appendix F). Any impacts to whales 

and seals from the planned exploration drilling program would be temporary and result in only short-term 

disturbance or displacement. From a historical perspective, the temporary activity of offshore exploration 
 

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drilling and associated support vessel activities, collectively and individually, have not resulted in impacts 

of biological significance to marine mammals of the Arctic, 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 potentially be exposed to sound levels of >160 decibels (dB) 

rms and >120 dB rms generated by drilling or ice management are summarized in Table 10.b-1 and 

discussed in the IHA (Appendix C). Many animals exposed 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 species that may change their behavior or alter their 

migration route, those changes are likely to be within the normal range of activities for the animals and 

may not rise to the level of “taking” based on guidance 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 (temporary 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 whale, as a consequence of Shell’s planned mitigation 

measures (see Section 12.0) any effects on the bowhead whale as a subsistence resource also will be 

negligible. 

The LOA application (Appendix E) provides an outline 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, Beaufort Sea, Alaska, 2010 Exploration Program. The 

LOA application does not require the inclusion of take estimates for polar bears or Pacific walrus. 
 

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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. 

Species 

Number of Exposures to Sound 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 numbers 

may be encountered than calculations suggested. Not all marine mammals will change their behavior when exposed to these 

sound levels 
 

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SECTION 11.0 LEASE STIPULATIONS INFORMATION 

The source for the italicized text below is the OCS 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 Supervisor, 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 notification to the lessee of the RS/FO’s 

decision to require such surveys. 

Based on any surveys that the RS/FO may require of the 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 established 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 immediately report such findings to the RS/FO 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 course 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 biological 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 provide detailed information on the seafloor sediments 

and relief, Shell conducted or participated 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 surveys to assess the relative environmental sensitivity of 

Chukchi Sea coastline segments, walrus tagging and monitoring studies, seal tagging and monitoring 

studies, bird and marine mammal surveys, assessments 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 summarized in the EIA in Appendix F. 

These studies also indicated that there are no areas of special biological significance in the vicinity of the 

drill sites. Video reconnaissance surveys were conducted at historical drill sites at Burger and 
 

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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 substrate 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 development and production plan (DPP) 

submitted under 30 CFR 250.211 and 250.241 a proposed orientation program for all personnel involved 

in exploration or development and production activities (including personnel of the lessee’s agents, 

contractors, and subcontractors) for review and approval 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 colonies, and marine mammals and provide guidance on how to avoid 

disturbance. This guidance will include the production 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 values, customs, and lifestyles in areas in which 

such personnel will be operating. The orientation program shall also include information concerning 

avoidance of conflicts with subsistence 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 personnel involved in lease 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 shall include the name and date(s) of attendance of each 

attendee. 

Shell Proposed Actions: 

Shell has developed and is currently implementing an approved orientation program for Shell and 

contractor personnel involved in Shell’s Alaska Venture 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 with the applications for Permits to Drill. 

All Shell and contractor personnel involved in field exploration activities will attend the orientation 

training annually. All other Shell and contractor personnel will attend the program 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 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 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 provides guidance on how to avoid disturbance. 

Shell’s Cultural Awareness Program addresses the following: 

 Alaska Native Ethnic Breakdown 
 

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 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 Awareness 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 feasible and environmentally preferable; and (c) if, in the opinion of the 
 

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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 conflicts. The lessor specifically reserves the right to 

require that any pipeline used for transporting production 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 capacity, no crude oil production 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 activities 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 necessary. 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 exploratory drilling operations can be commenced. 

The monitoring program will be designed to assess when bowhead 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 designing 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 sighting 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 determined 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 monitoring 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; and 
 

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7) Submitting a final report on the results of the monitoring 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 submittal timelines if the RS/FO determines such an 

extension is warranted to accommodate extenuating circumstances. 

The lessee will be required to fund an independent peer 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 monitoring plan and the draft report on the results of the 

monitoring program for other co-managed marine mammal resources. This peer review will consist of 

independent reviewers who have knowledge and experience in statistics, monitoring marine mammal 

behavior, the type and extent of the proposed operations, and an awareness of traditional knowledge. The 

peer reviewers will be selected by the RS/FO from experts recommended 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 monitoring 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 Authorization (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 lessee must advise the RS/FO 

when it is seeking an LOA or IHA in lieu of meeting the requirements of this stipulation 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 will 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 IHA’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, 6703 
 

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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 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 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 used 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 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, 

walrus can be hunted at local haulouts with the focal 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 unsuitable 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 Kukpowruk 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, Point 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. Beluga 
 

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whales are harvested from March to June in the same area used for 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 southern shore of the point from Point Hope to 

Akoviknak Lagoon. Point Hope residents hunt polar bears primarily from January to April and 

occasionally from October to January in the area south of the point and as far out as 10 miles from shore. 

This stipulation will remain in effect until termination or modification by the Department of the Interior 

after consultation with appropriate agencies. 

Shell Proposed Actions: 

Although none of the blocks listed in this stipulation 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 recruitment 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 LOA 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 data on observations of marine mammals 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 representatives of the Alaska Native community, the 

MMOs also serve as an important means of providing local 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 between 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 Barrow will begin in early- to mid- July and will 

continue until drilling operations in the Chukchi Sea are completed. The objectives of the aerial survey 

are to collect data on the distribution and abundance of marine mammals in coastal areas of the eastern 

Chukchi Sea; and to collect and report data on the distribution, numbers, orientation 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 levels, character, and propagation; and to document 
 

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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 conducted 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 those 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 distribution 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, walrus and ringed seal tagging studies 

 Collection of subsistence use of coastal and offshore 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 production operations shall be conducted in a manner that prevents 

unreasonable conflicts between the oil and gas industry 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 support activities, such as vessel and aircraft traffic, that 

traverse the blocks listed below or Federal 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, 7113-7124 
 

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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 development and production plan (including associated oilspill response plans) to the MMS for activities proposed during subsistence-use critical times and 

locations described below for bowhead whale and other marine mammals, the lessee shall consult with 

the North Slope Borough, and with directly affected subsistence communities (Barrow, Point Lay, Point 

Hope, or Wainwright) and co-management organizations to discuss potential conflicts with the siting, 

timing, and methods of proposed operations and safeguards or mitigating 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 resources 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 effort, including such mechanisms as a conflict avoidance agreement, 

to assure that exploration, development, and production activities are compatible with whaling and other 

marine mammal subsistence hunting activities and will not result in unreasonable interference with 

subsistence harvests. 

A discussion of resolutions reached during this consultation process and plans for continued consultation 

shall be included in the exploration plan or the development and production plan. In particular, the 

lessee shall show in the plan how its activities, in combination with other activities in the area, will be 

scheduled and located to prevent unreasonable 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 more 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 organizations at the time the plans are submitted to the 
 

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MMS to allow concurrent review and comment as part of the plan approval process. In the event no 

agreement is reached between the parties, the lessee, NMFS, USFWS, the appropriate co-management 

organizations, and any communities that could be directly affected by the proposed activity may request 

that the RS/FO assemble a group consisting of representatives from the parties to specifically address the 

conflict and attempt to resolve the issues. The RS/FO 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 prevent unreasonable conflicts with subsistence harvests. The lessee 

shall notify the RS/FO of all concerns expressed by subsistence hunters during operations and of steps 

taken to address such concerns. Activities on a lease may be restricted if the RS/FO determines it is 

necessary to prevent unreasonable conflicts with local 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 Chukchi 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 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 used to hunt walruses. 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 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, walruses can be hunted at local haulouts with the 

focal 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 unsuitable 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 Kukpowruk 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, 

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 March to June in the same area used for the 

bowhead whale hunt. Beluga whales can also be hunted in the open water later in the summer 
 

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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 

southern shore of the point from Point Hope to Akoviknak Lagoon. Point Hope residents hunt 

polar bears primarily from January 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 Arctic Borough (NWAB), and affected subsistence 

communities of Barrow, Point Hope, Point Lay, Wainwright, 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 communities, 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 through 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 stakeholders to build on its past efforts to inform and 

engage the communities that could be affected by exploration activities in the Chukchi Sea. It is also 

noted that a POC is required for an IHA from the 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 concerns. Shell has prepared a written POC that describes 

when and where the meetings were held, what was 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 the 2010 Chukchi Sea Exploration Drilling Program for 

Development of the POC 

2009 Meeting 

Location 

Meeting Attendees – Position 

12-13 January Barrow Harry Brower - Whaling Captain, AEWC Chairman and Assistant Director of the 

NSB Wildlife Department 

Edward Itta - Whaling Captain and Mayor of the NSB 

Eugene Brower - Whaling Captain, ASRC Board Member and President of the 

NSB Assembly 

Anthony Edwardsen - Whaling Captain and President of UIC 

Andy Mack - NSB Assistant to the Mayor 

Harold Curran - NSB Chief Administrative Officer 

Robert Suydam - NSB Wildlife 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 Director 
 

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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, May, 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, USFWS, 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 fuel 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 transfers are provided in Appendix D of the Chukchi Sea 

Regional ODPCP. Under Shell’s procedures all vessel-to-vessel, vessel-to-drillship, and dock-to-vessel 

transfers of fuel will be pre-boomed during the 2010 season. 
 

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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 stipulation 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 reporting 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 recovery or transport of dead or injured birds 

due to avian influenza concerns. 

(2) The following conditions apply to operations conducted in support of exploratory and 

delineation drilling. 

(a) Surface vessels (e.g., boats, barges) associated with exploration and delineation 

drilling operations should avoid operating within or traversing the listed blocks or 

Federal waters between the listed blocks and the coastline between April 15 and June 10, 

to the maximum extent practicable. If surface vessels must traverse this area during this 

period, the surface vessel operator will have ready access to wildlife hazing equipment 

(including at least three Breco buoys or similar 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 their dates of operation within the area. 

(b) Except for emergencies or human/navigation safety, surface vessels associated with 

exploration and delineation drilling operations will avoid travel within the Ledyard Bay 

Critical Habitat Area between July 1 and November 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 Federal 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 established by the lessee and MMS, in collaboration 

with the USFWS, during review of the EP. Route or altitude deviations for emergencies 

or human safety shall be reported 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. 

 
 

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(1) Drilling Structures: Lessees must adhere to lighting requirements for all exploration or 

delineation drilling structures so as to minimize the likelihood that migrating marine and coastal 

birds will strike these structures. Lessees are required to implement lighting requirements aimed 

at minimizing the radiation of light outward from exploration or delineation drilling structures to 

minimize the likelihood that birds will strike those structures. These requirements establish a 

coordinated process for a performance-based objective rather than pre-determined prescriptive 

requirements. The performance-based objective is to minimize the radiation of light outward 

from exploration/delineation structures 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 technical, operational, and management 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 this 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 federal waters between the listed blocks and the 

coastline. Exterior lights will be used only as necessary to illuminate active, on-deck work areas 

during periods of darkness or inclement weather (such 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, 7001 
 

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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 reduce personnel safety or prevent compliance with other 

regulatory requirements (e.g., U.S. Coast Guard (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 risk of Shell’s exploration drilling program having an 

effect on marine birds, especially Steller’s and spectacled 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 Lighting Plan that covers the planned exploration 

drilling program in the Chukchi Sea in 2010. In development of the plan, Shell considered all the 

measures identified for consideration in the stipulation, 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 recording and reporting bird, strikes for the 

collection of information on bird strikes and lighting configuration. This information can be 

used to better understand methods to reduce bird strikes. 

 Avian monitoring including visual observations and radar assessments to determine bird use 

of the prospect areas during the drilling period. 

 Installing shading and directing some drillship 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. 
 

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 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 J
 

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SECTION 12.0 ENVIRONMENTAL MITIGATION MEASURE INFORMATION 

a) Permits and Authorizations

The General Information section (Section 2.0) identifies 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 therefore 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, and 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 Kittlitz’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 the 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 intentional take of polar bears and Pacific walrus. 

Copies of the IHA and LOA applications are provided in Appendix C and E respectively. The IHA 

application contains a marine mammal mitigation and monitoring plan. The LOA application contains a 
 

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bear and walrus avoidance and human encounter / interaction plan. Shell has also developed and will 

implement a Bird Strike Avoidance and Lighting Plan (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 measures 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 entirely 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, Wainwright, Point Lay, Point Hope, Kaktovik, Nuiqsut, 

Kivalina, Shishmaref, and Savoonga for consultation 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. Aircraft will 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 other subsistence hunter or in poor 

weather (low ceilings) or any other emergency situations. 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 Communications 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 mammals, vessels will reduce speed, avoid separating 

members from a group and avoid multiple changes of direction 

 Vessel speed to be reduced during inclement weather conditions in order to avoid collisions with 

marine mammals 
 

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 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 the 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 with light and reduces probability of bird strikes 

 Shading and minimizing the use of high intensity lights on support vessels that minimizes the 

disorientation and attraction of birds associated with 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., whether mud properties have deteriorated to the point where they 

cannot be used further), to reduce discharges from 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 potential 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 transits 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 arrival 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 NOx emissions to under 0.5 g/kW-hr, and catalytic oxidation devices to reduce CO by 80 

percent, VOCs by 70 percent, and PM10 by at least 50 percent 
 

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 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 through 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/day 
 

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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, general 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 similar vessels. Photographs of some of these vessels 

are provided below with brief descriptions of their function and use. 

TABLE 13.a-1 

Specifications of Support Vessels 

Specification Vladimir Ignatjuk1 Tor Viking1

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 m3) 

7,484 bbl 

(1,190 cu m) 

667 bbl 

(106 m3) 

7,028 bbl 

(1,117 m3) 

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. 
 

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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 similar to the vessel pictured in Photograph 13.3 will 

provide support to the 2010 exploration activities. 

Photograph 13.3 Typical Shallow Water Landing Craft 
 

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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 shorebase. 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 and 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 

-- -- 
 

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The Nanuq (Photograph 13.5) or similar vessel will be staged in the vicinity of the drill site. 

Photograph 13.5 M/V Nanuq 

The Affinity (Photograph 13.6) or vessel with similar liquid storage 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, emulsions and free water. The Affinity has capacity beyond the storage volume for 

the maximum recovered oil and other liquids from the 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 storage capacity for recovered liquids in the event of a 

spill, and would carry onboard response equipment that 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 Tug 
 

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Aircraft 

Offshore operations will be serviced by helicopters operated 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 between 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 for Search and Rescue (SAR). This helicopter is 

expected to be a Sikorski 61 or similar model. This 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 equipment between the shorebase and hub airports such as 

Barrow or Fairbanks. A fixed wing aircraft, DeHavilland 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. These 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 drillship. The OSRB is stationed at West Dock at Prudhoe 

Bay and will be mobilized before drilling into liquid hydrocarbon bearing zones commences. The OSRB 

and associated tug will remain in the nearshore zone throughout Chukchi Sea exploration drilling 

operations. Drilling will cease on or before October 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 implement the procedures described in Shell’s Fuel 

Transfer Plan (Attachment 9.4) during all refueling 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 marine 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 shorebase 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 planned drilling program are listed below in Table 13.a3. 

 
 

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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 m3 Will remain generally upwind of the 

Discoverer from 3-25 miles away 

throughout the 2010 Chukchi 

exploration drilling program 

Tor Viking -Anchor handling and ice management 

vessel 

7,494 bbl 

1,190 m3 Stays in the area of Discoverer

throughout drilling season 

 

Offshore supply boat 7,028 bbl 

1,117 m3

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 m3

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 m3 Stays in vicinity of the drillship 

throughout the drilling season 

OSR work boats 7 bbl 

1.1 m3 12 round trips / week for 2 months 

for OSR drills & training – between 

Wainwright shorebase and OSRB 

OSRB 1,428 bbl (tug) 

227 m3 Will be located in the nearshore 

zone throughout the 2010 Chukchi 

exploration drilling program 

OST 513,000 bbl 

81,560 m3 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 m3 5 trips / week between Wainwright 

and Anchorage 

(1) Helicopter - Agusta AW 139 or EC225 – for 

crew rotation & groceries/supply 

18 bbl 

2.9 m3

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 m3 Stationed in Barrow – 40 hr/week 

for proficiency training & trips made 

in emergency 

 
 

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b) Air Emissions

Projected air emissions from support vessels are indicated 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 Associated with the Drillship Discoverer for the Chukchi 

Sea Exploration Drilling Program

Vessels PM10 PM25 NOx SO2 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-handler 
 

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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 operational 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 drilling 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 vessels 
 

2010 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 disposed of at a permitted and regulated facility. Food 

wastes associated with the Discoverer will be incinerated. 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 exploration 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 smaller support vessels would follow to access the shorebase 

are also shown. The flight corridors that helicopters 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 reflect 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 Routes 
2010 Outer Continental Shelf Leases Exploration Plan 

Shell Gulf of Mexico Inc. 135 15276-03-09-001A/09-011A 

Figure 13.e-2 Flight Corridor 
2010 Outer Continental Shelf Leases Exploration Plan 

Shell Gulf of Mexico Inc. 136 15276-03-09-001A/09-011A 

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2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska 

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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 exploration drilling program. Shorebase facilities for air 

support will be located in Barrow at the State-owned and operated Barrow Wiley Post Will Rogers 

Memorial Airport (Barrow Airport). A secondary aviation 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 arrangements. A temporary hangar would be constructed on 

an existing pad at either location for housing the helicopter. 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 Barrow), or remain in Wainwright if the hangar is 

constructed there. 

Shell currently leases office space in Barrow and will 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 existing facilities in Barrow is planned for 2010. Existing 

accommodations such as hotels will be used as accommodations 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 water and sewer systems, and airstrip. Shell will use the 

airstrip located in the Village of Wainwright, which 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. There 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 drilling program. Lift and hoisting equipment (crane) 

would be installed near the ramp if feasible; an investigation into the need and feasibility of the hoisting 

equipment is currently underway. Lifting may be accomplished 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 equipment and load staging for the marine vessels. Shell 

will use an existing 30,000-gallon (113 cubic meters [m3

]) tank for diesel and bring in three additional 

50,000-gallon (189 m3

) tanks for aviation fuel. All four tanks will be inspected, certified, double-walled 

tanks on gravel pads, with secondary containment capable 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. Existing 
 

2010 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 and 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 aircraft emissions, will be minimal and temporary. 

c) Unusual Solid and Liquid Wastes

There will not be any unusual solid or liquid wastes 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, Waste 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 

incinerated 
 

2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska 

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15276-03-09-001A/09-011A Rev. 1

SECTION 15.0 COASTAL ZONE MANAGEMENT ACT 

Attachment 15.1 is the Coastal Project Questionnaire and Certification Statement. 
 

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2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska 

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Attachment 15.1 

Alaska Coastal Management Program 

Coastal Project Questionnaire & Certification Statement 
2010 Outer Continental Shelf Leases Exploration Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. 142 July 2009 

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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 consistency 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 maps and plan drawings at scales large enough 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 within 

21 days of receipt if the packet is incomplete 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 reviewed 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 new 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 existing 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 nearest community, the name of the 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 / 171degrees (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 associated with the Trans Alaska Pipeline corridor? ......................................................................

 

 COASTAL DISTRICT Yes No

7. Is the project located in a coastal district? ..........................................................................................................................

If yes, identify the applicable 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 powers, 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 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: 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, overburden, 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, 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 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 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, 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 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 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 water exclusively from either an existing Public Water Supply or 

from 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 withdrawal on property you own? ............................................................................. 

11. Do you plan to build or alter a dam (regardless of land ownership)? .................................................................................. 

12. If you answered yes to any 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: 
 

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 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 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 other activity leading to or connected to a 

commercial timber harvest operation...................................................................................................................... 

14. If you answered yes to any question above, indicate 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 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 DIVISION OF OIL & GAS Yes No

15. a) Will you be exploring for or producing oil and/or gas? ........................................................................... 

b) Will you conduct surface use activities on/within an oil and gas 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 (regardless of land ownership)? .......................................................... 

17. If you answered yes to any question above, indicate the person you contacted 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, archaeological 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 Preservation Office 

for information. 

 

a) Name/date of Contact: 

 

DNR DIVISION OF GEOLOGICAL & GEOPHYSICAL SURVEYS Yes No

20. Is the proposed project located within a natural hazard area designated by a coastal district 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 coastal districts and not in any known hazard area. 

 

21. If “YES” and you have contacted someone, please 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 

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15276-03-09-001A/09-011A Rev. 1

DNR DIVISION OF PARKS & OUTDOOR RECREATION Yes No

22. Is the proposed project located in a unit of the Alaska State Park System including navigable waters, tidelands or 

submerged lands to three miles offshore? .............................................................................................. 

23. If you answered yes to any question above, indicate 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 flood plain, on islands, in or on the face 

of the banks, or, for streams entering or flowing through tidelands, above the level 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, indicate the person you contacted 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 Refuge, Critical Habitat Area or State Game Sanctuary? ............... 

2. Does your project include construction/operation of a salmon hatchery? ......................................................... 

3. Does your project affect, or is it related to, a previously permitted salmon hatchery? .......................................... 

4. Does your project include construction of an aquatic farm? ........................................................................ 

5. If you answered yes to any questions above, 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 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: 

 

 
 

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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 subsurface of the state occur? (see 18 

AAC 72.990 for definitions.) ........................................................................................................... 

c) Will the wastewater disposal activity require a mixing zone 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 collection/discharge system? ............................................................ 

e) Will the project include placing fill in wetlands? .................................................................................. 

f) Is the surrounding area inundated with water 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 for wastewater? ............................................................... 

 3. If you answered yes to any questions above, indicate the 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 result in storage or transfer 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 disposed 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 treatment works which are land applied for beneficial use.) .. 

5. Will your project require application of oil, pesticides, and/or any other broadcast chemicals? ............................... 

6. Does your project qualify for a general permit for solid waste? ................................................................ 

7. If you answered yes to any question above, 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. 

 
 

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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 with a rated capacity of at least five 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 preparation plant? ............................................................................................. 

f) Will you have a Port of Anchorage stationary source? ............................................................................ 

g) Will you have a facility with the potential to emit no less than 100 tons per year of any regulated air contaminant?..... 

h) Will you have a facility with the potential to emit no less than 10 tons per year of any hazardous air contaminant or 

25 tons per year of all hazardous air contaminants?........................................................................................................ 

i) Will you be constructing a new stationary 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 existing operating permit developed 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 pollutant 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 modification 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 Regulated Air Pollutants can be found at 

http://www.epa.gov/ttn/oarpg/t5/memoranda/rapdef.pdf .................................................................................................. 

9. If you answered yes to any questions above, 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 the 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: EPA 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). 

 

 
 

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DEC DIVISION OF SPILL PREVENTION AND RESPONSE Yes No

10 a) Will your project involve the operation 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 exploration 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 material or perform dredging activities in waters 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 perform work in waters of the U.S? Section 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 subject to the ebb and flow of the tide, rivers, 

streams, lakes tributaries, and wetlands. If you are not certain whether your proposed 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 above, 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 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: 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 cross 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 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: 

 

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 involve building an access to an island? ...................................................................... 

c) Do you plan to site, construct, or operate a deepwater port? ..................................................................... 
 

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7. If you answered yes to any question above, indicate the person you contacted at the appropriate US Coast Guard 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: 

 

U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA) Yes No

8 a) Will the proposed project have a discharge 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 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: 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 above, 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 natural gas or liquefied natural gas importation or exportation 

facilities under section 3 of the NGA? ............................................................................................................................. 

d) Does the project include construction for physical interconnection of electric transmission facilities under section 

202 (b) of the FPA? 

.......................................................................................................................... 

13. If you answered yes to any question above, indicate 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 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: 

 

U.S. FOREST SERVICE (USFS) Yes No

14 a) Does the proposed project involve construction on USFS land? ................................................................. 

b) Does the proposed project involve the crossing of USFS land with a water line? ............................................. 
 

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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 above, indicate the person you contacted at United States Forest Service 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: 

 

U.S. FISH AND WILDLIFE SERVICE (USFWS) Yes No

16 a) Is your proposed project on land managed 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 person you contacted at the US Fish and Wildlife Service 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: 

 

 

OTHER FEDERAL AGENCY APPROVALS Yes No

18 a) Other Federal agencies with authorizations reviewable 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 borough government to proceed with your activity. 

Attach the documentation requested under the Project Description. 
 

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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 certification. Evaluate your project against each section of 

the state standards and applicable district enforceable policies using the template below or by submitting a narrative 

description in letter or report form. District enforceable policies are available 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 physically 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-dependent nor water-related for which there is no 

practicable inland alternative to meet the 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 physically 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 obtained from the MMS during Lease Sale 193. Shell 

selected these leases based on their potential 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-dependent nor water-related, please explain why there is 

not a practicable inland alternative that meets the public need for the use or activity. Explain. 

(c) DCOM defers to the United States Corps of Engineers (USACE) to interpret 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 conditions 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 supporting 
 

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scientific evidence for the designation. 

(b) Areas likely to be affected by the occurrence 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, construction, 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, "appropriate measures in the siting, design, construction, and 

operation of the proposed activity" means those measures 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 Development 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 district 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 designed to accommodate the designated hazards. How will 

you use site design and operate the proposed activity to protect public safety, services and the 

environment from potential damaged caused by known 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 Occupational 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 protecting 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 projects maintain and, where appropriate, increase public 

access to, from, and along coastal water. 

Evaluation: 

Please explain how the proposed project will maintain and, where appropriate, increase public access 

to, from and along coastal water. The planned exploration drilling is approximately 60 -130 statute 

miles offshore in an area not frequented by the public. 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 satisfying 
 

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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, developers, and federal agencies in the development of facilities; 

(6) select sites with sufficient acreage to allow for reasonable expansion of facilities; 

(7) site facilities where existing infrastructure, including 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 control and collision avoidance systems; 

(10) select sites where development will require minimal 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 construction of those facilities and support infrastructures in 

coastal areas will allow for the free passage and movement of fish and wildlife with due consideration 

for historic migratory patterns; 

(13) site facilities so that areas of particular scenic, 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 disperse airborne emissions that cannot be captured 

before escape into the atmosphere; 

(16) site facilities so that associated vessel operations or activities will not result in overcrowded 

harbors or interfere with fishing operations and equipment. 

(b) The uses authorized by the issuance 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, please 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 eider habitat) boundaries. Seasonal drilling would 

occur generally July through October of 2010 using the drillship Frontier Discoverer and support 

vessels. Project equipment and operations are designed to avoid and minimize negative 

environmental effects governed by compliance with 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 delineated coastal community subsistence use areas. 

Pursuant to the Marine Mammal Protection Act, Shell is submitting an application to the National 

Marine Fisheries Service (NMFS) for an Incidental Harassment Authorization (IHA) for whales 

and seals, and an application for a Letter of Authorization to USFWS for incidental and intentional 

takes of polar bears and Pacific walrus to support offshore operations. The authorizations include 

measures to avoid and minimize social effects through conflict avoidance mechanisms and a NMFS 

Incidental Harassment Authorization Marine Mammal Monitoring and Mitigation Plan. 
 

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(2) The planned exploration drilling 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 marine 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 response equipment staging and crew changeouts.

(4) Concurrent use of facilities is described in (3) above. 

(5) The planned exploration drilling program is temporary and seasonal. Drilling operations will 

be conducted in consultation and 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 program 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 industry marine vessel communication protocols. 

Collision avoidance systems include the use of shipboard Global Positioning System (GPS) 

tracking and radar systems, with Automated Identification Devices (AID) devices installed on the 

Frontier Discoverer and support vessels. 

(10) This is a planned exploration drilling program with temporary and seasonal operations, not a 

development program. There will be minimal subsea bed excavation for mud line cellars at drilling 

locations. Mudline cellars are designed to protect wellhead casing and blowout preventers from 

potential ice scour events. Vessel anchoring systems 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 available 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 drill 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 Stipulation 7 (sensitive eider habitat boundaries), and the Polynya 

Zone. The drilling program would be conducted in a manner that controls wastewater effluents 

under the parameters and federal and Alaska water quality standards of NPDES AKG-28-0000 
 

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General Permit issued by EPA. Spill prevention strategies 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 and foster product recovery and proper disposal in 

accordance with an approved Oil Spill Response Plan, 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 harbors. 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 resource extraction you have applied for or received. 

MMS Exploration Plan, Oil Spill Response Plan, l; EPA NPDES General Permit AKG-28-0000, 

Air Quality Construction Permit; NMFS Incidental 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 sited 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 ground 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 sited adjacent to beaches or shorelines, explain how 

the route or facility is water dependent water related or why no practical inland alternative exits. 

Not applicable. 

(b) If the proposed utility route or facility is sited along the coast, explain how you will avoid, 

minimize or mitigate: 

(1) alterations in surface and ground 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 regulations adopted under 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 involve harvesting or processing of timber? Yes No X 
 

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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 extraction 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 practicable 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 subsistence 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 area 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 under AS 16.05.258, the department may, after 

consultation with the appropriate district, federally recognized Indian tribes, Native corporations, and 

other appropriate persons or groups, designate areas in which a subsistence use is an important use of 

coastal resources as demonstrated by local usage. 

(e) For purposes of this section, "federally recognized Indian tribe," "local usage", and "Native 

corporation" have the meanings given in 11 AAC 114.990. 

Evaluation: 

(a) Is your proposed project located within a subsistence 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 district plan in place, there are no coastal districtdesignated subsistence use areas. However, as required by NMFS and USFWS regulations, Shell held 

POC meetings with various individuals and groups from the affected communities. Through POC 

meetings, Shell has adopted mitigation measures designed 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. 
 

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 Shell has developed a Communication Plan and 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 minimize the risk of interfering with subsistence 

hunting activities, and keep current as to the 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 Beaufort 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 the whale migration and subsistence hunt. There 

will be a total of nine subsistence advisor-liaison positions, one per village, to work 

approximately 8-hours per day and 40-hour weeks through 2010. The subsistence advisor will 

use local knowledge (Traditional Knowledge) to gather data on subsistence lifestyle within the 

community and to advise in ways to minimize and mitigate potential negative impacts to 

subsistence resources during the drilling season. Responsibilities include reporting any 

subsistence concerns or conflicts; coordinating with subsistence users; reporting subsistencerelated comments, concerns, and information; and advising how to avoid subsistence conflicts. 

A subsistence advisor handbook will be developed prior to the operational season to specify 

position work tasks in more detail. 

 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, 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 situations) 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 identified through communications with the ComCenters. Except for airplanes engaged in marine 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 500 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 weather conditions in order to avoid collisions 

with marine mammals. 

Birds

 Lighting on the drillship will be shaded or replaced as appropriate to reduce the possibility of 

a bird collision with the drillship. 
 

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Drilling Transit and Operations; 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, approximately 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 Bering Strait will transit through the Chukchi Sea 

along a route that allows for the highest degree of safety regarding ice conditions and sea 

states. Those 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). In this case 

those vessels will move into the polynya zone far 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 redirecting, rather than breaking, ice floes while 

the floes are well away from the drill site. 

 Critical operations will not be started if potential hazards (ice floe, inclement weather, etc.) are 

in the vicinity and there is not sufficient time to complete the critical operation before the 

arrival ofthe hazard atthe drill site. 

 OSR vessels on standby at all times when drilling into 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 use area designated by the coastal district, provide an 

analysis or evaluation of its reasonably foreseeable 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, and 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 behavior. 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 management, 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 affect marine mammals, but any impacts would affect 

only a small percentage of the total species population for all marine mammals, if any, and fleeting 

because of the limited duration of spills of this size. Any potential effects from diesel or oil spills 
 

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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 and include those which affect the subsistence user’s 

activities or affect the subsistence resources. Reductions in subsistence resources and changes in 

subsistence resource distribution may impact subsistence 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 implementation 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 effects 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, however, are expected to be negligible, temporary and 

localized. These potential direct and indirect impacts on subsistence are discussed below by resource. 

(c) No response required. 

(d) If your project is not located in a designated subsistence 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 activities. 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 area. 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 whale hunting may extend east as far as Smith Bay and 

Cape Halkett. 

Wainwright spring bowhead whale hunting occurs from April 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 whales 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, Wainwright, 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 Appendix F of the EP). The pack-ice lead is rarely 

more than 6 - 7 mi (10 - 11 km) offshore (MMS 2007b).
 

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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 into 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 Beaufort in search of beluga whales (MMS 2007b). 

Point Hope residents take part in two beluga whale hunts a year. The first hunt occurs from late 

March through June. This hunt coincides 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 from July to August at the southern edge of the retreating pack ice –

generally within 45 mi (72.4 km) from shore. From August to September they may hunt walrus at 

local haul-outs, with the main area being from Milliktagvik north to Point Franklin. Icy Cape is a 

known walrus haulout location and subsistence hunting ground near Wainwright (Figure 3.11.7-9 in 

Appendix F of the EP).

Point Lay residents hunt walrus from June to August – 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 July along the southern shore from Point Hope to 

Akoviknak Lagoon (MMS 2007b). Walrus hunting generally 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 Bay. These activities generally occur within 45 mi 

(72.4 km) from shore.
 

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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 and 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 southwestward 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 Franklin, 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, spectacled eider, Steller’s eider, mallard, long-tailed 

duck, northern pintail, scoter, brant, Canada geese, snow geese, white fronted geese, tundra swan, 

crane, loons, red-throated loon, and ptarmigan (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 eider, 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 Daigneault 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 ptarmigan, and collect bird eggs (Johnson and Daigneault 

2008, ADF&G 2008). Residents living in Point Lay subsistence 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 whitefish, bull head white fish, Bering cisco, least cisco, 

humpback whitefish, and round white fish (Johnson 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 salmon, 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, humpback whitefish, and round whitefish (Johnson and 
 

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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 their diet (Johnson and Daigneault 2008). These 

activities generally occur along the shore and inland.

Point Hope residents harvest fish in the open water 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 Chukchi 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 ground 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 (MMO) program designed to guide vessel transit 

through the project area while avoiding or minimizing disruptions and deflections of marine 

mammals. 

(3) blockage of existing or traditional access. Existing 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 floodplains 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 subsistence fishing, to the extent that those uses 

are determined to be in competition with the proposed use; 
 

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(2) estuaries must be managed to avoid, minimize, or mitigate significant adverse impacts to 

(A) adequate water flow and natural 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 competition 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, minimize, or mitigate significant adverse impacts to 

(A) water flow and natural drainage patterns; and 

(B) competing uses such as commercial, recreational, or subsistence uses, to the extent that those uses 

are determined to be in competition 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 must 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 erosion 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 managed 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 stream, 500 feet on either side of the waterbody; 

(B) for split channel portions of a river or stream, 200 feet on either side of the waterbody; 

(C) for single channel portions of a river or stream, 100 feet on either side of the waterbody; 

(D) for a lake, 100 feet of the waterbody. 

Evaluation: 

(a) List the habitats from (a) above that are within your proposed project area or that could be affected 
 

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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 waters 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, barrier 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 traffic 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 Chukchi Sea, based on scientific reports concerning 

their biological significance, include Peard Bay, Kasegaluk 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, minimizes, 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 drillship, 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, and mitigates impacts to this offshore arctic 

environment. Up to three exploration wells will be drilled in July, August, September, 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 will 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 considered reasonably foreseeable. The impacts of such 

an event are therefore not addressed in this evaluation 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 

indicates that such a release could have a slick covering 20-200 ac. MMS trajectory analyses indicate 

that a release from Shell’s prospects would have only a remote chance of reaching coastal habitats 
 

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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 avoid, minimize, or mitigate potential impacts. 

These mitigation measures are included in the broad range of permits and plans required for the 

exploratory drilling program. Examples of these plans 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 prepared a fuel transfer plan (Attachment 9.4) that goes beyond 

the requirements of MMS stipulations and requires pre-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 drillship will be discharged under the conditions of the 

General Permit AKG280000, which will minimize 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 drillship 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 Discoverer 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 Monitoring Plan (4MP, Appendix D). The 4MP 

requires that marine mammal observers will be used on the drillship and support 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 yards of marine mammals, vessels underway will reduce 

speed, avoid separating members of a group and avoid 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 the 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 Avoidance 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 

collisions.
 

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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 compete with subsistence activities and resources. 

Helicopter traffic between Barrow and Wainwright, and between shorebase facilities and the 

prospects, will either traverse inland or proceed directly offshore to minimize disturbances to marine 

mammals and subsistence activities along the coast. Disturbances 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 effects. 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 transporting supplies. These vessels are would operate 

at slow speeds, generally 10 knots or less. As vessels 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. Disturbances 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 program 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 habitats 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 three MLCs would directly disturb about 0.03 ac (126 

m2) 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 ft2

 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 wastewaters, 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 these 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. Additionally, Shell will incinerate all food wastes on the 

drillship, will not discharge any untreated sanitary wastewaters, and will discharge no sanitary 

wastewaters within three miles of the coastline. 

The effects of drilling wastes will have longer duration as drill cuttings and drilling muds will be 
 

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deposited on the seafloor. Modeling indicates that the drilling of three wells could result in drilling 

wastes being deposited to depths of 0.4—1.6 inches over about 581 ft2 of seafloor. These discharges 

are benign, with the major impact being the smothering of benthic organisms. Modeling indicates that 

metal concentrations in the sediments may be elevated slightly within the area of deposition, but the 

concentrations would remain within 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 near 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 that have a relief of 6.0 ft or less. Based on 

baseline studies conducted in the Burger Prospect, benthic 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, mooring, and drilling waste discharged may be destroyed 

due to mechanical destruction or smothering with discharged materials. Re-colonization of these areas 

with a similar benthic invertebrate community could 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 fluids, 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. There 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 commercial 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 activities, 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 Point Lay, the nearest communities. Review of 

published mapping of subsistence use areas indicates 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 through some subsistence use areas, in support of the 

program. Effects on subsistence resources would be largely 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 and an existing earthen boat ramp on the Wainwright 

Inlet, which is an estuary, would be used to service 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 activities 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 subsistence, as detailed above under 11 AAC 112.270 

Subsistence and discussed at length in the EIA. 

WETLANDS 
 

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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 Wainwright 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 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 activities 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 subsistence, 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 Shell'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 lagoon, and transit through the inlet to the Chukchi 

Sea. Vessels would consist of a shallow-water landing craft and oil spill response work boats. 

The vessel and aircraft traffic should have 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 currents that would lead to the filling in or the erosion 

of barrier islands. The drillship would be a floating, anchored vessel, located more than 60 statute mi 

offshore and would have no effect on waves or currents.

Vessel and aircraft traffic will follow predetermined traffic corridors that have been selected to 

minimize disturbance to marine mammals (including polar bears) and marine and coastal birds. The 
 

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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 either 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. Existing boat ramps will be 

utilized at marine shorebase facilities in Wainwright, 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 this will require no land development. 

IMPORTANT HABITAT 

Important habitats along the northeastern Chukchi 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 traffic corridor is more than five miles from the 

shoreline of Peard Bay. The proposed exploration drilling should have no adverse impacts on the 

special productivity of these habitats. 

Kasegaluk Lagoon has been identified as an area of importance to marine mammals, including beluga 

whales, and staging waterfowl such as the Pacific black brant. For example, as much as 50 percent of 

the North American population of brant has been found 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. The 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). MMS'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. Shell's prospects are located more than 58 mi from 
 

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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 proposed 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 exploration program should have no adverse impacts on 

the special productivity of these habitats. 

Polynya Zone

The polynya zone is an area of recurring spring leads 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 concentrated in these areas during their migrations, and are 

thought to be sensitive to disturbance based on the restricted 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 traffic corridors traverse the Polynya Zone, which lies 

between the prospects and shorebase locations. Aircraft and vessel traffic should have no effect on the 

habitat, but could disturb marine mammals and birds. Any such effects would be minimized by 

Shell's mitigation measures, which include minimum flight altitude of 1,500 ft for operational aircraft. 

The proposed and relatively infrequent vessel traffic 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 proposed exploration program should have little or no 

adverse impacts on the special productivity of these habitats. 

 

All of the above-discussed important habitats 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 mammals 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 adverse impacts on the special productivity of these 

important habitats.

 

(c) No response required. 

 

 
 

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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 protection of air, land, and water quality identified in 

AS 46.40.040(b) are incorporated into the program and, as administered by that department, constitute 

the exclusive components of the program 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 coastal 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 important to the study, understanding, or illustration of 

national, state, or local history or prehistory, 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 Policies 

 
 

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Evaluate each applicable district enforceable policy using a format similar to the one you 

completed above for the State Standards. District 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 policies, 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 consistent 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 determination, per 15 CFR 930, Subpart C, rather 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 federal authorization requests 

have been submitted to the appropriate agencies. 
 

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SECTION 16.0 ENVIRONMENTAL IMPACT ANALYSIS 

Refer to Appendix F for the Environmental Impact Analysis. 
 

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THIS PAGE 

INTENTIONALLY 

LEFT BLANK 
 

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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 OCS 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 maps (Sections 3.1.c, 3.2.c, and 3.3.c) 

o Prospect 2D and 3D seismic lines (Sections 3.1.d, 3.2.d, and 3.3.d) 

o Prospect 2D and 3D seismic lines – geologic cross 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 study reports, survey reports or other material used. 

ASRC Energy Services. 2009. Subsistence Advisor 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 ambient air quality monitoring program first quarter data 

report November 2008 through January 2009 final. Unpublished report prepared by AECOM, Inc., for 

ConocoPhillips Alaska, Inc., Anchorage, Alaska. 

Boudreau, B. 1989. Biological clearance for Burger and Crackerjack Prospects. U.S. Govt. 

Memorandum, from Regional Supervisor, Field Operations, 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 prepared by Canyon Creek Consulting LLC, Seattle WA 

for ConocoPhillips Alaska, Inc. and Shell Exploration & Production Company, Anchorage, Alaska, 46 

pp. 

Finney, H. 1989. Summary: Biological reconnaissance, Burger Prospect, Sale 109, Chukchi Sea, 

Alaska. Unpublished Report submitted by H. Finney, Fugro-McClelland Marine Geosciences, Inc., 

Houston, Texas to Shell Western 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 Clearance 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 abundance of seabirds in the northeastern Chukchi Sea, 

2008. Report prepared by ABR, Inc - Environmental Research & Services, Fairbanks, AK for 

ConocoPhillips Alaska, Inc. and Shell Exploration & 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, Chukchi Sea, Alaska. Prepared by Geoscience Earth & 

Marine Services, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX. 

Geoscience Earth & Marine Services, Inc. 2009b. Shallow Hazards and Archeological Assessment, 

Crackerjack C Drill Site Karo Block NR03-01 6864, Chukchi 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 Seismic Exploration by Shell Offshore Inc. in the Chukchi Sea, July–

November 2008: 90–day report. LGL Draft Rep. P1049–1. Rep. from LGL Alaska Research Associates, 

Inc., Anchorage, AK, LGL Ltd. Environmental Research Associates, King City, Ont., King City, Ont., 

and JASCO Research Ltd., Victoria, BC, for Shell Offshore Inc., Houston, TX, and Nat. Mar. Fish. 

Serv., Silver Spring, MD. 

NMFS. 2001. Small takes of marine mammals incidental 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 Future Offshore Oil and Gas Development: Beaufort 

Sea, Chukchi Sea, and North Aleutian Basin. Report prepared by Northern Economics, Anchorage 

Alaska for Shell Exploration and Production, Houston, TX. 

Sherwood, K.W., J.D. Craig, J. Scherr, P.O. Johnson, and L.W. Cooke. 2001. Undiscovered Oil and Gas 

Resources of the U.S. Arctic Alaska Outer Continental 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. Shell 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 Plan 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 Information 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 BLANK 
Permit No.: 

AKG280000 

ATTACHMENT 1

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 the 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 5
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 waste 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-water 
 Saltwater 

 Saturated Saltwater 

 Nondispersed 

(Viscosifier/Polymer) PH/PA 

Page 3 of 5
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 shoreline 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 temperature data from the receiving water surface to the depth of the discharge port or diffuser. 

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 (measured 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 aquaculture, Supply for industrial use, Contact recreation, 

Secondary recreation, Fish spawning, Harvesting and consumption of raw fish, or other aquatic life (Not needed if not 

requesting a mixing zone from ADEC): 

If possible, provide salinity and temperature data from the receiving water surface to the depth of the discharge port or diffuser. 

Page 4 of 5
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF AND CONTIGUOUS STATE WATERS 

Special Conditions (provide justification for all that are 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 person 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 ADEC at the following addresses:

US EPA 

1200 6th Avenue, M/S OWW-130 

Seattle, WA 98101 

ADEC, Water Division 

555 Cordova Street 

Anchorage, Alaska 99501 

Page 5 of 5

 
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"

"

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

175°W 170°W 165°W 160°W 155°W

73°N

72°N

72°N

71°N

71°N

70°N

70°N

69°N

69°N

68°N

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 20 40 80

Miles

Shell OCS Lease Block SHE LL

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

r


Types 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 well 

Permit No.: 

AKG280000 

ATTACHMENT 1

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 the 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 5
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 waste 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-water 
 Saltwater 

 Saturated Saltwater 

 Nondispersed 

(Viscosifier/Polymer) PH/PA 

Page 3 of 5
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 shoreline 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 temperature data from the receiving water surface to the depth of the discharge port or diffuser. 

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 (measured 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 aquaculture, Supply for industrial use, Contact recreation, 

Secondary recreation, Fish spawning, Harvesting and consumption of raw fish, or other aquatic life (Not needed if not 

requesting a mixing zone from ADEC): 

If possible, provide salinity and temperature data from the receiving water surface to the depth of the discharge port or diffuser. 

Page 4 of 5
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF AND CONTIGUOUS STATE WATERS 

Special Conditions (provide justification for all that are 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 person 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 ADEC at the following addresses:

US EPA 

1200 6th 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

175°W 170°W 165°W 160°W 155°W

73°N

72°N

72°N

71°N

71°N

70°N

70°N

69°N

69°N

68°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 20 40 80

Miles

Shell OCS Lease Block SHE LL

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

r


Types 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 well 

Permit No.: 

AKG280000 

ATTACHMENT 1

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 the 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 5
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 waste 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-water 
 Saltwater 

 Saturated Saltwater 

 Nondispersed 

(Viscosifier/Polymer) PH/PA 

Page 3 of 5
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 shoreline 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 temperature data from the receiving water surface to the depth of the discharge port or diffuser. 

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 (measured 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 aquaculture, Supply for industrial use, Contact recreation, 

Secondary recreation, Fish spawning, Harvesting and consumption of raw fish, or other aquatic life (Not needed if not 

requesting a mixing zone from ADEC): 

If possible, provide salinity and temperature data from the receiving water surface to the depth of the discharge port or diffuser. 

Page 4 of 5
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF AND CONTIGUOUS STATE WATERS 

Special Conditions (provide justification for all that are 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 person 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 ADEC at the following addresses:

US EPA 

1200 6th 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

175°W 170°W 165°W 160°W 155°W

73°N

72°N

72°N

71°N

71°N

70°N

70°N

69°N

69°N

68°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 20 40 80

Miles

Shell OCS Lease Block SHE LL

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

r


Types 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 well 

Permit No.: 

AKG280000 

ATTACHMENT 1

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 the 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 5
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 waste 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-water 
 Saltwater 

 Saturated Saltwater 

 Nondispersed 

(Viscosifier/Polymer) PH/PA 

Page 3 of 5
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 shoreline 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 temperature data from the receiving water surface to the depth of the discharge port or diffuser. 

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 (measured 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 aquaculture, Supply for industrial use, Contact recreation, 

Secondary recreation, Fish spawning, Harvesting and consumption of raw fish, or other aquatic life (Not needed if not 

requesting a mixing zone from ADEC): 

If possible, provide salinity and temperature data from the receiving water surface to the depth of the discharge port or diffuser. 

Page 4 of 5
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF AND CONTIGUOUS STATE WATERS 

Special Conditions (provide justification for all that are 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 person 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 ADEC at the following addresses:

US EPA 

1200 6th 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

175°W 170°W 165°W 160°W 155°W

73°N

72°N

72°N

71°N

71°N

70°N

70°N

69°N

69°N

68°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 20 40 80

Miles

Shell OCS Lease Block SHE LL

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

r


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/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 well

Permit No.: 

AKG280000 

ATTACHMENT 1

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 the 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 5 
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 waste 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-water 
 Saltwater 

 Saturated Saltwater 

 Nondispersed 

(Viscosifier/Polymer) PH/PA 

Page 3 of 5 
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF 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 shoreline 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 temperature data from the receiving water surface to the depth of the discharge port or diffuser. 

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 (measured 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 aquaculture, Supply for industrial use, Contact recreation, 

Secondary recreation, Fish spawning, Harvesting and consumption of raw fish, or other aquatic life (Not needed if not 

requesting a mixing zone from ADEC): 

If possible, provide salinity and temperature data from the receiving water surface to the depth of the discharge port or diffuser. 

Page 4 of 5 
Attachment 1: NOI Information Sheet Permit No.: 

AKG280000 

NOTICE OF INTENT (NOI) INFORMATION SHEET 

NPDES GENERAL PERMIT AKG280000 

OIL AND GAS EXPLORATION FACILITIES 

ON THE OUTER CONTINENTAL SHELF AND CONTIGUOUS STATE WATERS 

Special Conditions (provide justification for all that are 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 person 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 ADEC at the following addresses:

US EPA 

1200 6th Avenue, M/S OWW-130 

Seattle, WA 98101 

ADEC, Water Division 

555 Cordova Street 

Anchorage, Alaska 99501 

Page 5 of 5 

 
"

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"

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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

175°W 170°W 165°W 160°W 155°W

73°N

72°N

72°N

71°N

71°N

70°N

70°N

69°N

69°N

68°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 20 40 80

Miles

Shell OCS Lease Block SHE LL

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

r


Projected 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