f 

PUBLIC INFORMATION 

Revised Outer Continental Shelf Lease 

Exploration Plan 

Camden Bay, Beaufort Sea, Alaska 

Flaxman Island Blocks 6559, 6610 & 6658 

Beaufort Sea Lease Sales 195 & 202 

May 2011 

Submitted to: 

U.S. Department of the Interior 

Bureau of Ocean Energy Management, Regulation and Enforcement 

Alaska OCS Region 

Prepared by: 

Shell Offshore Inc.

3601 C Street, Suite 1000 

Anchorage, AK 99503 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. i May 2011

TABLE OF CONTENTS

SECTION 1.0 PLAN CONTENTS.......................................................................................1-1

 Introduction .................................................................................................................. 1-1

 a) Description, Objectives and Schedule for the Exploration Drilling Program ....... 1-2

 b) Location ............................................................................................................ 1-4

 c) Drilling Vessels ............................................................................................... 1-15

 d) Service Fee .................................................................................................... 1-23

SECTION 2.0 GENERAL INFORMATION ..........................................................................2-1

 a) Applications and Permits .................................................................................. 2-1

 b) Drilling Fluids .................................................................................................... 2-2

 c) Chemical Products ............................................................................................ 2-4

 d) New or Unusual Technology ............................................................................. 2-4

 e) Bonds, Oil Spill Financial Responsibility and Well Control Statements .............. 2-4

 f) Suspension of Operations ................................................................................. 2-4

 g) Blowout Scenario .............................................................................................. 2-5

 h) Contact Information .......................................................................................... 2-6

SECTION 3.0 GEOLOGICAL AND GEOPHYSICAL INFORMATION (PROPRIETARY 

AND CONFIDENTIAL) .............................................................................................................3-1

SECTION 4.0 HYDROGEN SULFIDE ................................................................................4-1

 a) Concentration ................................................................................................... 4-1

 b) Classification .................................................................................................... 4-1

 c) Contingency Plan .............................................................................................. 4-1

 d) Modeling Report ............................................................................................... 4-1

SECTION 5.0 BIOLOGICAL, PHYSICAL, AND SOCIOECONOMIC INFORMATION.........5-1

 a) Biological Environment Reports ........................................................................ 5-1

 b) Physical Environment Reports .......................................................................... 5-3

 c) Socioeconomic Study Reports .......................................................................... 5-5

SECTION 6.0 SOLID & LIQUID WASTE AND DISCHARGE INFORMATION ....................6-1

 a) Projected Wastes and Projected Ocean Discharges ......................................... 6-1

 b) National Pollutant Discharge Elimination System Authorization to Discharge . 6-15

 c) Modeling Report ............................................................................................. 6-15

 d) Projected Cooling Water Intake ...................................................................... 6-21

SECTION 7.0 AIR EMISSIONS INFORMATION ................................................................7-1

 a) Projected Emissions ......................................................................................... 7-1

 b) Emissions Reduction Measures ...................................................................... 7-16

 c) Processes, Equipment, Fuels, and Combustibles ........................................... 7-17

 d) Distance to Shore ........................................................................................... 7-17

 e) Non-exempt Drilling Vessels ........................................................................... 7-17

 f) Modeling Report ............................................................................................. 7-18

SECTION 8.0 OIL SPILL RESPONSE PLANNING ............................................................8-1

 a) Oil Spill Response Planning .............................................................................. 8-1

 b) Location of Primary Oil Spill Equipment Base and Staging Area ....................... 8-1
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. ii May 2011

 c) Name(s) of Spill Removal Organization(s) for Both Equipment and Personnel . 8-2

 d) Volume of Worst Case Discharge Scenario [30 CFR 254.26(a)] ....................... 8-2

 e) Modeling Report ............................................................................................... 8-3

SECTION 9.0 ALASKA PLANNING INFORMATION ..........................................................9-1

 a) Oil Discharge Prevention and Contingency Plan ............................................... 9-1

 b) Well Control Plan .............................................................................................. 9-1

 c) Critical Operations and Curtailment Plan and Ice Management Plan ................ 9-2

 d) Fuel Transfer Plan ............................................................................................ 9-2

 e) Partial Well Scenario ........................................................................................ 9-2

 f) Surface Intervention – Capping Stack and Containment System ...................... 9-4

SECTION 10.0 ENVIRONMENTAL MONITORING INFORMATION .................................. 10-1

 a) Monitoring Systems ........................................................................................ 10-1

 b) Incidental Takes.............................................................................................. 10-3

SECTION 11.0 LEASE STIPULATIONS INFORMATION ................................................... 11-1

SECTION 12.0 ENVIRONMENTAL MITIGATION MEASURE INFORMATION .................. 12-1

 a) Proposed Measures ........................................................................................ 12-1

 b) Protected Species ........................................................................................... 12-5

SECTION 13.0 SUPPORT VESSELS AND AIRCRAFT INFORMATION ........................... 13-1

 a) General ........................................................................................................... 13-1

 b) Air Emissions .................................................................................................. 13-6

 c) Drilling Fluids and Chemical Products Transportation ..................................... 13-8

 d) Solid and Liquid Wastes Transportation .......................................................... 13-8

 e) Vicinity Map and Travel Routes .................................................................... 13-10

SECTION 14.0 SHOREBASE FACILITIES INFORMATION ............................................... 14-1

 a) General ........................................................................................................... 14-1

 b) Air Emissions .................................................................................................. 14-1

 c) Unusual Solid and Liquid Wastes ................................................................... 14-1

 d) Waste Disposal ............................................................................................... 14-1

SECTION 15.0 COASTAL ZONE MANAGEMENT ACT INFORMATION ........................... 15-1

 a) Consistency Certification ................................................................................ 15-1

 b) Other Information .......................................................................................... 15-38

SECTION 16.0 ENVIRONMENTAL IMPACT ANALYSIS ................................................... 16-1

SECTION 17.0 ADMINISTRATIVE INFORMATION ........................................................... 17-1

 a) Description of Exempted Information (Public Information Copies Only) .......... 17-1

 b) Bibliography .................................................................................................... 17-1

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. iii May 2011

Figures 

Figure 1.a-1 Planned EP Drilling Program Area (see also Figure 1.a-2 where 4 drills 

sites on 3 OCS blocks are shown) ................................................................. 1-5

Figure 1.a-2 Location of the Sivulliq and Torpedo Prospects and Respective Drill 

Sites .............................................................................................................. 1-6

Figure 1.a-3 Bathymetry and Planned Kulluk Anchor Locations – Sivulliq G ...................... 1-7

Figure 1.a-4 Bathymetry and Planned Kulluk Anchor Locations – Sivulliq N ...................... 1-8

Figure 1.a-5 Bathymetry and Planned Kulluk Anchor Locations – Torpedo H .................... 1-9

Figure 1.a-6 Bathymetry and Planned Kulluk Anchor Locations – Torpedo J ................... 1-10

Figure 1.a-7 Bathymetry and Planned Discoverer Anchor Locations – Sivulliq G ............. 1-11

Figure 1.a-8 Bathymetry and Planned Discoverer Anchor Locations – Sivulliq N ............. 1-12

Figure 1.a-9 Bathymetry and Planned Discoverer Anchor Locations – Torpedo H ........... 1-13

Figure 1.a-10 Bathymetry and Planned Discoverer Anchor Locations – Torpedo J ............ 1-14

Figure 5.c-1 Estimated Incremental Employment in Alaska and the Remainder of the 

United States from OCS Development in the Beaufort Sea (NEI and 

ISER 2011) .................................................................................................... 5-8

Figure 6a-1 Kulluk Disposal Caisson Location ................................................................ 6-14

Figure 6.c-1 Vertical Profiles of Temperature and Salinity Near the Sivulliq Prospect ...... 6-16

Figure 6.c-2 Vertical Profiles of Temperature and Salinity Near the Torpedo Prospect .... 6-17

Figure 6.c-3 Cooling Water Plume from the 36-in. Disposal Caisson on the Kulluk .......... 6-18

Figure 6.c-4 Cooling Water Plume From Each 6-in. Outfall on the Discoverer ................. 6-19

Figure 6.c-5 Cooling Water Plume From Each 2-in. Outfall on the Discoverer ................. 6-20

Figure 6.c-6 Cuttings Plume From Either Drilling Vessel .................................................. 6-21

Figure 13.a-1 Ice Management Vessels Configuration for the Kulluk or Discoverer ........... 13-2

Figure 13.e-1 Fleet Travel Route ..................................................................................... 13-11

Figure 13.e-2 Drilling Support Vessel and Aircraft Travel Routes ..................................... 13-12

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. iv May 2011

Tables

Table 1 Comparison of Shell’s Initial Camden Bay EP and the Revised Camden 

Bay EP ............................................................................................................. 1-1

Table 1.a-1 Camden Bay Drill Sites ..................................................................................... 1-2

Table 1.a-2 Planned Support Vessels for the Kulluk or Discoverer ...................................... 1-3

Table 1.c-1 Kulluk Specifications ....................................................................................... 1-16

Table 1.c-2 Discoverer Specifications ................................................................................ 1-21

Table 2.a-1 Permit and Authorization Applications ............................................................... 2-1

Table 2.b-1 List of WBM Products ....................................................................................... 2-3

Table 2.g-1 Calculated Worst Case Discharge (WCD) for the Camden Bay EP 

Potential Wells .................................................................................................. 2-5

Table 2.g-2 Relief Well Drilling Information .......................................................................... 2-6

Table 6.a-1 Projected Wastes Generated and Ocean Discharges for Sivulliq Location 

G ...................................................................................................................... 6-3

Table 6.a-2 Projected Wastes Generated and Ocean Discharges for Sivulliq Location 

N ....................................................................................................................... 6-5

Table 6.a-3 Projected Wastes Generated and Ocean Discharges for Torpedo 

Location H ........................................................................................................ 6-7

Table 6.a-4 Projected Wastes Generated and Ocean Discharges for Torpedo 

Location J ......................................................................................................... 6-9

Table 6.a-5 Drilling Fluid Components and Load Out List .................................................. 6-11

Table 6.d-1 Seawater Intake Mesh sizes on the Kulluk ...................................................... 6-22

Table 6.d-2 Seawater Intake Mesh Sizes on the Discoverer .............................................. 6-22

Table 7.a-1 Source Size, Rating and Fuel Usage ................................................................ 7-3

Table 7.a-2 Projected Hourly Emissions From the Kulluk (Individual Source) and 

Support Vessels (Source Groups) .................................................................... 7-6

Table 7.a-3 Vessel Source Group Annual Maximum Emissions in Tons/Year ..................... 7-6

Table 7.a-4 Owner Requested Limits in the Kulluk Minor Source Air Permit 

Application ........................................................................................................ 7-7

Table 7.a-5 Frequency and Duration of Emission Source Groups - Kulluk ........................... 7-7

Table 7.a-6 Description of Discoverer Drilling Vessel Emission Units and Associated 

Fleet ................................................................................................................. 7-9

Table 7.a-7 Projected Peak Hourly Emissions of Discoverer Drilling Vessel Emission 

Units and Associated Fleet ............................................................................. 7-13

Table 7.a-8 Annual Potentials to Emit for the Discoverer Emission Units and 

Associated Fleet ............................................................................................. 7-14

Table 7.a-9 Owner-Requested Restrictions and Permit Conditions from Shell’s PSD 

Air Quality Permit for the Discoverer in Camden Bay ...................................... 7-14

Table 7.a-10 Frequency and Duration of Emission Source Groups - Discoverer.................. 7-15

Table 7.e-1 BOEMRE Exemption Results .......................................................................... 7-18

Table 7.f-1 Summary of Maximum Estimated Concentrations ........................................... 7-19

Table 7.f-2 Summary of Maximum Impacts at the Nearest Villages on the Beaufort 

Sea Coast ....................................................................................................... 7-20

Table 7.f-3 Summary of Impacts on Air Quality ................................................................. 7-22

Table 7.f-4 Summary of Maximum Modeled Impacts – Beaufort Sea ................................ 7-23

Table 8.d-1 Oil Volume of a Worst Case Discharge Planning Scenario for the Beaufort 

Sea Regional ODPCP....................................................................................... 8-2

Table 8.d-2 Comparison of the WCD Planning Scenario Developed for the Beaufort 

Sea Regional ODPCP with the WCD Calculated for the revised Camden 

Bay EP for Three Relief Well Scenarios ............................................................ 8-3
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. v May 2011

Table 10.a-1 Kulluk Monitoring Equipment .......................................................................... 10-1

Table 10.a-2 Discoverer Monitoring Equipment ................................................................... 10-1

Table 10.b-1 Sound Propagation Modeling Results of Drilling and ZVSP Activities Near 

Camden Bay in the Beaufort Sea .................................................................... 10-4

Table 10.b-2 Estimates of the Numbers of Beluga and Bowhead Whales in Areas 

Where Maximum Received Sound Levels in the Water Would Be ≥120 dB .... 10-4

Table 10.b-3 Estimates of the Numbers of Beluga and Bowhead Whales in Areas 

Where Maximum Received Sound Levels in the Water Would Be ≥120 dB .... 10-5

Table 10.b-4 Estimates of the Numbers of Beluga and Bowhead Whales in Areas 

Where Maximum Received Sound Levels in the Water Would Be ≥160 dB 

from ZVSP Activities ....................................................................................... 10-5

Table 10.b-5 Estimates of the Numbers of Marine Mammals (Excluding Beluga and 

Bowhead Whales, Which are Shown in Table 10.b-2) in Each Offshore 

area where maximum received sound levels in the water would be ≥120 

dB ................................................................................................................... 10-6

Table 10.b-6 Estimates of the Numbers of Marine Mammals (Excluding Beluga and 

Bowhead Whales, Which are Shown in Table 10.b-3) in Each Offshore 

area where maximum received sound levels in the water would be ≥120 

dB ................................................................................................................... 10-6

Table 10.b-7 Estimates of the Numbers of Marine Mammals (Excluding Beluga and 

Bowhead Whales, Which are Shown in Table 10.b-4) in Each Offshore 

area where maximum received sound levels in the water would be ≥160 

dB ................................................................................................................... 10-7

Table 11-1 POC Meeting Dates and Locations and Attendees ......................................... 11-8

Table 12.b-1 Species Found in the Beaufort Sea and Protected Under the ESA ................. 12-5

Table 12.b-2 Marine Mammals Found in the Beaufort Sea and Protected Under the 

MMPA ............................................................................................................. 12-5

Table 13.a-1 Specifications of Support Vessels (Not Including OSR Vessels) ..................... 13-1

Table 13.a-2 Specifications of the Major Oil Spill Response Vessels ................................... 13-5

Table 13.a-3 Aircraft Flights and Frequency ........................................................................ 13-6

Table 13.b-1 Kulluk Support Vessel Source Group Annual Maximum Emissions in 

Tons/Year ....................................................................................................... 13-7

Table 13.b-2 Discoverer Support Vessel Source Group Annual Maximum Emissions in 

Tons/Year ....................................................................................................... 13-7

Table 13.d-1 Anticipated Wastes Generated During Drilling to be Transported From 

Area ................................................................................................................ 13-8

Table 14.d-1 Wastes and Volumes Generated During the Drilling Program ......................... 14-1

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. vi May 2011

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 Plan of Cooperation Addendum 

Appendix I Bird Strike Avoidance and Lighting Plan Camden Bay, Alaska 

Appendix J Critical Operations and Curtailment Plan 

Appendix K Ice Management Plan 

Appendix L Well Control Plan 

Appendix M Fuel Transfer Plan 

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. vii May 2011

ACRONYMS & ABBREVIATIONS 

° degree(s) 

°C degrees Celsius 

°F degrees Fahrenheit 

‘ minute(s) 

“ second(s) 

# number 

2D two-dimensional 

3D three-dimensional 

4MP marine mammal monitoring and mitigation plan 

AAC Alaska Administrative Code 

AAAQS Alaska Ambient Air Quality Standards 

ac-ft acres foot (feet) 

ACS Alaska Clean Seas 

ACMP Alaska Costal Management Program 

ADEC Alaska Department of Environmental Conservation 

ADNR State of Alaska, Department of Natural Resources 

APD Application for Permit to Drill 

API American Petroleum Institute 

ASRC Arctic Slope Regional Corporation 

BACT best available control technology 

bbl barrel(s) 

BHP bottom hole pressure 

BOEMRE Bureau of Ocean Energy Management, Regulation and Enforcement 

BOP blowout preventer 

bopd barrels of oil per day 

CDU conical drilling unit 

CFR Code of Federal Regulations 

C/L cementing and logging activity 

CLO Community Liaison Officer 

cm centimeter(s) 

cm/sec centimeters per second 

CO carbon monoxide 

COCP Critical Operations and Curtailment Plan 

Com Centers Communications and Call Centers 

Cp centipoise 

C-Plan Oil Discharge Prevention and Contingency Plan 

DCOM Division of Coastal and Ocean Management 

dB decibels 

Discoverer M/V Noble Discoverer 

DNV Det Norske Veritas 

DP dynamic positioning 

ea each 

EAB Environmental Appeals Board 

EP Exploration Plan 

EPA US Environmental Protection Agency 

ESA Endangered Species Act 

ESE east-southeast 

FBHP 1 Flowing pressure at the uppermost producing interval 

FBHP 2 Flowing pressure at the 9-5

/8” casing shoe 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. viii May 2011

FWHP Flowing pressure at the top of the BOP stack (8 ft 2-in. below mudline) 

FEIS Final Environmental Impact Statement 

FI Flaxman Island 

ft feet (foot) 

FTP Fuel Transfer Plan 

gal gallon(s) 

gal/min gallons per minute 

g/kW-hr grams per kilowatt-hour 

GP General Permit 

H2S hydrogen sulfide 

HAP hazardous air pollutants 

hp horsepower 

HPU hydraulic power units 

hr(s) hour(s) 

HSSE Health, Safety, Security and Environment 

IHA Incidental Harassment Authorization 

IMP Ice Management Plan 

in. inch(es) 

kg kilogram(s) 

km kilometer(s) 

kro relative permeability to oil 

kVA 1000 volt-ampere 

Kulluk conical drilling unit Kulluk

kW kilowatt(s) 

kWe kilowatt(s) equivalents 

lb pound(s) 

LBP length between perpendiculars 

lighting plan Bird Strike Avoidance and Lighting Plan 

LMRP lower marine riser package 

LOA Letter of Authorization 

m meter(s) 

m2 square meters 

m3 cubic meters 

MAWP maximum anticipated wellhead pressure 

max maximum 

mD millidarcies 

mi mile(s) 

min minute 

MLC mudline cellar 

MLT measured length thickness 

mm millimeter(s) 

MMPA Marine Mammal Protection Act 

MMOs marine mammal observers 

MMS Minerals Management Service 

MODU mobile offshore drilling unit 

mph miles per hour 

ms milliseconds 

MSD Marine Sanitation Device 

mt metric tons 

Mud Plan Drilling/Completion Fluids Proposal 

M/V Motor Vessel 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. ix May 2011

N North 

NAAQS National Ambient Air Quality Standards 

N/A Not Applicable 

NaCl sodium chloride 

NAD North American Datum 1983 

NEI Northern Economics Inc. 

NMFS National Marine Fisheries Service 

NOI Notice of Intent 

NOx nitrogen oxide(s) 

NPDES National Pollution Discharge Elimination System 

NSB North Slope Borough 

NSR/PSD new source review Prevention of Significant Deterioration 

NTL Notice to Lessee 

OCS Outer Continental Shelf 

ODPCP Oil Discharge Prevention and Contingency Plan 

OS offshore 

OSR oil spill response 

OSRA Oil-Spill-Risk Analysis 

OSRB oil spill response barge 

OSRP oil spill response plan 

OST oil spill tanker 

OSV offshore supply vessel 

pH para-hydronium ion concentration 

PM2.5 particulate matter less than 2.5 microns 

PM10 particulate matter less than 10 microns 

POC Plan of Cooperation 

ppg pounds per gallon 

ppm parts per million 

ppt parts per thousand 

PSD Prevention of Significant Deterioration 

psi pounds per square inch 

PSIA pounds per square inch 

psig pounds per square inch (gauge) 

PTE potentials to emit 

PTVD proposed total vertical depth 

RB reservoir barrels 

ROV remotely operated vehicle 

rpm revolutions per minute 

RS/FO Regional Supervisor, Field Operations 

SA Subsistence Advisor 

SCF standard cubic feet 

SCR selective catalytic reduction 

sec second 

Shell Shell Offshore Inc. 

SIWAC Shell Ice and Weather Advisory Center 

SO2 sulfur dioxide 

SS subsea 

STB stock tank barrel 

swi water saturation, initial 

TA temporarily abandon 

TBD To be determined 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. x May 2011

TDS Treatment/Disposal Site 

TSS total suspended solids 

TVD true vertical depth 

TVT true vertical thickness 

U.S. United States 

USACE U.S. Army Corps of Engineers 

USCG U.S. Coast Guard 

USFWS U.S. Fish and Wildlife Service 

VGP Vessel General Permit for Discharges Incidental to the Normal Operation of Vessels and 

Version Nov. 2010 

W West 

WBM water based drilling mud 

WCD worst case discharge 

WCP Well Control Plan 

WNW west-northwest 

VOC volatile organic compound(s) 

VOSS Vessel of Opportunity Skimming System 

VSP Vertical Seismic Profile 

YBP years before present 

ZVSP zero-offset vertical seismic profile 

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. xi May 2011

CROSS-REFERENCE TO RELEVANT REGULATIONS

Regulation 

Section 

Regulatory Information EP Section 

Minerals Management Service 

30 CFR 250.211 What must the EP include Section 1.0, Appendices A, J & K 

(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) 

 OCS Form-137 Information Appendix A 

30 CFR 250.212 What information must accompany the EP Section 2.0 through 17.0 & 

Appendices A through M 

(a) General information required by 250.213 Section 2.0, Appendices B, G, E, J, 

K, & L

(b) Geological and geophysical information required by 250.214 Section 3.0

(c) Hydrogen sulfide information required by 250.215 Section 4.0 

(d) Biological, physical, and socioeconomic information required by 

250.216 

Section 5.0, Appendices F, & H

(e) Solid and liquid wastes and discharges information and cooling water 

intake information required by 250.217 

Section 6.0, Appendices B, & F

(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 – C-Plan Information is 

submitted under separate cover 

(h) Alaska planning information required by 250.220 Section 9.0, Appendices J, K, L, & 

M

(i) Environmental monitoring information required by 250.221 Section 10.0, Appendices C, D, E, F, 

& I

(j) Lease stipulations information required by 250.222 Section 11.0, Appendices C, D, E, F, 

H, I, & M

(k) Mitigation measures information required by 250.223 Section 12.0, Appendices C, D, E, I, 

J, & K

(l) Support vessel and aircraft information required by 250.224 Section 13.0 

(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 & Appendix A

30 CFR 250.213 General information Section 2.0 

(a) Applications and permits Section 2.0 a) 

(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) 

(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) 

(f) Suspensions of operations Section 2.0 f) & Section 9.0 

(g) Blowout scenario Section 2.0 g) 

(h) Contact Section 2.0 h) 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. xii May 2011

Regulation 

Section 

Regulatory Information EP Section 

30 CFR 250.214 Geological and geophysical information required by 250.214 Section 3.0 

(a) Geological description Section 3.1 a) Sivulliq; Section 3.2 a) 

Torpedo; & Section 3.3 a) 

(b) Structure contour maps Section 3.1 b) & 3.2 b) 

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

(d) Geological cross-sections Section 3.1 d) & 3.2 d) 

(e) Shallow hazards information Section 3.1 e) & 3.2 e) 

(f) Stratigraphic column & time/depth charts Section 3.1 f) & 3.2 f) 

(g) Geochemical information Section 3.1 g) & 3.2 g) 

(h) Future G&G activities Section 3.1 h) & 3.2 h) 

30 CFR 250.215 Hydrogen sulfide information Section 4.0 

(a) Concentration Section 4.0 a) 

(b) Classification Section 4.0 b) 

(c) Contingency plan Section 4.0 c) 

(d) Modeling report Section 4.0 d) 

(d)(1) Site specific and area analysis Section 4.0 d) 

(d)(2) H2S emissions Section 4.0 d) 

30 CFR 250.216 Biological, physical, and socioeconomic information Section 5.0, Appendices F & H 

(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 & F 

(a) Projected wastes Section 6.0 a) 

(a)(1) Method used to determine this information Section 6.0 a) 

(a)(2) Plans for treating, storing and downhole disposal of wastes Section 6.0 a) 

(b) Projected ocean discharges Section 6.0 b) 

(b)(1) Table of waste name, projected amounts, rate of discharge Section 6.0 b) 

(b)(2) Description of discharge method Section 6.0 b) 

(c) NPDES permit Section 6.0 c) 

(c)(1) Compliance discussion Section 6.0 c) 

(c)(2) Copy of the application Appendix B 

(d) Modeling report Section 6.0 d) 

(e) Projected cooling water intake Section 6.0 e) 

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: Section 7.0 a) 

(a)(1)(i) Projected peak hourly emissions Section 7.0 a) 

(a)(1)(ii) Total annual emissions in tons per year Section 7.0 a) 

(a)(1)(iii) Emissions over the duration of the EP Section 7.0 a) 

(a)(1)(iv) Frequency and duration of emissions Section 7.0 a) 

(a)(1)(v) Total of all emissions listed in (a)(1)(i) through (iv) Section 7.0 a) 

(a)(2) Basis for emission calculations Section 7.0 a) 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. xiii May 2011

Regulation 

Section 

Regulatory Information EP Section 

(a)(3) Base projected emissions on maximum rated capacity of the equipment Section 7.0 a) 

(a)(4) Specific drill unit emissions Section 7.0 a) 

(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 – C-Plan Information is 

submitted under separate cover 

(a) Oil spill response planning Section 8.0 a) 

(a)(1) Oil spill response plan Section 8.0 a) 

(a)(2) OSRP to include: Section 8.0 a) 

(a)(2)(i) Discussion of regional OSRP Section 8.0 a) 

(a)(2)(ii) Location of primary oil spill equipment base and staging area Section 8.0 a) 

(a)(2)(iii) Name(s) of oil spill removal organizations for both equipment and 

personnel 

Section 8.0 a) 

(a)(2)(iv) Calculated volume of the worst case discharge Section 8.0 a) 

(a)(2)(v) Description of the worst case scenario discharge Section 8.0 a) 

(b) Modeling report Section 8.0 b) 

30 CFR 250.220 Alaska planning information Section 9.0, Appendices J, K, L, & 

M 

(a) Emergency plans Section 9.0 a) 

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

30 CFR 250.221 Environmental monitoring information Section 10.0, Appendices C, D, E, F, 

& I 

(a) Monitoring systems Section 10.0 a) 

(b) Incidental takes Section 10.0 b) 

(b)(1) Threatened and endangered species list under the ESA Section 10.0 b) 

(b)(2) Marine mammals Section 10.0 b) 

(c) Flower Garden Banks National Marine Sanctuary not applicable 

30 CFR 250.222 Lease stipulations information Section 11.0, Appendices C, D, E, F, 

H, I & M 

 Stipulation No. 1 Section 11.0 

 Stipulation No. 2 Section 11.0 

 Stipulation No. 3 Section 11.0 

 Stipulation No. 4 Section 11.0 

 Stipulation No. 5 Section 11.0 

 Stipulation No. 6 Section 11.0 

 Stipulation No. 7 Section 11.0 

31 CFR 250.223 Mitigation measures information Section 12.0, Appendices C, D, E, I, 

J & K 

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

(b) Mitigation measures to avoid or minimize incidental takes off: Section 12.0 b) 

(b)(1) Threatened and endangered species list under the ESA Section 12.0 b) 

(b)(2) Marine mammals Section 12.0 b) 

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) 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. xiv May 2011

Regulation 

Section 

Regulatory Information EP Section 

(c) Drilling fluids and chemical products transportation Section 13.0 c) 

(d) Solid and liquid wastes transportation Section 13.0 d) and e) 

(e) Vicinity map Section 13.0 f) 

31 CFR 250.225 Shorebase 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 Gulf of Mexico Section 14.0 a) 

(b) Air emissions Section 14.0 b) 

(c) Unusual solid and liquid wastes Section 14.0 c) 

(d) Waste disposal Section 14.0 d) 

31 CFR 250.226 Coastal zone management information Section 15.0 

(a) Consistency certification Section 15.0 a) 

(b) Other information Section 15.0 b) 

31 CFR 250.227 Environmental impact analysis information Section 16, Appendix F 

(a) General requirements 

(a)(1) Assess the potential environmental impacts 

(a)(2) Be project specific 

(a)(3) Be as detailed as necessary 

(b) Resources, conditions and activities 

(b)(1) Meteorology, oceanography, geology, and shallow hazards 

(b)(2) Air and water quality 

(b)(3) Benthic communities, marine mammals, sea turtles, coastal and marine 

birds, fish and shellfish, and plant life 

 

(b)(4) Threatened and endangered species and their critical habitat 

(b)(5) Sensitive biological resources or habitats 

(b)(6) Archaeological resources 

(b)(7) Socioeconomic resources 

(b)(8) Other coastal and marine uses 

(b)(9) Other resources, conditions, and activities identified by the Regional 

Supervisor 

 

(c) Environmental impacts 

(c)(1) Analyze the potential direct and indirect impacts 

(c)(2) Analyze and potential cumulative impacts 

(c)(3) Describe the potential impacts and their consequences and 

implications 

 

(c)(4) Describe potential mitigation measures 

(c)(5) Summarize information incorporated by reference 

(d) Consultation 

(e) References cited 

31 CFR 250.228 Administrative information Section 17.0 & Appendix A 

(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 

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. xv May 2011

Regulation 

Section 

Regulatory Information EP Section 

U.S. Environmental Protection Agency – NPDES 

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

 

National Marine Fisheries Service 

50 CFR 216.104 Submission of requests Section 10.0 b) 

50 CFR 216.107 Incidental harassment authorization for Arctic waters Section 10.0 b) & Appendix C 

 

U.S. Fish and Wildlife Service 

50 CFR 18.124 How do I obtain a Letter of Authorization Section 10.0 b) & Appendix E 

 

U.S. Army Corps of Engineers 

33 CFR 325.1 Applications for permits Appendix G 

 

State of Alaska 

ACMP Oil spill response planning Submitted under separate cover 

Coastal zone management act information Section 15.0 

 

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. xvi May 2011

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INTENTIONALLY 

LEFT BLANK 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-1 May 2011

SECTION 1.0 PLAN CONTENTS 

Introduction 

Shell Offshore Inc. (Shell) submitted its initial Outer Continental Shelf (OCS) Camden Bay Exploration 

Drilling Plan (Camden Bay EP) to the Minerals Management Service (MMS) (now the Bureau of Ocean 

Energy Management, Regulation and Enforcement and hereinafter collectively referred to as 

“BOEMRE”) in May 2009. BOEMRE conditionally approved the Camden Bay EP on October 16, 2009 

following a BOEMRE Environmental Assessment (EA) and Finding of No Significant Impact (FONSI). 

The initial Camden Bay EP contemplated a single season of operations using the Motor Vessel (M/V) 

Noble Discoverer (Discoverer) to drill exploration wells at two drill sites: one at the Sivulliq prospect 

(Sivulliq N – Flaxman Island Lease Block 6558) and one at the Torpedo prospect (Torpedo H – Flaxman 

Island Lease Block 6610). Shell planned to initiate exploration drilling activities under the Camden Bay 

EP in the summer of 2010, but the exploration drilling activities were postponed when BOEMRE 

suspended all exploration drilling activities in the Arctic following the Deepwater Horizon incident in the 

Gulf of Mexico. 

On October 5, 2010, Shell submitted an update to the Camden Bay EP, along with information in 

response to Notice to Lessee (NTL) NTL No. 2010-N06, and an Application for Permit to Drill (APD) for 

the Sivulliq N drill site. Shell submitted that update in anticipation of proceeding with exploration 

drilling activities in the summer of 2011. However, continued permitting delays required Shell to 

postpone its planned exploration drilling activities once again. 

Pursuant to this revised Camden Bay EP, Shell plans to drill four wells on three OCS lease blocks in the 

Camden Bay area of the Beaufort Sea (Figure 1a-1) beginning in the summer of 2012. Two of the four 

wells in this exploration plan (Sivulliq N and Torpedo H) were included in Shell’s initial Camden Bay 

EP, and were specifically reviewed in BOEMRE’s October 2009 EA and FONSI. This plan revision 

includes two additional wells, one each at the same prospects; addresses Shell’s agreement with the local 

communities to collect selected waste streams that, under the initial Camden Bay EP, otherwise would 

have been discharged pursuant to the current NPDES general discharge permit; and notes the possibility 

that Shell might ultimately decide to substitute the Discoverer for the conical drilling unit (CDU) Kulluk 

(Kulluk) to drill the wells contemplated by the Camden Bay EP. Additional plan revisions are noted in 

Table 1. 

Table 1 Comparison of Shell’s Initial Camden Bay EP and the Revised Camden Bay EP 

Parameter Initial Camden Bay EP (2010) Revised Camden Bay EP 

(2012 planned start) 

Drilling seasons July 10-October 31, 2010. July 10- October 31 starting in 2012 and each 

subsequent season through the end of the 

program. 

OCS Lease Blocks Flaxman Island 6610 and 6658 Flaxman Island 6559, 6610, and 6658 

Wells Two -- Sivulliq N and Torpedo H Four -- Sivulliq G and N; Torpedo H and J 

Drilling unit Drillship Discoverer CDU Kulluk or Drillship Discoverer

Drilling Mud, 

Treated domestic 

waste, Treated 

sanitary waste; 

Uncontaminated 

ballast water; 

Bilge water 

Discharged to the ocean as permitted under 

Environmental Protection Agency Arctic 

General Permit authorization AKG-28-0000 

Collected, stored and then transported to an 

approved treatment/disposal site (TDS) for 

disposal 

Primary Support 

Fleet 

Anchor handler, ice management vessel, 

offshore supply vessels (OSV), West Dock 

shuttle 

Similar fleet with the following variations: 

• OSV to collect waste streams from the 

Kulluk

• Deck barge and tug and waste barge and 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-2 May 2011

Table 1 Comparison of Shell’s Initial Camden Bay EP and the Revised Camden Bay EP 

Parameter Initial Camden Bay EP (2010) Revised Camden Bay EP 

(2012 planned start) 

tug to store the waste streams

• Additional OSV for offshore supply 

Oil Spill Response Oil Spill Response (OSR) Tug and Barge; 

OSR Vessel, Arctic Tanker 

OSR Tug and Barge; Arctic Tanker, OSR 

barge carrying containment system 

Air permit Discoverer – Prevention of Significant 

Deterioration (PSD) permit authorization 

R10OCS/PSD-AK-2010-01 

Discoverer – PSD permit authorization 

R10OCS/PSD-AK-2010-01 

Kulluk – Minor Source Permit application for 

Beaufort Sea submitted February 28, 2011

As required by 30 Code of Federal Regulations (CFR) 250.212-228, details of the planned exploration 

drilling program are provided in the following sections and accompanying appendix material. While 

Shell has made this submission as a plan revision, it acknowledges that, pursuant to 30 CFR 250.285(c), 

the impacts previously identified and evaluated in Shell’s initial Camden Bay EP and BOEMRE’s 

October 2009 EA and FONSI are different than the impacts potentially resulting from the plan revision, 

and that this plan revision is subject to all of the procedures under 30 CFR 250.231 through 30 CFR 

250.235. 

a) Description, Objectives and Schedule for the Exploration Drilling Program 

The leases listed in this revised Camden Bay EP were acquired at Beaufort Sea Oil and Gas Lease Sales 

195 (March 2005) and 202 (April 2007). The four drill sites identified in this revised Camden Bay EP are 

listed below in Table 1.a-1. 

Table 1.a-1 Camden Bay Drill Sites 

Drill Site Lease File 

Number 

NR06-04 

Flaxman Island 

Lease Block 

No. 

Surface Location (NAD 83)* Distance to 

Mainland Shore 

Latitude (N) Longitude (W) mi (km) 

Sivulliq G OCS-Y 1805 6658 70° 23' 46.82" 146° 01' 03.46" 16.6 (26.7) 

Sivulliq N** OCS-Y 1805 6658 70° 23' 29.58" 145° 58' 52.53" 16.2 (26.1) 

Torpedo H** OCS-Y 1941 6610 70° 27' 01.62" 145° 49' 32.07" 20.8 (33.5) 

Torpedo J OCS-Y 1936 6559 70° 28' 56.94" 145° 53' 47.15" 23.1 (37.2) 

*North American Datum 1983 

**Drill sites from approved Camden Bay EP 

Shell plans to drill four wells (Table 1.a-1) to objective depth pursuant to the revised Camden Bay EP. 

As with any Arctic exploration drilling program, weather and ice conditions, among other factors, will 

dictate actual sequence in which the wells are drilled. All wells are planned to be vertical. Bottomhole 

locations will have the same latitude and longitude as surface locations. 

This plan also contemplates a situation where a well that is started must be temporarily suspended due to 

ice, weather, or other conditions, and finished at a later date. Any well on which drilling is suspended 

will be secured in compliance with BOEMRE regulations and with the approval of the Regional 

Supervisor/Field Operations (RF/SO), whether it is permanently abandoned (30 CFR 250.1710 through 

1717) or temporarily abandoned (30 CFR 250.1721-1723). 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-3 May 2011

Shell may conduct a geophysical survey referred to as zero-offset vertical seismic profile(ZVSP) at each 

drill site where a well is drilled. Once the objective intervals are fully evaluated, each exploration well 

will be plugged and abandoned in compliance with BOEMRE regulation. 

During exploration drilling operations, the drilling vessel (hereafter drilling vessel refers to either the 

Kulluk or Discoverer) will be attended by a minimum of 11 vessels that will be used for ice management, 

anchor handling/ice management, OSR, refueling, resupply, waste removal, and servicing of the drilling 

operations (see Table 1.a-2). 

Table 1.a-2 Planned Support Vessels for the Kulluk or Discoverer 

Support Vessel(or similar) Kulluk or Discoverer

Primary Ice Management Nordica* 

Secondary Ice Management / Anchor 

Handling 

Hull 247* (also acts as tow vessel for the 

Kulluk and a berthing vessel for OSR) 

Shallow water resupply Arctic Seal* 

Offshore Resupply Vessel (OSV) Harvey Explorer* 

Waste Streams Transfer Vessel Carol Chouest* 

Waste Streams Temporary Storage and 

Transit to Disposal Facility (deck barge and 

tug; [deck barge]) 

Southeast Provider* and Ocean Ranger* 

Waste storage barge and tug (waste barge) TBD 

Primary Oil Spill Response (OSR) Point Oliktok* Tug and Endeavor Barge* 

OSR Liquid Storage and Refuel Supply 

Vessel Mikhail Ulyanov*

OSR Containment System Invader Class tug* and barge 

Anchor Handler – support for the 

Containment System Barge TBD 

*or equivalent vessel 

TBD = Vessel role is included, vessel not yet named. 

By agreement with the local communities, during exploration drilling activities contemplated by the 

revised Camden Bay EP, Shell will not discharge selected waste streams during routine drilling 

operations, even though the waste streams are allowable discharges under the current United States (U.S.) 

Environmental Protection Agency (EPA) administered Arctic National Pollutant Discharge Elimination 

System (NPDES) General Permit (GP) AKG-28-0000. Shell will not discharge treated sanitary waste 

(black water), domestic waste (gray water), bilge water and ballast water at any time and drilling mud and 

cuttings with adhered drilling mud below the depth of the 20-in. conductor shoe. These wastes will be 

collected and stored on a deck barge and waste barge and transported and disposed of at an approved and 

licensed facility. The following licensed facilities have been identified as potential sites for disposal of 

those waste streams collected during exploration drilling operations: 

• Waste Management Inc. (Arlington, Oregon) – water based mud, cuttings with adhered mud, non 

hazardous trash and debris, treated sanitary waste, treated domestic waste, uncontaminated ballast 

water, treated bilge water, hazardous waste, used oil 

• Emerald Services Inc. (Palmer, Alaska and Seattle, Washington) – hazardous waste, used oil 

Cuttings generated while drilling the mudline cellar, the 36- and 26-in. hole sections (all drilled with 

seawater and viscous sweeps only) plus cement discharged while cementing the 30- and 20-in. casing 

strings will be discharged on the surface of the seafloor under provisions of the previously mentioned 

NPDES GP. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-4 May 2011

When transiting to location, the Kulluk (under tow) or Discoverer (under its own propulsion) and 

associated support vessels will transit through the Bering Strait into the Chukchi Sea on or after July 1, 

arriving at location near Camden Bay approximately July 10. Exploration drilling activities at the drill 

sites are planned to begin on or about July 10 and run through October 31, with a suspension of all 

operations beginning August 25 for the Nuiqsut (Cross Island) and Kaktovik subsistence bowhead whale 

hunts. During the suspension for the whale hunts the drilling fleet will leave the Camden Bay project area 

and move to an area north of latitude 71o

 25’N and west of longitude 146o 4’W. Shell will return to 

resume activities after the subsistence bowhead whale hunts conclude. Drilling activities may extend 

through October 31, depending on ice and weather conditions. 

Helicopters will provide support for crew change, provision resupply, and search-and-rescue operations 

during the drilling season. A fixed wing aircraft will be part of the marine mammal monitoring and 

mitigation plan (4MP) for exploration drilling, carrying marine mammal observers (MMO) over the 

Sivulliq and Torpedo prospects to identify marine mammals. The crew change and resupply helicopter 

and the fixed wing aircraft will be based in Deadhorse, Alaska, with the search-and-rescue helicopter 

stationed in Barrow, Alaska. 

At the end of each drilling season, the Kulluk (under tow), or the Discoverer (under its own propulsion) 

and associated support vessels will transit west into and then south through the Chukchi Sea. 

b) Location 

The locations of prospect lease blocks at which the planned drill sites are located are shown on Figure 1a-1 

and -2. See also Table 1.a-1 for additional drill site location information. 

Figures 1.a-3 through -10 are mooring location maps showing the planned anchor locations for each drill 

site. 

Other information is provided for each of these planned drill sites in the OCS Plan Information Forms 

(MMS Form-137) included in Appendix A of the confidential copies of the revised Camden Bay EP. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-5 May 2011Figure 1.a-1 Planned EP Drilling Program Area (see also Figure 1.a-2 where 4 drills sites on 3 OCS blocks are shown) 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-6 May 2011Figure 1.a-2 Location of the Sivulliq and Torpedo Prospects and Respective Drill Sites 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-7 May 2011Figure 1.a-3 Bathymetry and Planned Kulluk Anchor Locations – Sivulliq G 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-8 May 2011Figure 1.a-4 Bathymetry and Planned Kulluk Anchor Locations – Sivulliq N 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-9 May 2011Figure 1.a-5 Bathymetry and Planned Kulluk Anchor Locations – Torpedo H 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-10 May 2011Figure 1.a-6 Bathymetry and Planned Kulluk Anchor Locations – Torpedo J 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-11 May 2011Figure 1.a-7 Bathymetry and Planned Discoverer Anchor Locations – Sivulliq G 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-12 May 2011Figure 1.a-8 Bathymetry and Planned Discoverer Anchor Locations – Sivulliq N 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-13 May 2011Figure 1.a-9 Bathymetry and Planned Discoverer Anchor Locations – Torpedo H 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-14 May 2011Figure 1.a-10 Bathymetry and Planned Discoverer Anchor Locations – Torpedo J 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-15 May 2011

c) Drilling Vessels 

Kulluk 

Shell anticipates using the drilling vessel Kulluk to drill the wells proposed in the revised Camden Bay 

EP. The Kulluk has an Arctic Class IV hull design, is capable of drilling in up to 600 feet (ft) [182.9 

meters (m)]) of water and is moored using a 12-point anchor system. The Kulluk’s mooring system 

consists of 12 Hepburn winches located on the outboard side of the main deck, Anchor wires lead off the 

bottom of each winch drum inboard for approximately 55 ft (16.8 m). The wire is then redirected by a 

sheave, down through a hawse pipe to an underwater, ice protected, swivel fairlead. The wire travels from 

the fairlead directly under the hull to the anchor system on the seafloor. The Kulluk will have an anchor 

radius of 3,117 ft (950 m) for the Sivulliq drill sites and 2,995 ft (913 m) for the Torpedo drill sites. 

Specifications for the Kulluk and various diagrams are attached as Table 1.c-1. 

The Kulluk is designed to maintain its location in drilling mode in moving ice with thickness up to 4 ft 

(1.2 m) without the aid of any active ice management. With the aid of the ice management vessels, the 

Kulluk would be able to withstand more severe ice conditions. In more open water conditions, the Kulluk

can maintain its drilling location during storm events with wave heights up to 18 ft (5.5 m) while drilling, 

and can withstand wave heights of up to 40 ft (12.2 m) when not drilling and disconnected (assuming a 

storm duration of 24 hours). 

The Kulluk will comply with the requirements of 30 CFR Part 250.417, the International Maritime 

Organization (IMO), the U.S. Coast Guard (USCG) and Det Norske Veritas (DNV). All drilling 

operations will be conducted under the provisions of 30 CFR 250, American Petroleum Institute (API) 

Recommended Practices (RP) 53, 65 Part 2 and 75, and other applicable regulations and notices, 

including those regarding the avoidance of potential drilling hazards and safety and pollution prevention 

control. Primary safety measures include: inflow detection and well control; monitoring for loss of 

circulation and seepage loss; and casing and cementing program designs. Primary pollution prevention 

measures consist of contaminated and non-contaminated drain systems, a mud drain system, and oily 

water processing. 

Discoverer 

As an alternative to the Kulluk, Shell might decide to use the Discoverer to drill some or all of the wells 

proposed in the revised Camden Bay EP. The Discoverer is a true, self-contained drillship. The 

Discoverer is an anchored drillship with an 8-point anchored mooring system and will likely have an 

anchor radius of 2,903 ft (885 m). The hull has been reinforced for ice resistance. Specifications for this 

drillship are provided below in Table 1.c-2. 

The Discoverer will comply with the requirements of 30 CFR Part 250.417, the IMO, the USCG and 

DNV. All drilling operations will be conducted under the provisions of 30 CFR Part 250 Subpart D, API 

RP 53, 65 Part 2 and 75 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 noncontaminated drain systems, the mud drain system, and the oily water processing system. 

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) which are attached as Appendices J 

and K of this revised Camden Bay EP. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-16 May 2011

Table 1.c-1 Kulluk Specifications 

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-17 May 2011

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-18 May 2011

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-19 May 2011
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-20 May 2011

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-21 May 2011

Table 1.c-2 Discoverer Specifications 

DISCOVERER OPERATING WATER DEPTH 

MAX WATER DEPTH 1,000 ft (305 m) with present equipment (can be outfitted to 2,500 ft [762 m]) 

MAX DRILLING DEPTH 20,000 ft 6,098 m 

 

DISCOVERER SPECIFICATIONS

TYPE-DESIGN Drillship - Sonat Offshore Drilling Discoverer Class

SHAPE Monohull with sponsons added for ice-resistance1

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 2010 

DISCOVERER DIMENSIONS 

LENGTH 514 ft 156.7 m 

LENGTH BETWEEN PERPINDICULARS (LBP) 486 ft 148.2 m 

WIDTH 85 ft 26 m 

MAXIMUM (MAX) HEIGHT (ABOVE KEEL) 274 ft 83.7 m 

HEIGHT OF DERRICK ABOVE RIG FLOOR 175 ft 53.3 m 

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 kilograms (kg) each (ea) 15,400 pounds (lb) ea 

ANCHOR LINES Chain Wire Combination 

SIZE/GRADE 2.75-in. wire 3-in. ORQ Chain 

LENGTH 2,750 ft (838 m) wire + 1,150 ft (351 m) chain (useable) per anchor 

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-22 May 2011

Table 1.c-2 Discoverer Specifications (continued)

DRAW WORKS EMSCO E-2,100 - 1,600 horsepower (hp) 

ROTARY National C-495 with 49 1⁄2 -in. opening 

MUD PUMPS 2 ea. Continental Emsco Model FB-1600 Triplex Mud Pumps 

DERRICK Pyramid 170 ft. with 1,300,000 lb nominal capacity 

PIPE RACKING BJ 3-arm system 

DRILL STING COMPENSATOR Shaffer 400,000 lb with 18-ft (5.5 m) stroke 

RISER TENSIONS 8 ea. 80,000 lb Shaffer 50-ft (15.2 m) stroke tensioners 

CROWN BLOCK Pyramid with 9 ea. 60-in. (1.5 m) diameter sheaves rated at 1,330,000 lb 

TRAVELING BLOCK Continental - Emsco RA60-6 

BLOWOUT PREVENTOR (BOP) Cameron Type U 18 3⁄4 -in. (48 cm) x 10,000 pounds per square in. (psi) 

RISER Cameron RCK type, 21-in. (53 cm) 

TOP DRIVE Varco TDS-3S, with GE-752 motor, 500 ton 

BOP HANDLING Hydraulic skid based system, drill floor 

1

 Sponsons designed and constructed to meet requirements of Det Norske Veritas (DNV) Additional Class Notation ICE-05. 

DISCOVERER DISPLACEMENT 

FULL LOAD 20,253 metric tons (mt) 

DRILLING 18,780 mt (Drilling, max load, deep hole, deep water) 

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 

DISCOVERER HELIDECK 

MAXIMUM HELICOPTER SIZE Sikorsky 92N 

FUEL STORAGE 2 ea. 720-gallon tanks 

DISCOVERER ACCOMODATIONS 

NUMBER OF BEDS 140 

SEWAGE TREATMENT UNIT Hamworthy ST-10 

DISCOVERER PROPULSION EQUIPMENT 

PROPELLER 1 ea 15 ft 7-in. (4.8 m) diameter, fixed blade 

PROPULSION DRIVE UNIT Marine Diesel, 6 cylinder, 2 cycle, Crosshead type 

HORSEPOWER 7,200 hp @ 135 revolutions per minute (RPM) 

TRANSIT SPEED 8 knots 

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 (bbl) 

Reserve 1,200 bbl 

Total 2,400 bbl 

POTABLE WATER 1,670 bbl / 265.5 m3 (aft peak can be used as add. pot water tank) 

DRILL WATER 5,798 bbl / 921.7 m3 

FUEL OIL 6,497 bbl / 1,033 m3 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-23 May 2011

d) Service Fee 

The required permit fee of $13,768 (four drill sites at $3,442 each) has been paid in full. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 1-24 May 2011

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Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 2-1 May 2011

SECTION 2.0 GENERAL INFORMATION 

 

a) Applications and Permits 

Table 2.a-1 lists the federal permit and authorization applications and the state consistency review 

application that are being submitted to the appropriate regulatory agencies that authorize the revised 

Camden Bay EP exploration drilling program. No local permits are needed for these drilling activities. 

Some of these permits and authorizations will cover all four drill site locations on the BOEMRE lease 

blocks north of Point Thomson in the Camden Bay area of the Beaufort Sea, Alaska for the duration of 

the drilling program, whereas other authorizations will require yearly renewal. 

Table 2.a-1 Permit and Authorization Applications 

Permits and Authorizations Agency Submittal Date Authorization Date Comment / Location 

Federal Permit / Authorization Applications Under Review

Air Quality Permit 

Discoverer

EPA 

Initial Application 

submitted May 29, 

2009; last revision 

sent January 18, 

2010 

April 9, 2010 Authorization 

R10OCS/PSD-AK-2010-

01; remanded back to 

EPA by the 

Environmental Appeals 

Board; see EPA 

website1

 

Air Quality Permit 

Kulluk

February 2011 Pending Application for a Minor 

Source Permit; permit 

covers the Kulluk for the 

duration of the drilling 

program; see EPA 

website2

Notices of Intent (NOI) to 

Discharge under NPDES 

General Permit AKG-28-0000

Discoverer 

EPA

December 2010 

(for administrative 

extensions for 

Lease Block 6610 

and 6658 and new 

NOI for Lease Block 

6559) 

AKG-28-0005 

authorized April 20, 

2010 (Discoverer – 

Lease Blocks 6610 

and 6658)

Letter sent for 

Administrative Extension 

for Lease Blocks 6610, 

6658 (current coverage 

under authorization 

AKG-28-0005)3

; see 

EPA website 

NOI sent for Lease Block 

6559 (see Appendix B 

this document) 

Notices of Intent to Discharge 

under NPDES General Permit 

AKG-28-0000 

Kulluk

April 8, 2011 Pending Supplemental NOI 

information sent for 

lease blocks 6559, 6610, 

and 6658 (see Appendix 

B this document) 

USACE NWP #8 Oil and Gas 

Structures

USACE May 2011 Pending See Appendix G of this 

document; authorization 

will be valid for two years

Application Permit to Drill (one 

per drill site) 

BOEMRE Sivulliq N submitted 

October 5, 2010 

including additional 

information required 

by NTL 2010-N06 

TBD APDs for Sivulliq G, 

Torpedo H and J to be 

filed as separate 

documents following 

approval of the revised 

EP
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 2-2 May 2011

Table 2.a-1 Permit and Authorization Applications 

Permits and Authorizations Agency Submittal Date Authorization Date Comment / Location 

Exploration Plan BOEMRE Revised EP 

submitted May 2011 

Camden Bay EP 

upon which this 

revision is based 

was approved 

October 16, 2009 

This document is a 

revision of a currently 

approved Camden Bay 

EP; authorization valid 

for the duration of the 

drilling program 

OSRP (aka Oil Discharge 

Prevention and Contingency 

Plan [ODPCP]) 

BOEMRE Revised ODPCP 

submitted May 2011 

Beaufort Sea 

Regional ODPCP 

upon which the 

revision is based 

was approved 

March 11, 2010

Revised edition of the 

currently approved 

ODPCP; submitted as a 

separate document 

MMPA IHA Application (whales 

and seals) 

NMFS May 2011 pending Appendix C of this 

document; authorization 

valid for one year 

MMPA LOA Application (polar 

bears and Pacific walrus); 

Incidental and Intentional Take

USFWS May 2011 pending Appendix E of this 

document; authorization 

valid for one year 

State of Alaska Coastal Management Program 

ACMP Consistency Review ADNRDCOM4 Anticipated June 

2011 

pending Section 15.0 of this 

document; consistency 

review concurrence valid 

for the duration of the 

drilling program

Notes 

1Additional information found at http://yosemite.epa.gov/R10/airpage.nsf/Permits/beaufortap/ 2Additional information found at http://yosemite.epa.gov/r10/airpage.nsf/Permits/kullukap/ 3Also found at http://yosemite.epa.gov/R10/WATER.NSF/NPDES+Permits/General+NPDES+Permits 4 Submitted to BOEMRE in this document, and then forwarded by BOEMRE to ADNR-DCOM for ACMP consistency review. 

ACMP = Alaska Coastal Management Program 

ADNR = State of Alaska, Department of Natural Resources 

DCOM = Division of Coastal and Ocean Management 

IHA = Incident Harassment Authorization 

LOA= Letter of Authorization 

MMPA = Marine Mammal Protection Act 

NMFS = National Marine Fisheries Service 

NOI = Notice of Intent 

ODPCP – Oil Discharge Prevention and Contingency Plan 

OSRP = Oil Spill Response Plan 

TBD = To be determined 

USACE = U.S. Army Corps of Engineers 

USFWS = U.S. Fish and Wildlife Service 

b) Drilling Fluids 

Shell is planning to use water based drilling mud (WBM) for the proposed drilling activities. Only 

seawater will be used during the construction of the mudline cellar (MLC), the 36–in. hole section (30-in. 

casing) and the 26–in. hole section (20-in. casing). Below the 26–in. hole section, Shell will use WBM 

during drilling. These WBMs and cuttings will be collected aboard the drilling vessel and will be 

transferred to an adjacent vessel for storage and ultimate transit out of the Arctic Ocean. This waste 

stream, as well as other waste streams collected during the drilling program (treated sanitary effluent, 

domestic waste, bilge water and ballast water) will be disposed of at an EPA approved treatment/disposal 

site (see Section 6). 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 2-3 May 2011

The following is the anticipated amounts of WBM and cuttings with adhered mud that will be generated, 

collected and disposed of per planned well regardless of whether the Kulluk or Discoverer drills the wells: 

• Sivulliq G – 1,426 bbl 

• Sivulliq N – 1,426 bbl 

• Torpedo H – 3,045 bbl 

• Torpedo J – 3,007 bbl 

In addition to the listed generated mud and cuttings, a reserved volume of 1,500 bbl of mud is available to 

replace mud that has deteriorated and cannot be recycled and it is available in the event of lost circulation 

down the hole. This volume of mud will be captured, stored and disposed of at the end of each drilling 

season, per disposal details discussed in Section 6. 

Shell’s drilling mud service provider drafted a Drilling/Completion Fluids Proposal (Mud Plan) 

specifically for each well that defines the types and amounts of drilling fluids to be used for each section 

of each well. The Mud Plan for each well is not submitted as part of the EP, but will be submitted as part 

of each APD that Shell submits to BOEMRE. Each mud plan will include the specific estimated 

quantities and loadout list of mud materials for each well. More information is provided on estimated 

weights and volume of mud for the proposed wells is found in Section 6 of this revised Camden Bay EP. 

The following Table 2.b-1 is a list of products that may be mixed in varying quantities to form various 

drilling fluid compositions. Weights or volumes of these products are found in Section 6. 

Table 2.b-1 List of WBM Products 

Product Function 

Caustic Soda (sodium hydroxide) pH adjuster 

Citric Acid pH adjuster 

DUOVIS Viscosifier 

M-I Wate (Barite) Weighting agent 

M-I Gel (Bentonite) Viscosifier 

Poly Pac UL Viscosifier, Fluid loss control 

Poly Pac R Viscosifier, Fluid loss control 

KlaStop Shale encapsulation 

Salt (NaCl) & brine solution Densifier 

Soda Ash Calcium precipitation 

Sodium Bicarbonate Alkalinity control 

SP-101 Fluid loss agent 

Tackle Polymeric thinner 

Contingency Products 

Gelex Bentonite extender 

Defoam X Defoamer 

Nut Plug (Assorted) Lost circulation material 

IDCAP D Lost circulation material 

Mix II (Assorted) Lost circulation material 

Desco CF Dispersant 

Sapp Dispersant 

Durogel Viscosifier 

Miocide biocide 

Mud products and additives will be available in sufficient quantities so that a completely new mud system 

can be built. There are also sufficient quantities to begin a relief well in the unlikely event that there is a 

blowout. Contingency products provide the means to combat lost circulation should it occur 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 2-4 May 2011

unexpectedly. There will be ample lost circulation material aboard the Kulluk or Discoverer to prevent 

wholesale mud losses. Excess cement is also available for permanently sealing lost circulation zones, and 

there is sufficient hole diameter available for contingent casing strings/liners to case off any severe lost 

circulation zones, as well. 

Details regarding drilling fluid volumes, discharge volumes and rates, additives and other information are 

found in Section 6.0.

c) Chemical Products 

No chemicals will be stored aboard the Kulluk or Discoverer above reportable quantities.

d) New or Unusual Technology 

There is no new or unusual technology proposed. 

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

Shell, BOEMRE Operator Number YK00689, is of sound financial strength and reliability and has 

demonstrated oil spill financial responsibility according to 30 CFR 253 for the facilities planned in the 

revised Camden Bay EP. 

The bond requirement for the activities planned in the revised Camden Bay EP is satisfied by an areawide bond of $1,000,000 furnished and maintained according to 30 CFR 256, subpart I, and Notice to 

Lessees No. 2008-N07, Supplemental Bond Procedures. The bond identification number is 022-014-198 

through Liberty Mutual Insurance Company. Shell is also covered under a $150,000,000 indemnity that 

certifies the company has the oil spill financial responsibility (OSFR) for the costs in the extremely 

unlikely event of an oil spill. BOEMRE renewed Shell’s OSFR April 11, 2011. 

This is a planned exploration drilling program with temporary and seasonal operations. There will be 

minimal sea bed disturbance for MLCs at any drill site. MLCs are designed to protect the wellhead, 

casing and BOP from potential ice gouge events should circumstances require that the lower section of 

the BOP remain on the well over the winter. Vessel anchoring systems employed during operations will 

be removed upon abandonment of each well. Permanent facilities will be limited to the casing, wellhead 

housings and the guide base remaining subsurface after well abandonment and will comply with the 

Abandonment of Wells citation listed under 30 CFR 250.702(i). The uppermost portion of the permanent 

guidebase (i.e., the top of the guidearms) will be in the MLC some 28 ft (8.5 m) below the mudline upon 

permanent abandonment of each well.

Outline emergency response plans including a COCP (Appendix J), IMP (Appendix K), and a Well Control 

Plan (WCP) including a Relief Well Plan (RWP) (Appendix L) are available in the unlikely event there is an 

emergency or drilling operations must be curtailed due to ice conditions, weather, a well control incident or 

other hazardous condition. 

f) Suspension of Operations 

Shell has plans and measures in place that accommodate the forced or voluntary suspension of operations 

during the planned exploration drilling program. 

Forced suspension of operations could result from conditions such as weather, ice conditions, the drilling 

vessel mechanical conditions, or downhole conditions, among others. In order to facilitate a possible 

suspension of operations, Shell has drafted several general plans containing Shell’s emergency 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 2-5 May 2011

management philosophy. These plans are presented in Section 9.0 and in Appendices J, K and L. 

Detailed emergency response procedures will be developed to reside on the drilling vessel and in Shell’s 

offices as references to guide response actions in the event of an emergency. 

Shell plans to voluntarily shut down exploration drilling operations on August 25 for the Nuiqsut (Cross 

Island) and Kaktovik subsistence bowhead whale hunts. During the suspension for the whale hunts the 

drilling fleet will leave the Camden Bay project area and move to an area north of latitude 71o

 25’N and 

west of longitude 146o

 4’W. Shell will return to resume activities after the subsistence bowhead whale 

hunts conclude. These and other mitigative measures are found in Section 12.0. 

g) Blowout Scenario 

Procedures and protocols for a blowout are detailed in the Oil Discharge Prevention and Contingency 

Plan (ODPCP), or C-Plan, (also referred to as an Oil Spill Response Plan - OSRP) which is submitted to 

BOEMRE as a separate document concurrent with this revised Camden Bay EP. This blowout scenario is 

summarized in Section 8 of this document. 

It is expected that in the unlikely event of a blowout, the highest calculated flow rate would be from the 

Torpedo H location, calculated at 9,468 bbl of oil per day (Table 2.g-1). 

Table 2.g-1 Calculated Worst Case Discharge (WCD) for the Camden Bay EP Potential Wells

Potential Well Calculated Worst Case Discharge (bbl/day)

Sivulliq G 594 

Sivulliq N 918 

Torpedo H 9,468 

Torpedo J 5,824 

Shell’s ODPCP details an oil spill response capability to cover a potential blowout of a flow rate of 

16,000 bbl/day for a duration of 30 days – a total volume of 480,000 bbl of oil. This is the volume used 

for planning purposes in the revised Beaufort Sea Regional ODPCP and is sufficient to cover a potential 

blowout of any well in the revised Camden Bay EP. 

The assumption and basis for calculation of the WCD are provided in Section 3 of this document. 

Potential for the Well to Bridge 

The WCD outlined in proprietary Section 3 does not include the potential for the well to bridge. 

Surface Intervention 

See Section 9f) to read a discussion of Surface Intervention – Capping Stack and Containment System. 

Relief Well Availability 

The Kulluk or Discoverer will serve as its own primary relief well drilling vessel in the unlikely event of a 

well blowout. In the event that the primary relief well drilling vessel cannot be used, the secondary relief 

well drilling vessel will be mobilized. If the Kulluk is drilling the well at the time of a blowout, it is 

estimated that the Discoverer will be available to be on-site within 9 days (Table 2.g-2). If the Discoverer

is drilling the well at the time of the blowout, it is estimated that the Kulluk will be onsite in 18 days. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 2-6 May 2011

Table 2.g-2 Relief Well Drilling Information 

Secondary Relief Well 

Drilling Vessel 

Location at time of 

blowout 

Time to Arrive at Relief 

Well Drill Site 

Days to Drill a Relief Well 

Discoverer Chukchi Sea 9 days (3 days for well 

suspension and mooring 

retrieval; 6 days transit) 

20 days (Sivulliq N or G) 

25 days (Torpedo H or J) 

Kulluk Dutch Harbor 18 days transit 20 days (Sivulliq N or G) 

25 days (Torpedo H or J) 

Drilling Vessel Constraints 

The Kulluk has an Arctic Class IV hull design and has successfully and safely drilled several wells in the 

arctic environment. The Discoverer has an ice-strengthened hull. Either vessel will be inspected by DNV 

and the USCG prior to mobilizing to Camden Bay. Final inspection reports will be submitted to 

BOEMRE when they are available. 

Time to Drill a Relief Well 

Once onsite, the Kulluk or Discoverer can drill a relief well for either the Sivulliq G or N well in 20 days 

and the Torpedo H or J well in 25 days. For the Kulluk as secondary relief well drilling vessel, total time 

from the blowout to completing the relief well is estimated to be 38 days for the Sivulliq wells and 43 

days for the Torpedo wells. For the Discoverer as secondary relief well drilling vessel, total time from the 

blowout to completing the relief well is estimated to be 29 days for the Sivulliq wells and 34 days for the 

Torpedo wells. 

h) Contact Information 

Contact Susan Childs, Alaska Venture Support Integrator Manager, at telephone number 907-646-7112, 

fax 907-646-7145, or e-mail at susan.childs@shell.com. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 3-1 May 2011

SECTION 3.0 GEOLOGICAL AND GEOPHYSICAL 

INFORMATION (PROPRIETARY AND 

CONFIDENTIAL) 

The information for the Sivulliq and Torpedo prospects in this section contains 

confidential and proprietary information and is not available in this public 

information copy of the revised Camden Bay EP. 

a) Geological Description and Drill Site Locations 

b) Structure Contour Maps 

c) Key Seismic Lines 

d) Geological Cross Sections 

e) Shallow Hazards Reports 

f) Shallow Hazards Assessment 

g) Stratigraphic Columns 

h) Time Versus Depth Charts 

i) High-Resolution Seismic Lines 

j) Geochemical Information 

k) Future Geological and Geophysical Activities 

l) WCD Calculations 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 3-2 May 2011

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Shell Offshore Inc. 4-1 May 2011

SECTION 4.0 HYDROGEN SULFIDE 

a) Concentration 

The concentration of hydrogen sulfide (H2S) is expected to be zero based on the information derived from 

the wells described in the following Classification sub-section. 

b) Classification 

Shell records indicate that hydrocarbon samples were collected from the Oligocene objective section in 

the two legacy Hammerhead Wells drilled by Unocal et al. in 1985 and 1986, respectively (Flaxman 

Island Block 6708, OCS-Y 849 #1 and #2). No H2S was observed in fluid samples from either well. 

Additionally, based on scout ticket information, final well reports, and publicly-available reservoir 

engineering data, none of the following nearby wells encountered H2S, including those that penetrated 

stratigraphically older Eocene and Paleocene horizons: 

• OCS Y-0917 #1 (Belcher) 

• OCS Y-0943 #1 (Aurora) 

• Point Thomson #1, #2 and #3 

• OCS-Y-1597 #1 (Wild Weasel) 

• OCS-Y-1663 #1 (Warthog) 

• OCS-Y-0866 #1, #2 and #3 (Kuvlum) 

• OCS Y-0871 #1 (Corona) 

• OCS Y-1092 #1 (Galahad) 

• OCS-Y-1578 #1 (McCovey) 

All these wells penetrated age-equivalent formations similar to Shell’s currently planned targets.

These data were supplied to the BOEMRE Anchorage office as part of a previous EP evaluation (initial 

Camden Bay EP submitted to BOEMRE in May 2009), and Shell requests that the RS/FO classify the 

objective zones in the planned exploration wells as “H2S absent”. 

c) Contingency Plan 

A Contingency Plan is not needed because of the expected absence of H2S in the Sivulliq and Torpedo 

prospects. 

d) Modeling Report 

A Modeling Report is not needed because of the expected absence of H2S. 

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 4-2 May 2011

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Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 5-1 May 2011

SECTION 5.0 BIOLOGICAL, PHYSICAL, AND 

SOCIOECONOMIC INFORMATION 

a) Biological Environment Reports 

The most current reports available regarding site specific biological studies over the Sivulliq and Torpedo 

prospects include data gathered during 2008. Shell funded biological and chemical studies of water and 

sediment samples in an around the planned Sivulliq and Torpedo prospects during 2008. The reports are 

titled: 

• Characterization of Benthic Habitat in Camden Bay (Sivulliq Prospect and Hammerhead Drill 

Sites) Beaufort Sea Alaska. Dunton, Schonberg and McTigue, University of Texas Marine 

Science Institute - Final Report July 15, 2009. 

• Chemical Assessment in Camden Bay (Sivulliq Prospect and Hammerhead Drill Sites) Beaufort 

Sea Alaska. Trefry and Trocine, Florida Institute of Technology - Final Report July 2009. 

Dunton et al. (2009) Report 

The overall objective of the Dunton et al. (2009) baseline sampling program was to collect samples for 

water quality determinations, sediment chemistry, and benthic biological data for subsequent evaluation 

of possible future oil and gas development impacts. This report is specifically focused on biological 

resources of the region surrounding the planned Sivulliq N and G drill sites and the previously drilled 

(1985 and 1986) two Hammerhead wells. At the time of data collection, coverage over the Torpedo 

Prospect was not part of the sampling program. However, some of the more northerly samples were 

collected in close proximity to the Torpedo H drill site. 

Benthic (seafloor surface sediments) and sediment cores 3-4 in. (8 – 10 cm) in length and water column 

samples were collected at 45 designated stations. Two benthic grabs were collected at each station, one 

for biology (infaunal abundance and biomass) and one for chemistry (sediment parameters and selective 

collection of biota for determination of trophic structure). Vertical profiles of water column characteristics 

were assayed at seven selected stations. 

One sample each was collected at 19 sites across the monitoring area to describe the spatial extent and 

patterns of biota biomass and density in the Sivulliq and Torpedo prospect areas on the nearshore shelf 

northwest of Camden Bay. The location for each site was chosen by laying a probability based grid over 

the study site area and randomly choosing a location within each grid cell. To gain a better resolution of 

the variability around a specific site, a second probability grid over a smaller area (1,640 ft [500 m]) was 

created. Six stations were located 820 ft (250 m) from a central point within the Sivulliq Prospect and 

another six stations were located at a distance of 1,640 ft (500 m). A third probability grid was created 

around a previous drill site (Hammerhead 1 drilled in 1985). Ten stations were sampled at this prospect 

but only nine benthic stations were sampled for biology. Finally, five stations that followed the course of 

the proposed pipeline route from the Sivulliq Prospect were sampled. Of the total number of sites 

sampled for benthic measurements (45), all but the five pipeline stations were located in water depths 

greater than 98 ft (30 m). 

Dunton et al. (2009) observed no obvious spatial trends in the biomass or density of benthic organisms in 

the study area. However, several sites contained some of the highest biomass values recorded on the 

nearshore shelf of the central Alaskan Beaufort Sea so far. The report indicates that the benthic 

communities have not been adversely affected by previously discharged mud and cuttings during drilling 

operations at the former Hammerhead prospect drill sites. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 5-2 May 2011

Additional discussion regarding benthic communities is found in the EIA (Appendix F). 

Trefry and Trocine (2009) Report 

These authors used the same set of samples as Dunton et al. (2009) yet rather than examining the benthic 

environment, this report presents results from chemical studies that include the following: (1) sediment 

total concentrations of various elements and other parameters; (2) water column concentrations of 

salinity, temperature, turbidity, acidity/alkalinity (pH), dissolved oxygen, total suspended solids (TSS) 

and particulate organic carbon. 

The main conclusions for the chemical portion of the study are as follows: 

• Camden Bay has background values for trace metals as well as aliphatic and polycyclic aromatic 

hydrocarbons, through-out the bay, except for sediments collected within < 328 ft (<100 m) of a 

1985 drilling site. 

• Based on one example, movement of drilling mud and cuttings seems to be restricted to within 

~328 ft (~100 m ) of the discharge site, at a water depth of ~105 ft (~32 m). 

• Baseline data and supporting interpretative techniques are now in place to facilitate identification 

of anomalous concentrations of potential contaminants in sediments from Camden Bay well 

before they reach values that could have adverse environmental effects. 

• Results from the companion study of sediment biology by Dunton et al. (2009) found no 

measurable differences in benthic community abundance or structure relative to the other 

stations in the area. This finding is consistent with the chemical data obtained during the 2008 

survey. 

In February 2011, BOEMRE released a fish population study for a portion of the western Beaufort Sea 

titled “Beaufort Sea Marine Fish Monitoring 2008: Pilot Survey and Test of Hypotheses”. The eastern 

extent of the survey area was approximately longitude 152o

W, near the Cape Halkett area west of 

Nuiqsut, well outside the Camden Bay exploration drilling program area. The prospects are situated 

approximately 140 mi (224 km) east of the fish survey area. A similar study of the central Beaufort Sea is 

scheduled to begin summer 2011. 

Shell has also collected a large amount of information regarding marine mammals in the Beaufort Sea, 

including the area containing the Sivulliq and Torpedo prospects. The data has been collected during 

various Shell marine surveys through its marine mammal monitoring program. Reports which include 

Beaufort Sea marine mammal data are as follows: 

• Funk, D. W., R. Rodrigues, D. S. Ireland, and W. R. Koski (eds.). 2007. Joint Monitoring 

Program in the Chukchi and Beaufort Seas, July-November 2006. LGL Alaska Report P891-2, 

Report from LGL Alaska Research Associates, Inc., LGL Ltd., Greeneridge Sciences, Inc., 

Bioacoustics Research Program, Cornell University, and Bio-Wave Inc. for Shell Offshore, Inc., 

ConocoPhillips Alaska, Inc., and GX Technology, and National Marine Fisheries Service, U.S. 

Fish and Wildlife Service. 316 p. plus Appendices. 

• Ireland, D.S., D.W. Funk, R. Rodrigues, and W. R. Koski (eds.). 2008. Joint Monitoring Program 

in the Chukchi and Beaufort Seas, July-November 2007. LGL Alaska Report P1050-3, Report 

from LGL Alaska Research Associates, Inc., LGL, Ltd., Greeneridge Sciences, Inc., and JASCO 

Research, Ltd. and for Shell Offshore, Inc., ConocoPhillips Alaska, Inc., and National Marine 

Fisheries Service, U.S. Fish and Wildlife Service. 445 p. plus Appendices. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 5-3 May 2011

• Funk., D.W., D.S. Ireland, R. Rodrigues, and W.R. Koski (eds.). 2010. Joint Monitoring Program 

in the Chukchi and Beaufort seas, open-water seasons, 2006–2008. LGL Alaska Report P1050-2, 

Report from LGL Alaska Research Associates, Inc., LGL Ltd., Greeneridge Sciences, Inc., and 

JASCO Applied Sciences, for Shell Offshore, Inc. and Other Industry Contributors, and National 

Marine Fisheries Service, U.S. Fish and Wildlife Service. 462 p. plus Appendices. 

• Funk., D.W., D.S. Ireland, R. Rodrigues, and W.R. Koski (eds.). 2011. Joint Monitoring Program 

in the Chukchi and Beaufort seas, open-water seasons, 2006–2009. LGL Alaska Report P1050-2, 

Report from LGL Alaska Research Associates, Inc., LGL Ltd., Greeneridge Sciences, Inc., and 

JASCO Applied Sciences, for Shell Offshore, Inc. and Other Industry Contributors, and National 

Marine Fisheries Service, U.S. Fish and Wildlife Service. 462 p. plus Appendices. 

b) Physical Environment Reports 

The following text is summarized from archaeological discussion from the shallow hazards reports 

covering the Sivulliq N and G and Torpedo H and J planned drill sites. These reports are listed below and 

are found in the bibliography in Section 17. 

• Fugro Geoconsultants. 2009a. Shallow Hazards Assessment, Sivulliq G, V, W and Supplemental N 

Wellsites, Blocks 6658, 6659, 6708 and 6709, Flaxman Island Area, Beaufort Sea, Alaska, Report 

No. 27.2008-2266 

• Fugro Geoconsultants. 2009b. Shallow Hazards Assessment, Torpedo A, B, G, and H Wellsites, 

Blocks 6609 and 6610, Flaxman Island Area, Beaufort Sea, Alaska, Report No. 27.2008-2267 

• Fugro Geoconsultants. 2011. Drill Site Clearance Letter, Proposed Torpedo J Drill Site, Block 

6559 Flaxman Island, Beaufort Sea Alaska. Report No. 27.2010-2375-10 (submitted to 

BOEMRE March 2011) 

• GeoLLC. 2007. Exploration Wellsites Geohazards Assessments, Sivulliq Prospect, Beaufort Sea, 

Alaska, Report 12731-005-00. 

• GeoLLC. 2008a. Exploration Wellsites Geohazards Assessments, Sivulliq Prospect, Beaufort Sea, 

Alaska, Addendum 1, Report 12731-001-02 

• GeoLLC. 2008b. Exploration Wellsites Geohazards Assessments, Torpedo Prospect, Beaufort 

Sea, Alaska. Report 12731-001-02.

• Northern Technical Services (Nortec). 1985. Data Report NR6-4, Federal OCS Lease Blocks 624 

and 625, Beaufort Sea Alaska. 

Shipwrecks 

The BOEMRE Web site was reviewed, and discussions were held with personnel in the BOEMRE Alaska 

office (June 2007) and it was determined that there are no known shipwrecks or obstructions in the areas 

surveyed by Fugro. Several shipwrecks are noted in the general area, however, most are nearshore 

wrecks (outside of the exploration drilling program area) or the locations are not known with certainty. 

No specific shipwrecks are known in the vicinity of the Sivulliq and Torpedo prospects. Shipwrecks or 

other historic artifacts were not observed or reported during the evaluation of side scan sonar data 

presently available for the prospects. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 5-4 May 2011

Archaeology 

Water depths at the planned drill site locations in the Camden Bay area range from 107 ft (32.6 m) at 

Sivulliq N to 124 ft (37.8 m) at Torpedo J. In general, water depths increase to the north. During the last 

major regression in sea level during the last ice age, approximately 18,000 years before present (YBP), 

the sea level was approximately 295 ft (90 m) below the present elevation. Recent research in the Bering 

Sea suggests that sea levels were about 164 ft (50 m) lower than present approximately 11,000 years ago. 

Rising marine waters following the last ice age (approximately 7,500 YBP) would have inundated all of 

the planned drill site locations on the prospects. Early humans in North America could have traversed 

presently inundated areas within the planned drill site locations up until about 7,500 YBP. It is also 

possible that prehistoric archaeological materials could have existed at suitable habitation sites at or near 

the planned drill sites. Candidate sites would be former subaerially exposed areas adjacent to stream 

channels or shoals and barrier islands that were exposed as land masses when sea levels were lower than 

present. Potential buried channels with nearby areas of subtle elevated relief are interpreted to exist near 

the planned drill sites. Early humans could have left behind artifacts at localized habitation sites near the 

planned drill site locations in the Camden Bay area before sea level rose and flooded the Beaufort Shelf 

area; however, shallow hazards reports do not indicate any greater likelihood of artifacts at planned drill 

site locations versus other surveyed areas of Camden Bay. 

The planned drill site locations at the Sivulliq and Torpedo prospects are within water depths where the 

seafloor is subject to extensive ice gouging and ice keel scouring. Side scan sonar studies document 

many intersecting and overlapping ice keel scour lines. Former subaerial exposures most suitable for 

human habitation (e.g. shoals, barrier islands, high terraces adjacent to stream channels, etc.) would be the 

landforms most susceptible to disturbance from ice thrusting and ice gouging after inundation by rising 

sea levels. Even if prehistoric habitation sites and artifacts may once have existed in the vicinity of the 

planned drill site locations, they have almost certainly been destroyed by repeated ice keel scour events 

over the last 7,500 years. Therefore, it can be concluded that the potential for encountering or damaging 

prehistoric archaeological resources by exploration drilling activities is remote at the planned drill site 

locations. 

Soils 

Sivulliq 

From GeoLLC (2007) the surficial Holocene soils consist primarily of soft to stiff silts and clays with low 

to medium plasticity. Surface deposits with interbedded layers of fine to medium sand, silty sand, and 

gravelly muds also may be present. The fine sand present in contact with underlying silts and clays is 

variable, as the sand tends to infill old gouges. Local depositional processes will strongly affect the range 

of properties for Holocene soils, which are expected to be less than 22 ft (7 m) thick at proposed drill site 

locations in the Sivulliq Prospect. Further review of the 1985 mapping of surficial sediment thickness at 

the Sivulliq Prospect finds a 1.6 - 4.9 ft (0.5 - 1.5 m) thinning of surficial sediment thickness between the 

major faults in the interpreted/mapped uplifted area. 

Chirp subbottom profiler data acquired at the Sivulliq Prospect during 2006 support interpretations that 

were made during the 1985 Nortec Hammerhead Prospect (now Sivulliq Prospect) geohazards assessment 

of remolded soils whose thickness was less than 16 - 22 ft (5 - 7 m). Holocene soils were found to be less 

than 22 ft (7 m) thick and underlain by hard cohesive Pleistocene soils. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 5-5 May 2011

As part of the past Hammerhead program, four grab samples and one soil boring were completed in 

relative proximity to several of the proposed Sivulliq wells (Nortec 1985). The grab samples were 

obtained with a Van Veen surface sampler. All of the grab samples indicated "soft, very fine muds." 

Hammerhead Boring 1 was drilled to a depth of 80 ft (24.5 m) approximately 4 mi (6.5 km) southwest of 

the planned Sivulliq N drill site. This soil boring encountered 7.8 ft (2.4 m) of soft to firm clay (likely 

remolded from ice gouging). The ice gouges present in the Hammerhead sonar records support 

interpretations of stiff to hard cohesive soils across the Sivulliq Prospect, as they appear well defined with 

steep-sided flanks and ridges. Hard Pleistocene clay was encountered at 22 ft (7.0 m). Ice-bonded clay 

was noted at 78 ft (24 m) in this borehole. The borehole was drilled by McClelland-EBA in September of 

1984 and the following geotechnical summary was provided: 

• 0 – 7.9 ft (0 -2.4 m) — soft to firm clay 

• 7.9 – 23.0 ft (2.4 - 7.0 m) — very stiff, thinly laminated clay 

• 23.0 – 26.9 ft (7.0 - 8.2 m) — hard/dense gravely clay 

• 26.9 – 80 ft (8.2 -24.5 m) — hard clay, with sand and gravel (ice –bonding at 78.7 ft [24 m]) 

Torpedo 

The surficial Holocene soils appear to consist primarily of silts and clays with a firm consistency and low 

to medium plasticity. The shallow hazards survey (GeoLLC, 2008b) dataset exhibits no evidence of 

bedforms such as sand waves, mounds shoals, or slumping. Local depositional processes in combination 

with ice gouging will strongly affect the range of properties for Holocene soils, which are expected to be 

less than 20 ft (6 m) thick at the Torpedo Prospect. 

Holocene soils are underlain by Pleistocene sediments consisting of laterally discontinuous marine and 

non-marine sequences corresponding to glacial and interglacial periods. These sediments typically 

consist of silty-clays, interspersed gravely muds, interbedded sands or sandy gravels in the Eastern 

Beaufort Sea. The acoustic transparency in the shallow geophysical sections is normally indicative of 

unconsolidated sediments and uniform composition; the hummocky reflectors suggest non-marine 

regressive sedimentary sequences. 

c) Socioeconomic Study Reports 

A Plan of Cooperation (POC) Addendum identifies the measures Shell has developed in consultation with 

North Slope communities and will implement during its planned revised Camden Bay exploration drilling 

program to minimize any adverse effects on the availability of marine mammals for subsistence uses. In 

addition, the POC Addendum details Shell’s communications and consultations with local communities 

concerning its planned exploration drilling program, potential conflicts with subsistence activities, and 

means of resolving any such conflicts (50 CFR § 18.128(d) and 50 CFR § 216.104(a) (12) (i), (ii), (iv)). 

Shell has documented its contacts with North Slope communities, as well as the substance of its 

communications with subsistence stakeholder groups. Tables summarizing the substance of Shell’s 

communications, and responses thereto, are included in the POC Addendum (Appendix H). This POC 

Addendum may be supplemented, as appropriate, to reflect additional engagements with local subsistence 

users and any additional or revised mitigation measures that are adopted as a result of those engagements.

The results of the POC meetings are submitted to BOEMRE in the revised Camden Bay EP, and will be 

provided contemporaneously to NMFS, and USFWS in applications for MMPA authorizations of 

incidental take of the trust species for which these agencies are responsible. The requirements of 

BOEMRE Stipulation No. 5 parallel requirements of the USFWS LOA and the NMFS IHA. The LOA 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 5-6 May 2011

and IHA provide authorization for the nonlethal harassment of species protected by the MMPA. Both the 

USFWS and NMFS require an applicant to implement a POC to mitigate the potential for conflicts 

between the proposed activity and traditional subsistence activities (50 CFR § 18.124(c)(4) and 50 CFR 

§ 216.104(a)(12)). The POC must identify the measures that will be taken to minimize any adverse 

effects on the availability of marine mammals for subsistence uses. In addition, both the USFWS and 

NMFS require an applicant to communicate and consult with local subsistence communities concerning 

the proposed activity, potential conflicts with subsistence activities, and means of resolving any such 

conflicts (50 CFR § 18.128(d) and 50 CFR § 216.104(a) (12) (i), (ii), (iv)). 

Shell offers several programs that involve the training and subsequent hiring of local residents. Programs 

include the following. 

MMO Program 

The MMO program involves the use of local Inupiat residents as MMOs. The MMOs obtain intensive 

training for marine mammal identification and documentation, computer use, and health and safety. 

During Shell’s planned exploration drilling operations, best efforts will be made to hire local MMOs to 

work aboard each vessel. MMOs will also serve as avian observers. 

Subsistence Advisors (SA) Program 

The SA program was developed to address the concerns of the North Slope residents regarding impacts to 

subsistence activities since Shell has active offshore exploration drilling programs in the Beaufort and 

Chukchi Seas. Objectives of the program include: 

• Preserve the subsistence lifestyle of North Slope residents 

• Establish and maintain frequent communications between Shell and subsistence users 

• Communicate the program objectives to community members and 

• Attend community meetings relevant to subsistence use on Shell’s behalf. 

During the SA program, subsistence questionnaires were designed and each SA was asked to fill in one 

questionnaire for each resident that participates in subsistence hunting/fishing activities. In addition, 

subsistence hunters and fishers were asked to draw subsistence use locations on regional maps of their 

respective areas. The maps are intended to define spring and fall hunting/fishing areas, migratory routes, 

calving routes, calving areas, mating areas and feeding ground locations. These various locations were 

digitally transferred onto maps for each village. 

SA reports have been generated documenting the results of the SA work in the villages. These reports are: 

• 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. 

• UIC UMIAQ. 2011. 2010 Subsistence Advisor Program, North Slope Alaska. Report prepared by 

UIC UMIAQ for Shell Exploration and Production Company, Anchorage Alaska. 

Community Liaison Officers (CLO) 

The CLO program includes community liaisons in Point Hope, Kaktovik, and Barrow that serve as 

Shell’s point-of-contact for questions regarding Shell programs . 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 5-7 May 2011

Cultural Awareness Program 

Shell and contractor personnel involved in field operations during the planned 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. The Cultural Awareness Program is described in more detail in Section 11. 

Communication and Call Centers (Com Centers) Program 

The Com Centers program involves hiring of one or two individuals from each of the coastal Beaufort 

and Chukchi Sea villages to monitor and relay radio transmissions between subsistence vessels and 

industry vessels. The sharing of information is intended to reduce or eliminate the potential conflict 

between subsistence users and industry vessels. 

Shell has also funded, sponsored, and supported many local events, charities, and associations in addition 

to holding job fairs and providing information at kiosks during community meetings. 

Shell will identify other locations that are appropriate for Com Centers to mitigate any potential impacts 

from maritime traffic from Dutch Harbor to either Chukchi or Beaufort Sea drilling locations. 

Northern Economics Inc. Report 

In 2009, Shell commissioned a study by Northern Economics Inc. (NEI) and the Institute of Social and 

Economic Research at the University of Alaska Anchorage. The study describes the potential economic 

benefits to the State of Alaska and local governments from developing oil and gas resources in the OCS 

areas, with focus on the Beaufort Sea, Chukchi Sea and the North Aleutian Basin. 

The study determined that development of offshore field(s) in either the Beaufort and/or Chukchi sea(s) 

as a result of Shell’s proposed project will have positive effects on the NSB economy and provide 

employment and community development opportunities for residents from the region (Figure 5.c-1). A 

successful exploration drilling program completed as a result of the wells planned in the revised Camden 

Bay EP could signal the start of such economic development. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 5-8 May 2011

Figure 5.c-1 Estimated Incremental Employment in Alaska and the Remainder of the United States from OCS Development in 

the Beaufort Sea (NEI and ISER 2011) 

An estimated annual average of 30,100 new jobs would be created and sustained for 50 years from 

development of the oil and gas resources of the US Beaufort Sea, with total payroll of $80 billion (NEI 

and ISER 2011). Approximately 13,700 of these new jobs would be in Alaska and approximately 3,100 

would be located in the North Slope Borough (NEI and ISER 2009, NEI and ISER 2011). New revenue 

for the NSB from development of the oil and gas resources of the US Beaufort Sea would total nearly 

$1.2 billion over a 50-year period under current policies (NEI 2011). 

More detail regarding the NEI February 2011 report can be found in the EIA, Appendix F. 

0

5

10

15

20

25

30

35

40

45

50

2008 2014 2020 2026 2032 2038 2044 2050

Employment (in thousands)

Year

Beaufort: 

Rest of the 

Nation Jobs

Beaufort: 

Alaska Jobs
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-1 May 2011

SECTION 6.0 SOLID & LIQUID WASTE AND DISCHARGE 

INFORMATION 

a) Projected Wastes and Projected Ocean Discharges 

This section describes the potential solid and liquid waste generated and disposal methods for four 

planned exploration wells for both the Kulluk and Discoverer. The potential total generated waste stream 

volumes were estimated or calculated from the following sources: 

• Drill cuttings, mud and cement volumes: calculated based on the various approximate widths and 

lengths of portions of each well, while taking into account an additional factor for hole “washout” 

during drilling; 

• Volume for non-contact cooling water, sanitary waste, domestic waste, ballast water, desalination 

unit water, firewater, used oil, potential hazardous waste and trash/debris: supplied by the drilling 

contractor currently working on the Kulluk and Discoverer; 

• Deck drainage: estimated based on collected precipitation expected during each drilling season. 

The EPA GP AKG-28-0000 allows for authorization to discharge regulated waste streams to the ocean 

waters of the Beaufort Sea. In response to comments from North Slope communities, Shell has 

voluntarily decided to not discharge to the ocean the following regulated waste streams: 

• drilling mud and cuttings with adhered mud (GP AKG-28-0000 discharge 001); 

• treated sanitary waste (discharge 003); 

• domestic waste (discharge 004); 

• bilge water (discharge 011); and 

• ballast water (discharge 010). 

These wastes will be transferred from the drilling vessel to a support vessel that will transport the wastes 

to an ocean-going deck barge or waste barge. The deck barge or waste barge will temporarily store the 

mud and cuttings waste, treated sanitary waste, domestic waste, bilge water, and ballast water. At the end 

of each drilling season, all wastes will be transported to an EPA-permitted TDS (see list of potential TDS 

below). 

During drilling operations, cuttings will be separated from the drilling fluids with shakers, de-sanders and 

de-silters. Drilling fluids will be recovered, reconditioned and reused as much as practicable. When 

drilling fluids have been exhausted, those spent drilling fluids will be held in storage aboard the drilling 

vessel until they are transported to the deck barge or waste barge for temporary storage. Drill cuttings 

that are recovered off the shakers will be transferred from the drilling vessel to the same adjacent vessel, 

via a separate flexible hose connection, using compressed air. On the adjacent vessel, the cuttings will be 

held within lined, covered containers. 

The treated sanitary water, domestic water, bilge and ballast water will be transferred via a separate 

flexible hose with secured fittings to an adjacent vessel for transport to and temporary storage on a deck 

barge or waste barge. Shell is finalizing a contract for the handling, transporting and disposal of the 

recovered waste streams. 

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-2 May 2011

In addition to these waste streams, Shell will also temporarily store trash and debris, used petroleum 

products, and potential hazardous waste (i.e. paint, solvents, unused chemicals, batteries, lamps, etc.) to 

be disposed at an EPA-permitted TDS. 

Although Shell has not signed a contract with any particular disposal facility regarding the handling of 

waste streams that will not be discharged to the ocean as of the submission of this revised Camden Bay 

EP, Shell has located appropriate licensed facilities capable of handling the various waste streams. These 

facilities are licensed to handle the materials identified above in accordance with all applicable laws and 

regulations, including the Solid Waste Disposal Act and Resource Conservation and Recovery Act 42 

USC 6901 et seq., and the EPA Solid Waste Disposal Facilities Regulations at 40 CFR 257-259. The 

addresses for these facilities are: 

Waste Management Inc. 

Columbia Ridge Recycling and Landfill

18177 Cedar Springs Lane 

Arlington, OR 97812 

Telephone: 541-454-2030 Fax: 541-454-3312 

http://www.wmnorthwest.com/landfill/landfillcities/columbia.html

(disposal of WBM, cuttings, sanitary waste water, domestic waste water, ballast water, bilge water, solid 

trash and debris, used petroleum products, hazardous waste) 

Emerald Services Inc. (local address) 

425 Outer Springer Loop Road 

Palmer, AK 99645 

Telephone: 907-258-1558 

(disposal of used petroleum products, hazardous waste; disposal occurs in Seattle, WA) 

The following tables (6.a-1 through 6.a-4) present relevant information regarding disposal of solid and 

liquid wastes expected to be generated by the Kulluk or Discoverer per well drilled during the revised 

Camden Bay drilling program. The discharge number listed under the ‘Type of Waste’ column is a 

reference to the numbered discharges listed in GP AKG-28-0000. 

Kulluk Disposal Caisson 

All wastes not captured for offsite disposal will be discharged to the ocean. 

The base of the disposal caisson while drilling is approximately 41 ft (12.5 m) below the surface of the 

ocean. Because of heave, the water level inside the caisson is constantly undergoing minor changes. The 

disposal caisson is not equipped with a one-way or "float" valve; it is a 36-in. diameter open pipe. Since 

it remains open to the sea at all times, the disposal caisson is constantly filled with water and serves as the 

conduit through which selected waste streams are disposed below sea level. Figure 6a-1 displays the 

disposal caisson for the Kulluk. 

Modeling of the discharge of cuttings generated while constructing the MLC, as well as the 36- and 26-

inch hole segments, was completed assuming a discharge point of approximately 10 ft (3 m) above the 

seafloor (Section 6c). 

Discoverer 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 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-3 May 2011

and extends from the main deck level to well below the water line. Certain waste streams are collected 

aboard the drillship to a point on the main deck near the mud room. A 15-in. (38 cm) 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. Because it remains open to the sea 

at all times, the disposal caisson is constantly filled with water and serves as the conduit through which 

selected waste streams are disposed below sea level. 

With the bottom of the sponson located 5.6 ft (1.7 m) above the keel, and the draught of the Discoverer

being 25.2 ft (7.7 m) while drilling, the base of the disposal caisson while drilling is approximately 19.6 ft 

(6.0 m) below mean sea level. Because of heave, the water level inside the caisson changes constantly. 

Figure 6.a-1 shows the disposal caisson location. 

Modeling of the discharge of cuttings generated while constructing the MLC, as well as the 36- and 26-

inch hole segments, was completed assuming a discharge point of approximately 10 ft (3 m) above the 

seafloor (Section 6c). 

In addition to cuttings and WBM that will be captured and stored on the drilling vessel for later disposal, 

there will be an additional 1,500 bbl of mud stored onboard in a reserve tank. At the end of the drilling 

season, this mud will also be transferred to a vessel for disposal at one of the facilities previously listed. 

Because the drilling sequence is not defined, and since ice and weather conditions could limit the 

available time remaining in the drilling season, this 1,500 bbl mud volume is included in the following 

discharge tables for each well in the planned exploration drilling program. 

Table 6.a-1 Projected Wastes Generated and Ocean Discharges for Sivulliq Location G 

Type of Waste Total Generated* Total Amount to be 

Discharged Discharge Rate Discharge Method** 

Drill Cuttings – 

Discharge 013 

Kulluk – 5,184 bbl 

(cuttings only; no 

drilling mud used) 

5,184 bbl (cuttings 

only; no drilling mud 

used) 

432 bbl/day 

(discharged over 

12 days) 

Cuttings from the MLC 

through 26-in. diameter 

hole section will be 

deposited on the 

surface of the seafloor 

Discoverer – 3,851 bbl 

(cuttings only; no 

drilling mud used) 

3,851 bbl (cuttings 

only; no drilling mud 

used) 

321 bbl/day 

(discharged over 

12 days) 

Cuttings from the MLC 

through 26-in. diameter 

hole section will be 

deposited on the 

surface of the seafloor 

Water Based 

Mud – 

Discharge 001 

2,213 bbl (includes 

1,500 bbl of mud in the 

active pit system 

remaining at the 

conclusion of drilling 

and abandonment 

operations) 

0 bbl 0 bbl/day No discharge. Water 

based mud will be 

collected and 

transported out of 

region for disposal at a 

licensed TDS 

Drill Cuttings 

From Water 

Base Drilling 

Interval – 

Discharge 001 

713 bbl 0 bbl 0 bbl/day No discharge. 

Cuttings will be 

collected and 

transported out of 

region for disposal at a 

licensed TDS 

Excess Cement 

– Discharge 012 

50 bbl 50 bbl Two occasions at 

1 bbl/minute (min) 

Forty-five bbl 

discharged at seafloor 

during 30-and 20-in. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-4 May 2011

Table 6.a-1 Projected Wastes Generated and Ocean Discharges for Sivulliq Location G 

Type of Waste Total Generated* Total Amount to be 

Discharged Discharge Rate Discharge Method** 

pipe cementing 

operations with 5 bbl 

discharged at the 

surface with wash-up 

water 

Non-Contact 

Cooling Water – 

Discharge 009 

Kulluk – 448,052 bbl 

(13,178 bbl/day for 34 

days) 

448,052 bbl 13,178 bbl/day Discharged to the sea 

through the disposal 

caisson 

Discoverer – 1,530,000 

bbl (45,000 bbl/day for 

34 days) 

1,530,000 bbl 45,000 bbl/day Discharged to the sea 

at several sites around 

the hull 

Sanitary Waste 

– Discharge 003 

Kulluk – 4,371 bbl all 

recycled (throughput 

based on 108 persons 

at 50 gallons 

(gal)/person/day for 34 

days) 

0 bbl/well 0 bbl/day No discharge. Treated 

in the Marine Sanitation 

Device (MSD) and 

recycled for use aboard 

the Kulluk. Any 

unrecycled sanitary 

waste will be 

transported out of 

region for disposal at a 

licensed TDS 

Discoverer – 1,020 bbl 

(based on 140 persons 

at 9 gal/person/day for 

34 days) 

0 bbl/well 0 bbl/day No discharge. Treated 

in the MSD and stored 

on the drillship then 

transported out of 

region for disposal at a 

licensed TDS

Domestic Waste 

– Discharge 004 

Kulluk – 8,742 bbl 

(based on 108 persons 

at 100 gal/person/day 

for 34 days) 

0 bbl 0 bbl/day No discharge. Treated 

as required and stored 

aboard then 

transported out of 

region for disposal at a 

licensed TDS. 

Food wastes will not be 

discharged, they will be 

incinerated 

Discoverer – 11,333 

bbl (based on 140 

persons at 100 

gal/person/day for 34 

days) 

0 bbl 0 bbl/day 

Desalination 

Unit Brine Water 

– Discharge 005 

4,200 bbl (based on 

125 bbl/day for 34 

days) 

4,200 bbl 125 bbl/day Discharged through 

disposal caisson below 

water’s surface 

Deck Drainage 

– Discharge 002 

170 bbl (based on 5 

bbl/day for 34 days) 

170 bbl 5 bbl/day 

(dependent on 

rainfall) 

Discharged through 

disposal caisson below 

water’s surface 

Uncontaminated 

Ballast Water – 

Discharge 010 

Kulluk – 1,500 bbl 

(approximately 44 

bbl/day for 34 days) 

0 bbl 0 bbl/day No discharge. Ballast 

water is stored aboard 

then transported out of 

region for disposal at a 

licensed TDS 

Discoverer – 170 bbl 

(based on 5 bbl/day for 

34 days) 

0 bbl 0 bbl/day 

Firewater 

Bypass – 

Discharge 008 

Kulluk – 286 bbl (1 test) 286 bbl (1 test) Monthly test of fire 

hoses at 200 

gallons per minute 

(gal/min) for 60 

minutes 

Discharged through 

disposal caisson below 

water’s surface 

Discoverer – no testing No testing No testing No testing 

Bilge Water – 

Discharge 011 

Kulluk – 170 bbl 

(based on 5 bbl/day for 

34 days) 

0 bbl/well 0 bbl/day No discharge. Treated 

in an oil/water 

separator; 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-5 May 2011

Table 6.a-1 Projected Wastes Generated and Ocean Discharges for Sivulliq Location G 

Type of Waste Total Generated* Total Amount to be 

Discharged Discharge Rate Discharge Method** 

Discoverer – 442 bbl 

(based on 13 bbl/day 

for 34 days) 

0 bbl/well 0 bbl/day uncontaminated water 

is stored aboard then 

transported out of 

region for disposal at a 

licensed TDS 

BOP Fluid – 

Discharge 006 

56.4 bbl 56.4 bbl Up to 6 BOP tests 

at an average 9.4 

bbl/test 

Discharged at the 

seafloor at the BOP 

Trash and 

Debris 

300 bbl/month 0 bbl/well 0 bbl/day No discharge. 

Segregated and 

disposed of at an 

approved TDS 

Used Oil (Lube 

Oil) 

50 bbl 0 bbl 0 bbl/day No discharge. Stored 

aboard in waste oil 

tanks. Transferred to 

lube cubes for transport 

by boat to an approved 

TDS 

Hazardous 

Waste 

10 bbl 0 bbl 0 bbl/day No discharge. Stored 

aboard in an approved 

container. Transferred 

by boat to an approved 

TDS 

*Discharges for the Kulluk or Discoverer are the same unless where noted. 

**The types of wastes whose discharge method is listed as “No Discharge” will be shipped to one of the EPA approved facilities listed in Section 

6 a). 

Table 6.a-2 Projected Wastes Generated and Ocean Discharges for Sivulliq Location N 

Type of Waste Total Generated* Total Amount to be 

Discharged Discharge Rate Discharge Method** 

Drill Cuttings – 

Discharge 013 

Kulluk – 5,187 bbl 

(cuttings only; no 

drilling mud used) 

5,187 bbl (cuttings 

only; no drilling mud 

used) 

432 bbl/day 

(discharged over 

12 days) 

Cuttings from the MLC 

through 26-in. diameter 

hole section will be 

deposited on the 

surface of the seafloor 

Discoverer – 3,854 bbl 

(cuttings only; no 

drilling mud used) 

3,854 bbl (cuttings 

only; no drilling mud 

used) 

321 bbl/day 

(discharged over 

12 days) 

Cuttings from the MLC 

through 26-in. diameter 

hole section will be 

deposited on the 

surface of the seafloor 

Water Based 

Mud – 

Discharge 001 

2,213 bbl (includes 

1,500 bbl of mud in the 

active pit system 

remaining at the 

conclusion of drilling 

and abandonment 

operations) 

0 bbl 0 bbl/day No discharge. Water 

based mud will be 

collected and 

transported out of 

region for disposal at a 

licensed TDS 

Drill Cuttings 

From Water 

Base Drilling 

Interval – 

Discharge 001 

713 bbl 0 bbl 0 bbl/day No discharge. 

Cuttings will be 

collected and 

transported out of 

region for disposal at a 

licensed TDS 

Excess Cement 

– Discharge 012 

50 bbl 50 bbl Two occasions at 

1 bbl/min 

Forty-five bbl 

discharged at seafloor 

during 30- and 20-in. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-6 May 2011

Table 6.a-2 Projected Wastes Generated and Ocean Discharges for Sivulliq Location N 

Type of Waste Total Generated* Total Amount to be 

Discharged Discharge Rate Discharge Method** 

pipe cementing 

operations with 5 bbl 

discharged at the 

surface with wash-up 

water 

Non-Contact 

Cooling Water – 

Discharge 009 

Kulluk – 448,052 bbl 

(13,178 bbl/day for 34 

days) 

448,052 bbl 13,178 bbl/day Discharged to the sea 

through the disposal 

caisson 

Discoverer – 1,530,000 

bbl (45,000 bbl/day for 

34 days) 

1,530,000 bbl 45,000 bbl/day Discharged to the sea 

at several sites around 

the hull 

Sanitary Waste 

– Discharge 003 

Kulluk - 4,371 bbl all 

recycled (throughput 

based on 108 persons 

at 50 gal/person/day for 

34 days) 

0 bbl/well 0 bbl/day No discharge. Treated 

in the MSD and 

recycled for use aboard 

the Kulluk. Any 

unrecycled sanitary 

waste will be 

transported out of 

region for disposal at a 

licensed TDS 

Discoverer – 1,020 bbl 

(based on 140 persons 

at 9 gal/person/day for 

34 days) 

0 bbl/well 0 bbl/day No discharge. Treated 

in the MSD and stored 

on the drillship then 

transported out of 

region for disposal at a 

licensed TDS 

Domestic Waste 

– Discharge 004 

Kulluk – 8,742 bbl 

(based on 108 persons 

at 100 gal/person/day 

for 34 days) 

0 bbl 0 bbl/day No discharge. Treated 

as required and stored 

aboard then 

transported out of 

region for disposal at a 

licensed TDS. Food 

wastes will not be 

discharged, they will be 

incinerated 

Discoverer – 11,333 

bbl (based on 140 

persons at 100 

gal/person/day for 34 

days) 

0 bbl 0 bbl/day 

Desalination 

Unit Brine Water 

– Discharge 005 

4,200 bbl (based on 

125 bbl/day for 34 

days) 

4,200 bbl 125 bbl/day Discharged through 

disposal caisson below 

water’s surface 

Deck Drainage 

– Discharge 002 

170 bbl (based on 5 

bbl/day for 34 days) 

170 bbl 5 bbl/day 

(dependent on 

rainfall) 

Discharged through 

disposal caisson below 

water’s surface 

Uncontaminated 

Ballast Water – 

Discharge 010 

Kulluk – 1,500 bbl 

(approximately 44 

bbl/day for 34 days) 

0 bbl 0 bbl/day No discharge. Ballast 

water is stored aboard 

then transported out of 

region for disposal at a 

licensed TDS 

Discoverer – 170 bbl 

(based on 5 bbl/day for 

34 days) 

0 bbl 0 bbl/day 

Firewater 

Bypass – 

Discharge 008 

Kulluk – 286 bbl (1 test) 286 bbl (1 test) Monthly test of fire 

hoses at 200 

gal/min for 60 

minutes 

Discharged through 

disposal caisson below 

water’s surface 

Discoverer – no testing No testing No testing No testing 

Bilge Water – Kulluk – 170 bbl 0 bbl/well 0 bbl/day No discharge. Treated 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-7 May 2011

Table 6.a-2 Projected Wastes Generated and Ocean Discharges for Sivulliq Location N 

Type of Waste Total Generated* Total Amount to be 

Discharged Discharge Rate Discharge Method** 

Discharge 011 (based on 5 bbl/day for 

34 days) 

in an oil/water 

separator; 

uncontaminated water 

is stored aboard then 

transported out of 

region for disposal at a 

licensed TDS 

Discoverer – 442 bbl 

(based on 13 bbl/day 

for 34 days) 

0 bbl/well 0 bbl/day 

BOP Fluid – 

Discharge 006 

56.4 bbl 56.4 bbl Up to 6 BOP tests 

at an average 9.4 

bbl/test 

Discharged at the 

seafloor at the BOP 

Trash and 

Debris 

300 bbl/month 0 bbl/well 0 bbl/day No discharge. 

Segregated and 

disposed of at an 

approved TDS 

Used Oil (Lube 

Oil) 

50 bbl 0 bbl 0 bbl/day No discharge. Stored 

aboard in waste oil 

tanks. Transferred to 

lube cubes for transport 

by boat to an approved 

TDS 

Hazardous 

waste 

10 bbl 0 bbl 0 bbl/day No discharge. Stored 

aboard in an approved 

container. Transferred 

by boat to an approved 

TDS 

*Discharges for the Kulluk or Discoverer are the same unless where noted. 

**The types of wastes whose discharge method is listed as “No Discharge” will be shipped to one of the EPA approved facilities listed in Section 

6 a). 

Table 6.a-3 Projected Wastes Generated and Ocean Discharges for Torpedo Location H 

Type of Waste Total Generated* Total Amount to be 

Discharged** Discharge Rate Discharge Method 

Drill Cuttings – 

Discharge 013 

Kulluk – 5,335 bbl 

(cuttings only; no 

drilling mud used) 

5,335 bbl (cuttings 

only; no drilling mud 

used) 

445 bbl/day 

(discharged over 

12 days) 

Cuttings from the MLC 

through 26-in. diameter 

hole section will be 

deposited on the 

surface of the seafloor 

Discoverer – 4,002 bbl 

(cuttings only; no 

drilling mud used) 

4,002 bbl (cuttings 

only; no drilling mud 

used) 

334 bbl/day 

(discharged over 

12 days) 

Cuttings from the MLC 

through 26-in. diameter 

hole section will be 

deposited on the 

surface of the seafloor 

Water Based 

Mud – 

Discharge 001 

3,022 bbl (includes 

1,500 bbl of mud in the 

active pit system 

remaining at the 

conclusion of drilling 

and abandonment 

operations) 

0 bbl 0 bbl/day No discharge. Water 

based mud will be 

collected and 

transported out of 

region for disposal at a 

licensed TDS 

Drill Cuttings 

From Water 

Base Drilling 

Interval – 

Discharge 001 

1,522 bbl 0 bbl 0 bbl/day No discharge. 

Cuttings will be 

collected and 

transported out of 

region for disposal at a 

licensed TDS 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-8 May 2011

Table 6.a-3 Projected Wastes Generated and Ocean Discharges for Torpedo Location H 

Type of Waste Total Generated* Total Amount to be 

Discharged** Discharge Rate Discharge Method 

Excess Cement 

– Discharge 012 

50 bbl 50 bbl two occasions at 

1 bbl/min 

Forty-five bbl 

discharged at seafloor 

during 30- and 20-in. 

pipe cementing 

operations with 5 bbl 

discharged at the 

surface with wash-up 

water 

Non-Contact 

Cooling Water – 

Discharge 009 

Kulluk – 579,832 bbl 

(13,178 bbl/day for 44 

days) 

579,832 bbl 13,178 bbl/day Discharged to the sea 

through the disposal 

caisson 

Discoverer – 1,980,000 

bbl (45,000 bbl/day for 

44 days) 

1,980,000 bbl 45,000 bbl/day Discharged to the sea 

at several sites around 

the hull 

Sanitary Waste 

– Discharge 003 

Kulluk – 5,657 bbl all 

recycled (throughput 

based on 108 persons 

at 50 gal/person/day for 

44 days) 

0 bbl 0 bbl/day No discharge. Treated 

in the MSD and 

recycled for use aboard 

the Kulluk. Any 

unrecycled sanitary 

waste will be 

transported out of 

region for disposal at a 

licensed TDS 

Discoverer – 1,320 bbl 

(based on 140 persons 

at 9 gal/person/day for 

44 days) 

0 bbl 0 bbl/day No discharge. Treated 

in the MSD and stored 

on the drillship then 

transported out of 

region for disposal at a 

licensed TDS

Domestic Waste 

– Discharge 004 

Kulluk – 11,314 bbl 

(based on 108 persons 

at 100 gallons/person/ 

day for 44 days) 

0 bbl 0 bbl/day No discharge. Treated 

as required and stored 

aboard then 

transported out of 

region for disposal at a 

licensed TDS. Food 

wastes will not be 

discharged, they will be 

incinerated 

Discoverer – 14,667 

bbl (based on 140 

persons at 100 

gal/person/day for 44 

days) 

0 bbl 0 bbl/day 

Desalination 

Unit Brine Water 

– Discharge 005 

5,500 bbl (based on 

125 bbl/day for 44 

days) 

5,500 bbl 125 bbl/day Discharged through 

disposal caisson below 

water’s surface 

Deck Drainage 

– Discharge 002 

220 bbl (based on 5 

bbl/day for 44 days) 

220 bbl 5 bbl/day 

(dependent on 

rainfall) 

Discharged through 

disposal caisson below 

water’s surface 

Uncontaminated 

Ballast Water – 

Discharge 010 

Kulluk – 1,500 bbl 

(approximately 34 

bbl/day for 44 days) 

0 bbl 0 bbl/day No discharge. Ballast 

water is stored aboard 

then transported out of 

region for disposal at a 

licensed TDS 

Discoverer – 220 bbl 

(based on 5 bbl/day for 

44 days) 

0 bbl 0 bbl/day 

Firewater 

Bypass – 

Discharge 008 

Kulluk – 572 bbl 

(2 tests) 

572 bbl (2 tests) Monthly test of fire 

hoses at 200 

gal/min for 60 

minutes 

Discharged through 

disposal caisson below 

water’s surface 

Discoverer – no testing No testing No testing No testing 

Bilge Water – 

Discharge 011 

Kulluk – 220 bbl (based 

on 5 bbl/day for 44 

0 bbl 0 bbl/day No discharge. Treated 

in an oil/water 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-9 May 2011

Table 6.a-3 Projected Wastes Generated and Ocean Discharges for Torpedo Location H 

Type of Waste Total Generated* Total Amount to be 

Discharged** Discharge Rate Discharge Method 

days) separator; 

uncontaminated water 

is stored aboard then 

transported out of 

region for disposal at a 

licensed TDS 

Discoverer – 572 bbl 

(based on 13 bbl/day 

for 44 days) 

0 bbl 0 bbl/day 

BOP Fluid – 

Discharge 006 

56.4 bbl 56.4 bbl Up to 6 BOP tests 

at an average 9.4 

bbl/test 

Discharged at the 

seafloor at the BOP 

Trash and 

Debris 

300 bbl/month 0 bbl 0 bbl/day No discharge. 

Segregated and 

disposed of at an 

approved TDS 

Used Oil (Lube 

Oil) 

50 bbl 0 bbl 0 bbl/day No discharge. Stored 

aboard in waste oil 

tanks. Transferred to 

lube cubes for transport 

by boat to an approved 

TDS 

Hazardous 

Waste 

10 bbl 0 bbl 0 bbl/day No discharge. Stored 

aboard in an approved 

container. Transferred 

by boat to an approved 

TDS 

*Discharges for the Kulluk or Discoverer are the same unless where noted. 

**The types of wastes whose discharge method is listed as “No Discharge” will be shipped to one of the EPA approved facilities listed in Section 

6 a). 

Table 6.a-4 Projected Wastes Generated and Ocean Discharges for Torpedo Location J 

Type of Waste Total Generated* Total Amount to be 

Discharged** Discharge Rate Discharge Method 

Drill Cuttings – 

Discharge 013 

Kulluk – 5,335 bbl 

(cuttings only; no 

drilling mud used) 

5,335 bbl (cuttings 

only; no drilling mud 

used) 

445 bbl/day 

(discharged over 

12 days) 

Cuttings from the MLC 

through 26-in. diameter 

hole section will be 

deposited on the 

surface of the seafloor 

Discoverer – 4,002 bbl 

(cuttings only; no 

drilling mud used) 

4,002 bbl (cuttings 

only; no drilling mud 

used) 

334 bbl/day 

(discharged over 

12 days) 

Cuttings from the MLC 

through 26-in. diameter 

hole section will be 

deposited on the 

surface of the seafloor 

Water Based 

Mud – 

Discharge 001 

3,003 bbl (includes 

1,500 bbl of mud in the 

active pit system 

remaining at the 

conclusion of drilling 

and abandonment 

operations) 

0 bbl 0 bbl/day No discharge. Water 

based mud will be 

collected and 

transported out of 

region for disposal at a 

licensed TDS 

Drill Cuttings 

From Water 

Base Drilling 

Interval – 

Discharge 001 

1,503 bbl 0 bbl 0 bbl/day No discharge. 

Cuttings will be 

collected and 

transported out of 

region for disposal at a 

licensed TDS 

Excess Cement 

– Discharge 012 

50 bbl 50 bbl Two occasions at 

1 bbl/min 

Forty-five bbl 

discharged at seafloor 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-10 May 2011

Table 6.a-4 Projected Wastes Generated and Ocean Discharges for Torpedo Location J 

Type of Waste Total Generated* Total Amount to be 

Discharged** Discharge Rate Discharge Method 

during 30- and 20-in. 

pipe cementing 

operations with 5 bbl 

discharged at the 

surface with wash-up 

water 

Non-Contact 

Cooling Water – 

Discharge 009 

Kulluk – 579,832 bbl 

(13,178 bbl/day for 44 

days) 

579,832 bbl 13,178 bbl/day Discharged to the sea 

through the disposal 

caisson 

Discoverer – 1,980,000 

bbl (45,000 bbl/day for 

44 days) 

1,980,000 bbl 45,000 bbl/day Discharged to the sea 

at several sites around 

the hull 

Sanitary Waste 

– Discharge 003 

Kulluk – 5,657 bbl all 

recycled (throughput 

based on 108 persons 

at 50 gal/person/day for 

44 days) 

0 bbl 0 bbl/day No discharge. Treated 

in the MSD and 

recycled for use aboard 

the Kulluk. Any 

unrecycled sanitary 

waste will be 

transported out of 

region for disposal at a 

licensed TDS 

Discoverer – 1,320 bbl 

(based on 140 persons 

at 9 gal/person/day for 

44 days) 

0 bbl 0 bbl/day No discharge. Treated 

in the MSD and stored 

on the drillship then 

transported out of 

region for disposal at a 

licensed TDS

Domestic Waste 

– Discharge 004 

Kulluk – 11,314 bbl 

(based on 108 persons 

at 100 gal/person/day 

for 44 days) 

0 bbl 0 bbl/day No discharge. Treated 

as required and stored 

aboard then 

transported out of 

region for disposal at a 

licensed TDS. Food 

wastes will not be 

discharged, they will be 

incinerated 

Discoverer – 14,667 

bbl (based on 140 

persons at 100 

gal/person/day for 44 

days) 

0 bbl 0 bbl/day 

Desalination 

Unit Brine Water 

– Discharge 005 

5,500 bbl (based on 

125 bbl/day for 44 

days) 

5,500 bbl 125 bbl/day Discharged through 

disposal caisson below 

water’s surface 

Deck Drainage 

– Discharge 002 

220 bbl (based on 5 

bbl/day for 44 days) 

220 bbl 5 bbl/day 

(dependent on 

rainfall) 

Discharged through 

disposal caisson below 

water’s surface 

Uncontaminated 

Ballast Water – 

Discharge 010 

Kulluk – 1,500 bbl 

(approximately 34 

bbl/day for 44 days) 

0 bbl 0 bbl/day No discharge. Ballast 

water is stored aboard 

then transported out of 

region for disposal at a 

licensed TDS 

Discoverer - 220 bbl 

(based on 5 bbl/day for 

44 days) 

0 bbl 0 bbl/day 

Firewater 

Bypass – 

Discharge 008 

Kulluk – 572 bbl (2 

tests) 

572 bbl (2 tests) Monthly test of fire 

hoses at 200 

gal/min for 60 

minutes 

Discharged through 

disposal caisson below 

water’s surface 

Discoverer – no testing No testing No testing No testing 

Bilge Water – 

Discharge 011 

Kulluk – 220 bbl/well 

(based on 5 bbl/day for 

44 days) 

0 bbl 0 bbl/day No discharge. Treated 

in an oil/water 

separator; 

Discoverer – 572 bbl 0 bbl 0 bbl/day uncontaminated water 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-11 May 2011

Table 6.a-4 Projected Wastes Generated and Ocean Discharges for Torpedo Location J 

Type of Waste Total Generated* Total Amount to be 

Discharged** Discharge Rate Discharge Method 

(based on 13 bbl/day 

for 44 days) 

is stored aboard then 

transported out of 

region for disposal at a 

licensed TDS 

BOP Fluid – 

Discharge 006 

56.4 bbl 56.4 bbl Up to 6 BOP tests 

at an average 9.4 

bbl/test 

Discharged at the 

seafloor at the BOP 

Trash and 

Debris 

300 bbl/month 0 bbl 0 bbl/day No discharge. 

Segregated and 

disposed of at an 

approved TDS 

Used Oil (Lube 

Oil) 

50 bbl 0 bbl 0 bbl/day No discharge. Stored 

aboard in waste oil 

tanks. Transferred to 

lube cubes for transport 

by boat to an approved 

TDS 

Hazardous 

Waste 

10 bbl 0 bbl 0 bbl/day No discharge. Stored 

aboard in an approved 

container. Transferred 

by boat to an approved 

TDS 

Discharges for the Kulluk or Discoverer are the same unless where noted. 

**The types of wastes whose discharge method is listed as “No Discharge” will be shipped to one of the EPA approved facilities listed in Section 

6 a). 

A list of the components that may be added to the drilling fluid are captured in Table 6.a-5. This 

component list and the respective volumes have been designed for the drilling depth from the MLC to 

proposed total depth for the Torpedo H wells in the revised Camden Bay EP (the Load Out list for the 

Sivulliq wells will involve smaller volumes and numbers of containers due to the shallower depths). 

Table 6.a-5 Drilling Fluid Components and Load Out List 

PRODUCT UNITS Unit Size Units per Box Total Sacks 

Number of 

Pallets 

(unless 

noted) 

M-I WATE SACK bulk N/A 6,800 340 tons 

M-I GEL SACK bulk 30 1,500 75 tons 

CAUSTIC SODA SACK 50 lb 50 100 2 

SODA ASH SACK 50 lb 50 100 2 

SODIUM BICARBONATE SACK 50 lb 50 100 2 

DUOVIS SACK 25 lb 80 320 4 

KLASTOP DRUM 55 gal 4 240 60 

POLY PAC R SACK 50 lb 40 80 2 

POLY PAC UL SACK 50 lb 40 160 4 

CITRIC ACID SACK 50 lb 50 100 2 

CONTINGENCY

SALT (or Brine) SACK BIG BAG 1500 kg 55 55 

DEFOAM X CAN 5 gal 32 32 1 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-12 May 2011

Table 6.a-5 Drilling Fluid Components and Load Out List 

PRODUCT UNITS Unit Size Units per Box Total Sacks 

Number of 

Pallets 

(unless 

noted) 

NUT PLUG (ASST.) SACK 50 40 40 1 

IDCAP D SACK 50 40 160 4 

MIX II (ASST.) SACK 25 40 40 1 

DESCO CF SACK 25# 80 80 1 

SAPP SACK 50 45 45 1 

DUROGEL SACK 50 40 320 8 

Myacide SACK 5 gal 32 128 4 

 Total Pallets 154 

BRINE (9.8 pounds per gallon 

[ppg]), only 8 Big Bags of Salt 

for contingencies 8,214 bbl 

Aboard the Kulluk or Discoverer there is a sufficient supply of mud materials to prepare a completely 

new mud system in case the original mud system must be replaced. There is also a sufficient supply of 

mud chemicals and other materials available to combat lost circulation should it become problematic. 

Further, there is sufficient cement to squeeze off and permanently seal a severe lost circulation zone. In 

addition, sufficient hole diameter is planned and pipe will be available to case off a severe lost circulation 

zone and still deliver a suitable wellbore through all objective intervals. 

Cement Composition 

Two types of cement discharges are expected. One of these involves bulk cement plus additives 

circulated around the 30-inch (in.) structural pipe and 20-in. conductor casing that collects in the base of 

the MLC. There, the cement cures to a hardened mass surrounding the 30-in. conductor. The combined 

volume of both circulated cement volumes can be as much as 45 barrels (bbl) of cement slurry per well. 

The other discharge involves small volumes of cement washed from the cement pump and lines on the 

drilling vessel at the surface after cementing casing strings1

 or setting cement abandonment plugs. The 

total volume of cement slurry discharged to the ocean from these operations could be as much as five bbl 

per well. 

1. Both of the large-diameter pipe strings are cemented using the following mixture (total 

discharged volume in base of MLC = 45 bbl/well): 

 

1

 While cementing each casing string, the surface lines and cement pump will be cleaned by washing up “on top of 

the plug” meaning that the cement so removed is pumped down the casing ahead of the displacement fluid to 

minimize discharges to the sea. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-13 May 2011

• Type C Permafrost2 cement (API Class C cement plus gypsum and/or calcium sulfate 

hemi-hydrate) 

• Seawater 

2. Cement and other materials washed from the cement unit and piping may include (total 

discharged volume = 5 bbl/well): 

• Type C Permafrost2

 cement 

• API Class G “Premium” cement 

• Econolite L2

 (flyash, calcium oxide) in small amounts 

• Halad-344EXP2

 (fluid loss additive) in very small amounts 

• Calcium chloride (accelerator) in very small amounts 

• SCR-1002

 (sodium citrate retarder) in very small amounts 

• Dual Spacer2

 (surfactant blend) in trace amounts 

• Fresh water (mixing fluid) 

• Seawater (wash water) 

Blowout Preventer Fluid Composition 

BOP fluid is a pressured fresh water-based fluid used to operate various components of the subsea BOP 

including rams, locking mechanisms, annular preventers, choke and kill line valves and the hydraulic 

connectors to the wellhead and to the lower marine riser package. The fluid is discharged at the device 

after use rather than bringing it back to the surface in a closed loop system. This reduces back-pressure 

and ensures the devices will function quickly. Only small volumes of fluid are discharged within and just 

above the MLC which dilute and diffuse quickly in the seawater column. It is estimated that 6 or 7 BOP 

tests will occur during the drilling of each well for a total of 56.4 bbl of BOP fluid per well (see Section 6 

of the revised Camden Bay EP). The composition of the BOP fluid is as follows: 

• Fresh water 

• 12.5% Pelagic GZ3

 (water-based lubricant concentrate) 

• 25% monoethylene glycol (antifreeze) 

 

 

2

 All additive names are registered products of Halliburton. 3

 A product of Niche Products Ltd., classified Green Zone (OSPAR) or PLONOR 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-14 May 2011Figure 6a-1 Kulluk Disposal Caisson Location 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-15 May 2011

In addition to Shell’s authorization to discharge wastes under the NPDES General Permit AKG-28-0000, 

drilling support vessels in excess of 300 gross registered tons or having a ballast capacity of 2,113 gal (8 

m3

) or greater must acquire authorization to discharge under the EPA administered Vessel General Permit 

for Discharges Incidental to the Normal Operation of Vessels Version Nov. 2010 (VGP). Authorizations 

to discharge under this VGP will be undertaken by the vessel owner and/or operator and is not a part of 

Shell’s required permit and authorization application submittals. 

b) National Pollutant Discharge Elimination System Authorization to Discharge 

Authorization for the Discoverer to discharge under GP AKG-28-0000 (authorization No. AKG-28-0005) 

was granted to Shell on April 20, 2010 covering lease blocks 6610 and 6658. 

On October 12, 2010, Shell submitted a new NOI for the Discoverer to discharge waste on lease block 

6658, updating the EPA regarding the selected waste streams that would not be discharged, but collected, 

temporarily stored onsite and then shipped for final disposal at an approved disposal site. These waste 

streams include drilling mud and cuttings (GP AKG-28-0000 Discharge 001), sanitary wastes (Discharge 

003), domestics wastes (Discharge 004), uncontaminated ballast water (Discharge 010) and bilge water 

(Discharge 011). 

On December 15, 2010, Shell submitted a letter request to the EPA for an administrative extension of 

coverage under the GP AKG-28-0000 for the current authorization AKG-28-0005. In accordance with 40 

CFR 122.21(d) Shell submitted the request for administrative extension, including copies of completed 

NOIs for lease block 6610 and 6658, greater than 180 days prior to expiration of GP AKG-28-0000. At 

the same time Shell submitted a new NOI requesting authorization for the Discoverer to discharge under 

GP AKG-28-0000 for lease block 6559. 

On April 8, 2011, Supplemental NOI information requesting authorization for the Kulluk to discharge 

under GP AKG-28-0000 for lease block 6559, 6610 and 6658 was sent to the EPA. These NOIs are 

similar to those of the Discoverer in that the previously mentioned wastes will be collected, stored and 

disposed of at an approved facility. 

The projected wastes and amounts listed in Tables 6.a-1 through 6.a-4 are only applicable to the Kulluk or 

Discoverer; support vessels are not subject to GP AKG-28-0000. Support vessels will be authorized to 

discharge various waste under the VGP administered by the EPA. 

c) Modeling Report 

All permitted discharges will occur in OCS waters. No extended mixing zones or zones of deposit have 

been requested. Shell has committed to not discharging drilling mud, cuttings with adhered mud, treated 

sanitary wastes, domestic wastes, bilge water and ballast water. These waste streams will be collected, 

stored and then shipped for disposal at one of the approved facilities listed in Section 6a). 

Shell has modeled the discharge of (non-contact) cooling water to the ocean as well as cuttings from the 

MLC, the 36-in. diameter hole and the 26-in. diameter hole sections of each well on the seafloor. 

Modeling information regarding these discharges is as follows. 

Temperature and Salinity in the Area of the Prospects 

In the summer, Beaufort Sea coastal waters become stratified with warm, fresh water blanketing 

underlying colder dense seawater. Stratification produces warmer, brackish water along the shoreline 

where an abundance of fish, birds, marine mammals, and other biota can feed and travel. Stratification is 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-16 May 2011

disrupted by storm activity or wind that agitates the water column delivering nutrient rich water to the 

surface. Stratification ceases as temperatures cool surface waters producing a uniform temperature water 

column. From October through June, the water column remains unstratified and fairly uniform with 

salinities range from 24 to 35 parts per thousand (ppt). Marine waters colder than 28.4 °F (-2.0 °C) 

typically freeze. 

In 1996, the ADEC designated the nearshore Beaufort Sea lagoon waters from the Sagavanirktok River to 

Simpson Lagoon as “impaired” (ADEC 2008). Reports indicated hydrology and water quality 

(temperature and salinity) were affected by causeway development. To mitigate the effects, breaches 

were cut in the West Dock and Endicott causeways. This reversed the problem and two years later in 

1998 the waters were delisted but continue to be tracked and monitored. 

During the summer of 2008, the vertical profiles of salinity and temperature within Sivulliq and Torpedo 

prospect areas showed stratification (Figures 6.c-1 and 6.c-2). The sea at Torpedo demonstrated greater 

display of stratification, with warmer surface water and salinity lower than that measured near the Sivulliq 

Prospect. (Trefry and Trocine 2009; Dunton et al. 2009). 

Figure 6.c-1 Vertical Profiles of Temperature and Salinity Near the Sivulliq Prospect 

Temperature (oC)

01234567

Water Depth (m)

0

5

10

15

20

25

30

35

Station L250-1

August 20, 2008

Salinity

26 28 30 32

Water Depth (m)

0

5

10

15

20

25

30

35

Station L250-1

August 20, 2008
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-17 May 2011

Figure 6.c-2 Vertical Profiles of Temperature and Salinity Near the Torpedo Prospect 

Camden Bay Area Water Velocity

Voparil (2009) summarizes that the open-water circulation depends mostly on the wind, and the wind’s 

direction is more important than its speed (Hanzlick et al. 1990). Other controls on circulation include 

river discharge, ice-melt, bathymetry, and the configuration of the coastline. The mean surface-current 

direction year-round is to the west and parallels the bathymetry. Average currents are generally 10 

centimeters per second (cm/sec) in summer, though storms create short-lived currents that approach 100 

cm/sec (MBC Applied Environmental Sciences 2003).

Kulluk Cooling Water Modeling 

Shell has modeled the cooling water discharge from the Kulluk. A detailed analysis of the dispersion of 

cooling water into the water column is found in the EIA (Appendix F). 

Temperature (°C)

01234567

Water Depth (m)

0

5

10

15

20

25

30

Station HEX-19

August 19, 2008

Salinity

26 28 30 32

Water Depth (m)

0

5

10

15

20

25

30

Station HEX-19

August 19, 2008
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-18 May 2011

Shell has modeled the cooling water discharge of 13,178 bbl per day (plus a minor amount of water 

discharge from other onboard system – 125 bbl per day) from the Kulluk. The modeling shows that the 

cooling water reaches ambient seawater temperatures a relatively short distance from the outfall. 

The cooling water from the Kulluk will be released through a 36-in. (91 cm) disposal caisson at a depth of 

41 ft (12.5 m) below the ocean surface at an average rate of 554 bbl/hr. The discharged water creates a 

plume approximately 256 ft (78 m) in length and up to 16 ft (5 m) wide (Figure 6.c-3). At the edges of 

this plume, the cooling water will have reached ambient seawater temperatures. 

Figure 6.c-3 Cooling Water Plume from the 36-in. Disposal Caisson on the Kulluk 

Discoverer Cooling Water Modeling 

Shell has modeled the cooling water discharge of 45,000 bbl per day from the Discoverer. The modeling 

shows that the cooling water reaches ambient seawater temperatures a relatively short distance from the 

outfall. 

The cooling water from the Discoverer will be released at five outfalls each located 11.2 ft (3.4 m) above 

the surface of the ocean. Two of the outfalls are through 6-in. (15.2 cm) diameter pipe and three outfalls 

are from 2-in. (5.1 cm) diameter pipes. The flow rate through each 6-in. (15.2 cm) pipe is approximately 

562.5 bbl/hr and approximately 250 bbl/hr through each 2-in. (5.1 cm) pipe. 

The cooling water coming out of each 6-in. (15.2 cm) outfall attenuates to a plume approximately 164 ft 

(50m) in length and 13 ft (4m) wide (Figure 6c-4). The cooling water from each 2-in. (5.1 cm) outfall 

0 10 20 30 40 50 60 70 80 90 100

meters

-20

0

20

meters

-2

-1.8

-1.6

-1.4

-1.2

-1

-0.8

-0.6

3D Plume Projection Onto Ocean Floor ("Shadow")

(0.01)

(0.25)

Log_10 Atten. Factor

Thermal Plume Footprint

Kulluk, Water Disposal, 36" Caisson, 12.5 m Below Waterline, 554 bbl/hr

(Tplume - Tambient) = Factor X (To - Tambient)
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-19 May 2011

results in a plume 30 ft (9 m) and 305 ft (1-1.5 m) wide (Figure 6c-5). At the edges of both plumes, the 

cooling water will have reached ambient seawater temperature. 

Figure 6.c-4 Cooling Water Plume From Each 6-in. Outfall on the Discoverer

0 5 10 15 20 25 30 35 40 45 50

meters

-10

-5

0

5

10

meters

-2

-1.8

-1.6

-1.4

-1.2

-1

-0.8

-0.6

3D Plume Projection Onto Ocean Floor ("Shadow")

(0.01)

(0.25)

Log_10 Atten. Factor

Thermal Plume Footprint

1 out of 2 6" Pipe Outfalls which Carry 60% of Total Discharge

 Vertical X-Section Profile (562 b/hr, 6" Pipe)

(Tplume - Tambient) = Factor X (To - Tambient)
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-20 May 2011

Figure 6.c-5 Cooling Water Plume From Each 2-in. Outfall on the Discoverer

Discoverer and Kulluk MLC, 36-in. and 26-in. Cuttings at the Seafloor Modeling 

Shell has modeled the deposition of cuttings on the seafloor from a height of 10 ft (3 m) for each drilling 

vessel. The cuttings pile is thickest and widest approximately 66 ft (20 m) down-current from the MLC 

(Figure 6.c-6). At this point the cutting pile is approximately 10 ft (3m) thick and 328 ft (100 m) wide. 

Other cutting pile dimensions are: 

• 295 ft (90 m) down-current: 246 ft (75 m) wide and 4 in. (10 cm) thick 

• 886 ft (270 m) down-current: 246 ft (75 m) wide and 0.4 in. (1 cm) thick 

• 1591 ft (485 m) down-current: end of plume 

0 5 10 15

meters

-4

-2

0

2

4

meters

-2

-1.8

-1.6

-1.4

-1.2

-1

-0.8

-0.6

3D Plume Projection Onto Ocean Floor ("Shadow")

(0.01)

(0.25)

Log_10 Atten. Factor

Thermal Plume Footprint

1 out of 3 2" Pipe Outfalls which Carry 40% of Total Discharge

 Vertical X-Section Profile (250 b/hr, 6" Pipe)

(Tplume - Tambient) = Factor X (To - Tambient)
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-21 May 2011

Figure 6.c-6 Cuttings Plume From Either Drilling Vessel 

d) Projected Cooling Water Intake 

Kulluk 

The Kulluk will require a non-contact cooling water rate of 13,178 bbl/day. This volume may vary 

slightly as determined by the number of engines running and duration on a daily basis. The non-contact 

cooling water will be supplied by a salt water service pump able to pump at a rate of 23,505 gal/hr (559.6 

bbl/hr or 13,431 bbl/day). This seawater intake is from a central sea chest containing four separate 

compartments (Table 6.d-1). This volume is mainly used for non-contact cooling water purposes and the 

remainder is used for other waste streams including toilet service, water maker source (desalination unit), 

fire water source or other accessory salt water needs (mud, chemical mix, and other seawater demands). 

-100 0 100

meters

-100

0

100

200

300

400

500

600

meters

-2

-1.5

-1

-0.5

0

0.5

1

1.5

2

2.5 (316 cm)

(0.01 cm)

Kulluk MLC Discharge

3, 8" nozzles co-current, minus 45 deg,

and plus 45 deg relative to current (north)

Log_10, thickness in cm

Current
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 6-22 May 2011

Table 6.d-1 Seawater Intake Mesh sizes on the Kulluk

Sea-suction Screen Mesh Size Compartment Size 

Central Sea Chest – Compartment 1 0.2 in. (5.0 mm) 10.75-in. (273 mm) X 16-in. (406 mm) 

Central Sea Chest – Compartment 2 0.2 in. (5.0 mm) 10.75-in. (273 mm) X 16-in. (406 mm) 

Central Sea Chest – Compartment 3 0.2 in. (5.0 mm) 10.75-in. (273 mm) X 16-in. (406 mm) 

Central Sea Chest – Compartment 4 0.2 in. (5.0 mm) 10.75-in. (273 mm) X 16-in. (406 mm) 

mm – millimeter(s) 

The calculated velocity of intake water across the screens is approximately 12 ft/min (6 cm/sec). 

Discoverer 

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 NOIs in Appendix B. 

The saltwater service system consists of saltwater pumps (Aurora 5-483-11C), four sea-suctions (each 

with strainer having holes 5 mm 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.d-2. 

Table 6.d-2 Seawater Intake Mesh Sizes 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/min (20 cm/sec). 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-1 May 2011 

SECTION 7.0 AIR EMISSIONS INFORMATION 

a) Projected Emissions 

Kulluk Emissions 

Shell is applying for a synthetic minor source operating air emissions permit from the EPA Region 10 for 

exploration drilling using the Kulluk on OCS leases in the Beaufort Sea, Alaska. 

These leases are beyond the Alaska seaward boundary, which is three 3 mi (4.8 km) out from the 

shoreline, and air permits are therefore administered by EPA through the 40 CFR Part 55 rules, the “OCS 

rules”. Most of the leases in the Beaufort Sea are also within 25 mi (40 km) of Alaska’s seaward 

boundary, a region within which the EPA also applies the Alaska air rules. So, only the federal rules 

apply to the leases beyond this 25 mi (40 km) distance, but Alaska rules also apply within the 25 mi (40 

km) distance. 

In general, the Kulluk’s emissions are greater during construction of the MLC than the remainder of the 

well. Large air compressors and hydraulic power units (HPUs) must be used for construction of the MLC. 

The MLC only requires a few days to construct. Emissions are reduced during casing, logging and 

cementing. Support vessel emissions remain relatively constant throughout these exploration drilling 

activities. 

Engine Size and Rating: Table 7.a-1 lists the emission source groups for the vessel types (or similar 

vessel) listed in the Kulluk air permit application that was submitted to the EPA February 28, 2011. 

Projected Peak Hourly Emissions: The projected peak hourly emissions from sources on the Kulluk and 

support vessel sources are provided in Table 7.a-2 as required by 30 CFR 250.218(1)(i). 

Total Annual Emissions: Total annual potential emissions from sources on the Kulluk and support vessel 

sources are provided in Table 7.a-3 as required by 30 CFR 250.218(1)(ii). These emissions are based on 

a maximum 120-day drilling season although it is likely that environmental conditions and the shutdown 

for the Kaktovik and Cross Island (Nuiqsut) whale hunts will limit the Kulluk to less than 120 drilling 

days. 

Emissions over the Duration of the Exploration Drilling Activities: The annual emissions associated with 

the proposed exploration drilling activities planned in the revised Camden Bay EP, as required under 30 

CFR 250.218(1)(iii), are presented in Table 7.a-3. 

Frequency and Duration of Emissions: Proposed owner requested limits, listed in Table 7.a-4, include a 

high level summary of the frequency and duration of the listed emission sources as required under 30 

CFR 250.218(1)(iv). The frequency and duration of source group emissions are listed in Table 7.a-5. 

In addition, Shell anticipates that the ice management vessels will be operating at maximum emission 

rates for 38 percent of the 120 days. For modeling purposes, the ice management vessels are assumed to 

be operating at the maximum emission rates whenever the meteorology indicates that ice is present and 

assumed to be beyond the 25 mi radius when the data indicate open water. 

Total of All Emissions: As required under 30 CFR 250.218(1)(v), the total of all annual emissions for the 

Kulluk emission sources, and for the associated vessels, are provided in Table 7.a-3 by pollutant. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-2 May 2011 

Basis for Calculations: As required under 30 CFR 250.218(2), total annual emissions by pollutant for the 

Kulluk sources and for the associated vessels, are provided in Table 7a-3. These projected total annual 

emissions, including support vessel emissions, are based on the Kulluk being an OCS source for a 

maximum of 120 days. Emissions for all emission units associated with the Kulluk are estimated as 

potential to emit, which are the emissions assuming continuous operation at maximum rated capacity for 

the entire 120-day drilling season per year, unless limited by owner-requested restriction (Table 7.a-4). 

Engine size and rating are provided in Table 7.a-1. 

The emissions for the ice management fleet propulsion engines are estimated for operation at maximum 

rate for 38 percent of the 120-day season. Kulluk emissions are estimated without the propulsion engines 

operating (drilling and propulsion are exclusive). The emergency and backup engines are only used 

during emergencies and maintenance of paired engines. Shell will purchase ultra-low sulfur diesel 

(ULSD;0.0015 percent sulfur) fuel for all vessels. 

Emission factors used in the calculations of hourly and total emissions are found in Attachment A of the 

Kulluk Minor Source Air Permit application. A copy of the application has been submitted to BOEMRE. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska

Shell Offshore Inc. 7-3 May 2011 Table 7.a-1 Source Size, Rating and Fuel Usage 

Vessel and Source Group Description Make/Model Rating Fuel Usage 

Kulluk Generation Generator Engine 

386 gal/hr Generator Engine 

Generator Engine 

MLC HPUs HPU Engine Caterpillar/3306 250 hp 80 gal/hr HPU Engine Caterpillar/3306 250 hp Air Compressors Air Compressor Hydraulic 500 hp 

80 gal/hr Air Compressor Hydraulic 500 hp 

Air Compressor Hydraulic 500 hp 

Cranes Port Deck Mercedes/OM404 293 kw 

26 gal/hr Starboard Deck Mercedes/OM404 293 kw 

Aft Deck Mercedes/OM404 293 kw 

Heaters and Boilers Heat Boiler unknown 2.4 MMBtu/hr 

46 gal/hr Heat Boiler unknown 2.4 MMBtu/hr Hot Water Heat unknown 0.54 MMBtu/hr 

Hot Water Heat unknown 0.54 MMBtu/hr 

Seldom Used Units Rig Air Compressor Lister TS-2 23 hp 

566 gal/30-days 

ROV HPU Cummins QSX15-G9 755 hp Life Boat Perkins 4154 50 hp Life Boat Perkins 4154 50 hp Life Boat Perkins 4154 50 hp Life Boat Perkins 4154 50 hp Fast Rescue Boat STEYR/144 144 LARS Diesel Drive Unknown 150 kW 

Emergency Generator Emergency Generator 77 gal/30-days Incinerator Incinerator TeamTec/GS5000C 276 lb/hr NA Primary Ice ManagementFennica/Nordica Propulsion and Generation Main Prop Engine Wartsila/16V32 6,000 kW 1,718 gal/hr 

Main Prop Engine Wartsila/16V32 6,000 kW Main Prop Engine Wartsila/12V32 4,500 kW Main Prop Engine Wartsila/12V32 4,500 kW Generator ABB Stromberg Drives/HSG 1120 MP8 8,314 kVA* Generator ABB Stromberg Drives/HSG 1120 MP8 8,314 kVA* Generator ABB Stromberg Drives/HSG 900 LR8 6,235 kVA* Generator ABB Stromberg Drives/HSG 900 LR8 6,235 kVA* Harbour Set Generator Wärtsilä/VASA 4R22 710 hp Bow Thrusters Brunvoll FV-80 LTC-2250 1,150 kW* 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska

Shell Offshore Inc. 7-4 May 2011 Table 7.a-1 Source Size, Rating and Fuel Usage 

Vessel and Source Group Description Make/Model Rating Fuel Usage 

Bow Thrusters Brunvoll FV-80 LTC-2250 1,150 kW* Bow Thrusters Brunvoll FV-80 LTC-2250 1,150 kW* 

Heaters and Boilers Heat Boiler unknown 4.44 MMBtu/hr 76 gal/hr 

Heat Boiler unknown 4.44 MMBtu/hr 

Seldom Used Units Emergency Generator Caterpillar/3412 300 hp 100 gal/wk Incinerator Incinerator unknown 154 lb/hr NA Secondary Ice Management/ Anchor HandlerTor Viking II Propulsion and Generation Main Propulsion MaK 8M32 5,046 hp 

1,718 gal/hr 

Main Propulsion MaK 8M32 5,046 hp Main Propulsion MaK 6M32 3,784 hp Main Propulsion MaK 6M32 3,784 hp Harbor Generator Caterpillar 3412 1,168 hp Harbor Generator Caterpillar 3412 1,168 hp 

Heaters and Boilers Heat Boiler Pyro/E1130 1.37 MMBtu/hr 76 gal/hr Seldom Used Units Skimmer 100 gal/wk Incinerator none NA Resupply ShipHarvey Spirit Propulsion and Generation Main Engine GE/7FDM12D5 3070 hp 

1,200 gal/1-way during transit 4,800 gal/event during DP mode 

Main Engine GE/7FDM12D5 3070 hp Generator Cummins/KTA19-D(M) 485 kW Generator Cummins/KTA19-D(M) 485 kW Generator Cummins/KTA19-D(M) 485 kW Bow Thrusters Cummins/KTA38-D(M) 1200 hp Bow Thrusters Cummins/KTA38-D(M) 1200 hp Stern Thrusters Cummins/KTA38-D(M) 1200 hp 

Seldom Used Units Emergency Generator Cummins/6BTAA5.9-G1 99 hp 20 gal/wk Skimmer OSR VesselPt. Oliktok Tug and Endeavor BargePropulsion and Generation Main Propulsion Caterpillar 3512 1,050 hp 

2,800 gal/day Main Propulsion Caterpillar 3512 1,050 hp Generator Caterpillar 3304 150 hp 

Generator Caterpillar 3304 150 hp 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska

Shell Offshore Inc. 7-5 May 2011 Table 7.a-1 Source Size, Rating and Fuel Usage 

Vessel and Source Group Description Make/Model Rating Fuel Usage 

Generator Caterpillar C4.4 80 hp Generator Caterpillar C4.4 80 hp 

Seldom Used Units Crane Manitowok NTA855-C360 350 hp 

100 gal/wk 

Light Plant unknown 30 hp HPU Engine Caterpillar C6.6 158 kW HPU Engine Caterpillar C6.6 158 kW HPU Engine Deutz F6L914 84 kW Generator Lugger M753W2 8 kW Anchor Engine John Deere 50 hp 

Incinerator none OSR Work BoatsKvichaks 2 X 34 ft Rozema 1 X 47 ft 

Propulsion Cummins QSB 5.9 300 hp 

3,789 gal/wk 

Propulsion Cummins QSB 5.9 300 hp Generator unknown 12 hp Propulsion Cummins QSB 5.9 300 hp Propulsion Cummins QSB 5.9 300 hp Generator unknown 12 hp Propulsion Lugger 6140 600 hp Propulsion Lugger 6140 600 hp Generator unknown 12 hp 

* Electrical 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-6 May 2011 

Table 7.a-2 Projected Hourly Emissions From the Kulluk (Individual Source) and Support Vessels (Source Groups) 

Vessel and Source Group NOx 

lb/hr 

PM2.5 

lb/hr 

PM10 

lb/hr 

CO

lb/hr 

SO2 

lb/hr 

VOC 

lb/hr 

Kulluk

Generation 19.0 3.0 3.0 8.6 5.4E-01 1.37 

MLC HPUs 37.0 1.5 1.5 2.0 1.1E-01 1.10 

Air Compressors 29.6 0.6 0.6 1.8 1.1E-01 0.28 

Cranes 11.8 0.5 0.5 0.6 3.6E-02 0.35 

Heaters and Boilers 0.9 0.2 0.2 0.2 6.4E-02 0.05 

Seldom Used Units 0.4 2.9E-02 0.1 1.1E-03 0.04 

Emergency Generator 17.8 1.4 1.4 4.8 5.4E-02 1.77 

Incinerator 0.4 1.9 2.3 41.4 3.5E-01 13.80 

Ice Management

Propulsion and Generation 84.7 13.2 13.2 38.3 2.4E+00 6.09 

Heaters and Boilers 1.5 0.2 0.2 0.4 1.1E-01 0.08 

Seldom Used Units 0.3 2.2E-02 2.2E-02 0.1 8.3E-04 0.03 

Incinerator 0.2 1.1 1.3 23.1 1.9E-01 7.70 

Anchor Handler

Propulsion and Generation 84.7 13.2 13.2 38.3 2.4E+00 6.09 

Heaters and Boilers 1.5 0.2 0.2 0.4 1.1E-01 0.08 

Seldom Used Units 0.3 2.2E-02 2.2E-02 0.1 8.3E-04 0.03 

Incinerator 0.2 1.1 1.3 23.1 1.9E-01 7.70 

Resupply Ship – transport mode *

Propulsion and Generation 0 0 0 0 0 0 

Seldom Used Units 0 0 0 0 0 0 

Resupply Ship – Dynamic Positioning mode

Propulsion and Generation 236.7 9.9 9.9 71.4 9.0E-01 7.56 

Seldom Used Units 5.5E-02 4.4E-03 4.4E-03 1.5E-02 1.7E-04 5.5E-03 

OSR Vessel

Propulsion and Generation 44.4 1.8 1.8 13.0 1.6E-01 1.38 

Seldom Used Units 2.8E-01 2.2E-02 2.2E-02 7.4E-02 8.3E-04 2.7E-02 

Incinerator 0.2 0.9 1.0 18.8 1.6E-01 6.25 

OSR Work Boats

Kvichaks 10.4 0.8 0.8 2.8 3.2E-02 1.04 

* This activity cannot occur simultaneously with Resupply - DP mode. DP mode has greater impacts. 

Table 7.a-3 Vessel Source Group Annual Maximum Emissions in Tons/Year 

Vessel and Source Group NOx

ton/yr 

PM2.5

ton/yr 

PM10

ton/yr 

CO

ton/yr 

SO2

ton/yr 

VOC 

ton/yr 

Kulluk 

Generation 23.9 3.7 3.7 10.8 6.8E-01 1.72 

MLC HPU’s 8.9 0.4 0.4 0.5 2.7E-02 0.26 

Air Compressors 7.1 0.1 0.1 0.4 2.7E-02 0.07 

Cranes 6.6 0.3 0.3 0.4 2.0E-02 0.2 

Heaters and Boilers 1.3 0.2 0.2 0.3 9.2E-02 0.07 

Seldom Used Units 5.2E-01 4.2E-02 4.2E-02 1.4E-01 1.6E-03 5.2E-02 

Emergency Generator 7.1E-02 5.7E-03 5.7E-03 1.9E-02 2.2E-04 7.1E-03 

Incinerator 0.3 1.4 1.6 29.8 0.25 9.94 

Ice Management 

Propulsion and Generation 46.3 7.2 7.2 21 1.3 3.33 

Heaters and Boilers 0.8 0.1 0.1 0.2 5.8E-02 0.04 

Seldom Used Units 1.5E-01 1.2E-02 1.2E-02 4.1E-02 4.6E-04 1.5E-02 

Incinerator 0.1 0.6 0.7 12.6 0.11 4.21 

Anchor Handler

Propulsion and Generation 46.3 7.2 7.2 21 1.3 3.33 

Heaters and Boilers 0.8 0.1 0.1 0.2 5.8E-02 0.04 

Seldom Used Units 1.5E-01 1.2E-02 1.2E-02 4.1E-02 4.6E-04 1.5E-02 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-7 May 2011 

Table 7.a-3 Vessel Source Group Annual Maximum Emissions in Tons/Year 

Vessel and Source Group NOx

ton/yr 

PM2.5

ton/yr 

PM10

ton/yr 

CO

ton/yr 

SO2

ton/yr 

VOC 

ton/yr 

Incinerator 0.1 0.6 0.7 12.6 0.11 4.21 

Resupply Ship – transport mode 

Propulsion and Generation 10.6 0.4 0.4 3.2 4.0E-02 0.34 

Seldom Used Units 7.9E-02 6.3E-03 6.3E-03 2.1E-02 2.4E-04 7.9E-03 

Resupply Ship – Dynamic Positioning mode

Propulsion and Generation 21.3 0.9 0.9 6.4 8.1E-02 0.68 

Seldom Used Units 7.9E-02 6.3E-03 6.3E-03 2.1E-02 2.4E-04 7.9E-03 

OSR Vessel 

Propulsion and Generation 37.3 1.6 1.6 11.2 1.4E-01 1.19 

Seldom Used Units 4.0E-01 3.2E-02 3.2E-02 1.1E-01 1.2E-03 3.9E-02 

Incinerator 0.3 1.3 1.5 27 0.2 9.00 

OSR Work Boats 

Kvichaks 15.0 1.2 1.2 4.0 4.5E-02 1.49 

Total Potential to Emit 229 28 28 162 5 40 

Note: ton = short tons. 

Table 7.a-4 Owner Requested Limits in the Kulluk Minor Source Air Permit Application 

Owner Requested Limits Value

MLC construction 480 hours per season (20 days) 

MLC construction and well drilling combined 1,632 hours per season (68 days) 

All OCS activities combined 2,880 hours per season (120 days) 

Number of resupply/waste removal trips 24 per season 

Kulluk incinerator 12 hours per day (8 a.m. – 8 p.m.) 

Fuel sulfur content – Kulluk and fleet Purchase ULSD (0.0015 percent sulfur); less than 0.01% during use 

All internal combustion engine and heater groups Emission limits (in lb/day) for each pollutant highlighted in Updated Tables 2-

1, 2-2, and 2-3 of Kulluk Impacts Memo, May 4, 2011 (Air Sciences, 2011a) 

Table 7.a-5 Frequency and Duration of Emission Source Groups - Kulluk

Source Capacity Operating Duration 

(hr/day) 

Operating Frequency*

 Activity Activity

Kulluk MLC Drill C/L MLC Drill C/L

Generation 85% 85% 60% 24 24 24 Every day of listed activity 

MLC HPUs 100% 0% 0% 24 0 0 Every day of listed activity 

Air Compressors 100% 0% 0% 24 0 0 Every day of listed activity 

Cranes 40% 40% 40% 7 7 12 Every day of listed activity 

Heaters and Boilers 100% 100% 100% 24 24 24 Every day 

Incinerator 100% 100% 100% 12 12 12 Every day 

Seldom Used Units** 100% 100% 100% 24 24 24 Based on weekly fuel limit 

Emergency Generator 100% 100% 100% 2 2 2 Every 30 days 

Fleet 

Resupply Ship-Transport 24 events per year 

Resupply Ship-DP 24 24 24 24 events per year 

Ice Management Vessels 24 24 24 On days when ice is present, 38% of 

season 

OSR vessel Based on daily fuel limit 

OSR Workboats Based on weekly fuel limit 

*when source is operating 

** The operating duration values listed in this table are specific to assumptions made for air quality modeling purposes. The emissions from the 

seldom used sources (several small engines; non-emergency generator) will occur at undefined times and are evenly spread over the 30-day 

period for modeling purposes. Emissions for the seldom used sources are based on a maximum fuel consumption rate for the source group of no 

more than 150 gallons per week which is based on the expectation that the seldom used sources operate only a few hours per week. 

Discoverer Emissions 

The air quality information provided herein is based on the drillship and associated support vessels. Shell 

submitted a major new source review Prevention of Significant Deterioration (NSR/PSD) application to 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-8 May 2011 

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 BOEMRE on 18 May and 29 May 2009. The 

EPA prepared a Statement of Basis and issued PSD Permit No. R10OCS/PSD-AK-09-01 to Shell on 31 

March 2010. Projected emissions, based on the Statement of Basis, are provided below in Tables 7.a-6 

through 7.a-8. Air quality impacts are provided in Section 7(f) and Table 7.f-1 and 7.f-2, and are from the 

Statement of Basis (EPA 2010) and a revised modeling report (Air Sciences Inc. 2011b) provided to EPA 

in response to the remand. 

Shell has provided the documents referenced above to BOEMRE, and BOEMRE 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 ownerrequested enforceable limits in the application including burning ULSD fuel; and installing diesel 

particulate filters, catalytic diesel particulate filters, and selective catalytic reduction (SCR) controls on 

the drillship emission units. These emission reduction measures satisfy the best available control 

technology (BACT) component of PSD permitting and EPA has incorporated these measures and other 

emission reduction measures as enforceable permit limitations. Shell’s PSD application and subsequent 

submissions include 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. 

Sources: The Discoverer emission units are listed in Table 7.a-6 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-7. 

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)]: The annual emissions associated with the proposed 

exploration drilling activities planned in the revised Camden Bay EP, as required under 30 CFR 

250.218(1)(iii), are presented in Table 7.a-8. 

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 emissions by pollutant for the Discoverer sources and for 

the associated vessels, are provided in Table 7.a-8. These emissions are based on a maximum 120- day 

drilling season. Emissions for all emission units associated with the Discoverer are estimated as realistic 

maximum emissions, 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-9 and frequencies and duration of emission source groups are found 

in Table 7.a-10. These restrictions and the following text summarize the basis for the calculation of the 

maximum emissions. Discoverer emissions are estimated without the propulsion engines operating 

(drilling and propulsion are exclusive). The emergency and backup engines are only used during 

emergencies and maintenance of paired engines. Shell will purchase fuel for the Discoverer and support 

vessels that will have a sulfur content equal to or less than 0.0015 weight percent. 

Additional details are provided in the permit (OCS PSD R10OCS/PSD-AK-09-01), Statement of Basis 

for the permit (EPA 2010), and Shell’s application materials, available on-line at 

http://yosemite.epa.gov/R10/airpage.nsf/Permits/chukchiap/#comment and Shell’s remand permit 

materials (Discoverer Drillship Impact Evaluation for SO2 and NO2 Using AERMOD). 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-9 May 2011 

Table 7.a-6 Description of Discoverer Drilling Vessel Emission Units and Associated Fleet 

Vessel and Source Group Unit Description Make/Model Rating Fuel Usage 

DiscovererGeneration Generator Engine Cat / D399 1,325 hp 

297 gal/hr 

Generator Engine Cat / D399 1,325 hp Generator Engine Cat / D399 1,325 hp Generator Engine Cat / D399 1,325 hp Generator Engine Cat / D399 1,325 hp Generator Engine Cat / D399 1,325 hp 

Propulsion Propulsion Engine* MI / 6UEC65 7,200 hp NA MLC Compressors 

MLC Compressor Caterpillar C – 15 540 hp 

57 gal/hr MLC Compressor Caterpillar C – 15 540 hp 

MLC Compressor* Caterpillar C – 15 540 hp 

HPU Engines HPU Engine TBD 250 hp 26 gal/hr 

HPU Engine TBD 250 hp 

Cranes Port Deck Crane Cat / D343 365 hp 15 gal/hr 

Starboard Deck Crane Cat / D343 365 hp 

Cementing/Logging 

Cementing Unit Detroit / 8V-71N 335 hp 320 gal/day Cementing Unit Detroit / 8V-71N 335 hp Cementing Unit GM 3-71 147 hp Logging Winch** Caterpillar/C7 250 hp Logging Winch** John Deere/PE4020TF270D 35 kW 

Heaters & Boilers Heat Boiler Clayton 200 Boiler 7.97 MMBtu/hr 120 gal/hr 

Heat Boiler Clayton 200 Boiler 7.97 MMBtu/hr 

Seldom Used Units To Be Determined Various 150 gal/wk Emergency Generator Emergency Generator* Caterpillar / 3412 639 hp 67 gal/monthIncinerator Incinerator TeamTec/GS500C 276 lb/hr NA 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-10 May 2011 

Table 7.a-6 Description of Discoverer Drilling Vessel Emission Units and Associated Fleet

Vessel and Source Group Unit Description Make/Model Rating Fuel Usage 

Primary Ice Management Fennica/Nordica Propulsion and Generation Main Prop Engine Wartsila/16V32 6,000 kW 1,313 gal/hr 

Main Prop Engine Wartsila/16V32 6,000 kW Main Prop Engine Wartsila/12V32 4,500 kW Main Prop Engine Wartsila/12V32 4,500 kW Generator ABB Stromberg Drives/HSG 1120 MP8 8,314 kVA* Generator ABB Stromberg Drives/HSG 1120 MP8 8,314 kVA* Generator ABB Stromberg Drives/HSG 900 LR8 6,235 kVA* Generator ABB Stromberg Drives/HSG 900 LR8 6,235 kVA* Harbour Set Generator Wärtsilä/VASA 4R22 710 hp Bow Thrusters Brunvoll FV-80 LTC-2250 1,150 kW* Bow Thrusters Brunvoll FV-80 LTC-2250 1,150 kW* Bow Thrusters Brunvoll FV-80 LTC-2250 1,150 kW* 

Heaters and Boilers Heat Boiler unknown 4.44 MMBtu/hr 75 gal/hr 

Heat Boiler unknown 4.44 MMBtu/hr 

Seldom Used Units Emergency Generator Caterpillar/3412 300 hp 100 gal/wk Incinerator Incinerator unknown 154 lb/hr NA Secondary Ice Management/ Anchor HandlerTor Viking II Propulsion and Generation Main Propulsion MaK 8M32 5,046 hp 

1,353 gal/hr 

Main Propulsion MaK 8M32 5,046 hp Main Propulsion MaK 6M32 3,784 hp Main Propulsion MaK 6M32 3,784 hp Harbor Generator Caterpillar 3412 1,168 hp Harbor Generator Caterpillar 3412 1,168 hp 

Heaters and Boilers Heat Boiler Pyro/E1130 1.37 MMBtu/hr 30 gal/hr Seldom Used Units Skimmer 100 gal/wk Incinerator none NA 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-11 May 2011 

Table 7.a-6 Description of Discoverer Drilling Vessel Emission Units and Associated Fleet 

Vessel and Source Group Unit Description Make/Model Rating Fuel Usage 

Resupply ShipHarvey Spirit Propulsion and Generation Main Engine GE/7FDM12D5 3,070 hp 

1,200 gal/1-way during transit 4,800 gal/event during DP mode 

Main Engine GE/7FDM12D5 3,070 hp Generator Cummins/KTA19-D(M) 485 kW Generator Cummins/KTA19-D(M) 485 kW Generator Cummins/KTA19-D(M) 485 kW Bow Thrusters Cummins/KTA38-D(M) 1,200 hp Bow Thrusters Cummins/KTA38-D(M) 1,200 hp Stern Thrusters Cummins/KTA38-D(M) 1,200 hp 

Seldom Used Units Emergency Generator Cummins/6BTAA5.9-G1 99 hp 100 gal/wk 

Skimmer 

Offshore Management / Skimmer VesselPt. Barrow Tug and Endeavor BargePropulsion and Generation Main Propulsion Caterpillar 3512 1,050 hp 

2,800 gal/day 

Main Propulsion Caterpillar 3512 1,050 hp Generator Caterpillar 3304 150 hp Generator Caterpillar 3304 150 hp Generator Caterpillar C4.4 80 hp Generator Caterpillar C4.4 80 hp 

Seldom Used Units Crane Manitowok NTA855-C360 350 hp 

100 gal/wk 

Light Plant unknown 30 hp HPU Engine Caterpillar C6.6 158 kW HPU Engine Caterpillar C6.6 158 kW HPU Engine Deutz F6L914 84 kW Generator Lugger M753W2 8 kW Anchor Engine John Deere 50 hp 

Incinerator none 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-12 May 2011 

Table 7.a-6 Description of Discoverer Drilling Vessel Emission Units and Associated Fleet 

Vessel and Source Group Unit Description Make/Model Rating Fuel Usage 

OSR Vessel Propulsion and Generation Propulsion Engine Caterpillar/3608 2,710 kW 

3,800 gal/day Propulsion Engine Caterpillar/3608 2,710 kW Electrical Generator Caterpillar/3508 1,285 hp 

Electrical Generator Caterpillar/3508 1,285 hp 

Seldom Used Units Emergency Generator John Deere 166 hp 100 gal/wk Incinerator Incinerator ASC / CP100 125 lb/hr NA OSR Work BoatsKvichaks 2 X 34 ft Rozema 1 X 47 ft 

Propulsion Cummins QSB 5.9 300 hp 

3,789 gal/wk 

Propulsion Cummins QSB 5.9 300 hp Generator unknown 12 hp Propulsion Cummins QSB 5.9 300 hp Propulsion Cummins QSB 5.9 300 hp Generator unknown 12 hp Propulsion Lugger 6140 600 hp Propulsion Lugger 6140 600 hp Generator unknown 12 hp 

Notes: *Not used during drilling ** Logging winch operation combined with cementing units 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-13 May 2011 

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

Vessel and Source Group NOx

lb/hr 

PM2.5

lb/hr 

PM10

lb/hr 

CO

lb/hr 

SO2

lb/hr 

VOC

lb/hr 

Discoverer

Generation 4.6 1.2 1.2 1.7 6.30E-02 0.2 

MLC Compressors 7.1 0.2 0.2 3.3 1.2E-02 7.1 

HPU Engines 3.3 2.47E-02 2.47E-02 0.6 5.58E-03 3.3 

Cranes 5.0 3.43E-02 3.43E-02 0.1 3.26E-03 3.07E-02 

Cement / Logging 6.6 0.2 0.2 0.4 2.83E-03 0.2 

Heaters and Boilers 3.2 0.4 0.4 1.2 2.54E-02 2.23E-02 

Seldom Used Units 5.24E-01 3.68E-02 3.68E-02 1.13E-01 1.89E-04 4.16E-02 

Emergency Generator 19.7 1.4 1.4 4.2 7.13E-03 1.6 

Incinerator 0.7 1.0 1.1 4.3 3.45E-01 0.4 

Ice Management

Propulsion and Generation 65.7 10.3 10.3 29.7 2.78E-01 4.7 

Heaters and Boilers 1.5 0.2 0.2 0.4 1.59E-02 2.55E-02 

Seldom Used Units 3.49E-01 2.46E-02 2.46E-02 7.53E-02 1.26E-04 2.77E-02 

Incinerator 0.4 0.7 1.0 23.1 1.93E-01 7.7 

Anchor Handler

Propulsion and Generation 67.7 10.6 10.6 30.6 2.87E-01 4.9 

Heaters and Boilers 0.6 0.1 0.1 0.2 6.37E-03 1.02E-02 

Seldom Used Units 3.49E-01 2.46E-02 2.46E-02 7.53E-02 1.26E-04 2.77E-02 

Incinerator 0.4 0.7 1.0 23.1 1.93E-01 7.7 

Resupply Ship – transport mode*

Propulsion and Generation 0.0 0.0 0.0 0.0 0.0 0.0 

Resupply Ship – Dynamic Positioning mode

Propulsion and Generation 370.4 9.9 9.9 79.8 1.34E-01 29.4 

Offshore Management / Skimmer Vessel

Propulsion and Generation 49.7 0.9 0.9 13.2 2.47E-02 1.4 

Seldom Used Units 3.49E-01 2.46E-02 2.46E-02 7.53E-02 1.26E-04 2.77E-02 

Incinerator 0.3 0.6 0.8 18.8 1.56E-01 6.3 

OSR Vessel

Propulsion and Generation 67.4 0.1 0.1 0.4 3.36E-02 0.5 

Seldom Used Units 3.49E-01 2.46E-02 2.46E-02 7.53E-02 1.26E-04 2.77E-02 

Incinerator 0.3 0.6 0.8 18.8 1.56E-01 6.3 

OSR Work Boats

Kvichaks 13.2 0.9 0.9 2.9 4.78E-03 1.1 

* This activity cannot occur simultaneously with Resupply - DP mode. DP mode has greater impacts. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-14 May 2011 

Table 7.a-8 Annual Potentials to Emit for the Discoverer Emission Units and Associated Fleet 

Vessel and Source Group NOx 

ton/yr 

PM2.5 

ton/yr 

PM10 

ton/yr 

CO

ton/yr 

SO2 

ton/yr 

VOC

ton/yr 

Discoverer 

Generation 5.8 1.5 1.5 2.1 7.90E-02 0.3 

MLC Compressors 1.7 4.26E-02 4.26E-02 7.93E-01 2.89E-03 1.7 

HPU Engines 0.8 5.92E-03 5.92E-03 1.38E-01 1.34E-03 0.8 

Cranes 2.8 1.91E-02 1.91E-02 5.88E-02 1.81E-03 1.71E-02 

Cementing / Logging 4.1 0.1 0.1 0.2 1.76E-03 1.30E-01 

Heaters and Boilers 4.6 0.5 0.5 1.8 3.66E-02 3.21E-02 

Seldom Used Units 0.8 5.30E-02 5.30E-02 1.63E-01 2.73E-04 5.99E-02 

Emergency Generator 0.1 5.55E-03 5.55E-03 1.70E-02 2.85E-05 6.26E-03 

Incinerator 0.2 0.3 0.3 1.2 9.75E-02 1.17E-01 

Ice Management 

Propulsion and Generation 36.0 5.6 5.6 16.3 1.52E-01 2.6 

Heaters and Boilers 0.8 1.36E-01 1.36E-01 2.06E-01 8.72E-03 1.40E-02 

Seldom Used Units 0.2 1.34E-02 1.34E-02 4.12E-02 6.91E-05 1.52E-02 

Incinerator 0.2 0.4 0.6 12.6 1.05E-01 4.2 

Anchor Handler

Propulsion and Generation 37.1 5.8 5.8 16.8 1.57E-01 2.7 

Heaters and Boilers 0.3 5.43E-02 5.43E-02 8.22E-02 3.49E-03 5.59E-03 

Seldom Used Units 0.2 1.34E-02 1.34E-02 4.12E-02 6.91E-05 1.52E-02 

Incinerator 0.2 0.4 0.6 12.6 1.05E-01 4.2 

Resupply Ship – transport mode 

Propulsion and Generation 16.9 0.5 0.5 3.6 6.11E-03 1.3 

Resupply Ship – Dynamic Positioning mode

Propulsion and Generation 33.8 0.9 0.9 7.3 1.22E-02 2.7 

Offshore Management / Skimmer Vessel

Propulsion and Generation 71.6 1.3 1.3 19.0 3.56E-02 2.0 

Seldom Used Units 0.5 3.54E-02 3.54E-02 1.08E-01 1.82E-04 3.99E-02 

Incinerator 0.5 0.8 1.2 27.0 2.25E-01 9.0 

OSR Vessel 

Propulsion and Generation 97.1 0.2 0.2 0.5 4.83E-02 0.7 

Seldom Used Units 0.5 3.54E-02 3.54E-02 1.08E-01 1.82E-04 3.99E-02 

Incinerator 0.5 0.8 1.2 27.0 2.25E-01 9.0 

OSR Work Boats 

Kvichaks 19.1 1.3 1.3 4.1 6.89E-03 1.5 

336 21 22 154 1 43 

Table 7.a-9 Owner-Requested Restrictions and Permit Conditions from Shell’s PSD Air Quality Permit for the 

Discoverer in Camden Bay 

Source Owner-requested Restriction Permit Condition 

Stationary source engines on 

drilling vessel and support fleet 

Restrict annual greenhouse gas (GHG) 

emissions to less than 70,000 tons 

Discoverer Seldom used units limited to 150 

gallons per week 

Primary Ice Management Seldom used units limited to 100 

gallons per week 

Secondary Ice Management Seldom used units limited to 100 

gallons per week 

Offshore Management / Skimmer 

Vessel 

Seldom used units limited to 100 

gallons per week 

OSR Vessel Seldom used units limited to 100 

gallons per week 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-15 May 2011 

Table 7.a-9 Owner-Requested Restrictions and Permit Conditions from Shell’s PSD Air Quality Permit for the 

Discoverer in Camden Bay 

Source Owner-requested Restriction Permit Condition 

Stationary source engines on 

drilling vessel and support fleet

-- Sulfur content on all stationary 

source engines on drilling vessel 

0.0015% by weight

Discoverer 

Generators 

 FD 1-6

-- Aggregate electrical power not to 

exceed 3,872 kWe for any hour 

used

Discoverer 

Propulsion Engine 

 FD 7

-- Will not be used when Discoverer

is an OCS source

Discoverer 

Emergency 

Generator 

FD 8

-- Operation of source will not exceed 

120 minutes / day, and/or total of 

48 hr / 12-month period

Discoverer 

MLC Compressors 

FD 9-11

-- Max fuel use of 81,346 gallons in 

all 3 units in aggregate during any 

12-month period

Discoverer 

HPU Engines 

FD 12-13

-- Max fuel use of 44,338 gallons in 

both units in aggregate during any 

12-month period 

Discoverer 

Deck Cranes 

FD 14-15 

-- Max fuel use of 63,661 gallons in 

both units in aggregate during any 

12-month period

Discoverer 

Cementing & Logging Winches 

FD 16-20

-- Max fuel use of 320 gallons per day 

and 53,560 gallons during any 12-

month period in all units in 

aggregate 

Discoverer Incinerator 

FD 23

-- Max of 50,400 lbs of all types of 

trash in any 12-month period 

Supply Ship 

Generator 

FD 31 

-- Max use of 184 gal / day, 1,472 / 

12-month period, 8 events / 12-

month period 

Table 7.a-10 Frequency and Duration of Emission Source Groups - Discoverer

Source Capacity Operating Duration 

(hr/day) 

Operating Frequency 

 Activity Activity

Discoverer MLC Drill C/L MLC Drill C/L

Generation 71% 71% 50% 24 24 24 Every day of listed activity 

MLC Compressors 67% 0% 0% 24 0 0 Every day of listed activity 

HPU Engines 100% 0% 0% 24 0 0 Every day of listed activity 

Cranes 40% 40% 40% 7.2 7.2 12 Every day of listed activity 

Cementing / Logging Based on daily fuel limit 

Heaters and Boilers 100% 100% 100% 24 24 24 Every day 

Seldom Used Units* 100% 100% 100% 24 24 24 Based on weekly fuel limit 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-16 May 2011 

Table 7.a-10 Frequency and Duration of Emission Source Groups - Discoverer

Source Capacity Operating Duration 

(hr/day) 

Operating Frequency 

 Activity Activity

Emergency Generator 100% 100% 100% 2 2 2 Every 30 days 

Incinerator 20% 20% 20% 5 5 5 Every day 

Fleet 

Resupply Vessels – 

Transit mode 

 1 8 events per year 

Resupply Vessels – DP 

mode 

 24 8 events per year 

Ice Management Vessels 24 On days when ice is 

present, 38% of Season 

Offshore Management Based on daily fuel limit 

OSR vessels Based on daily fuel limit 

OSR Workboats Based on weekly fuel limit 

* The operating duration values listed in this table are specific to assumptions made for air quality modeling purposes. The emissions from the 

seldom used sources (several small engines; non-emergency generator) will occur at undefined times and are evenly spread over the 30-day 

period for modeling purposes. Emissions for the seldom used sources are based on a maximum fuel consumption rate for the source group of no 

more than 150 gallons per week which is based on the expectation that the seldom used sources operate only a few hours per week. 

b) Emissions Reduction Measures 

Kulluk 

Shell offers the following emission reduction measures, 30 CFR 250.218(b), and restrictions on its 

operation for the purposes of limiting emissions and air quality impacts from the Kulluk: 

• The Kulluk will have selective catalytic reduction (SCR) as a nitrogen oxide (NOx) tailpipe 

emission control on its primary engines, reducing NOx emissions to less than 1.6 g/kW-hr. The 

primary generators will also have oxidation catalysts installed for control of particulate matter 

less than 2.5 microns (PM2.5), volatile organic compounds (VOC), and carbon monoxide (CO). 

Oxidation Catalysts are assumed to control engine emissions to 50 percent for PM2.5, 80 percent 

for CO, and 70 percent for VOC. 

• The other engines normally used in the drilling activities (the air compressors, the MLC, 

hydraulic power units (HPU), and cranes) will also have oxidation catalysts as tailpipe control for 

oxidizing all oxidize-able substances, including PM2.5, VOC, and CO. Control of engine 

emissions is assumed to be 50 percent for PM2.5, 80 percent for CO, and 70 percent for VOC. 

• Ice management vessels and anchor handlers will have SCR as a nitrogen oxide (NOx) tailpipe 

emission control, and oxidation catalyst on its primary propulsion and generation engines with the 

same reduction efficiencies as the Kulluk primary engines. 

• ULSD (0.0015 percent sulfur) fuel will be purchased for the Kulluk and support vessels to reduce 

sulfur dioxide (SO2) emissions. 

Discoverer 

Shell offers the following emission reduction measures, 30 CFR 250.218(b), and restrictions on its 

operation for the purposes of limiting emissions and air quality impacts from the Discoverer: 

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-17 May 2011 

• Primary generators on the Discoverer are retrofitted with selective catalytic reduction devices to 

reduce NOx emissions to under 0.5 g/kW-hr, and catalytic oxidation devices to reduce CO, VOCs 

and particulate matter less than 10 microns (PM10). 

• All other engines on the Discoverer will either be Tier 3 (low emissions) or will be retrofitted 

with Catalytic Diesel Particulate Filters devices to reduce CO, VOCs, and hazardous air 

pollutants (HAPs) and fine particulate matter. 

• ULSD (0.0015 percent sulfur) fuel will be purchased for the Discoverer and support vessels to 

reduce sulfur dioxide (SO2) emissions. 

• Ice management vessels and anchor handlers will have SCR as a nitrogen oxide (NOx) tailpipe 

emission control, and oxidation catalyst on its primary propulsion and generation engines. 

c) Processes, Equipment, Fuels, and Combustibles 

Kulluk 

Per 30 CFR 250.218(c), the following summarize equipment, fuels, and combustibles associated with the 

project. Emission units on the Kulluk are primarily associated with the generation of electricity, 

compressed air, and hydraulic energy to support drilling. All others are secondary and related to general 

purpose heating, transfer of materials about the deck, pumping of cement, incineration of (primarily) 

domestic waste, and other small emission sources. All emission source groups aboard the Kulluk are 

listed in Table 7.a-1. 

Shell will purchase only ULSD fuel for use in the Kulluk and all of the associated fleet while the Kulluk 

is an OCS source. This fuel is produced with a sulfur content of 0.0015 percent (15 ppm) by weight or 

less. 

Discoverer 

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. Fuel for all stationary source engines on the Discoverer will be purchased with sulfur 

content at or below 0.0015 weight percent. 

d) Distance to Shore 

Per requirements set forth in 30 CFR 250.218(b), distances from the drill sites to the mainland shore are 

as follows: 

• Sivulliq G – 16.6 mi (26.7 km) 

• Sivulliq N – 16.2 mi (26.1 km) 

• Torpedo H – 20.8 mi (33.5 km) 

• Torpedo J – 23.1 mi (37.2 km) 

e) Non-exempt Drilling Vessels 

Kulluk 

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 drilling vessel and associated support vessels are exempt using the 

exemption formula found at 30 CFR 250.303(d). The following table lists the emission totals based on 

the BOEMRE formula at 30 CFR 250.303(d) and the yearly totals projected by Shell. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-18 May 2011 

Table 7.e-1 BOEMRE Exemption Results 

Parameter BOEMRE formula at 

30 CFR 250.303(d)* 

BOEMRE Value 

(V in tons/yr) 

Shell Projected Annual Total 

(tons/yr) 

Exempt?

CO V=3400D2/3 21,971 162 Yes 

TSP (PM2.5 & PM10) V=33.3D 539 28 Yes 

SO2 V=33.3D 539 5 Yes 

NOx V=33.3D 539 229 Yes 

VOC V=33.3D 539 40 Yes 

*D=distance from drill site to the closest onshore area; in this case the Sivulliq N drill site is used since it is the drill site closest to 

shore (16.2 mi) 

Shell has applied for a Synthetic Minor Source Permit from EPA. The proposed program will minimize 

air quality impacts by employing selective catalytic reduction and oxidation catalyst emissions control 

technology. 

Discoverer 

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 

(now owned by Noble) Discoverer Drilling 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 

Kulluk 

Per requirements set forth in 30 CFR 250.218(f), information on air emissions modeling can be found in 

Shell’s air permit application. Portions of this modeling report are repeated here. 

Results of the modeling and impact analysis are provided in Shell’s air permit application. Table 7.f-1 

displays the maximum estimated concentrations of NO2, PM2.5, PM10 and SO2 near the drilling vessel. 

The concentrations do not exceed National Ambient Air Quality Standards (NAAQS) or Alaska Ambient 

Air Quality Standards (AAAQS) at or beyond 500m from the hull of the Kulluk. 

A summary of the maximum modeled impacts of the Kulluk and associated fleet plus background 

concentrations for comparison to the NAAQS/AAAQS for the Beaufort Sea analysis is provided in Table 

7f-2. These results show that Shell’s proposed Kulluk Camden Bay exploration drilling program will 

comply with the NAAQS/AAAQS. Note that all maximum impacts are located on the ambient air 

boundary. 

The nearest coastal villages to the OCS lease blocks are Nuiqsut, Deadhorse, and Kaktovik, which are 

located 23, 20 and 9 mi (37, 32, and 14 km) from the nearest OCS lease blocks, respectively. Modeling 

from the nearest lease block was done since the permit application was drafted to cover the Kulluk if it 

were permitted to drill on any lease block currently valid in the Beaufort Sea. Table 7f-2 provides a 

summary of the modeled impacts from the proposed Kulluk project at the nearest coastal village locations 

and shows that impacts are well below the NAAQS/AAAQS. Shell-only impacts are no higher than 5 

percent of the NAAQS/AAAQS for any pollutant. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-19 May 2011 Table 7.f-1 Summary of Maximum Estimated Concentrations 

 Averaging 

Utilize 

Emissions 

Pair 

Background 

Max. Modeled Impact - 

Shell Only at or Beyond 

Ambient 

Air Boundary 1A, 2A

Background 

Concentration 

Max. Total 

Impact 3, 1B, 2B

AAAQS/ 

NAAQS 

Pollutant Period Sequence? In Time? μg/m3 μg/m3 μg/m3 μg/m3 (or ppm where 

noted) 

Comply? 

 NO2 1-hour Yes Yes 60.0 48.7 108.7 0.10 ppm Yes 

Annual 1B Yes Yes 9.8 2.4 5.6 100 Yes 

 PM2.5 24-hour Yes Yes 7.0 7.0 14.0 35 Yes 

Annual 1B Yes Yes 2.5 4.7 5.5 15 Yes 

 PM10 24-hour Yes No 20.6 55.1 75.7 150 Yes  SO2 1-hour No No 23.5 13.0 36.5 0.075 ppm Yes 

3-hour No No 16.0 11.4 27.4 1,300 Yes 

24-hour No No 10.8 4.2 15.0 365 Yes 

Annual 2B No No 5.5 1.7 4.0 80 Yes 

CO 1-hour No No 1,136 1,746 2,882 40,000 Yes 

8-hour No No 714 862 1,576 10,000 Yes 

NH3 8-hour No No 6.6 --- 6.6 2,100 Yes 1A Impact analyses for NO2, PM2.5, and PM10 span all 5 months of potential drilling activity (July 1 through November 30) using two 120-day emissions 

sequences to eliminate bias in the meteorological data; The highest impacts from the two 120-day sequences are shown. 

1B For the total annual impact values, the 120-day period average impacts for NO2 and PM2.5 are adjusted to annual impacts by taking into account the 

periods of the year when Shell operations don’t occur (i.e., multiply the 120-day average impacts by 0.329 (120 drilling days out of 365 days in a 

year)). 

2A Impact analyses for SO2, CO, and NH3 span all 5 months (153 days) of potential drilling activity (July 1 through November 30) using a single, worstcase configured model run (153 days) without consideration of emissions sequencing or intermittent source operations. 2B The 153-day period average impacts for SO2 are adjusted to annual impacts by taking into account the periods of the year when Shell operations don’t 

occur (i.e., multiply the 153-day average impacts by 0.419 (153 drilling days out of 365 days in a year)). 

3 Total modeled impact is the sum of the highest modeled impact (from either 2009 or 2010) plus background concentrations. For NO2 and PM2.5, the 

98th percentile values consistent with the form of the NAAQS are presented. For all other pollutants, the maximum modeled impacts are presented. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-20 May 2011 Table 7.f-2 Summary of Maximum Impacts at the Nearest Villages on the Beaufort Sea Coast 

 Averaging 

Shell Only Contribution to Maximum 

Total Impact 

(μg/m3) 1A, 2A

Maximum Total Impact - 

Background Included 3, 1B, 2B

AAAQS/ 

NAAQS 

Highest Shell -

Only Impact, 

Percentage of 

NAAQS/AAAQS 

Pollutant Period Nuiqsut Deadhorse Kaktovik Nuiqsut Deadhorse Kaktovik 

μg/m3 (or 

ppm where 

noted) 

Comply? (%) 

 NO2 1-hour 6.6 0.02 0.01 22.2 24.5 26.0 0.10 ppm Yes 4% 

Annual 1B 0.1 0.2 0.2 0.8 0.9 0.9 100 Yes 0.2% 

 PM2.5 24-hour 0.003 0.1 0.1 7.0 7.1 7.1 35 Yes 0.3% 

Annual 1B 0.01 0.02 0.02 1.5 1.6 1.5 15 Yes 0.2% 

 PM10 24-hour 0.3 0.6 0.5 55.4 55.7 55.6 150 Yes 0.4%  SO2 1-hour 6.4 6.9 10.1 19.5 19.9 23.1 0.075 ppm Yes 5% 

3-hour 4.8 5.2 8.1 16.2 16.6 19.5 1,300 Yes 1% 

24-hour 2.7 2.9 4.2 5.3 5.4 5.9 365 Yes 1% 

Annual 2B 0.5 0.6 0.9 1.9 1.9 2.1 80 Yes 1% 

CO 1-hour 230 251 379 1,976 1,997 2,125 40,000 Yes 1% 

8-hour 137 150 227 999 1,012 1,089 10,000 Yes 2% 

NH3 8-hour 1.6 1.8 2.6 1.6 1.8 2.6 2,100 Yes 0.1% 1A Impact analyses for NO2, PM2.5, and PM10 span all 5 months of potential drilling activity (July 1 through November 30) using two 120-day emissions sequences  to eliminate bias in the meteorological data;  The highest impacts from the two 120-day sequences are shown: Sequence "A" = July 1 through October 28, Sequence "B" = August 3 through November 30. 1B For the total annual impact values, the 120-day period average impacts (Shell only impact plus background) for NO2 and PM2.5 are adjusted to annual impacts by taking into 

account the periods of the year when Shell operations don’t occur (i.e., multiply the 120-day average impacts by 0.329 (120 drilling days out of 365 days in a year)). 

2A Impact analyses for SO2, CO, and NH3 span all 5 months (153 days) of potential drilling activity (July 1 through November 30) using a single, 

 worst-case configured model run (153 days) without consideration of emissions sequencing or intermittent source operations. 

2B The 153-day period average impacts for SO2 are adjusted to annual impacts by taking into account the periods of the year when Shell operations don’t occur 

 (i.e., multiply the 153-day Shell-only average impacts by 0.419 (153 drilling days out of 365 days in a year))and are then added to the background concentration. 

3 Total modeled impact is the sum of the highest modeled impact (from either 2009 or 2010) plus background concentrations. 

 For NO2 and PM2.5, the 98th percentile values consistent with the form of the NAAQS are presented. For all other pollutants, the maximum modeled impacts are presented. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-21 May 2011 

Discoverer 

Results of the modeling and impact analysis are provided in Shell’s air permit application and are 

summarized below in Table 7.f-3 and 7.f-4. The impacts were remodeled using the AERMOD model for 

SO2 and NO2. The EPA-acceptable dispersion modeling indicates that the NAAQS and PSD increments 

will be met at and beyond 500m from the hull of the Discoverer. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-22 May 2011 Table 7.f-3 Summary of Impacts on Air Quality 

NAAQS/ Background Max. Modeled Impact PSD Class II Max. Modeled Impact 

Averaging AAAQS 1 Concentration With Background Increment 4,5 Without Background Data Source for Modeled Impact 

Pollutant Period 

μg/m3

(or ppm 

where 

noted) 

 (μg/m3) Concentration 2 (μg/m3) (μg/m3) Concentration3 (μg/m3) and Background Concentrations 

 Nitrogen Dioxide (NO2) 1-hour 0.10 ppm 0.0 74.9 NE 74.9 March 18, 2011 Report, Table 3-9 8

Annual 100 11.3 31.0 25 19.7 EPA Statement of Basis, Table 5-14 7

 Particulate Matter (PM10) 24-hour 150 55.1 75.8 30 20.7 EPA Statement of Basis, Table 5-14 7 Fine Particulate Matter (PM2.5) 24-hour 35 10.0 29.2 NA 6 19.2 EPA Statement of Basis, Table 5-14 7

Annual 15 2.0 3.1 NA 6 1.1 EPA Statement of Basis, Table 5-14 7

 Sulfur Dioxide (SO2) 1-hour 0.075 ppm 13.0 35.0 NE 22.0 March 18, 2011 Report, Table 3-9 8

3-hour 1,300 41.6 66.6 512 25.0 EPA Statement of Basis, Table 5-14 7

24-hour 365 13.0 16.2 91 3.2 EPA Statement of Basis, Table 5-14 7

Annual 80 2.6 6.0 20 3.39 EPA Statement of Basis, Table 5-14 7

Carbon Monoxide (CO) 1-hour 40,000 1,750 2,977.1 NA 1,227.1 EPA Statement of Basis, Table 5-14 7

8-hour 10,000 1,070 1,527.5 NA 457.5 EPA Statement of Basis, Table 5-14 7

1 National Ambient Air Quality Standards and Alaska Ambient Air Quality Standards. 2 Maximum modeled impacts plus background concentration are compared to the NAAQS/AAAQS. 3 Maximum modeled impacts only without background concentration are compared to the PSD Increments. 4 NE = not established. 5 NA = not applicable. 6 NA = PM2.5 increments have been established, but are not yet in effect. 7 From EPA’s Statement of Basis for the Proposed Outer Continental Shelf Prevention of Significant Deterioration Permit No. R10OCS/PSD-AK-2010-01, 

Shell Gulf of Mexico Inc., Frontier Discoverer Drillship, Beaufort Sea Exploratory Drilling Program (February 2010), Table 5-14. 

8 Air Sciences Inc., Discoverer Drillship Impact Evaluation for SO2 and NO2 Using AERMOD Chukchi and Beaufort Seas, Shell Alaska Exploratory 

Drilling Program Prepared for Shell Offshore Inc., March 18, 2011, Table 3-9. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-23 May 2011 Table 7.f-4 Summary of Maximum Modeled Impacts – Beaufort Sea 

Distance from Shell-Only Impact, 

Drilling Location Max. Total Impact - Shell-Only Contribution to NAAQS Percentage of 

Receptor (km) Background Included (μg/m3) * Max. Total Impact (μg/m3) (ppm) Comply? NAAQS (%) 

 1-hour NO2At or Beyond Ambient Air Boundary 0.5 74.9 74.9 0.10 Yes 40% Kaktovik 14 25.9 0.001 0.10 Yes 0.001% Deadhorse (as represented by 50 km from nearest leases) 50 23.7 0.0002 

0.10 

Yes 0.0001% 

Deadhorse 84 23.4 9.4 0.10 Yes 5%  1-hour SO2At or Beyond Ambient Air Boundary 0.5 35.0 22.0 0.075 Yes 11% Kaktovik 14 15.9 2.9 0.075 Yes 1% Deadhorse (as represented by 50 km from nearest leases) 50 14.4 1.4 

0.075 

Yes 1% 

Deadhorse 84 14.0 1.0 0.075 Yes 1%  * For NO2, the 98th percentile impacts consistent with the form of the NAAQS are presented. 

 For SO2, maximum impacts are presented. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 7-24 May 2011 

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Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 8-1 May 2011

SECTION 8.0 OIL SPILL RESPONSE PLANNING 

a) Oil Spill Response Planning 

Shell’s Beaufort Sea Regional Exploration ODPCP was unconditionally approved on 11 March 2010 and 

is a fundamental component for the planned exploration drilling program. The latest revision (ODPCP 

Revision 1) has been submitted to BOEMRE as a separate document and the full text version is not 

included in this EP. Revision 1 reflects the inclusion of using either the Kulluk or the Discoverer as the 

drilling vessel and updates the WCD information and the oil spill response based on the new WCD. 

 

BOEMRE has revised and increased the requirements for WCD scenario calculations through NTL No. 

2010-N06. Lessees are now required to incorporate all potential hydrocarbon-bearing intervals in each 

open hole section into the WCD volume calculation. The hole section with the highest uncontrolled flow 

scenario is to be considered the basis of the WCD scenario. Shell has revised the ODPCP to address this 

increase in the WCD volume. The ODPCP is a regional oil spill response plan that demonstrates Shell’s 

capabilities to prevent or rapidly and effectively manage oil spills that may result from exploration 

drilling operations. Despite the very low likelihood of a large oil spill event, Shell has designed their 

response program based upon a regional capability of responding to an increasing range of spill volumes, 

from small operational spills up to and including the WCD from an exploration well blowout. Shell’s 

program is based upon a WCD planning scenario that meets the response planning requirements of the 

state and federal oil spill planning regulations. 

The ODPCP includes information regarding Shell’s regional oil spill organization and dedicated response 

assets, potential spill risks, and local environmental sensitivities. Details of Shell’s spill prevention 

programs, including personnel training and the procedures and management practices to prevent 

discharges are also provided. The ODPCP’s response information addresses personnel and equipment 

mobilization from various locations, equipment operating characteristics, and the availability of additional 

response resources both on and off site. 

b) Location of Primary Oil Spill Equipment Base and Staging Area 

Shell is planning to conduct an exploration drilling program located north of Point Thomson in the 

Camden Bay area. The Discoverer or Kulluk is expected to transit into Camden Bay and begin 

exploration drilling approximately July 10. During the planned exploration drilling program, the Kulluk

or Discoverer will be accompanied by an ice management vessel, an anchor handler, and other support 

vessels that include two oil spill response (OSR) barges with associated tugs. One OSR barge and tug 

will provide the primary oil spill response platform along with the assistance of the anchor handler, and 

one Offshore Supply Vessel (OSV) as Vessel of Opportunity Skimming Systems (VOSS). Ice conditions 

will determine the proximity of the OSR vessels to the Kulluk or Discoverer. Shell will station and 

maintain its OSR vessels to ensure timely response to any spill event. 

The dedicated OSR barge, VOSS, and other equipped support vessels would possess sufficient onboard 

storage capacity to provide containment, recovery, and storage for the initial 42-hour operational period. 

An Arctic OST would be staged within 240 mi (384 km) of the Camden Bay drill sites and would arrive 

at the recovery site within 24 hours of departure from its staging location. At hour 42, the Chukchi OSR 

barge and OSR vessel, or a similar vessels, would be available to relieve the on-site OSR barge and OSR 

vessels to lighter their recovered fluids to the OST. The two OSR barges, VOSS and OSR vessel would 

work in conjunction to maintain containment and skimming operations and to lighter recovered fluids to 

the OST for the duration of the response. The OST will possess a minimum liquid storage capacity of 

513,000 bbl, sufficient capacity to store all recovered liquids for 20 days of recovery operations. Another 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 8-2 May 2011

OST with similar liquid storage capacity will arrive within 20 days with adequate minimum storage 

capacity for the remainder of the 30-day blowout event. 

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

area. 

c) Name(s) of Spill Removal Organization(s) for Both Equipment and Personnel 

Shell’s primary response action contractor for Beaufort Sea offshore, nearshore, and onshore spill 

response program is Alaska Clean Seas (ACS). ACS provides program oversight and spill management 

team assistance, oil spill management and response training, and spill response support through provision 

of equipment and personnel. Additionally, Shell augments ACS and the spill response program with 

dedicated vessels and equipment carried onboard the OSR barge. Response activities will be conducted 

using ACS or Shell tactics as defined in the ACS’s Technical Manual and/or Shell’s Beaufort and 

Chukchi Seas Regional Tactics Manual, or as otherwise defined in the ODPCP. 

The 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. 

d) Volume of Worst Case Discharge Scenario [30 CFR 254.26(a)] 

A planning volume WCD scenario for the Beaufort Sea Regional ODPCP is provided in Table 8.d-1. 

Table 8.d-1 Oil Volume of a Worst Case Discharge Planning Scenario for the Beaufort Sea Regional 

ODPCP 

Element Capacity (bbl) Reference

Possible Daily Volume of 

Highest Capacity Well 16,000 30 CFR 254.47(b) 

Total Worst Case Discharge 

(Daily Volume X 30-day 

Duration of Blowout) 

480,000 30 CFR 254.47(b) 

Total Storage Capacity 

Requirements 480,000 30 CFR 254.47(b) 

Shell has calculated the WCD from each of the four wells described in this EP (Table 2.g-1). Of the four 

wells, Torpedo H has the highest calculated WCD at 9,468 bbl/day, significantly less than the 16,000 

bbl/day assumed in the ODPCP planning scenario. 

Description of Worst Case Discharge Scenario 

Under the requirements of the BOEMRE, the plan must include a WCD scenario. A full discussion of the 

WCD scenario is found in the ODPCP, Section 1.6.13. For exploration or development drilling 

operations, the WCD scenario is equal to, or greater than, the daily volume (BOEMRE NTL-No. 2010-

N06) possible from an uncontrolled blowout for a period of 30 days. In order to address BOEMRE 

requirements for a 30-day blowout, the total WCD planning volume was calculated based upon 

BOEMRE’s planning requirement, resulting in a WCD scenario volume of 480,000 bbl (76,312 m3

) of oil 

during the 30 days. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 8-3 May 2011

In addition to the response fleet description, WCD description and the WCD modeling report detailed in 

this portion of the EP, this information can also be found in Sections 1.6.7 (Recovery Strategies) and 

1.6.13 (Spill Response Scenarios) of the ODPCP. 

There are three scenarios in the unlikely event of a WCD (Table 8.d-2). Scenario 3 results in the largest 

volume of oil spilled – 407,124 bbl. Shell will have an OST tanker available (at least 513,000 bbl liquid 

capacity) to take on lightered recovered liquids within 24 hours (hrs), and an additional tanker of similar 

liquid capacity would be onsite within 20 days if needed. Therefore, Shell’s OSR fleet capacity for 

recovered liquids is more than sufficient to cover the unlikely WCD event. 

Table 8.d-2 Comparison of the WCD Planning Scenario Developed for the Beaufort Sea Regional ODPCP with the 

WCD Calculated for the revised Camden Bay EP for Three Relief Well Scenarios 

Element ODPCP 

Planning WCD 

WCD SCENARIO 1 

Revised Beaufort Sea EP 

- Kulluk or Discoverer

Drill its own Relief Well 

WCD SCENARIO 2

Revised Beaufort Sea 

EP – Discoverer as 

the secondary relief 

well drilling vessel 

WCD SCENARIO 3

Revised Beaufort Sea 

EP – Kulluk as the 

secondary relief well 

drilling vessel 

Maximum flow 

rate (bopd) 16,000 9,4681

 9,4681 9,4681

Total Duration 30 days 25 days 34 days (includes 9 

transit days) 

43 days (includes 18 

transit days) 

Total Oil 

Volume (bbl) 480,000 236,7002

 321,9122 407,1242

1

 calculated WCD for Torpedo H 

2

 flow diminishes over time but diminishment is not reflected in these totals 

e) Modeling Report

The WCD scenario is based upon a spill simulation model of a well blowout at the sea floor (or mudline) 

in approximately 100 ft (30 m) of water that rises and spreads on the surface. Oil on the water surface is 

assumed to move as a function of ocean currents and wind for the duration of the release. Section 1.6.13 

of the ODPCP outlines and details the spill response scenarios. 

The regional ocean current used to model trajectories for the Torpedo and Sivulliq drill site locations was 

0.87 mi/hr (1.4 km/hour) to the west-northwest (WNW). The wind data used for the trajectory modeling 

were collected from the nearest National Weather Service weather station at Barter Island from readings 

tabulated from August 1 through August 30 between 1971 and 1988. The predominant wind directions 

were determined as the 16 cardinal compass directions with a frequency greater than 10 percent of the 

time. These four wind directions were then normalized to 100 percent resulting in the following set of 

prevailing winds: 

• East wind = 34.3 percent frequency 

• WNW wind = 22.4 percent frequency 

• West wind = 21.9 percent frequency 

• East-southeast (ESE) wind = 21.3 percent frequency 

The trajectory simulation applied these predominant winds in two 15-day cycles to equal the 30-day 

simulation. The duration of the wind pattern was calculated from the frequency percent of each wind 

direction. For purposes of the scenario, the model employs an east wind at the initial time of the blowout. 

This is the most conservative approach, as the principal wind and the ocean current are both from the east, 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 8-4 May 2011

resulting in the quickest movement of the leading edge of the oil plume from the drill site. The resulting 

wind pattern for the trajectory model would be as follows: 

• Day 1 through Day 5, Hour 4: wind from the east 

• Day 5, Hour 4 through Day 8, Hour 13: wind from the WNW (292.5°) 

• Day 8, Hour 13 through Day 11 Hour 20: wind from the west 

• Day 11, Hour 20 through Day 15: wind from the ESE (112.5o

) 

• Day 16 through Day 21, Hour 4: wind from the east 

• Day 21, Hour 4 through Day 24, Hour 13: wind from the WNW (292.5o

) 

• Day 24, Hour 13 through Day 27 Hour 20: wind from the west 

• Day 27, Hour 20 through Day 30: wind from the ESE (112.5o

) 

The above winds and currents were applied in oil spill trajectory modeling for two locations, the Torpedo 

Prospect and the Sivulliq Prospect, since the prospects are close to one another. For the Torpedo drill site 

location, the trajectory analysis revealed that a majority of the oil would move under the influence of 

wind and current offshore with a slight potential for lesser amounts impacting the mainland and barrier 

islands between Cross Island and Barrow. From Day 1 through Day 5, Hour 4, oil movement is 

controlled by a 0.86 miles per hour (mph) WNW current and a 15 mph wind from the east. Left 

unrecovered, the oil plume travels almost due west across open ocean north of Cross Island. By Day 19, 

the oil would have reached the shorelines of Barrow and would then move to open ocean north of land. 

The trajectory analysis for the Sivulliq drill site is similar to that for Torpedo with a low potential for 

contacting barrier islands and shorelines between Cross Island and Barrow. The analysis revealed that a 

majority of the oil would move under the influence of the 15 mph east wind and 0.86 mph WNW current 

offshore with no impacts to the mainland and barrier islands through Day 3. Left unrecovered, the oil 

slick is predicted to travel to the WNW potentially contacting Barrow shorelines by Day 19 moving north 

of land into open ocean. 

Both trajectory simulations are consistent with the results presented in the BOEMRE Final Environmental 

Impact Statement (FEIS) for the Beaufort Sea Planning Area Oil and Gas Lease Sales (OCS EIS/ES 

MMS 2003-001). The BOEMRE FEIS included a trajectory analysis based upon the Oil-Spill-Risk 

Analysis (OSRA) model. Using collected Beaufort Sea environmental data and modeled currents, this 

OSRA model estimated the summer conditional probabilities of contact to be typically <0.5 percent to 4 

percent within the region near Milne Point, Point Brower, Bullen Point, Arey Island, Barter Island, and 

Beaufort Lagoon (Land Segments 37 through 39 and 41 through 49) during summer conditions. 

Probabilities were based upon the movement of oil without interception by containment or recovery 

activities for a period of 30 days, from source locations (Hypothetical Launch Area #15) that include 

Shell’s planned drill sites in the revised Camden Bay EP. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 9-1 May 2011

SECTION 9.0 ALASKA PLANNING INFORMATION 

a) Oil Discharge Prevention and Contingency Plan 

The following parameters are detailed in the approved Beaufort Sea Regional ODPCP (March 11, 2010) 

that was submitted separately to BOEMRE with the approved, initial 2010 Camden Bay 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 

This plan is routinely updated and revised to match anticipated conditions and circumstances and to 

comply with existing regulations. The revised ODPCP will be submitted concurrent with this revised EP 

as appropriate. 

b) Well Control Plan 

A regional WCP (Appendix L) outlining emergency procedures for dealing with a blowout situation was 

also submitted with the initial 2010 Camden Bay EP. This plan still remains in effect from a broad areawide perspective. The WCP includes a general section on relief well planning including drilling 

trajectory, special homing, or ranging, tools and blowout kill procedures. 

Shell prepared and submitted site specific well control plans for the Sivulliq N and Torpedo H locations 

in the initial 2010 Camden Bay EP. Similar site specific well control plans are submitted with this revised 

Camden Bay EP. Shell also prepared site specific relief well drilling and blowout kill plans for each 

individual drill site. The Relief Well Plan includes the strategy for dealing with the loss or disablement of 

the Kulluk or Discoverer. In the event that the Kulluk is the drilling vessel on site drilling the Sivulliq or 

Torpedo wells and is capable of drilling the relief well, it will be used as the primary relief well drilling 

vessel. If the Kulluk is disabled for any reason, the Discoverer will immediately deploy to the relief well 

site in the Camden Bay area to initiate relief well drilling operations. The opposite case is true if the 

Discoverer is the drilling vessel on site. It will act as the primary relief well drilling vessel with the 

Kulluk acting as a back-up secondary drilling vessel. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 9-2 May 2011

c) Critical Operations and Curtailment Plan and Ice Management Plan 

A COCP and an IMP have been prepared to support the planned exploration drilling program (see 

Appendices J and K). 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 exploration well drill site. However, scope of the IMP is limited to approaching 

hazardous ice and its potential effects on exploration drilling operations and safety. Both plans discuss 

general procedures that could be employed depending on circumstances to cease certain operations (or not 

initiate them), secure the well to prevent flows, recover or abandon moorings, as appropriate, and move 

off the location in advance of an approaching hazardous condition. 

d) Fuel Transfer Plan 

While not an emergency response plan, the Fuel Transfer Plan (FTP) is also attached for information (see 

Appendix M). The FTP outlines the procedures used to move fuel from vessel-to-vessel and dock-tovessel in such a way that transfers are performed safety and prevent fuel spills onto the water’s surface. 

During all fuel transfers, regardless of volume, Shell requires that the area downwind of the transfer 

points are pre-boomed to capture any fugitive spills of diesel fuel. 

Beaufort Sea Lease Sale 195 and 202 Stipulation No. 6 includes the statement that “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.” Fuel transfers during the planned exploration drilling operations will 

involve vessels using dynamic positioning (DP). DP vessels use thrusters to maintain position, and oil 

spill booms in the vicinity of the vessels can be pulled into the thrusters leaving the supplying vessels 

disabled near the drilling vessel. Thus, pre-booming downwind of the refueling vessel provides the best 

and safest method for capturing any spilled fuel resulting from refueling operations. 

e) Partial Well Scenario 

Several scenarios exist that could impact exploration drilling plans and result in partial wells being drilled 

during execution of this revised Camden Bay EP: 

• Drilling has not yet been completed through the deepest primary objective on the initial well prior 

to August 25 when, by agreement with subsistence whalers and other hunters, Shell will cease 

drilling operations and suspend the well before leaving the area for the fall Kaktovik and Cross 

Island (Nuiqsut) whale hunts 

• Drilling has been completed on the initial well, but there is ample time remaining before the 

whale hunt to start, but not finish, drilling the second planned well under the revised Camden Bay 

EP 

• Drilling must be suspended although the final well has not yet been finished (i.e. the deepest 

primary objective has not been penetrated and or evaluated) by the end of the drilling season on 

October 31 

• A hazardous condition (e.g., approaching ice) forces suspension of drilling operations, temporary 

abandonment of a wellbore in a safe and secure manner and demobilization from the Camden 

Bay area with no opportunity to return before the end of the drilling season to finish drilling 

operations on the final well 

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 9-3 May 2011

Each of these is discussed more fully below: 

INITIAL DRILLING SEASON 

If drilling and/or evaluation of the initial or second well of a drilling season has not been concluded (i.e., 

the deepest primary objective has not been penetrated and/or evaluated) and the well plugged and 

permanently abandoned before the start of the Kaktovik and Nuiqsut whaling season (set as August 25 

each year), Shell plans to suspend drilling operations, temporarily abandon (TA) the well in compliance 

with BOEMRE regulations and leave the drill site for the duration of the hunts. 

Once the whaling season has concluded, the drilling vessel will return to the drill site, re-enter the well 

and continue drilling and/or evaluating the wellbore. Once the well has been evaluated, it will be plugged 

and permanently abandoned in compliance with BOEMRE regulations before the rig recovers the subsea 

BOP stack and moorings. 

After its initial exploration well, depending on operational consideration (including the time remaining in 

the drilling season before the October 31 cessation of operations), Shell may begin work on a second well 

as described herein. This work could include MLC construction, drilling additional hole sections and 

cementing casing strings. If operational considerations limit Shell’s ability to drill the well to objective 

depth and evaluate the reservoir section, the well will be suspended before penetrating objective 

hydrocarbon-bearing zones. Suspension of the well will be done in compliance with applicable 

regulations and in consultation with BOEMRE. One method of suspending the well could include 

running casing, cementing it in the hole, setting a mechanical plug near the top of the well and capping 

the well. The proposed suspension procedure on any unfinished, or partial well, will be provided via 

submission of an APM for BOEMRE approval. 

In the succeeding exploration drilling season, the drilling vessel will return to this unfinished drill site, reenter the well and continue drilling or evaluation as described in the revised Camden Bay EP and APD. 

Once all objectives have been satisfied, the well will be plugged and permanently abandoned according to 

BOEMRE regulations before the drilling vessel moves to a new drill site to initiate drilling operations. 

If a hazardous condition requires curtailment of critical operations (or prevents initiating them, depending 

on time available) per the provisions of the COCP (see Appendix J), the well will be suspended and 

secured using a BOEMRE-approved procedure, moorings will be recovered if possible and the drilling 

vessel will move to a safe area. Once the hazardous condition has passed, the drilling vessel will return to 

the drill site and conclude drilling operations, evaluation, permanent plugging and abandonment 

operations. 

If, however, the hazardous condition (e.g., ice) does not permit moving back over the well, re-mooring, 

re-entering and continuing drilling/evaluation operations before the end of the drilling season, on October 

31, the well will remain TA’d until the next drilling season. The drilling vessel will return to the 

suspended well and conclude drilling/evaluation operations during the next drilling season prior to 

permanently abandoning the well. 

SUBSEQUENT DRILLING SEASON(S) 

A partial well will not be left at the end of the last exploration drilling season under the revised Camden 

Bay EP. All wells will be plugged and permanently abandoned before the drilling fleet demobilizes. The 

only exception would involve a situation where Shell is unable to plug and abandon the well due to an 

emergency evacuation caused by an approaching hazard such as ice. If a well cannot be permanently 

abandoned due to ice, it will be properly suspended before the drilling vessel evacuates. At the beginning 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 9-4 May 2011

of the next drilling season, the drilling vessel will return to the drill site to permanently abandon the 

unfinished well or continue drilling/evaluation of the well under another approved EP.

f) Surface Intervention – Capping Stack and Containment System 

Containment capability in the unlikely event of a blowout in Camden Bay is provided by a combination 

of a subsea capping stack, positioned on an ice management vessel, and surface separation equipment on 

a containment vessel. 

Surface intervention involves work done on the wellhead of a subsea well. Surface intervention in the 

OCS, involves subsea devices used on the top of the well or some device connected thereto (e.g., the BOP 

stack or wellhead). 

A set of subsea devices is being assembled for the drilling seasons to provide direct surface intervention 

capability with the following priorities: 

1. Attaching a device or series of devices to the well to affect a seal capable of withstanding the 

maximum anticipated wellhead pressure (MAWP) and closing the assembly to completely 

seal the well against further flows (commonly called “capping and killing”) 

2. Attaching a device or series of devices to the well and diverting flow to surface vessel(s) 

equipped for separation and disposal of hydrocarbons (commonly called “capping and 

diverting”) 

These devices form what is generally known as a capping stack. The devices include ram-type BOP 

bodies equipped with blind and/or pipe rams, spacer spools, flow crosses (or mud crosses) for pumping 

kill weight fluid into the well or for flowing the well in a controlled manner through piping to the surface 

and connectors to attach to the upper H4 connector mandrel, the high-pressure wellhead housing if the 

entire BOP stack has been removed or the flanged connection on top of the lower marine riser package 

(LMRP). This equipment will be stored aboard a designated vessel in Alaska with a marine crew aboard, 

warm-stored and ready for use. It is anticipated that surface intervention efforts will successfully stop the 

flow from a blowout in less time than is required to drill a relief well. 

Various crossovers and spools, ram sets and other equipment (including demolition tools for clearing 

debris away from the well) will be included on the designated vessel. Extra studs, nuts, gaskets, hydraulic 

wrenches and other tools will be available to allow the capping stack to be modified aboard the vessel as 

necessary to provide flexibility to deal with a wide variety of capping situations. 

All of the separation equipment on the containment vessel will be designed for conditions found in the 

Arctic including ice and cold temperatures. This equipment will also be designed for maximum reliability, 

ease of operation, flexibility and robustness so it could be used for a variety of blowout situations. The 

capping stack located on an ice management vessel and the separation equipment, located on the 

containment vessel will be available for inspection by BOEMRE prior to the drilling season. 

Efforts to contain the blowout will begin immediately after the containment vessel arrives to clear debris 

from the well and attach a capping stack. If these efforts fail to capture all the oil, Shell’s OSR fleet will 

still be available at the blowout well site to collect and recover fugitive oil emissions from the surface. 

This equipment will be positioned downwind and down current from the blowout well and will not 

interfere with either containment efforts or relief well drilling. Containment efforts will continue during 

relief well drilling operations unless it is unsafe or futile to do so. The surface oil spill response fleet 

would remain and oil spill cleanup would continue, as necessary, until the blowout is under control. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 10-1 May 2011

SECTION 10.0 ENVIRONMENTAL MONITORING 

INFORMATION 

a) Monitoring Systems 

The following Tables 10a-1 and 10a-2 list the navigational and environmental monitoring systems aboard 

the Kulluk and Discoverer. 

Table 10.a-1 Kulluk Monitoring Equipment 

Instrument Make /Model

Navigation Radar Seles Mar Selux. Model T-340 ARPA 

Navigation Receiver Navtex NCR 333 

Satellite Communications Sailor System 4000 GMDSS Console 

Gyro Compass Navigat X MK 1 

Echo Sounder, fathometer ELAC STG 721 Digitizer 

Roll and Pitch Monitors Moeller Instrument Co. Inclinometers 

Anchor Tensions Bailey 

Anemometer RM Young Company Model 04503 N 

Meteorological Thermometer RM Young Model 46203 

Meteorological Barometer Weems and Plath Barometer 

Table 10.a-2 Discoverer Monitoring Equipment 

Instrument Make /Model

Navigation Radar Furuno ARPA FAR - 28 X 7 SERIES 

Furuno FAR - 21 X 7 (-BB) SERIES 

Satellite Communications 

GMDSS EQUIPMENT 

Sailor HC 4500 MF / HF control unit (2 units) 

System 4000 GMDSS 

Sailor HF SSB 250W PEP 

Thrane &Thrane TT - 3020C / TT - 3022D Capsat Transceiver 

JMC Dual Frequency Navtex Receiver Model NT - 1800 

Sat Phone Sailor TT3622B 

Navigation Receiver Furuno GPS Navigator GP - 150 

AIS L3 Communications 

Gyro Compass Simrad GL 80 / 85 

Magnetic Compass Cassen & Plath GmbH Type 12 Reflector compass 

Echo sounder Furuno FE 700 

Pitch & Roll Standard clinometer model MOELLER 5 / 15 degs 

Anchor Tensions Plimsoll Anchor tension monitoring system, needs to be calibrated, efforts 

to integrate it are in progress 

Wind Young Marine Wind Tracker Model 06206; Mounted on Cranes System for 

Helicopter flights 

Air Temperature 1 pair of wet & dry thermometers 

Water Temperature Laser mounted flute to measure seawater inlet temperature 

Barometric Pressure Sato Sigma - II Barograph model NS II - BR 

Barometer Hanseatic Instruments 

Helicopter landing information 

Philips 190S, SMC Ship Motion Control Recording Roll, Pitch, Helideck 

Inclination, Max Heave, Heave Period. 

Philips 170 S, Observation Instruments BV. Wind obs.: Actual, Average, 

Minimum, Maximum, Gust, Air Temp, Air Pressure, Humidity. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 10-2 May 2011

Air Emissions 

On April 9, 2010, the EPA issued Shell an OCS PSD Permit to Construct (permit number – 

R10OCS/PSD-AK-2010-01) for the Discoverer to operate in the Camden Bay area. The permit was 

challenged and the Environmental Appeals Board (EAB) has remanded the permit back to the EPA, 

where it currently resides. After the EPA addresses the remanded issues, and a final permit is issued to 

Shell, the Discoverer and support vessels air emissions will be monitored in compliance with the permit 

conditions. 

A synthetic minor operating air permit application for the Kulluk was submitted to the EPA on February 

28, 2011. When a final permit is issued to Shell, the air emissions from the Kulluk and its support fleet 

will be monitored in compliance with the permit conditions. 

Ocean Discharges 

Authorization for the Discoverer to operate under NPDES GP AKG-28-0000 was issued to Shell for lease 

block 6610 and 6658 on April 20, 2010 (authorization AKG-28-0005). Sivulliq N and G drill sites are 

located within lease block 6658 and the Torpedo H drill site is located within lease block 6610. On 

October 12, 2010, Shell submitted a new NOI for the Discoverer to discharge waste on lease block 6658, 

updating the EPA regarding the selected waste streams that would not be discharged, but collected, 

temporarily stored onsite and then shipped for final disposal at an approved disposal site. Shell submitted 

a NOI for the Discoverer to discharge under GP AKG-28-0000 for lease block 6559 on December 16, 

2010. Supplemental NOI information for the Kulluk to discharge under GP AKG-28-0000 for lease 

blocks 6559, 6610 and 6658 was submitted to the EPA on April 8, 2011. 

Shell will adhere to the monitoring terms and conditions of the NPDES GP AKG-28-0000. The required 

waste monitoring equipment will be aboard the drilling vessel and Shell will adhere to its Quality 

Assurance Plan, which outlines sampling procedures and protocols. 

Ice 

The Shell Ice and Weather Advisory Center (SIWAC) will be based in Anchorage and will monitor ice 

and weather conditions for the Camden Bay exploration drilling operations. As stated in the IMP, SIWAC 

will forecast the arrival of ice hazards based on ice and weather predictions from satellite data combined 

with observations from vessels supporting the Kulluk or Discoverer. 

Information for developing ice loading predictions is provided through the consideration of actual on-site 

conditions in conjunction with forecasted weather advisory information from the SIWAC. The IMP 

outlines how the arrival of ice hazards in particular are predicted, based on observations of ice features by 

Ice Advisors on support vessels and on the drilling vessel, combined with ice and weather predictions 

provided by the SIWAC in Anchorage. 

Environmental Monitoring at Drill Sites While Drilling 

In addition to monitoring of marine mammals, a comprehensive environmental monitoring program will 

be implemented during exploration drilling operations. A dedicated science vessel staffed by a team of 

physical and biological oceanographers will be responsible for assessing pre-, during, and post drilling 

conditions in both biota and water and sediment quality. All drilling locations have been sampled at 

multiple times during the last three years to provide a baseline understanding of pre-existing conditions 

and interannual variability at these sites. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 10-3 May 2011

Physical oceanography characteristics that will be monitored continuously at the each location throughout 

the drilling process include: surface wind direction and speed, ambient air temperature, current speed and 

direction throughout the water column, water temperature through the water column and salinity through 

the water column. 

Water chemistry and characteristics that will be monitored will include assessment of metals and organics 

through the water column at multiple fixed and random locations around the drilling operation. These 

measurements will be made regularly before, during, and after drilling and will capture conditions during 

all significant phases of drilling operations and potential discharge. Physical characteristics of the water 

column will also be assessed including turbidity, temperature, and oxygen content in an effort to 

document and model plumes of released discharges. 

Biological observations will include assessments of benthos, epibenthos, zooplankton and phytoplankton, 

and fishes. In addition to characterization of the communities of these organisms at and near the drillsites 

before, during, and after operations, samples of biota will be collected before and after operations for 

tissue analysis for metals and organics. 

Bird and mammal observations will be made from all surface operation vessels throughout the exploration 

drilling activity in accordance with the 4MP and Bird Strike Lighting and Avoidance Plan (Appendix I). 

b) Incidental Takes 

Applications will be submitted contemporaneously for the following MMPA authorizations: 

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

• LOA from USFWS – Non-lethal, Incidental and Intentional Take of Polar Bear and Pacific 

Walrus (Appendix E) 

During the planned exploration drilling program, the Kulluk or Discoverer and support vessels will each 

have MMOs aboard to observe for marine mammals and record all observations. In addition, MMOs may 

act as avian observers and the observation data will also be recorded. Complete details of the MMO 

program are presented in the 4MP (Appendix D) submitted in support of the NMFS IHA and the USFWS 

LOA applications. The 4MP is valid for when either the Kulluk or the Discoverer is drilling. 

NMFS IHA Application 

Species for which an IHA is sought from NMFS are: 

• Mysticetes: bowhead gray, humpback and minke whales 

• Odontocetes: beluga, narwhal, and harbor porpoise 

• Pinnipeds: bearded, ringed, ribbon and spotted seals 

The only anticipated impacts to marine mammals associated with the exploration drilling program are 

propagation of sounds from the drilling vessel , ice management and support vessels, aircraft, and a short 

duration ZVSP survey at each well. Any impacts to whales and seals would be temporary and result in 

only short-term displacement of seals and whales from within ensonified zones produced by such energy 

sources and will not result in impacts of biological significance. Lists of protected species listed under the 

MMPA and the ESA are found in Section 12 b). Discussion regarding potential impacts to marine 

mammals is located in the EIA (Appendix F). 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 10-4 May 2011

Estimated incidental takes from the sound modeling results (Table 10.b-1) for the Kulluk, Discoverer and 

the ZVSP are shown in Tables 10.b-2 through -7. 

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. 

In regard to the subsistence hunt of bowhead whale in the Beaufort Sea, 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. 

Table 10.b-1 Sound Propagation Modeling Results of Drilling and ZVSP Activities Near Camden Bay in the Beaufort 

Sea 

Table 10.b-2 Estimates of the Numbers of Beluga and Bowhead Whales in Areas Where Maximum Received Sound 

Levels in the Water Would Be ≥120 dB 

Note: Estimates From operations conducted by Kulluk During Shell’s Planned Exploration Drilling Program in Summer (July – August) and Fall 

(September – October) near Camden Bay in the Beaufort Sea, Alaska, 2012. Not All Marine Mammals Will Change Their Behavior When 

Exposed to these Sound Levels. 

Received Level Modeling Used in

Source (dB re 1 μPa) Results (km) Calculations (km)

Kulluk 120 13.27 19.91

Discoverer 120 3.32 4.98

ZVSP 160 3.67 5.51

Season

Species Avg. Max. Avg. Max. Avg. Max.

Summer

Beluga 3 10 1 5 4 15

Bowhead whale 16 60 8 29 23 89

Fall

Beluga 2 9 2 9 4 18

Bowhead whale a* 5,575 11,150 N/A N/A 5,575 11,150

a

Ice Margin

See IHA Application text (Appendix C) for description of bowhead whale estimates for the Fall in the Beaufort Sea 

Number of Exposure to Sound Levels ≥120 dB from Kulluk

Nearshore Total
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 10-5 May 2011

Table 10.b-3 Estimates of the Numbers of Beluga and Bowhead Whales in Areas Where Maximum Received Sound 

Levels in the Water Would Be ≥120 dB 

Note: Estimates From operations conducted by Discoverer During Shell’s Planned Exploration Drilling Program in Summer (July – August) and 

Fall (September – October) near Camden Bay in the Beaufort Sea, Alaska, 2012. Not All Marine Mammals Will Change Their Behavior When 

Exposed to these Sound Levels. 

Table 10.b-4 Estimates of the Numbers of Beluga and Bowhead Whales in Areas Where Maximum Received Sound 

Levels in the Water Would Be ≥160 dB from ZVSP Activities 

Note: Estimates During Shell’s Planned Exploration Drilling Program in Summer (July – August) and Fall (September – October) near Camden 

Bay in the Beaufort Sea, Alaska, 2012. Not All Marine Mammals Will Change Their Behavior When Exposed to these Sound Levels. 

Season

Species Avg. Max. Avg. Max. Avg. Max.

Summer

Beluga 0 1 0 0 0 5

Bowhead whale 1 4 1 2 2 7

Fall

Beluga 0 1 0 1 0 5

Bowhead whale a N/A N/A N/A N/A N/A N/A

a See IHA Application text for description of bowhead whale estimates for the Fall in the Beaufort Sea. Estimates for VSP activities

Number of Exposure to Sound Levels ≥160 dB from ZVSP

Nearshore Ice Margin Total

have been included in the calculations from drilling (Table 6-6 or 6-7) 

Season

Species Avg. Max. Avg. Max. Avg. Max.

Summer

Beluga 0 1 0 0 0 5

Bowhead whale 1 4 0 2 1 6

Fall

Beluga 0 1 0 1 0 5

Bowhead whale a 1,387 2,774 N/A N/A 1,387 2,774

a See IHA Application text (Appendix C) for description of bowhead whale estimates for the Fall in the Beaufort Sea 

Number of Exposure to Sound Levels ≥120 dB from Discoverer

Nearshore Ice Margin Total
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 10-6 May 2011

Table 10.b-5 Estimates of the Numbers of Marine Mammals (Excluding Beluga and Bowhead Whales, Which are Shown 

in Table 10.b-2) in Each Offshore area where maximum received sound levels in the water would be ≥120 

dB 

Note: from the Kulluk during Shell’s Planned Exploration Drilling Program near Camden Bay in the Beaufort Sea, Alaska, July – October 31, 

2012. Not All Marine Mammals Will Change Their Behavior When Exposed to these Sound Levels. 

Table 10.b-6 Estimates of the Numbers of Marine Mammals (Excluding Beluga and Bowhead Whales, Which are Shown 

in Table 10.b-3) in Each Offshore area where maximum received sound levels in the water would be ≥120 

dB 

Note: from the Discoverer during Shell’s Planned Exploration Drilling Program near Camden Bay in the Beaufort Sea, Alaska, July – October 

31, 2012. Not All Marine Mammals Will Change Their Behavior When Exposed to these Sound Levels. 

Species Avg Max Avg Max Avg Max

Odontocetes

Monodontidae

Narwhal 0 0 0 0 0 5

Phocoenidae

Harbor porpoise 0 0 0 0 0 5

Mysticetes

Gray whale 0 0 0 0 0 5

Pinnipeds

Bearded seal 2 7 1 3 3 10

Ribbon seal 0 0 0 0 0 5

Ringed seal 37 146 13 52 49 198

Spotted seal 0 2 0 0 0 5

Number of Exposure to Sound Levels >120 dB from Discoverer

Nearshore Ice Margin Total

Species Avg Max Avg Max Avg Max

Odontocetes

Monodontidae

Narwhal 0 0 0 0 0 5

Phocoenidae

Harbor porpoise 0 1 0 0 0 5

Mysticetes

Gray whale 0 1 0 0 0 5

Pinnipeds

Bearded seal 30 121 11 42 41 163

Ribbon seal 0 1 0 0 0 5

Ringed seal 592 2367 206 825 798 3192

Spotted seal 6 25 0 0 6 25

Nearshore Ice Margin

Number of Exposure to Sound Levels >120 dB from Kulluk

Total
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 10-7 May 2011

Table 10.b-7 Estimates of the Numbers of Marine Mammals (Excluding Beluga and Bowhead Whales, Which are Shown 

in Table 10.b-4) in Each Offshore area where maximum received sound levels in the water would be ≥160 

dB 

Note: from ZVSP Activities during Shell’s Planned Exploration Drilling Program near Camden Bay in the Beaufort Sea, Alaska, July – October 

31, 2012. Not All Marine Mammals Will Change Their Behavior When Exposed to these Sound Levels. 

USFWS LOA Application 

The LOA application submitted to the USFWS provides an outline of the Camden Bay exploration 

drilling activities and includes an updated, drilling program specific bear and Pacific walrus plan titled: 

Polar Bear, Pacific Walrus and Grizzly Bear Avoidance and Human Encounter/Interaction Plan, Outer 

Continental Shelf Exploration Plan, Camden Bay, Alaska. The LOA application does not require the 

inclusion of take estimates for polar bears or Pacific walrus. Discussion regarding potential impacts to 

polar bear and Pacific walrus is located in the EIA (Appendix F).

The bear and walrus interaction plan ensures that workers are familiar with the issues and safety 

precautions associated with working in bear and walrus territory. The goal of this interaction plan is to 

standardize bear interaction and avoidance protocol and wildlife reporting efforts for the project. With 

proper knowledge and training, workers will detect the presence of bears and walrus quickly and respond 

appropriately through monitoring, avoidance, and/or, if necessary, active deterrence by USFWS certified 

bear hazers. The awareness and prevention of human/bear and human/walrus interactions will ensure the 

safety of workers as well as wildlife. 

 

Species Avg Max Avg Max Avg Max

Odontocetes

Monodontidae

Narwhal 0 0 0 0 0 5

Phocoenidae

Harbor porpoise 0 0 0 0 0 5

Mysticetes

Gray whale 0 0 0 0 0 5

Pinnipeds

Bearded seal 2 9 1 3 3 12

Ribbon seal 0 0 0 0 0 5

Ringed seal 44 178 16 63 60 241

Spotted seal 0 2 0 0 0 5

Nearshore Ice Margin

Number of Exposure to Sound Levels >160 dB from ZVSP

Total
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 10-8 May 2011

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Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 11-1 May 2011

SECTION 11.0 LEASE STIPULATIONS INFORMATION 

In compliance with 30 CFR 250.222 What lease stipulations information must accompany the EP?, the 

following section describes what measures Shell’s planned Camden Bay exploration drilling program will 

take to meet the lease sale stipulations of Beaufort Sea Lease Sale EIS 186, 195 and 202. 

Stipulation No. 1 - Protection of Biological Resources 

If biological populations or habitats that may require additional protection are identified in the lease 

area by the 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. 

Shell Actions: 

Marine surveys for site clearance of the planned drill sites have not identified any biological populations 

or habitats that may require additional protection. As required by 30 CFR 250.33 (b)(1)(ix), and as 

specified in BOEMRE Alaska OCS Region Notice to Lessee No. 05-A01, Shell acquired shallow hazards 

surveys over these planned drill sites (reports submitted previously under separate cover). The survey data 

includes detailed bathymetry through the use of subbottom profilers and side scan sonar methods. 

Shell acquired shallow hazards survey data over the Sivulliq and Torpedo drill sites in 2008. The shallow 

hazards data did not identify any special benthic communities at these planned drill sites. Hard-bottom 

biological communities (e.g. “boulder patch” areas) have high species diversity and provide valuable 

habitat for fish and invertebrates. No confirmed boulder patch-type habitat has been identified at any of 

the planned drill sites. 

The most recent published biological studies commissioned by Shell for the Beaufort Sea are from 

surveys completed in 2008. Shell commissioned both biological and chemical studies of water and 

sediment samples in an around the Sivulliq Prospect and in the near vicinity of the Torpedo Prospect 

(Dunton et al, 2009 Trefry and Trocine, 2009 - see also Section 5.0 a) and 17.0). 

During 2008, benthic and water column sampling was completed at 45 designated stations in the Camden 

Bay area to help establish a baseline data set in advance of future oil and gas exploration. Two benthic 

grab samples were collected at each station, one for biology (infaunal abundance and biomass) and one 

for chemistry (sediment parameters and selective collection of biota for determination of trophic 

structure). Vertical profiles of water column characteristics were assayed at seven selected stations. 

Samples were collected in and around the Sivulliq Prospect (12 locations), around the 1985 Hammerhead 

well (9 locations), along a possible pipeline corridor (5 locations), and several samples were taken at 

random in the study area (19 locations). 

The following sample types were collected in 2008: 

• Seafloor surface sediment samples 

• Sediment cores, 3 to 4 in. (8-10 cm) in length 

• Hydrographic profiles and water samples 

No biological resources that require additional protection were found. The sample locations and a more 

detailed account of the results of the sampling are discussed in the EIA (Appendix F). 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 11-2 May 2011

Stipulation No. 2 - Orientation Program 

The lessee shall include in any exploration or development and production plans submitted under 30 CFR 

250.203 and 250.204 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, commercial fishing activities, and pertinent mitigation. 

Shell Actions: 

Shell has developed and is currently implementing an orientation program for all Shell and contractor 

personnel involved in Shell’s Alaska Venture exploration drilling activities. 

All Shell and contractor personnel involved in on-lease exploration drilling activities will attend the 

orientation training annually. All other Shell and contractor personnel will attend the orientation program 

at least once at the time they join the team. Shell will maintain a record, not to exceed five years, of all 

personnel who attend the program, including relevant attendee and program information. Copies of the 

orientations programs have been submitted to BOEMRE. 

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 Composition 

• Brief history of land claims 

• Formation of regional corporations, and regions within which Shell is working 

• History of the North Slope 

• Cultural diversity 

• Comparison of cultural values of Alaska Natives vs. non-Natives 

• Patterns of language 

• Communication skills and body language 

• Guidelines on cultural artifacts 

• Local community values and customs 

• Whaling 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 11-3 May 2011

Shell has further developed a Health, Safety, Security and Environment (HSSE) Awareness Program, 

which addresses the following: 

• Shell’s HSSE Commitment 

• Intervention policy 

• Journey Management Travel 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 

o Cold Climate Work Standard 

o Firearms Use in Wildlife Confrontations 

o Procedure for Vessel-to-Vessel Personnel Transfers 

• Incident Reporting 

• Environmental Awareness 

o Endangered Species Act (ESA) – Major Provisions 

o Endangered and threatened species 

o MMPA of 1972 

o Marine mammal interactions 

o Sensitive Habitats on the North Slope 

o Wildlife interactions 

o Prohibited activities of hunting, trapping and fishing 

o Environmental requirements, for air, spills and waste 

o 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 

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 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 advisory 

groups and Federal, state, and local governmental 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 any emergency. Determinations as to 

emergency conditions and appropriate responses to these conditions will be made by the RS/FO. 

Shell Actions: 

Not applicable to the activities described in the revised Camden Bay EP. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 11-4 May 2011

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

Lessees proposing to conduct exploratory drilling operations, including seismic surveys, during the 

bowhead whale migration 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 the North Slope Borough (NSB) and the Alaska Eskimo Whaling Commission (AEWC), 

determine that a monitoring program is not necessary. The RS/FO will provide the NSB, AEWC, and the 

State of Alaska a minimum of 30 but no longer than 60 calendar days to review and comment on a 

proposed monitoring program prior to approval. The monitoring program must be approved each year 

before exploratory drilling operations can be commenced. 

Shell Actions: 

Shell submits with this revised Camden Bay EP a copy of the 4MP (Appendix D) which also 

accompanies Shell’s application for an IHA (Appendix C) and the LOA (Appendix E). The 4MP 

describes a site-specific bowhead whale monitoring program as a component of compliance with the 

issuance of an IHA from NMFS. Shell understands that BOEMRE will accept Shell’s application for an 

IHA to cover this exploration drilling program, which is required to have a 4MP, as meeting the 

requirements of Stipulation No. 4. Also, Shell understands that BOEMRE will coordinate with NMFS to 

ensure that Shell’s IHA, monitoring program, peer review and oversight of Shell’s exploration drilling 

program will satisfy the requirements of Stipulation No. 4. 

Shell has and will continue to be an active participant in pre-season NMFS Arctic Open Water meetings 

and an active participant in the independent review of other monitoring and mitigation plans and reports 

generated for future activities. These Open Water meetings provide a venue for peer review of Shell’s 

plans and allow constructive critique of Shell’s procedures. 

A summary of key components of the program is presented below. 

Marine Mammal Observers 

The presence of MMOs aboard all 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 birds and for 

advising on appropriate mitigation measures. Observations made by MMOs serve as the primary basis 

for estimation of impacts to marine mammals and birds. Because their ranks may include representatives 

of the Alaska Native community, the MMO program also serves as a means of providing local hire and 

local oversight of the monitoring program. 

One of the MMOs aboard each vessel will be able to speak Inupiaq. This will allow communication with 

whaling crews should the need arise. 

In support of drilling, the Kulluk or Discoverer, ice management vessels, and all other support vessels will 

require MMOs to be available during operations to monitor for marine mammals and to advise on 

mitigation measures. All support vessels will staff MMOs during transit and other drilling related 

activities as stipulated by federal authorizations for incidental takes of marine mammals. 

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 11-5 May 2011

Subsistence Advisors (SA) Program 

The SA program was developed to address the concerns of the North Slope residents regarding impacts to 

subsistence activities since Shell has active offshore exploration drilling programs in the Beaufort and 

Chukchi Seas. Objectives of the SA program include: preserve the subsistence lifestyle of North Slope 

residents; establish and maintain frequent communications between Shell and subsistence users; 

communicate the program objectives to community members and; attend community meetings relevant to 

subsistence use on Shell’s behalf. During the SA program, subsistence questionnaires were designed and 

each SA was asked to fill in one questionnaire for each resident that participates in subsistence 

hunting/fishing activities. In addition, subsistence hunters and fishers were asked to draw subsistence use 

locations on regional maps of their respective areas. The maps are intended to define spring and fall 

hunting/fishing areas, migratory routes, calving routes, calving areas, mating areas and feeding ground 

locations. These various locations were digitally transferred onto maps for each village. 

SA reports have been generated documenting the results of the SA work in the villages. These reports are: 

• 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 

• UIC UMIAQ. 2011. 2010 Subsistence Advisor Program, North Slope Alaska. Report prepared by 

UIC UMIAQ for Shell Exploration and Production Company, Anchorage Alaska. 

Community Liaison Officers 

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 on-lease operations during the planned 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. 

Com Center Program 

The Com Center program involves hiring individuals from the coastal Beaufort and Chukchi Sea villages 

to monitor and relay radio transmissions between subsistence vessels and industry vessels. The sharing of 

information is intended to reduce or eliminate the potential conflict between subsistence users and 

industry vessels. 

Aerial Monitoring Program

The main goal of the aerial monitoring program is to monitor marine mammal populations and 

movements during each season of exploration drilling proposed in this revised Camden Bay EP. Aerial 

monitoring will use aircraft in support of the vessel-based 4MP during the revised Camden Bay EP. The 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 11-6 May 2011

aerial monitoring program is projected to begin 5-7 days before exploration drilling begins and continue 

5-7 days after exploration drilling ceases. 

For marine mammal monitoring flights, aircraft will be flown at approximately 120 knots ground speed 

and usually at an altitude of 1,000 ft (305 m) over a predefined grid. The transect lines in the grid will be 

oriented north-south, equally spaced at 5 mi (8 km), and randomly shifted in the east-west direction for 

each survey by no more than the transect spacing. The survey grid will total about 1300 km in length, 

requiring approximately 6 hours to survey at a speed of 120 knots, plus ferry time. Exact lengths and 

durations will vary somewhat depending on the position of the exploration drilling operation and thus of 

the grid, the sequence in which lines are flown (often affected by weather), and the number of refueling/rest stops. 

More information can be found in the 4MP (Appendix D). 

Acoustic Recorders 

A combination of acoustic recorder technologies will be employed to document the overall distribution of 

marine mammals in the area; the distribution of marine mammals in relation to exploration drilling 

activities; to add clarity to exploration drilling sound levels, character, and propagation; and to document 

presence of marine mammals. This will be accomplished by deploying several acoustic recorder buoys in 

a wide area surrounding the planned drill sites. Shell has deployed acoustic monitoring recorder from 

Harrison Bay to Kaktovik, encompassing Camden Bay since 2007. 

Sound Modeling 

Sound modeling will be required for the planned exploration drilling program in the Camden Bay area, 

and will take place during each exploration drilling season. The sound data will enable Shell to refine 

sound level thresholds and use the thresholds to more accurately define marine mammal take estimates. 

Sound Source Verification 

The drilling vessel and each support vessel listed in the revised Camden Bay EP will have a sound source 

verification done within five days of arriving at the first drill site. In addition, Shell will have acoustic 

recorders in the area of exploration drilling activities during the duration of the exploration drilling 

program. 

Additional Studies 

Shell may participate in additional studies of marine resources in the Beaufort Sea in an effort to further 

understand baseline conditions and the distribution of critical resources, to enhance understanding of 

interactions between industry activities and marine resources, and to contribute to enhanced 

understanding of resource status and conservation/management needs. The list of potential studies and 

monitoring projects includes: 

• Offshore bird (eider) distribution and use of project areas in Beaufort Sea 

• Benthic biota survey 

• Pinniped distribution and response to industry activities 

• Participation in bowhead tagging study 

• Analysis of subsistence harvest data with respect to industry activities supplemented by 

Traditional Knowledge compilation and analysis 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 11-7 May 2011

Stipulation No. 5 - Plan of Cooperation 

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 (including, but not 

limited to, bowhead whale subsistence hunting). Prior to submitting an exploration plan or development 

and production plan (including associated oil-spill contingency plans) to BOEMRE for activities 

proposed during the bowhead whale migration period, the lessee shall consult with the directly affected 

subsistence communities, Barrow, Kaktovik, or Nuiqsut, the NSB, and the AEWC to discuss potential 

conflicts with the siting, timing, and methods of proposed operations and safeguards or mitigating 

measures which could be implemented by the operator to prevent unreasonable conflicts. 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 subsistence hunting activities and will not result in unreasonable interference 

with subsistence harvests. 

Shell Actions: 

A POC Addendum identifies the measures Shell has developed in consultation with potential affected 

communities and subsistence user groups and will implement during its planned revised Camden Bay 

exploration drilling program to minimize any adverse effects on the availability of marine mammals for 

subsistence uses. In addition, the POC Addendum details Shell’s communications and consultations with 

local communities concerning its proposed exploration drilling program, potential conflicts with 

subsistence activities, and means of resolving any such conflicts (50 CFR § 18.128(d) and 50 CFR 

§ 216.104(a) (12) (i), (ii), (iv)). Shell has documented its contacts with North Slope communities (Table 

11-1), as well as the substance of its communications with subsistence stakeholder groups. Tables 

summarizing the substance of Shell’s communications, and responses thereto, are included in the POC 

Addendum (Appendix H). This POC Addendum may be supplemented, as appropriate, to reflect 

additional engagements with local subsistence users and any additional or revised mitigation measures 

that are adopted as a result of those engagements. 

The results of the POC meetings (Appendix H) have been documented and submitted to BOEMRE in the 

revised Camden Bay EP, and contemporaneously to NMFS, and USFWS in applications for MMPA 

authorizations of incidental takes of the trust species for which these agencies are responsible. The 

requirements of BOEMRE Stipulation No. 5 parallel requirements of the USFWS LOA and the NMFS 

IHA. Both the USFWS and NMFS require an applicant to implement a POC to mitigate the potential for 

conflicts between the proposed activity and traditional subsistence activities (50 CFR § 18.124(c)(4) and 

50 CFR § 216.104(a)(12)). The POC must identify the measures that will be taken to minimize any 

adverse effects on the availability of marine mammals for subsistence uses. In addition, both USFWS and 

NMFS require an applicant to communicate and consult with local subsistence communities concerning 

the proposed activity, potential conflicts with subsistence activities, and means of resolving any such 

conflicts (50 CFR § 18.128(d) and 50 CFR § 216.104(a) (12) (i), (ii), (iv)). 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 11-8 May 2011

Table 11-1 POC Meeting Dates and Locations and Attendees 

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 Point Hope Steve Oommittuk - Mayor of Point Hope 

21 January Barrow Charlie Hopson – Whaling Captain Representative, LCMF employee, and 

AEWC alternate commissioner in Barrow 

Adeline Hopson – NSB Assembly Member 

Deano Oleuman – NSB Assembly Member 

21 January Barrow Roy Koonuk – AEWC Commissioner and Point Hope Whaling Captain 

21 January Barrow George Edwardson – ICAS President 

Juanita Smith – ICAS Natural Resource Director 

21 January Point Hope Rex Rock Sr.; NSB Assembly Member and Tikiqag Representative 

27 January Kotzebue Jackie Hill – Maniilaq Association Representative 

27 January Kotzebue Martha Whiting – Mayor of the NWAB 

27 January Kotzebue NWAB Assembly Meeting 

27 January Kotzebue Chuck Greene, EJ Doll Garoutte, Walter Sampson, Gladys Pungowiyi - 

NANA Representatives 

27 January Kaktovik Fenton Rexford NSB Assembly Member and Native Village of Kaktovik 

Executive Director 

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 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 

20 April Barrow Native Village of Barrow Meeting 

22 April Point Lay Plan of Cooperation Public Meeting 

23 April Kivalina Community Meeting 

2010 Meeting 

Location 

Meeting Attendees – Position 

14 January Barrow ICAS Monthly Meeting 

15 January Anchorage Eugene Brower – Barrow Whaling Captains Association President 

22 January Anchorage George Oleuman – Deputy Mayor 

Eugene Brower – NSB Assembly President 

Taqulik Hepa – NSB Wildlife Director 

Bessie O’Rouke – NSB Law Department 

Marvin Olson – NSB Director Public Works 

Dan Forster – NSB Planning Director 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 11-9 May 2011

Table 11-1 POC Meeting Dates and Locations and Attendees 

24 February Barrow Plan of Cooperation Public Meeting 

25 February Point Hope Plan of Cooperation Public Meeting 

26 February Kaktovik Plan of Cooperation Public Meeting 

26 February Barrow Edward Itta – Mayor of the NSB 

1 March Wainwright Plan of Cooperation Public Meeting 

2 March Kotzebue Community Meeting 

5 March Point Hope Plan of Cooperation Public Meeting 

1 April Point Lay Plan of Cooperation Public Meeting 

8 April Barrow Martha Whiting – Mayor of the NWAB 

Walter Sampson – NWAB Assembly President 

30 April Barrow Edward Itta – Mayor of the NSB 

1 June Barrow NSB Assembly Meeting 

1 June Point Lay Point Lay Community Meeting 

2 June Barrow Barrow Community Meeting 

3 June Kaktovik Kaktovik Community Meeting 

8 June Barrow Utqiagvik Agviqsiuqtit Aganangich Meeting 

8 June Barrow Barrow Whaling Captains Association Meeting 

24 June Barrow NWAB/NSB Joint Planning Commission Meeting 

19 July Barrow Edward Itta – Mayor of the NSB 

3 August Barrow NSB Assembly Meeting 

7 September Barrow NSB Assembly Meeting 

23 September Nuiqsut Nuiqsut Whaling Captains Association Meeting 

23 September Nuiqsut Plan of Cooperation Public Meeting 

24 September Barrow Plan of Cooperation Public Meeting 

25 September Kaktovik Plan of Cooperation Public Meeting 

8 November Anchorage Alaska Beluga Whale Committee Meeting 

6 December Anchorage Alaska Beluga Whale Committee Members 

Ice Seal Committee Members 

Alaska Nanuuq Commission Members 

Eskimo Walrus Commission Members 

2011 Meeting 

Location 

Meeting Attendees – Position 

27 January Barrow Barrow Whaling Captains Association Meeting 

27 February – 

2 March 

Dutch Harbor Edith Vorderstrasse – UIC UMIAQ Consulting Division Manager 

Ray Koonuk, Sr. – Whaling Captain 

Christopher Oktollik – Whaling Captain 

John Long, Jr. – Native Village of Point Hope Council Member 

Joseph Frankson – Whaling Captain 

Franklin Sage – Native Village of Point Hope Council Member 

Caroline Cannon – Native Village of Point Hope President 

Luke Koonook, Sr. – Elder and Whaling Captain 

Alzred Oomittuk – City of Point Hope Council Member 

Bessie Kowunna – Shell Point Hope Community Liaison, Tikigaq Board 

Member, and City Council Member 

Theodore Frankson – Native Village of Point Hope Staff 

Aaron Oktollik – AEWC Commissioner for Point Hope and Whaling Captain 

Carl Brower – Whaling Captain 

Dora Leavitt – City of Nuiqsut Council Member 

Thomas Napageak – City of Nuiqsut Mayor and Whaling Captain 

Edgar Kagak – Wainwright Health Board 

Oliver Peetook – City of Wainwright Vice Mayor 

Sandra Peetook – City of Wainwright Council Member 

Joseph Kaleak – AEWC Commissioner for Kaktovik and Whaling Captain 

George Tagarook – NSB Fire Department Fire Chief and Whaling Captain 

28 February – 

3 March 

Dutch Harbor William Tracey, Sr. – NSB Planning Commissioner and Point Lay Fire Chief 

Marie Tracey – NSB Village Liaison 

Emma Ahvakana – NWAB Assembly Member 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 11-10 May 2011

Table 11-1 POC Meeting Dates and Locations and Attendees 

Enoch Mitchell – Noatak IRA President 

Ronald Moto, Sr. – Nana Board Member and City of Deering Mayor 

Cole Schaeffer – Kikiktagruk Inupiat Corporation President & CEO 

Nellie Wesley – NWAB Planning Commission EPA Assistant 

Anthony Edwardsen – UIC President/CEO 

Troy Izat – Tikigaq Corporation COO 

Susan Harvey – Harvey Consulting, LLC and Consultant to the NSB 

Thomas Nageak – Barrow Whaling Captain and NSB Cultural Resource 

Specialist 

Roy Nageak Jr. – Native Village of Barrow Natural Resource Technician 

Michael Shults – Barrow City Council 

Mary Sage – NSBSD School Board Member, IIisagvik College Board 

Member, and Native Village of Barrow Council Member 

Robert Suydam – NSB Wildlife Biologist 

Qaiyaan Opie – ICAS Environmental Director 

Lloyd Leavitt – City of Barrow Council Member 

Robert Nageak – City of Barrow Council Member 

Johnny Aiken – AEWC Executive Director 

Harry Brower, Jr. – AEWC Chairman 

7-8 March Anchorage Arctic Open Water Meeting 

21 March Barrow Plan of Cooperation Public Meeting 

22 March Kaktovik Plan of Cooperation Public Meeting 

23 March Wainwright Plan of Cooperation Public Meeting 

23 March Wainwright Rossman Peetok – AEWC Commissioner for Wainwright 

Jason Ahmaogak – Wainwright Whaling Captain 

24 March Nuiqsut Plan of Cooperation Public Meeting 

24 March Nuiqsut Isaac Nukapigak – AEWC Commissioner for Nuiqsut 

Herbert Ipalook – President of the Nuiqsut Whaling Captains Association 

Thomas Napageak – Nuiqsut Whaling Captain 

Carl Brower – Nuiqsut Whaling Captain 

Eli Nukapigak – Nuiqsut Whaling Captain 

25 March Point Lay Plan of Cooperation Public Meeting 

28 March Point Hope Plan of Cooperation Public Meeting 

29 March Kiana Community Meeting 

30 March Kotzebue Community Meeting 

31 March Kivalina Community Meeting 

2 April Nome Vera Metcalf – Eskimo Walrus Commission 

Charlie Johnson – Alaska Nanuuq Commission 

5 April Barrow NSB Assembly Meeting 

7 April Kotzebue/ 

Anchorage 

(Teleconference) 

Willie Goodwin – Alaska Beluga Whale Committee 

8 April Anchorage John Goodwin – Ice Seal Committee 

15 April Anchorage Vera Metcalf – Eskimo Walrus Commission 

25 April Savoonga Community Meeting 

26 April Shishmaref Community Meeting 

27 April Gambell Community Meeting 

Notes: 

ASRC = Arctic Slope Regional Corporation 

CAA = Conflict Avoidance Agreement 

ICAS = Inupiat Community of the Arctic Slope 

LCMF = LCMF Incorporated. A subsidiary of Ukpeagvik Iñupiat Corporation

NSBSD = North Slope Borough School District 

UIC = Ukpeagvik Iñupiat Corporation 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 11-11 May 2011

Stipulation No. 6 - Pre-Booming Requirements for Fuel Transfers 

Fuel transfers (excluding gasoline transfers) of 100 barrels or more occurring 3 weeks prior to or during 

the bowhead whale migration 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. This stipulation is applicable to the blocks and migration times listed in 

the stipulation on Industry Site-Specific Bowhead Whale-Monitoring. The lessee’s oil-spill-contingency 

plans must include procedures for the pre-transfer booming of the fuel barge(s). 

Shell Actions: 

Shell developed a fuel transfer plan titled: Alaska Fuel Transfer Operating Conditions and Procedures. 

The fuel transfer plan is designed to establish special operating conditions and procedures to ensure that 

vessel-to-vessel fuel transfers are in full compliance with this lease stipulation as well as the USCG 

requirements. Shell’s fuel transfer plan will be adhered to for all fuel transfer, including transfers less than 

100 bbl. The fuel transfer plan is included in Appendix M of the revised Camden Bay EP. 

Fuel transfers during the planned drilling operations will involve vessels using DP instead of fuel barges. 

DP vessels use thrusters to maintain position, and oil spill booms in the vicinity of the vessels can be 

pulled into the thrusters leaving the supplying vessels disabled near the drilling vessel. Thus, instead of 

pre-booming completely around the DP vessel, Shell’s plan to pre-booming downwind of the refueling 

vessel provides the best and safest method for capturing any spilled fuel resulting from refueling 

operations. 

Stipulation No. 7 - Lighting of Lease Structures to Minimize Effects to Spectacled and 

Steller’s Eider 

In accordance with the Biological Opinion for the Beaufort Sea Lease Sale 186 issued by the U.S. Fish 

and Wildlife Service (USFWS) on October 22, 2002, and USFWS’s subsequent amendment of the 

Incidental Take Statement on September 21, 2004, lessees must adhere to lighting requirements for all 

exploration or delineation structures so as to minimize the likelihood that migrating spectacled or 

Steller’s eiders will strike these structures. Lessees are required to implement lighting requirements 

aimed at minimizing the radiation of light outward from exploration/delineation structures to minimize 

the likelihood that spectacled or Steller’s eiders 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. 

Shell Actions: 

Lighted vessels and structures in open waters and on-ice pose a collision risk to many species of birds. 

Growing scientific evidence indicates some bird species are attracted to light sources, which may increase 

the risk of bird strikes. Most related studies conclude that increased darkness, coupled with inclement 

weather, increases attraction by birds to lighted vessels and structures. Birds drawn to light often become 

disoriented and collide with these structures, which may result in injury or death. 

Shell presents the attached Bird Strike Avoidance and Lighting Plan, Camden Bay, Alaska (lighting plan) 

to outline the Shell bird strike avoidance strategy for exploration drilling operations in Camden Bay 

(Appendix I). Emphasis is on the prevention of bird strikes into the drilling vessel and support vessels by 

threatened spectacled eiders (Somateria fischeri) and Steller’s eiders (Polysticta stelleri) whose habitat 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 11-12 May 2011

includes the Beaufort Sea, including Camden Bay. Three of the four planned exploration drill sites are 

outside the area stipulated where a lighting plan is required by BOEMRE (i.e. between 146o

 W and 156o

W), and one is at the eastern boundary, therefore the chances of bird strikes to the drilling vessel and 

support vessels are considered to be low. This low probability of bird strikes will be further reduced by 

implementing lighting modifications as specified in this lighting plan. In addition, if a bird strike is 

observed, and the cause is believed to be at least in part due to lighting of the drilling vessel and support 

vessels, then reporting the bird strike and the conditions under which it occurred will help in better 

understanding the risks of bird strikes. 

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 12-1 May 2011

SECTION 12.0 ENVIRONMENTAL MITIGATION MEASURE 

INFORMATION 

a) Proposed Measures 

The permits and authorizations table included in Section 2.0 lists the authorizations and necessary permits 

to conduct the planned exploration drilling program. Shell will adopt the mitigation measures written into 

these authorizations, and will therefore be working within regulatory requirements. 

In addition to meeting all regulatory requirements, Shell is committed to other mitigation measures 

including those that will decrease any potential conflicts between exploration drilling activities and 

subsistence harvests. For the revised Camden Bay EP exploration drilling program, these mitigation 

measures include: 

Communications 

• Shell has developed a Communication Plan and will implement this plan before initiating 

exploration drilling operations to coordinate activities with local subsistence users, as well as 

Village Whaling Captains’ Associations, to minimize the risk of interfering with subsistence 

hunting activities, and keep current as to the timing and status of the bowhead whale hunt and 

other subsistence hunts. The Communication Plan includes procedures for coordination with 

Com Centers to be located in coastal villages along the Chukchi and Beaufort Seas during Shell’s 

proposed exploration drilling activities. 

• Shell will employ local SAs from the Beaufort and Chukchi Sea villages that are potentially 

impacted by Shell’s exploration drilling activities. The SAs will provide consultation and 

guidance regarding the whale migration and subsistence activities. There will be one per village, 

working approximately 8-hr per day and 40-hr weeks during the drilling seasons. 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 subsistence-related comments, concerns, and information; coordinating with the Com 

and Call Center personnel; and advising how to avoid subsistence conflicts. Subsistence advisors 

will have a handbook that will specify work tasks in more detail. 

Aircraft Travel 

• Aircraft shall not operate below 1,500 ft (457 m) unless the aircraft is engaged in marine mammal 

monitoring, approaching, landing or taking off, in poor weather (fog or low ceilings) in an 

emergency situation. Aircraft engaged in marine mammal monitoring shall not operate below 

1,500 ft (457 m) in areas of active whaling; such areas to be identified through communications 

with the Com Centers. 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 south of its 

offshore destination, then at that point it shall fly directly north through the Mary Sachs Entrance 

to its destination. Shell reserves the option to use an alternate flight route in the event that transit 

through the Mary Sachs Entrance is unsafe due to weather, other environmental conditions, or in 

the event of an emergency. 

• Aircraft and vessels will not operate within 0.5 mi (0.8 km) of walrus or polar bears when 

observed on land or ice. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 12-2 May 2011

• Shell will also implement non-MMO 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. This flight will also help avoid 

disturbance of and collisions with birds. 

Vessel Travel 

• The Kulluk or Discoverer and support vessels will enter the Chukchi Sea through the Bering 

Strait on or after July 1, minimizing effects on marine mammals and birds that frequent open 

leads and minimizing effects on spring and early summer bowhead whale hunting. 

• Exploration drilling activities at the Sivulliq or Torpedo drill sites are planned to begin on or 

about July 10 following transit into the Beaufort Sea and run through October 31, with a 

suspension of all operations beginning August 25 for the Nuiqsut (Cross Island) and Kaktovik 

subsistence bowhead whale hunts. During the suspension for the whale hunts, the drilling fleet 

will leave the Camden Bay project area and move to an area north of latitude 71o

 25’N and west 

of longitude 146o

 4’W. Shell does not plan to anchor during this suspension. Shell will return to 

resume activities after the subsistence bowhead whale hunts conclude. Exploration drilling 

activities will be completed by October 31, depending on ice and weather. 

• The drilling support fleet transit route will avoid known fragile ecosystems, including the 

Ledyard Bay Critical Habitat Unit, and will include coordination through Com Centers. 

• To minimize impacts on marine mammals and subsistence hunting activities, the drilling vessel 

and support fleet 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 drilling vessel 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. As soon as the fleet transits past the ice, it will exit the 

polynya zone and continue a path in the open sea toward the Camden Bay drill sites. 

• MMOs will be aboard the Kulluk or Discoverer and all support vessels (see the 4MP in Appendix 

D of the revised Camden Bay EP). 

• 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 is to be reduced during inclement weather conditions in order to avoid collisions 

with marine mammals. 

• All vessels must maintain cruising speed not to exceed nine knots while transiting the Beaufort 

Sea. This measure would reduce the risk of ship-whale collisions. 

• Shell will communicate and coordinate with the Com Centers regarding all vessel transit. 

Drilling Operations 

• Shell will collect all drilling mud and cuttings with adhered mud from all well sections below the 

26-in. (20-in. casing) hole section, as well as treated sanitary waste water, domestic wastes, bilge 

water and ballast water, and transport them outside the Arctic for proper disposal in an EPAlicensed TDS. These waste streams will not be discharged to the ocean. 

 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 12-3 May 2011

• Drilling mud will be cooled to mitigate any potential permafrost thawing or thermal dissociation 

of any methane hydrates encountered during drilling, if such materials are present at the drill site. 

• Drilling muds 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) so that 

the volume of the spent mud is reduced. 

• 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 of 

the hazard at the drill site (see COCP in Appendix J of the revised Camden Bay EP). 

• All casing and cementing programs will be certified by a registered professional engineer. 

• Airguns arrays will be ramped up slowly during ZVSPs to warn cetaceans and pinnipeds in the 

vicinity of the airguns and provide time for them to leave the area and avoid potential injury or 

impairment of their hearing abilities. Ramp ups from a cold start when no airguns have been 

firing will begin by firing a single airgun in the array. A ramp up to the required airgun array 

volume will not begin until there has been a minimum of 30 min of observation of the safety zone 

by MMOs to assure that no marine mammals are present. The safety zone is the extent of the 180 

dB radius for cetaceans and 190 dB for pinnipeds. The entire safety zone must be visible during 

the 30-min lead-in to an array ramp up. If a marine mammal(s) is sighted within the safety zone 

during the 30-min watch prior to ramp up, ramp up will be delayed until the marine mammal(s) is 

sighted outside of the safety zone or the animal(s) is not sighted for at least 15-30 min: 

15 min for small odontocetes and pinnipeds, or 30 min for baleen whales and large odontocetes. 

• The blowout prevention program will be enhanced through the use of two sets of blind/shear 

rams, increased frequency of BOP performance tests from 14 days to 7 days, a remotely operated 

vehicle (ROV) control panel on the seafloor with sufficient pressured water-based fluid to operate 

the BOP, a containment system that includes treatment and flaring capabilities, capping stack 

equipment, a fully-designed relief well drilling plan and provisions for a second relief well 

drilling vessel (Discoverer or Kulluk) to be available to drill the relief well if the primary drilling 

vessel is disabled and not capable of drilling its own relief well. 

• Lighting on the drilling vessel will be shaded and has been replaced with ClearSky lighting. 

ClearSky lighting is designed to minimize the disorientation and attraction of birds to the lighted 

drilling vessel to reduce the possibility of a bird collision (see the Bird Strike Avoidance and 

Lighting Plan in Appendix I of the revised Camden Bay EP). 

Ice Management 

• Ice management will involve preferentially redirecting, rather than breaking, ice floes while the 

floes are well away from the drill site (see the Ice Management Plan in Appendix K of the revised 

Camden Bay EP). 

• Real time ice and weather forecasting will be from the SIWAC. 

Oil Spill Response 

• The primary OSR vessel will be on standby at all times when drilling into zones containing oil to 

ensure that oil spill response capability is available within one hour, if needed. 

• Shell will deploy an OSR fleet that is capable of collecting oil on the water up to the calculated 

WCD flowrate of a blowout in the unlikely event that one should occur. The primary OSR vessel 

will be on standby when drilling into zones containing oil to ensure that oil spill response 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 12-4 May 2011

capability is available within one hour, if needed. The remainder of the OSR fleet will be fully 

engaged within 72 hours. 

• In addition to the OSR fleet, an oil spill containment system will be available for use in the 

unlikely event of a blowout. The containment system barge will be centrally located in the 

Beaufort Sea and supported by an Invader Class Tug and possibly an anchor handler. The 

containment system will be designed for conditions found in the Arctic including ice and cold 

temperatures. This equipment will also be designed for maximum reliability, ease of operation, 

flexibility and robustness so it could be used for a variety of blowout situations. 

• Capping stack equipment will be stored aboard one of the ice management vessels and will be 

available for immediate deployment in the unlikely event of a blowout. Capping stack equipment 

consist of subsea devices assembled to provide direct surface intervention capability with the 

following priorities: 

o Attaching a device or series of devices to the well to affect a seal capable of withstanding 

the maximum anticipated wellhead pressure (MAWP) and closing the assembly to 

completely seal the well against further flows (commonly called “capping and killing”) 

o Attaching a device or series of devices to the well and diverting flow to surface vessel(s) 

equipped for separation and disposal of hydrocarbons (commonly called “capping and 

diverting”) 

• A polar bear culvert trap has been constructed in anticipation of OSR needs and will be deployed 

near Point Thomson or Kaktovik prior to drilling. 

• Pre-booming is required for all fuel transfers between vessels. 

Air Emissions 

Kulluk 

• The Kulluk will have selective catalytic reduction (SCR) as a nitrogen oxide (NOx) tailpipe 

emission control on its primary engines. The primary generators will also have oxidation 

catalysts installed for control of particulate matter less than 2.5 microns (PM2.5), volatile organic 

compounds (VOC), and carbon monoxide (CO). 

• The other engines normally used in the exploration drilling activities (the air compressors, the 

MLC, hydraulic power units (HPU), and cranes) will also have oxidation catalysts as tailpipe 

control for oxidizing all oxidize-able substances, including PM2.5, VOC, and CO. Control of 

engine emissions is assumed to be 50 percent for PM2.5, 80 percent for CO, and 70 percent for 

VOC. 

• Ice management vessels and anchor handlers will have SCR as a nitrogen oxide (NOx) tailpipe 

emission control on its primary engines.. 

• ULSD (0.0015 percent) fuel will be purchased for the Kulluk and support vessels to reduce sulfur 

dioxide (SO2) emissions. 

Discoverer 

• Primary generators on the Discoverer are retrofitted with selective catalytic reduction devices to 

reduce NOx emissions to under 0.5 g/kW-hr, and catalytic oxidation devices to reduce CO, VOCs 

and PM10. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 12-5 May 2011

• All other engines on the Discoverer will either be Tier 3 (low emissions) or will be retrofitted 

with Catalytic Diesel Particulate Filters devices to reduce CO, VOCs, and HAPs and fine 

particulate matter. 

• Installation of selective catalyst reduction and oxidation catalyst emission controls on all 

propulsion and generation engines on the primary ice management vessel. 

• ULSD (0.0015 percent) fuel will be purchased for the Discoverer and support vessels to reduce 

SO2 emissions. 

b) Protected Species 

Species that occur within the Beaufort Sea and are listed under the ESA as either threatened or 

endangered are listed below in Table 12.b-1. The following table is a list of marine mammals found in the 

Beaufort Sea that are covered under the MMPA. 

Table 12.b-1 Species Found in the Beaufort Sea and Protected Under the ESA 

Common Name Scientific Name ESA Status Extralimital (Yes/No) 

Spectacled eider Somateria fischeri Threatened No 

Steller’s eider Polysticta stelleri Threatened No 

Yellow-billed loon1 Gavia adamsii Candidate No 

Pacific walrus1 Odobenus rosmarus divergens Candidate Yes 

Polar bear Ursus maritimus Threatened No 

Bowhead whale Balaena mysticetus Endangered No 

Fin whale Balaenoptera physalus Endangered Yes 

Humpback whale Megaptera novaeangliae Endangered Yes 

Bearded seal1 Erignathus barbatus Candidate No 

Ringed seal1 Phoca hispida Candidate No 

1 These are candidate species only and presently receive no protection under the ESA 

Table 12.b-2 Marine Mammals Found in the Beaufort Sea and Protected Under the MMPA

Common Name Scientific Name ESA Status Extralimital (Yes/No) 

Beluga whale Delphinapterus leucas Not listed No 

Narwhal Monodon monoceros Not listed Yes 

Killer whale Orcinus orca Not listed Yes 

Harbor Porpoise Phocoena phocoena Not listed Yes 

Bowhead whale Balaena mysticetus Endangered No 

Gray whale Eschrichtius robustus Not listed Yes 

Minke whale Balaenoptera acutorostrata Not listed Yes 

Humpback whale Megaptera novaeangliae Endangered Yes 

Pacific walrus Odobenus rosmarus divergens Candidate Yes 

Bearded seal Erignathus barbatus Candidate No 

Spotted seal Phoca largha AK population segment not listed No 

Ringed seal Phoca hispida Candidate No 

Ribbon Seal Histriophoca fasciata Not listed No 

Polar bear Ursus maritimus Threatened No 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 12-6 May 2011

The planned exploration drilling program may involve the non-lethal incidental take of certain marine 

mammals. Shell has applied to NMFS for an IHA for the incidental take of whales and seals, and to 

USFWS for an LOA for the incidental take of polar bear and Pacific walrus and intentional take (by 

deterrence) of polar bears. The IHA and LOA applications each contain a copy of the 4MP. The LOA 

application contains a bear and walrus avoidance and human encounter / interaction plan. Shell has also 

developed and will implement a Bird Strike Avoidance and Lighting Plan (Appendix I). All three of 

these documents describe mitigation measures that Shell will implement to minimize any effects on 

protected species. The resulting authorizations, when issued, may also contain additional mitigation 

measures to help avoid or minimize incidental takes. A summary of mitigation measures that will be 

undertaken by Shell is provided in the previous section. 

The IHA application is located in Appendix C, the LOA application is located in Appendix E, and the 

4MP is located in Appendix D. 

Mitigation measures that will be taken so to avoid or minimize the incidental take of the species listed in 

Table 12.b-2 are listed under the various drilling activities in Section 12 a). 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 13-1 May 2011 

SECTION 13.0 SUPPORT VESSELS AND AIRCRAFT 

INFORMATION 

a) General 

Table 13.a-1 lists the vessels proposed during all or part of the revised Camden Bay EP exploration 

drilling program. Fixed-wing aircraft and helicopters will be employed, but neither is currently under 

contract. If the specific vessels listed in Table 13.a-1 are not available, vessels of similar size and/or rating 

will be used. 

Table 13.a-1 Specifications of Support Vessels (Not Including OSR Vessels) 

Specification Nordica1 Hull 

2471

Carol 

Chouest1,2

Harvey 

Spirit1,3 

Arctic 

Seal1,4

Southeast Provider 

Barge & Ocean Ranger 

Tug1

Waste Storage 

Barge1

 Barge Tug Barge Tug 

Length 380.5 ft 

(116 m) 

360.6 ft 

(110 m) 

280 ft 

(85.34 m) 

280 ft 

(85.4 m) 

134 ft 

(50.3 m) 

360 ft 

(110 m) 

117 ft 

(35.7 m) 

500 ft 

(152.4 

m) 

126.75 

ft (38.6 

m) 

Width 85 ft 

(26 m) 

80 ft 

(24.4 m) 

60 ft 

(18.29) 

60 ft 

(18.3 m) 

32 ft 

(11.6 m) 

100 ft 

(30.5 m) 

32 ft (.8 

m) 

74 ft 

(22.6 m) 

42 ft 

(12.8 

m) 

Draft 27.5 ft 

(8.4 m) 

24 ft 

(7.3 m) 

19.24 ft 

(5.87 m) 

16.5 ft (5.0 

m) 

7 ft (2.1 

m) 14 ft - 27.5 ft 

(8.4 m) 

19 ft 

(5.8 m) 

Berths 82 64 29 26 17 - 10 - - 

Maximum 

Speed 

16 knots 

(30 

km/hr) 

15 knots 

(27.8 

km/hr) 

15 knots 

(27.8 km/hr) 

13.5 knots 

(25 km/hr) 

10 knots 

(18.5 

km/hr) 

- 

10 knots 

(18.5 

km/hr) 

- 12 

knots 

(22.2 

km/hr) 

Fuel 

Capacity 

11,070 

bbl 

12,575 

bbl 

8,411 bbl 

(normal)11,9

05 bbl (max) 

6,235 bbl 

(normal) 667 bbl - 

2,381 

bbl 

155,000 

bbl 

3,810 

bbl 

1 or similar vessel 

2Dutch Harbor supply vessel 

3Dutch Harbor supply vessel/waste removal 

4West Dock supply vessel 

Photo - M/V Nordica 

Diagram – Hull 247 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 13-2 May 2011 

Ice Management 

The M/V Nordica or a similar vessel, will serve as the primary ice management vessel in support of the

Kulluk or Discoverer. Hull 247 will provide anchor handling duties, serve as the berthing 

(accommodations) vessel and will also serve as a secondary ice management vessel. When managing ice, 

the Nordica (or similar vessel) and Hull 247 will generally be confined to a 40o

 arc up to 3.1 mi (5 km) 

upwind originating at the drilling vessel (Figure 13a-1). It is anticipated that the ice management vessels 

will be managing ice for up to 38 percent of the time when within 25 mi (40 km) of the Kulluk or 

Discoverer. Active ice management involves using the ice management vessel to steer larger floes so that 

their path does not intersect with the drill site. In some instances, the ice management vessel may have to 

break ice that is an immediate safety hazard for the drill site. Around-the-clock ice forecasting using 

realtime satellite coverage (available through SIWAC) will support the ice management duties. When the 

Nordica is not needed for ice management, it will reside outside the 25 mi (40 km) radius from the Kulluk

or Discoverer if it is safe to do so. The vessel will enter and exit the Beaufort Sea with the Kulluk or 

Discoverer.

As anchor handler, Hull 247’s duties include setting and removing anchors, berthing (accommodations) 

vessel, providing supplemental oil recovery capability (VOSS) and managing smaller ice floes that may 

pose a potential safety issue to the Kulluk or Discoverer and the support vessels that will service the 

Kulluk or Discoverer. 

Figure 13.a-1 Ice Management Vessels Configuration for the Kulluk or Discoverer
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 13-3 May 2011 

Resupply and Waste Removal 

The exploration drilling operations will require the transfer of supplies between the Deadhorse/Westdock 

shorebase and Dutch Harbor with the Kulluk or Discoverer. While the Kulluk or Discoverer is anchored 

at a drill site as an OCS-source under the EPA air permit, Shell has allowed for 24 visits/tie-ups (if the 

Kulluk is the drilling vessel being used) or 8 visits/tie-ups (if the Discoverer is being used) throughout the 

drilling season from support vessels. The Harvey Spirit (or similar vessel) will shuttle supplies from the 

Arctic Seal (or similar vessel) and/or the Southeast Provider (or similar vessel) to the Kulluk or 

Discoverer. During the resupply trips, the Harvey Spirit, or similar vessel, will be used to remove the 

mud/cuttings and other waste streams. The mud/cuttings will be transported to the Southeast Provider

(aka deck barge; or similar vessel) or the waste barge for storage. Other waste streams (sanitary waste, 

domestic waste, bilge water, ballast water) will also be transferred to the Southeast Provider (deck barge; 

or similar vessel), or the waste barge for temporary storage. All waste streams will be barged south for 

disposal at the end of the drilling season. 

While the Kulluk or Discoverer leaves Camden Bay temporarily during the Kaktovik and Nuiqsut (Cross 

Island) subsistence whale hunts, Shell will resupply the Kulluk or Discoverer with drilling supplies and 

equipment brought in from Dutch Harbor and stored on the Carol Chouest (or similar vessel) or the 

Harvey Spirit (or similar vessel). Approximately 10 resupply trips from Dutch Harbor to the resupply 

barge will be needed during each drilling season. The Carol Chouest (or similar vessel), will be used as a 

backup supply vessel and shuttle between Camden Bay and Dutch Harbor. When drilling starts up again 

after the bowhead whaling hunt has concluded, additional resupply may be required from West Dock via 

the Arctic Seal (or similar vessel) via transfer to the Harvey Spirit (or similar vessel) to the drilling vessel. 

Each support vessel will require refueling 4-6 times during the drilling season depending on fuel 

consumption based on utilization. 

Removal of waste and resupply to the drilling vessel will be conducted the same way regardless of 

drilling vessel. 

 

Photo – Harvey Spirit
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 13-4 May 2011 

Oil Spill Response 

The OSR vessels will include a primary OSR barge (the Arctic Endeavor and Point Class Tug, or similar 

vessel), Hull 247 will act as a berthing (quartering) vessel and a VOSS and an oil storage tanker (OST - 

M/V Mikhail Ulyanov or a similar vessel). The Harvey Spirit (or similar vessel) will also act as a VOSS. 

The OSR barge will have associated smaller workboats called Kvichaks. There are three 34-ft (10.4 m) 

Kvichaks that will support the OSR barge by laying out booms. One 47-ft (14.3 m) Rozema will provide 

skimming services. The Berthing Vessel (Hull 247) will be dedicated to the revised Camden Bay EP 

exploration drilling program and remain in the vicinity of the Kulluk or Discoverer, with the OSR barge 

and the OST being staged to respond as needed to a discharge. Specifications for these vessels are 

provided below in Table 13.a-2. 

An additional barge housing the oil spill containment system will be centrally located in the Beaufort Sea. 

The barge will be supported by an Invader Class Tug and possibly an anchor handler. The tug tending the 

OSR containment system barge will either drift or motor under “slow-steam” movement with the barge. 

An anchor handler is included in this plan only as an additional tending option for the OSR containment 

system barge, if Shell deems it necessary in advance of the season to anchor the OSR containment system 

barge. Shell does not assume the OSR containment system barge will be anchored or that the anchor 

handler is necessary, but includes the option of anchoring the barge and it being also tended by an anchor 

handler in case that option is chosen. 

Oil spill capping stack equipment will be housed on one of the ice management vessels in the unlikely 

event of a blowout. 

Photo - M/V Arctic Seal Photo - M/V Carol Chouest
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 13-5 May 2011 

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

Specification 

OSR Barge and Tug 

OST 

(Mikhail 

Ulyanov1

) 

OSR Containment System 

Arctic

Endeavor 

Barge1

Point 

Class Tug1 Barge1

Tug1

 (invader 

class 

specifications 

provided) 

Anchor 

Handler1

(support for 

the 

Containment 

System 

barge) 

Length 205 ft 

(62.5 m) 

90 ft (27.4 

m) 

853 ft 

(260 m) 

400 ft 

(122 m) 

136.2 ft 

(41.5 m) 

274 ft 

(83.5 m) 

Width 90 ft 

(27.4 m) 

32 ft (9.8 

m) 

112 ft 

(34 m) 

100 ft 

(30.5 m) 

36.5 ft 

(11.1 m) 

59 ft 

(18 m) 

Draft NA 8.5 ft (2.6 

m) 44.6 ft (13.6 m) 12 ft 

(3.7 m) 

20 ft 

(6.1 m) loaded 

20 ft 

(6.1 m) 

Accommodations NA 8 25 berths NA 8 berths 23 berths 

Maximum Speed NA 7 knots 

(13 km/hr) 

16 knots (30 

km/hr) NA 8 knots (15 km/hr) 

16 knots 

(30 km/hr) 

Fuel Capacity NA 1,428 bbl 

(227 m3

) 

440,000 bbl 

(69,952 m3) NA 3,690 bbl 

(587 m3

) 

7,485 bbl 

(1,190 m3) 

Liquid Storage 18,636 bbl NA 543,000 bbl 

(86,328 m3

) 

80,000 bbl 

(12,719 m3) NA 37,462 bbl 

(5,956 m3

) 

Workboats 

(1) 47 ft 

(14 m) skim 

boat 

(3) 34 ft 

(10 m) work 

boats 

(4) minibarges 

NA NA NA NA NA 

Notes: 

1 or similar vessel 

NA – not applicable 

1m3 = 6.29 bbl 

The Mikhail Ulyanov or similar vessel with similar liquid 

storage capacity will be the OST and will be staged such 

that it would arrive at a recovery site, if needed, within 24 

hours of departure from their staging location. 

The purpose of the OST would be to provide a place to 

store large volumes of recovered crude oil, emulsion and 

free water. Surplus storage capacity aboard the OST 

beyond what is required for response at a recovery site may 

be allocated to store other liquid commodities consumed 

by the drilling vessel and support vessels, including diesel 

fuel. Refueling will be done per the fuel transfer plan in appendix M of the revised Camden Bay EP. Each 

vessel will require refueling four to six times during the season, depending on fuel consumption based on 

utilization. 

Photo – M/V Mikhail Ulyanov
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 13-6 May 2011 

Aircraft 

An AW139 or Sikorsky S-92 helicopter based in Deadhorse will be used for flights between the shorebase 

and drill sites (Table 13.a-3). It is expected that on average, up to two flights per day (approximately 12 

flights per week) will be necessary to transport supplies and rotate crews. A Sikorsky S-92 based in 

Barrow will be used for search and rescue operations. 

MMO overflights will utilize a de Havilland Twin Otter aircraft. The de Havilland Twin Otter is expected 

to fly daily. 

Table 13.a-3 Aircraft Flights and Frequency 

Aircraft* Flight Trip Frequency Duration per trip Flight Speed

AW139 or Sikorsky S92 (based in 

Deadhorse) 

Return trip Deadhorse to 

drilling vessel 

12/week 2 hrs 125 knots 

Sikorsky S-92 SAR 

(based in Barrow) 

training 1/month 2 hrs 125 knots 

De Havilland DHC-6 

(based in Deadhorse) 

MMO flights centered 

around the drilling vessel 

daily 6 hrs 120 knots 

*or similar aircraft 

b) Air Emissions 

Details concerning the source, composition, frequency and duration of air emissions for the Kulluk and 

Discoverer, and support vessels are summarized in Section 7.0. Maximum emission in tons per year for 

support vessel source groups for the Kulluk and Discoverer are summarized in Table 13.b-1 and -2 

respectively. 

Photo - Endeavor Barge and Point Class Tug
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 13-7 May 2011 

Table 13.b-1 Kulluk Support Vessel Source Group Annual Maximum Emissions in Tons/Year 

Vessel and Source Group NOx

ton/yr 

PM2.5

ton/yr 

PM10

ton/yr 

CO

ton/yr 

SO2

ton/yr 

VOC 

ton/yr 

Ice Management 

Propulsion and Generation 46.3 7.2 7.2 21 1.3 3.33 

Heaters and Boilers 0.8 0.1 0.1 0.2 5.8E-02 0.04 

Seldom Used Units 1.5E-01 1.2E-02 1.2E-02 4.1E-02 4.6E-04 1.5E-02 

Incinerator 0.1 0.6 0.7 12.6 0.11 4.21 

Anchor Handler

Propulsion and Generation 46.3 7.2 7.2 21 1.3 3.33 

Heaters and Boilers 0.8 0.1 0.1 0.2 5.8E-02 0.04 

Seldom Used Units 1.5E-01 1.2E-02 1.2E-02 4.1E-02 4.6E-04 1.5E-02 

Incinerator 0.1 0.6 0.7 12.6 0.11 4.21 

Resupply Ship – transport mode 

Propulsion and Generation 10.6 0.4 0.4 3.2 4.0E-02 0.34 

Seldom Used Units 7.9E-02 6.3E-03 6.3E-03 2.1E-02 2.4E-04 7.9E-03 

Resupply Ship – Dynamic Positioning mode

Propulsion and Generation 21.3 0.9 0.9 6.4 8.1E-02 0.68 

Seldom Used Units 7.9E-02 6.3E-03 6.3E-03 2.1E-02 2.4E-04 7.9E-03 

OSR Vessel 

Propulsion and Generation 37.3 1.6 1.6 11.2 1.4E-01 1.19 

Seldom Used Units 4.0E-01 3.2E-02 3.2E-02 1.1E-01 1.2E-03 3.9E-02 

Incinerator 0.3 1.3 1.5 27 0.2 9.00 

OSR Work Boats 

Kvichaks 15.0 1.2 1.2 4.0 4.5E-02 1.49 

Total Potential to Emit 229 28 28 162 5 40 

Note: ton = short tons. 

Table 13.b-2 Discoverer Support Vessel Source Group Annual Maximum Emissions in Tons/Year 

Vessel and Source Group NOx PM2.5 PM10 CO SO2

Primary Ice Management 

Propulsion and Generation 36.0 5.6 5.6 16.3 0.152 

Heaters and Boilers 0.8 0.1 0.1 0.2 0.0872 

Seldom Used Units 0.2 0.0 0.0 0.0 0.00007 

Incinerator 0.2 0.4 0.6 12.6 0.105 

Secondary Ice Management / Anchor Handler

Propulsion and Generation 37.1 5.8 5.8 16.8 0.157 

Heaters and Boilers 0.3 0.1 0.1 0.1 0.00349 

Seldom Used Units 0.2 0.0 0.0 0.0 0.00007 

Incinerator 0.2 0.4 0.6 12.6 0.105 

Resupply Ship – Transport mode 

Propulsion and Generation 16.9 1.2 1.2 3.6 0.00611 

Resupply Ship – Dynamic Positioning mode

Propulsion and Generation 33.8 2.4 2.4 7.3 0.0122 

OSR Vessel 

Propulsion and Generation 97.1 0.2 0.2 0.5 0.0483 

Seldom Used Units 0.5 0.0 0.0 0.1 0.00018 

Incinerator 0.5 0.8 1.2 27.0 0.225 

Offshore Management / Skimmer Vessel 

Propulsion and Generation 71.6 1.3 1.3 19.0 0.0356 

Seldom Used Units 0.5 0.0 0.0 0.1 0.00018 

Incinerator 0.5 0.8 1.2 27.0 0.225 

OSR Work Boats 

Kvichaks* 19.1 1.3 1.3 4.1 0.00689 

Note: ton = short tons. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 13-8 May 2011 

On February 28, 2011Shell sent an application to the EPA requesting a Synthetic Minor Source Permit for 

exploration drilling using the Kulluk on OCS leases in the Beaufort Sea. 

The Discoverer is currently issued a PSD Permit (authorization R10OCS/PSD-AK-2010-01, issued April 

7, 2010) to operate in the Beaufort Sea. This permit was remanded to the EPA on 30 December 2010 for 

the EPA to address certain outstanding issues. 

Air emissions from aircraft will be minimal. 

c) Drilling Fluids and Chemical Products Transportation 

The Kulluk or Discoverer will be preloaded with drilling muds and other chemicals to be used during the 

drilling process. The Kulluk or Discoverer will have additional materials supplied by support vessels 

during the drilling season and between wells (planned to occur during the Kaktovik and Nuiqsut [Cross 

Island] subsistence whaling blackout period outside of the Camden Bay area). The types and drilling 

program totals for these muds and chemicals are presented in Section 6.0. No chemical will be stored 

above reportable quantities. 

During each drilling season, the West Dock Supply Vessel (Arctic Seal or similar vessel) may make 

several resupply runs to and from West Dock or other port. Shell anticipates that there will be 24 

visits/tie-ups by support vessels to the Kulluk while the Kulluk is anchored as an OCS-source under the 

EPA air permit, or 8 visits/tie-ups to the Discoverer while the Discoverer is anchored as an OCS-source 

under the EPA air permit, these include the vessel resupply and waste removal. 

d) Solid and Liquid Wastes Transportation 

Shell has applied to the EPA for authorization under GP AKG-28-0000 for the Kulluk and Discoverer to 

discharge various waste streams into the ocean at each proposed drill site. Shell has made a commitment 

to not discharge any drilling mud, cuttings with adhered mud, treated sanitary waste (black water), 

domestic waste (gray water), bilge water and ballast water. These wastes are permitted discharges under 

the GP AKG-28-0000; however, Shell will store these wastes and transport them to a licensed facility (see 

Section 6 or 14 for a list of the facilities). Shell will also store and dispose of solid trash and debris, used 

oil and hazardous wastes, none of which are allowed to be released into the ocean. Table 13.d-1 identifies 

the waste streams that will be transported for proper disposal. 

Table 13.d-1 Anticipated Wastes Generated During Drilling to be Transported From Area 

Type of Waste 

Approximate 

Composition 

Total Amount Name/Location Transport Method 

WBM and Cuttings with 

adhered WBM* 

Sivulliq G – 2,926 bbl 

Sivulliq N – 2,926 bbl 

Torpedo H – 4,545 bbl 

Torpedo J – 4,507 bbl 

Waste Management 

Inc., Arlington OR** 

Hauled aboard ocean 

going barge to Seattle for 

transport to Oregon. 

Treated Sanitary Waste 

(black water) 

Sivulliq G – 20 bbl (Kulluk); 

1,020 bbl (Discoverer) 

Sivulliq N – 20 bbl Kulluk); 1,020 

bbl (Discoverer) 

Waste Management 

Inc., Arlington OR ** 

Hauled aboard ocean 

going barge to Seattle for 

transport to Oregon. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 13-9 May 2011 

Table 13.d-1 Anticipated Wastes Generated During Drilling to be Transported From Area 

Type of Waste 

Approximate 

Composition 

Total Amount Name/Location Transport Method 

Torpedo H – 20 bbl (Kulluk); 

1,320 bbl (Discoverer) 

Torpedo J – 20 bbl (Kulluk); 

1,320 bbl (Discoverer) 

Domestic Waste (gray 

water) 

Sivulliq G – 8,742 bbl (Kulluk); 

11,333 bbl (Discoverer) 

Sivulliq N – 8,742 bbl (Kulluk); 

11,333 bbl (Discoverer) 

Torpedo H – 11,314 bbl (Kulluk); 

14,667 bbl (Discoverer) 

Torpedo J –11,314 bbl (Kulluk); 

14,667 bbl (Discoverer) 

Hauled aboard ocean 

going barge to Seattle for 

transport to Oregon. 

Bilge Water 

Sivulliq G –170 bbl (Kulluk); 

442 bbl (Discoverer) 

Sivulliq N – 170 bbl (Kulluk); 

442 bbl (Discoverer) 

Torpedo H – 220 bbl (Kulluk); 

572 bbl (Discoverer) 

Torpedo J – 220 bbl (Kulluk); 

572 bbl (Discoverer) 

Hauled aboard ocean 

going barge to Seattle for 

transport to Oregon. 

Ballast Water 

Sivulliq G –10,200 bbl (Kulluk); 

170 bbl (Discoverer) 

Sivulliq N – 10,200 bbl (Kulluk); 

170 bbl (Discoverer) 

Torpedo H – 13,200 bbl (Kulluk); 

220 bbl (Discoverer) 

Torpedo J – 13,200 bbl (Kulluk); 

220 bbl (Discoverer) 

Hauled aboard ocean 

going barge to Seattle for 

transport to Oregon. 

Used Oil 50 bbl/well Waste Management 

Inc., Arlington OR ** 

and/or 

Emerald Services Inc* 

Ocean going barge to 

Seattle 

Chemical products and 

general hazardous 

waste 

10 bbl/year 

Trash and debris (nonrecyclables & 

recyclables) 

300 bbl/month Waste Management 

Inc., Arlington OR** 

Hauled aboard supply 

vessel to West Dock or by 

ocean going barge to 

Seattle for transport to 

Oregon. 

*each well includes the addition of 1,500 bbl of mud from an active mud pit; this 1,500 bbl volume will be recycled from well to well and 

disposed of at the end of the drilling season 

** or other EPA-permitted facility 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 13-10 May 2011 

All WBM, cuttings from below the 20-in. casing, treated sanitary waste, domestic waste, bilge water and 

ballast water will be collected aboard the Kulluk or Discoverer, temporarily stored aboard the deck and/or 

waste barges, then transported to a facility licensed for disposal of this type of waste. Mud chemicals will 

be stored in recyclable bags and the mud additives will be contained in sacks stored aboard the drilling 

vessel. The mud chemicals and additives will be mixed onboard. The sacks will be incinerated or 

backhauled to an approved disposal site and the recyclable bags stored for later return to the supplier. 

No drilling wastes will be transported via aircraft. 

e) Vicinity Map and Travel Routes 

Figure 13.e-1 outlines the proposed transit route for the Kulluk or Discoverer through the Chukchi Sea 

then into the Beaufort Sea. The aircraft and resupply vessel routes are shown in Figure 13.e-2. All of the 

scheduled flights associated with the planned exploration drilling program will be from the Deadhorse 

airport. The airport at Kaktovik, Alaska may be used only in emergencies. 

The vessel transit route through the Bering Strait into the Chukchi Sea will occur on or after July 1. To 

minimize impacts on marine mammals and subsistence hunting activities, the drilling vessel and support 

fleet 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 drilling vessel 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. As soon as 

the fleet transits past the ice, it will exit the polynya zone and continue a path in the open sea toward the 

Camden Bay drill sites. 

Aircraft travelling from the shorebase to the Kulluk or Discoverer, 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 south of its offshore destination, then at that point it shall fly directly north through the 

Mary Sachs Entrance to its destination. Shell reserves the option to use an alternate flight route in the 

event that transit through the Mary Sachs Entrance is unsafe due to weather, other environmental 

conditions, or in the event of an emergency. This flight path will be flown in the opposite direction for 

return flights. 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 13-11 May 2011 Figure 13.e-1 Fleet Travel Route 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 13-12 May 2011 Figure 13.e-2 Drilling Support Vessel and Aircraft Travel Routes 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 14-1 May 2011

SECTION 14.0 SHOREBASE FACILITIES INFORMATION 

a) General 

Shell’s shorebase for air transportation for the planned exploration drilling program will be located at the 

Deadhorse Airport. A Search and Rescue helicopter, a Sikorsky S-92, or equivalent, will be stationed in 

Barrow in support of the drilling operations. A crew change helicopter, an AW-139, or Sikorsky S-92 will 

be based at the Deadhorse airport. A de Havilland Twin Otter will also be based at the Deadhorse airport. 

The Deadhorse airport (airport code SCC) has a paved runway that is 6,500 ft (1,981 m) in length and 

supports daily commercial and cargo flights from Anchorage and other locations in Alaska. 

Marine support for the planned exploration drilling program will be primarily from the BP Exploration 

(Alaska) Inc. operated West Dock. 

Facilities will be consolidated in Deadhorse to support drilling, logistics, and oil spill response. 

Approximately 30 Shell personnel will be based in Deadhorse. Facilities include accommodations at the 

Prudhoe Bay Hotel and Service Area 10; office space at the existing Carlile building, rental of existing 

Carlile yard space for short term Oil Response and Drilling equipment staging, and the leasing of Era 

Helicopter's terminal building to support crew change operations across the different function of Shell 

offshore drilling. No construction or expansion is planned at the Deadhorse facilities.

Shell will also manage portions of the exploration drilling program from their Anchorage and Houston 

offices. Also stationed in Anchorage is the SIWAC. 

b) Air Emissions 

There will be minimal additional emissions generated at the shorebase facilities, with respect to those 

emissions listed in Shells air permit (see Section 7.0), generated by land based aircraft at the shorebase. 

With respect to emissions generated by facilities used by Shell, Shell is using pre-existing infrastructure 

that would be functioning whether or not Shell is using the infrastructure. Any excess emissions based on 

Shell’s usage are deemed to be minimal to the existing emissions. 

c) Unusual Solid and Liquid Wastes 

There will not be any unusual solid or liquid wastes generated at the shorebase facilities. 

d) Waste Disposal 

Table 14.d-1 identifies the types of waste and volumes likely to be generated during offshore drilling 

activities and the possible facility where the wastes will be shipped. 

Table 14.d-1 Wastes and Volumes Generated During the Drilling Program 

Name/Location of Facility Type of Waste Amount 

Waste Management Inc., Arlington OR 

Water based mud 

Sivulliq G and N – 2,213 bbl each 

Torpedo H – 3,022 bbl 

Torpedo J – 3,003 bbl 

Drill cuttings with adhered 

mud 

Sivulliq G and N - 713 bbl each 

Torpedo H – 1,522 bbl 

Torpedo J – 1,503 bbl 

Non-hazardous trash and 

debris 300 bbl/month 
Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 14-2 May 2011

Table 14.d-1 Wastes and Volumes Generated During the Drilling Program 

Name/Location of Facility Type of Waste Amount 

Waste Management Inc., Arlington OR 

Treated Sanitary waste 

Sivulliq G and N – 20 bbl/well (Kulluk); 

1,020 bbl (Discoverer) 

Torpedo H and J – 20 bbl/well (Kulluk); 

1,320 bbl (Discoverer) 

Treated Domestic waste 

Sivulliq G and N – 8,742 bbl/well (Kulluk); 

11,333 bbl (Discoverer) 

Torpedo H and J – 11,314 bbl/well 

(Kulluk); 14,667 bbl (Discoverer) 

Uncontaminated Ballast 

Water 

Sivulliq G and N – 10,200 bbl/well 

(Kulluk); 170 bbl (Discoverer) 

Torpedo H and J – 13,200 bbl/well 

(Kulluk); 220 bbl (Discoverer) 

Treated Bilge Water 

Sivulliq G and N – 170 bbl/well (Kulluk); 

442 bbl (Discoverer) 

Torpedo H and J – 220 bbl/well(Kulluk); 

572 bbl (Discoverer) 

Waste Management Inc., Arlington OR 

and/or 

Emerald Services Inc. 

Hazardous Waste (Paint, 

solvents, unused chemicals, 

batteries, lamps, etc.) 

10 bbl/well 

Used oil & glycol 50 bbl/well 

Addresses for the waste facilities are: 

Waste Management Inc’s 

Columbia Ridge Recycling and Landfill

18177 Cedar Springs Lane 

Arlington, OR 97812 

Telephone: 541-454-2030 Fax: 541-454-3312 

http://www.wmnorthwest.com/landfill/landfillcities/columbia.html

Emerald Services Inc. 

425 Outer Springer Loop Road 

Palmer, AK 99645 

Telephone: 907-258-1558 

http://www.emeraldnw.com
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-1 May 2011 

SECTION 15.0 COASTAL ZONE MANAGEMENT ACT 

INFORMATION 

a) Consistency Certification 

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 Offshore Inc

Name of Applicant

3601 C Street, Suite 1000 

Address

Anchorage, Alaska 99503 

City/State/Zip 

907-770-3700 (main); 907-646-7112 (direct) 

Daytime Phone

907-646-7145 susan.childs@shell.com 

Fax Number E-mail Address

2. 

Agent (or responsible party if other than applicant)

Address

City/State/Zip 

Daytime Phone

Fax Number E-mail Address
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-2 May 2011

 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

ACMP Consistency Determination AK 0908-02OG 22 January 2010 none 

Exploration Plan Approval BOEMRE none 16 October 2009 none 

ODPCP Approval BOEMRE none March 11, 2010 none 

ODPCP Consistency ADEC none 22 January 2010 none 

PSD Air Quality Permit EPA R10OCS/PSD-AK-010-01 9 April 2010 none 

NPDES EPA AKG-28-0005 20 April 2010 26 June 2011 

Section 10/404 USACE POA-2009-662 8 July 2009 8 July 2011 

Shell Offshore Inc. (Shell) submitted its initial Camden Bay Exploration Plan (Camden Bay EP) to BOEMRE in 

May 2009. After a thorough round of reviews, BOEMRE approved the Camden Bay EP on 16 October 2009. The 

Camden Bay EP was deemed consistent with the ACMP on 22 January 2010. Shell planned to conduct the 

exploration drilling program detailed in its Camden Bay EP during the 2010 open water season; however, its 

exploration activities were postponed when BOEMRE suspended all oil and gas exploration drilling activities in 

the Arctic following the Deepwater Horizon incident in the Gulf of Mexico. 

Shell now plans to initiate its Camden Bay exploration drilling program during the 2012 open water season. 

Shell’s plans for its renewed exploration drilling program are detailed in its revised Camden Bay Exploration Plan 

(revised Camden Bay EP), which was submitted to BOEMRE on 4 May 2011. Shell’s revised Camden Bay EP 

includes a Coastal Project Questionnaire (CPQ) and consistency evaluation. Because the CPQ is for a project 

modification of an exploration drilling program previously found consistent with state standards and applicable 

district enforceable policies, pursuant to Chapter 11, Alaska Administrative Code (AAC), Section 110.820 (Project 

modification after issuance of a final consistency determination), the following sections of the CPQ and the 

Consistency Evaluation and Certification Statement discuss only the modifications of the project as detailed in the 

revised Camden Bay EP. 

Shell’s Camden Bay EP described a two well exploration drilling program, which was to be conducted using a 

single drilling vessel during a single season of operations. The revised Camden Bay EP contemplates completion 

of those wells evaluated as a part of the initial Camden Bay EP and describes two additional wells that will be 

drilled at the same two prospects previously identified and evaluated for exploration activities under the ACMP. 

The revised Camden Bay EP describes a scope of work of four wells that notionally may be accomplished over two 

drilling seasons. However, as with any Arctic exploration drilling program, weather and ice conditions, among 

other factors, will dictate actual length of each drilling season during which wells may be accomplished, hence 

more than two drilling seasons may be required to accomplish all four wells. Table 1 summarizes the comparison 

of the modification of the project from the initial Camden Bay EP to the revised Camden Bay EP. 

3. If this is a modification, was this original project reviewed for consistency with the Alaska Coastal Management 

Program? .................................................................................................................................................................... 

Previous ACMP I.D. Number: AK 0908-02OG 

Previous Project Name: 2010 Camden Bay Exploration Plan Previous Project Applicant: Shell Offshore Inc. 

 

 

 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 

 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-3 May 2011

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: The revised Camden Bay EP is planned to begin during the summer of 2012. 

The initial Camden Bay EP described a single season of operations. The annual timing and schedule for the 

revised Camden Bay EP is the same as the initial EP such that the drilling vessel and support fleet will leave Dutch 

Harbor and pass through the Bering Strait on or after 1 July each season. Depending on weather and ice 

conditions, as well as other factors, the drilling activities are expected to commence at a drill site each season on or 

about 10 July. Exploration drilling activities at the drill sites will be suspended beginning 25 August for the 

Nuiqsut (Cross Island) and Kaktovik subsistence bowhead whale hunts and resume after the subsistence bowhead 

whale hunts conclude. 

Proposed ending date for the project: All exploration drilling activities will cease on 31 October during each 

drilling season, the same date as proposed in the initial Camden Bay EP. 

Project description: For the revised Camden Bay EP, beginning in the summer of 2012 Shell plans to drill four 

wells on the same two prospects that were analyzed in the initial Camden Bay EP that included only two wells 

(Figure 1a-1). The drill sites for the four wells occur among three OCS lease blocks in Camden Bay 

(Figure 1a-2). Two of the three OCS blocks were evaluated in the initial Camden Bay EP and the ACMP. The 

revised Camden Bay EP also contemplates a situation where a well that is started must be temporarily 

suspended due to ice, weather, or other conditions, and finished at a later date. As described in the revised 

Camden Bay EP, any well on which drilling is suspended will be secured in compliance with BOEMRE 

regulations and with the approval of the Regional Supervisor/Field Operations (RS/FO), whether it is 

permanently abandoned (30 CFR 250.1710 through 1717) or temporarily abandoned (30 CFR 250.1721-1723). 

Figure 1.a-1 Planned Exploration Drilling Program – Revised Camden Bay EP 

 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-4 May 2011

Figure 1.a-2 Location of the Sivulliq and Torpedo Prospects and Respective Drill Sites

Shell may conduct a geophysical survey referred to as zero-offset vertical seismic profile (ZVSP) at each drill 

site where a well is drilled. During exploration operations, the drilling vessel, which may be either the conical 

drilling unit Kulluk or drillship Noble Discoverer (Discoverer), will be attended by a minimum of 11 vessels 

that will be used for ice management, anchor handling/ice management, OSR, refueling, resupply, waste 

removal, and servicing of the drilling operations. 

Primary elements of the modified exploration drilling program, as detailed in the revised Camden Bay EP, are 

compared to the analogous elements in the initial Camden Bay EP, which was found to be consistent with the 

ACMP, state standards and applicable district enforceable policies, in Table 1. 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-5 May 2011

Table 1 Comparison and Similarities of Shell’s Initial Camden Bay EP and the Revised Camden Bay EP

Parameter Initial Camden Bay EP (2010) Revised Camden Bay EP 

(2012 planned start) 

Timing of operations 10 July – 31 October 10 July – 31 October 

Prospects and OCS Lease 

Blocks 

Sivulliq and Torpedo 

Flaxman Island 6610 and 6658 

Sivulliq and Torpedo 

Flaxman Island 6559, 6610, and 6658 

Drill site (wells) Two - Sivulliq N and Torpedo H Four - Sivulliq N, Torpedo H, Sivulliq G, 

Torpedo J 

Drilling unit Drillship Discoverer Drillship Discoverer or the Kulluk

ZVSP None Zero offset vertical seismic profile at each 

drill site 

Drilling fluids and cuttings 

with adhered fluids, 

Treated domestic waste, 

Treated sanitary waste; ballast 

water; 

Bilge water 

Discharged to the ocean as permitted 

under NPDES Arctic General Permit 

AKG-28-0000 

Collected, stored and then transported to an 

approved treatment/disposal site (TDS) for 

disposal 

Primary Support Fleet Anchor handler, 

Ice management vessel, 

Offshore supply vessel (OSV), 

West Dock shuttle 

Anchor handler, 

Ice management vessel, 

OSV, 

West Dock shuttle 

OSV to collect waste streams from the Kulluk

Deck barge and tug to store the waste streams

(deck barge) 

Barge and tug to store liquid waste streams 

(waste barge)

Oil Spill Response (OSR) OSR barge and tug, 

OSR vessel, 

Oil storage tanker (OST) 

OSR barge and tug, 

Oil storage tanker (OST) 

Containment barge, tug, and anchor 

handler1

 for carrying containment 

equipment 

Air permit Discoverer – Prevention of Significant 

Deterioration (PSD) permit 

authorization R10OCS/PSD-AK-2010-

01 

Discoverer – PSD permit authorization 

R10OCS/PSD-AK-2010-01 

Kulluk – Minor Source Permit application 

for Beaufort Sea submitted February 28, 

2011

Note: 1 Anchor handler included for planning purposes only, not assumed necessary since it is unlikely the 

containment barge will be anchored, but as an additional tending option if deemed necessary by Shell. 

Based on the comparison provided in Table 1, the components that are in the revised Camden Bay EP that were 

not in the initial Camden Bay EP, and are assessed below in the Consistency Evaluation and Certification 

Statement are as follows: 

• Two additional wells – Sivulliq G and Torpedo H 

• The collection and transport of five waste streams 

• Additional support vessels – an OSV, deck barge and tug, waste barge and tug, and a 

containment barge, tug, and anchor handler1

, and additional OSR vessel. 

• ZVSPs – one at each of four drill sites 

• Evaluation of the Kulluk as the primary drilling vessel as a possible replacement for the 

Discoverer 

Note: See 1 above. 

The project elements of the modification in the revised Camden Bay EP are further described below. 

Additional Wells 

The revised Camden Bay EP includes two additional wells that were not in the initial Camden Bay EP, one each 

in each of the prospects identified and evaluated in the initial Camden Bay EP and ACMP. The two new drill 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-6 May 2011

sites identified in this revised Camden Bay EP are listed below in Table 2; the leases were acquired in Beaufort 

Sea Oil and Gas Lease Sale 195 (OCS-Y-1805) and 202 (OCS-Y-1936). Sivulliq G is located in the same lease 

block as the Sivulliq N drill site evaluated as a part of the initial Camden Bay EP and ACMP, and the Torpedo J 

drill site is in a lease block that is adjacent to the one in which Torpedo H is located, which was also evaluated 

in the initial Camden Bay EP and ACMP. Only lease block 6559 for the Torpedo J location is new for the 

revised Camden Bay EP. Drilling of these proposed wells would be done in the same manner as those approved 

with the initial Camden Bay EP and would generate similar amounts of waste. Shallow hazards surveys have 

been conducted at each drill site and no hazards to drilling or archeological resources were identified in the 

vicinity of the drill sites. 

Table 2 Drill Sites in the Revised Camden Bay EP that Were Not in the Initial Camden Bay EP 

Drill Site Lease File 

Number 

NR06-04 Flaxman 

Island 

Lease Block No. 

Surface Location (NAD 83)* Distance to 

Mainland Shore 

Latitude (N) Longitude (W) mi (km) 

Sivulliq G OCS-Y 1805 6658 70° 23' 46.82" 146° 01' 03.46" 16.6 (26.7) 

Torpedo J OCS-Y 1936 6559 70° 28' 56.94" 145° 53' 47.15" 23.1 (37.2) 

Collection and Transport of Five Waste Streams 

In response to stakeholder concerns, Shell has modified its proposed waste management procedures. The 

revised Camden Bay EP describes how Shell plan to implement its agreement with the local communities to 

collect selected waste streams and haul them outside the Arctic to a land based TSD facility for disposal. 

By agreement with the local communities, during the completion of exploration activities contemplated by the 

revised Camden Bay EP, Shell will not discharge certain waste streams generated during routine drilling 

operations, even though the waste streams are allowable discharges under the current United States (U.S.) 

Environmental Protection Agency (EPA) administered Arctic National Pollutant Discharge Elimination System 

(NPDES) General Permit (GP) AKG-28-0000. Shell will not discharge 1) treated sanitary waste (black water), 

2) domestic waste (gray water), 3) bilge water, 4) ballast water at any time, and 5) drilling mud and cuttings 

with adhered drilling mud when drilling below the depth of the 20-in conductor shoe. These wastes will be 

collected and stored on the deck barge and/or waste barge, then transported and disposed of at an approved and 

licensed onshore facility. Cuttings generated while constructing the mudline cellar (MLC) and drilling the 36-

in. and 26-in. hole sections (all drilled with seawater and viscous sweeps only) plus cement discharged while 

cementing the 30-in and 20-in casing strings will be discharged to the surface of the seafloor under provisions 

of the previously mentioned NPDES GP. 

During drilling operations, cuttings will be separated from the drilling fluids with shakers, de-sanders and desilters. Drilling fluids will be recovered, reconditioned and reused as much as practicable. When drilling fluids 

have been exhausted, those spent drilling fluids will be held in storage aboard the drilling vessel. Drill cuttings 

that are recovered off the shakers will be transferred from the drilling vessel to an adjacent vessel, via a separate 

flexible hose connection, using compressed air. On the adjacent vessel (OSV), the cuttings will be held within 

lined, covered containers. In the event the storage tanks on the drilling vessel do not have the capacity to store 

the volume of spent drilling fluids generated during operations, the fluids in the storage tanks on the drilling 

vessel will be commingled with the drill cuttings waste stream during transfer. The treated sanitary water, 

domestic water, bilge and ballast water will be transferred from the drilling vessel via a separate flexible hose 

with secured fittings to an adjacent vessel and stored in above-deck storage tanks. The wastes would then be 

transferred in a similar manner from the OSV to the deck barge or waste barge. The deck barge and waste 

barge would transport the wastes to a treatment and disposal site onshore. Shell is finalizing a contract with the 

waste handler vessel owner for handling, transporting and disposal of the spent drilling fluids. Although Shell 

has not signed a contract with any disposal facility regarding the handling of waste streams that will not be 

discharged to the ocean, Shell has located appropriate licensed facilities to handle various waste streams. These 

facilities are located in Oregon and are licensed to handle the materials identified above in accordance with all 

applicable laws and regulations, including the Solid Waste Disposal Act and Resource Conservation and 

Recovery Act 42 USC 6901 et seq., and the EPA Solid Waste Disposal Facilities Regulations at 40 CFR 257-

259. 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-7 May 2011

Additional Support Vessels 

Additional support vessels (Table 3) in the revised Camden Bay EP that were not in the initial Camden Bay EP 

include a second OSV, a deck barge and tug, a waste barge and tug, and a containment barge/tug/anchor 

handler. The primary need for these additional vessels is for the handling, storing, and transport of the five 

collected waste streams. The OSV will transfer the wastes from the drilling vessel to the deck barge or waste 

barge. The deck barge and waste barge will be stationed approximately 25 mi (40 km) from the drilling vessel 

and will be used to store the collected wastes, and at the end of the drilling season transport the wastes to a TDS 

in Oregon. One more OSR vessel is included in the revised Camden Bay EP that was not included in the initial 

Camden Bay EP (Table 4). The containment barge is part of the well control and OSR response equipment, and 

will house containment equipment. The tug is required to support the containment barge, whereas the anchor 

handler is included in this plan only as an additional tending option for the containment barge, if Shell deems it 

necessary in advance of the season to anchor the containment barge. Shell does not assume the containment 

barge will be anchored or that the anchor handler is necessary, but includes the option of anchoring the barge 

and it being also tended by an anchor handler in case that option is chosen.

Table 3 Specifications for Additional Support Vessels (Not Including OSR Vessels) for Revised Camden Bay EP 

Additional Vessels Included Only in Revised Camden Bay EP 

Specification Harvey 

Spirit1,2 

Southeast Provider Barge 

& Ocean Ranger Tug1,3 

(Deck barge) 

Waste Storage Barge1,3 

(Waste barge) 

 Barge Tug Barge Tug 

Length 280 ft 

(85.4 m) 

360 ft 

(110 m) 

117 ft 

(35.7 m) 

TBD TBD 

Width 60 ft 

(18.3 m) 

100 ft 

(30.5 m) 

32 ft (.8 m) TBD TBD 

Draft 16.5 ft 

(5.0 m) 14 ft - TBD TBD 

Berths 26 - 10 TBD TBD 

Maximum 

Speed 

13.5 knots 

(25 km/hr) - 10 knots 

(18.5 km/hr) 

TBD TBD 

Fuel Capacity 6,235 bbl 

(normal) - 2,381 bbl TBD TBD 

1 Or similar vessel applies to all vessels. 

2 Dutch Harbor supply vessel/Waste removal 

3 Storage for drilling vessel resupply and waste streams removed from the drilling vessel 

Table 4 Specifications for Additional OSR Vessel 

Vessel Included Only in Revised Camden Bay EP

Specification 

Containment Barge1,2,3

Barge Tug Anchor Handler3 

Length 400 ft (122m) 136 ft (36.5 m) 275 ft (83.7 m) 

Width 100 ft (30.5 m) 36 ft (11.1 m) 59 ft (18.0 m) 

Accommodations -- 10 23 

Maximum Speed -- 10 knots 16 knots 

Fuel Capacity -- 3,690 bbl 7,484 bbl 1

 Or similar vessel applies to all vessels. 

2

 Based on a standard deck barge, Crowley Invader class ocean going tug, and a Tor Viking-style anchor handler 3 Vessel included for planning purposes only, not assumed necessary but as an additional tending option if deemed necessary 

by Shell. 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-8 May 2011

Zero Offset Vertical Seismic Profiles 

Shell plans to conduct a geophysical survey referred to as a vertical seismic profile or VSP at each drill site 

where a well is drilled. During VSP surveys, an airgun array, which is typically much smaller than those used 

for routine seismic surveys, is deployed at a location near or adjacent to the drilling vessel, while receivers are 

placed (temporarily anchored) in the wellbore. The sound source (airgun array) is fired repeatedly, and the 

reflected sonic waves are recorded by receivers (geophones) located in the wellbore. The geophones, typically 

in a string, are then raised up to the next interval in the wellbore and the process is repeated until the entire 

wellbore has been surveyed. The purpose of the VSP is to gather geophysical information at various depths, 

which can then be used to tie-in or ground-truth geophysical information from the previous seismic surveys 

with geological data collected within the wellbore. 

Shell would likely be conducting a particular form of VSP referred to as a zero-offset vertical seismic profile 

(ZVSP), in which the sound source is maintained at a constant location near the wellbore. A typical sound 

source that would be used by Shell is the ITAGA eight-airgun array, which consists of four 150 in3

 (2,458 cm3) 

airguns and four 40 in3

 (655 cm3) airguns. These airguns can be activated in any combination and Shell would 

utilize the minimum gun volume required to obtain an acceptable signal. The airgun array is approximately 

6 ft x 5 ft x 10 ft (1.8 x 1.5 x 3.0 m). Typical receivers would consist of a Schlumberger wireline four level 

vertical seismic imager (VSI) tool, which has four receivers 50-ft (15.2-m) apart. 

A ZVSP survey is normally conducted at each well after total depth is reached but may be conducted at a 

shallower depth. For each survey, Shell would deploy the sound source (airgun array) over the side of the 

drilling vessel with a crane (sound source would be approximately be 50-200 ft [(15-60 m]) from the wellhead 

depending on the crane location), to a depth of approximately 10-23 ft (3-7 m) below the water surface. The 

VSI with its four receivers would be temporarily anchored in the wellbore at depth. The sound source is then 

routinely pressured up to 2,000 pounds per square inch (psi), and activated 5-7 times at approximately 

20-second intervals. The VSI would then be moved to the next interval of the wellbore and re-anchored, after 

which the airgun array would again be activated 5-7 times. This process would be repeated until the entire well 

bore is surveyed in this manner. The interval between anchor points for the VSI is usually 200-300 ft 

(60-91 m). A normal ZVSP survey is conducted over a period of about 10-14 hours depending on the depth of 

the well and the number of anchoring points. 

Use of the Drillship Discoverer or Kulluk to Drill the Wells 

The revised Camden Bay EP also addresses the possibility that Shell might ultimately decide to substitute the 

drilling vessel Kulluk for the Discoverer to drill the wells contemplated by the revised Camden Bay EP. A 

comparison of attributes and specifications of the two drilling vessels is provided in Table 5. The Discoverer

was to be the drilling vessel in the initial Camden Bay EP, which was found consistent, and therefore requires 

no further analysis. Both the Kulluk and Discoverer were to be used in Shell’s 2007 Beaufort Sea EP, which 

was also found to be consistent with the ACMP. 

There are no differences that would result in substantially different environmental impacts, if one or the other 

drilling vessel were to be used. The volumes of wastewater waste streams differ due to crew size and 

equipment, but these wastes will not be discharged to the ocean. The Kulluk has larger anchors, and more 

anchors (12 vs. 8) and would therefore impact a slightly larger area of the seafloor when mooring. Given the 

Kulluk’s conical shape, the sound source level is louder for the Kulluk than the Discoverer, thus yielding a 

larger number of incidental takes of marine mammals due to sound for the Kulluk. Regardless of the drilling 

vessel, the exploration drilling program in Camden Bay is not expected to incidentally take more than small 

numbers of marine mammals, or have more than a negligible impact on their populations. All anticipated takes 

would be “takes by harassment”, involving temporary changes in behavior. 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-9 May 2011

Table 5 Drilling Vessel Comparison 

Drilling Vessel Specifications - Relevant to Camden Bay Drill Sites 

ITEM KULLUK DISCOVERER 

Vessel Movement No self-propulsion; must be towed Self-propelled 

Crew size 108 140 

Cooling Water Discharge 13,178 bpd 45,000 bpd 

Domestic Waste Volumes1 100 gallons per person/per day = 

10,800 gals or 257 bbl/day 

100 gallons per person/per day = 

14,000 gal/day or 333 bbl/day 

Sanitary Waste Volumes1 20 bbl at end of well – waste water 

purified and recycled 

9 gal/person/day = 

1,260 gal/day or 30 bpd 

Bilge Water1 5 bpd 13 bpd 

Ballast Water1 34-44 bpd 5 bpd 

Fuel Storage Capacities 10,085 bbl 6,498 bbl 

Anchor System 12-point anchor system 8-point anchored mooring system 

Anchors (number of anchors) 12 8 

Anchor type Twelve, 15mt Stevpris anchors Eight, 7.5 ton Stevpris anchors 

Anchor radii (maximum) 3,117 ft (950 m) 2,969-2,986 ft (905-910 m) 

Operational Restraint

ITEM KULLUK DISCOVERER

Vessel to Vessel Transfers2 24 resupply visits2 8 resupply visits2

Seafloor Impacts

Anchor scar (area [ft2]and volume 

[yd3

]) per anchor 

2,928 ft2

(272 m2)

531 yd3

406 m3 2,027 ft2

(188 m2) 

390 yd3 

(298 m3) 

MLC Size 41 ft x 24 ft 41 ft x 20 ft 

MLC – Excavated Volume3 4,382 bbl (696 m3) 3,049 bbl (485 m3) 

MLC to 20” casing depth – cuttings 

discharge seafloor sediment coverage 

802-953 bbl 

(128-152 m3

) 

Notes: 

a Per well unless otherwise specified. 1 Collected, held during season, disposed onshore at end of season. 

2 Per drilling season 3 Included in this is a 30% washout of MLC excavation. 

Key: 

bbl – barrels 

bpd – barrels/day 

dB – decibel 

ft - feet 

ft2

 – square feet 

m2

 – square meters 

m3

 – cubic meter 

mt – metric ton 

μPa – micropascal 

MLC – Mud line cellar 

OSV – Offshore supply vessel 

yd3 - cubic yard 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-10 May 2011

 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 70° 23' 46.82" /146° 01' 03.46" Sivulliq G drill site; 70° 28' 56.94" 145° 53' 47.15" 

Torpedo J (NAD 83 ) (specify Decimal Degrees or Degrees, Minutes, Seconds) 

USGS Quad Map not applicable; federal outer continental shelf submerged lands; see Figure 1-1 for location 

map 

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) OCS Exploration Plan review triggers ACMP 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: Shorebase facilities are on State owned land and will be used under 

third party contractors and permits 

 

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 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-11 May 2011

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: 

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: 

 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-12 May 2011

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: 

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: no contact made – federal OCS leases 

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: appropriate applications to be submitted to 

BOEMRE 

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? ......................................................... 

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.

 

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: 

 

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: 

 

 

 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-13 May 2011

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 subm

 

 

 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: 

 

 

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: 

Non-domestic 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: no contact made – federal OCS leases 

b) Is an application required for the proposed activity? .................................................................. 

 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-14 May 2011

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: The project will discharge waste streams authorized pursuant to 

NPDES GP AKG-28-0000. Shell has authorization (AKG-28-0005) for the Discoverer to discharge under 

AKG-28-0000 on lease block 6658 (Sivulliq G). Shell submitted an NOI to the EPA for authorization for the 

Discoverer to discharge on lease block 6559 (Torpedo J) on 10 December 2010. Shell submitted 

supplemental NOI information for authorization for the Kulluk to discharge on lease blocks 6558 and 6559 

and on 8 April 2011, Copies of these NOI submittals are available in Appendix B of the revised Camden Bay 

EP.

 

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, semisolid 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: no contact made – federal OCS leases 

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: 

 

 

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? 

Incinerator capacity is 276 lb/hr. 

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 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-15 May 2011

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: no contact made – federal OCS leases 

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 has jurisdiction of air emissions associated with OCS oil and gas exploration. Shell now has an air permit 

for the Discoverer to operate in the Beaufort Sea – authorization R10OCS/PSDAK-2010-01. Shell is applying 

for a synthetic minor source operating air emissions permit from EPA Region 10 for exploration drilling with the 

Kulluk (source) and its associated support vessels in the Beaufort Sea within the 25 mile Alaska seaward 

boundary. It is to be used for exploration drilling activity (NAICS category 211111) on the OCS of the Beaufort 

Sea near Camden Bay. As such, the application is made under the OCS permitting rules (40 CFR 55). Because 

the area of operation will be within 25 miles of the Alaska seaward boundary, the Kulluk is subject to the federal 

requirements of §55.13 and the Alaska rules as documented in §55.14. The permits and permit applications and 

supporting documents are available on line at the EPA’s website at 

http://yosemite.epa.gov/R10/AIRPAGE.NSF/Permits/ocsap/

 

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. 

 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-16 May 2011

a) Name/date of Contact: Bob Tisserand, various dates 

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: A revised Beaufort Sea Regional 

Exploration ODPCP was found consistent by ADEC during the last ACMP review (22 January 2010). A 

modification to the Beaufort Sea Regional Exploration ODPCP found consistent by ADEC and approved 

by BOEMRE 11 March 2010 was submitted to BOEMRE concurrent with the revised Camden Bay EP. 

 

 

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 

ODPCP (2010 Beaufort Sea Regional Exploration ODPCP) Found consistent 22 January 2010 

ODPCP (2011 revised Beaufort Sea Regional Exploration ODPCP) Submitted May 2011 

 

 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: Julie McKim, March 23, 2009; Michiel Holley March 2011 

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: A Pre-Construction Notification (PCN) has been submitted to the 

USACE for authorization of these activities at Sivulliq G and Torpedo J, and a copy is available in 

Appendix G of the revised Camden Bay 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? ......................................................... 

7. If you answered yes to any question above, indicate the person you contacted at the appropriate U.S. Coast 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-17 May 2011

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 U.S. Environmental 

Protection Agency for information. 

a) Name/date of Contact: Sonia Porter; October 2008; Hahn Shaw, various dates 2010, 2011 

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: The project will discharge waste streams authorized pursuant to NPDES 

GP AKG-28-0000. Shell has authorization (AKG-28-0005) for the Discoverer to discharge under GP AKG-28-

0000 on lease block 6658 (Sivulliq G) and lease block 6610. Shell submitted an NOI to the EPA for 

authorization for the Discoverer to discharge on lease block 6559 (Torpedo J) on 10 December 2010. Shell 

submitted supplemental NOI information for authorization for the Kulluk to discharge on lease blocks 6559, 

6610 and 6658 on 8 April 2011, Copies of these NOI submittals are available in Appendix B of the revised 

Camden Bay 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: 

 

Yes No
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-18 May 2011

U.S. FOREST SERVICE (USFS)

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? .............................. 

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? See table below.............................................................................. 

19. Have you applied for any other federal permits or authorizations? ................................................... 

 

 

Agency Approval Type Date Submitted

BOEMRE Revised Exploration Plan May 2011 

BOEMRE Revised Oil Spill Response Plan (State ODPCP) May 2011 

NMFS MMPA IHA for Incidental Harassment 

Authorization for the Non-Lethal Taking of 

Whales and Seals May 2011 

USFWS MMPA LOA for the Incidental Take of Polar 

Bears and Pacific walrus and the Intentional 

Take of Polar Bears May 2011 

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. 

 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-19 May 2011

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 complete the exploration drilling activities described in its revised Camden Bay EP on its OCS 

leases obtained from the BOEMRE during Lease Sales 195 and 202. Shell selected these leases based on their 

potential for holding oil and gas resources. Sivulliq G is located 16.6 mi (26.7 km) from shore and Torpedo J is 

located 23.1 mi (37.2 km) from shore and cannot be accessed / drilled from shore. Only Torpedo J is located on an 

OCS lease block (6559) not included in the initial Camden Bay EP. The project includes the use of existing coastal 

facilities at West Dock. 

(b) Evaluation of development priority. 

(1) How is the proposed project water-dependent? Explain. 

The project involves exploration drilling on one more OCS lease block not included in initial Camden Bay EP 23.1 

mi (37.2 km) from shore, which cannot be reached from shore via directional drilling. Existing boat ramps will be 

utilized to support the offshore operations. 

(2) How is the proposed project water-related? Explain. 

The project is water-dependant. 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-20 May 2011

(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. 

The project is water-dependant. 

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? 

Shell has received approval under NWP #8 to place the M/V Noble Discoverer in federal waters offshore Alaska 

(authorization # POA-2009-662) and a copy is provided in Appendix G of the revised Camden Bay EP. This 

authorization is valid until July 2011. Because the authorization will expire prior to Shell’s drilling activities, Shell 

has applied to the USACE for coverage for either the Discoverer or the Kulluk to be placed on three OCS blocks, 

only one of which (6559) was not included in the initial Camden Bay EP. The application is also included as 

Appendix G of the revised Camden Bay EP. 

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 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. 

In the DCOM review of the initial Camden Bay EP, DCOM granted the North Slope Borough’s (NSB’s) request for 

designation of all state waters within the area bounded on the west by a longitudinal line at 148°31’40.36” (the 

longitude of West Dock) due north to federal waters to a longitudinal line in the east at 143°36’31” (longitude of 

Kaktovik due north to federal waters as a natural hazard area containing permafrost. DCOM also granted the NSB’s 

request that these same state waters be designated as natural hazard areas for ice hazards. Ice hazards may include 

“ice ridging, shear zones, ice break-off, strudel scour, ice gouging, ice override, and ice pileup.” Shell assumes the 

same designations will apply to the revised Camden Bay EP. Modification of the project does not change the 

conclusions regarding the evaluation of the revised project due to the natural hazards designation. 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-21 May 2011

(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? 

Shell Responses: 

Permafrost Designated Natural Hazard Area 

Shallow hazards surveys have been conducted at each of the additional drill sites. Resulting reports have indicated 

the possible presence of permafrost in both the Sivulliq and Torpedo prospects. The main constraint associated with 

permafrost in exploration drilling is the loss of soil strength around the drillpipe. However, because of the highly 

consolidated nature of the subbottom soils at the drill sites, permafrost is not expected to present a hazard to drilling 

operations. At the Sivulliq G and Torpedo H drill sites, as was the case with other drill sites in the initial Camden 

Bay EP, Shell plans to use a mud cooler to mitigate any potential permafrost thawing while drilling the upper 

portions of the wells below the MLCs. Shell will also use permafrost cement in both the 30-in. and 20-in. casings. 

This cement has a very low heat of hydration, and will develop adequate compressive strength at low temperatures. 

These measures will ensure that once the 20-in. casing is set, permafrost thawing will be minimized or eliminated if 

any is present. The planned offshore exploration drilling program will not present a threat to public safety, services, 

and the environment as a result of permafrost potentially present in the drilling area. Permafrost hazards are not an 

issue with the EP modification (collection and transport of wastes, additional support vessels or OSR vessel, ZVSPs, 

and the use of the Kulluk as the drilling vessel). 

Ice Hazards Designated Natural Hazard Area 

The additional drill sites, Sivulliq G and Torpedo J, are located in an area characterized by active sea ice movement, 

ice scouring, and storm surges, as is the case for the drill sites included in the initial Camden Bay EP. Shell will 

therefore implement the same mitigation measures as reviewed by DCOM for the initial Camden Bay EP, including 

implementation of an Ice Management Plan (IMP), ice and weather forecasting provided by Shell’s Ice and Weather 

Advisory Center. And Critical Operations and Curtailment Plan (COCP). The planned offshore exploration drilling 

program will not present a threat to public safety, security, and the environment as a result of operating in an area that 

may present ice hazards. 

Sivulliq G Shallow Hazards Reports 

A GeoLLC (2007) geohazards assessment is based on a synthesis of publicly-available geotechnical and high-resolution 

geophysical data, and reprocessed 2D seismic data. The GeoLLC (2008a) addendum report contains the same 

assessment plus high-resolution geophysical data acquired by Shell over the Sivulliq prospect during the 2006 open 

water season. The following parameters were analyzed in the 2007 geohazards assessment at the Sivulliq prospect: 

a. Bathymetry 

b. Ice gouging 

c. Geologic conditions 

d. Faulting 

e. Seismicity 

f. Gas hydrates 

g. Shallow gas 

h. Gas hydrates 

i. General soil stratigraphy 

j. Offshore permafrost 

k. Buried channels 

l. Historic shipwrecks 

m. Prehistoric archaeological potential 
 

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Shell Offshore Inc. 15-22 May 2011

These parameters were analyzed for both shallow hazards (defined as a feature or condition that presents difficulties that 

cannot be easily mitigated by design, implementation or procedures) and constraints (defined as a feature or condition 

that presents difficulties but can be easily mitigated by design, implementation or procedures). 

Of all the parameters listed above, the following potential shallow hazards were identified near the Sivulliq G drill site: 

• the possible occurrence of “acoustic permafrost” near the Sivulliq G drill site but not at the proposed drill sites 

(permafrost is not expected to be encountered during the drilling of either of these wells) 

• shallow gas has been identified near the Sivulliq G drill site 

o shallow gas may be proximal to the Sivulliq G drill site and the chance of encountering shallow gas at 

the drill site is considered to be very low 

Ice gouging is noted as an active process in the mid-shelf region of the Beaufort Sea. The majority of the gouges are 

oriented east to west with occasional deeper gouges crossing from the northeast to southwest. Maximum gouge depth as 

measured from the undisturbed seafloor is 8.2 ft (2.5 m) and the median width is 33 ft (10 m). The installation of a 

MLC at the Sivulliq G drill site will mitigate this constraint. The depth of the MLC is determined by the maximum ice 

keel scour depth, currently measured at 8.2 ft (2.5 m) below the seafloor in the Sivulliq area. The MLC depth will be 

adjusted to ensure that the top of the Upper H4 connector will be greater than 8.2 ft (2.5 m) below the seafloor in the 

event the well is temporarily abandoned leaving the ram-type BOP in place on the well during the winter, thereby 

protecting the BOP from damage from ice keel scouring. 

Permafrost is identified in the acoustic signal over different portions of the Sivulliq prospect area and is expected to 

present little risk to the drilling operations. Shell will mitigate this by using chilled drilling fluids to prevent as much 

thawing of permafrost as possible. 

Mitigation procedures and protocols for drilling safely through potential shallow gas zones are outlined in Shell’s 

document Protocols for Drilling Shallow Hole Segments Above the BOP Depth. This document will be submitted as 

part of an APD application. 

No shipwrecks or other historical artifacts were observed within the Sivulliq G drill site clearance area. No evidence of 

prehistorical archaeological potential was recognized within the Sivulliq G drill site clearance area. 

Fugro 2009 Report 

The following shallow hazards parameters were assessed for the Sivulliq G drill site in the supplemental Fugro report: 

a. Man-made infrastructure 

b. Seafloor conditions 

c. Stratigraphy and structure 

d. Permafrost 

e. Shallow gas 

f. Gas hydrates 

The 2009 Fugro report confirmed the findings of the 2007 GeoLLC report. No shallow hazards, man-made obstructions 

(historic or prehistoric) were identified, specifically at the Sivulliq G drill site. The report concludes that the seafloor 

and shallow geologic conditions are favorable for exploration drilling operations. 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-23 May 2011

Torpedo J Shallow Hazards Report 

Fugro (2011) issued a site specific assessment of the Torpedo J location utilizing data collected in 2008. 

The following shallow hazards parameters were assessed in the drill site clearance letter covering the Torpedo 

prospect, including the Torpedo J drill site: 

a. Man-made facilities, obstructions, or debris 

b. Seafloor features 

c. Stratigraphy 

d. Sub-seafloor geologic features 

e. Gas hazards (shallow gas and gas hydrates) 

f. Archaeological assessment 

The Torpedo J drill assessment reported the following: 

• No evidence of permafrost was observed at the drill site: 

• No man-made facilities, obstructions or debris were identified; 

• Ice gouging up to 3.5 ft (1.0 m) in depth were noted in the vicinity of the drill site. This will be mitigated by the 

depth of the MLC; 

• Nothing unusual was identified in the stratigraphy down to the depth of investigation of 5,107 ft (1,557 m); 

• No seafloor faults were identified. Four interpreted buried faults occur in the general area with the closest fault 

located 1,900 ft (579 m) to the northeast. None of these faults will be penetrated by the proposed well and they 

are not expected to adversely affect exploration drilling; and 

• Anomalies indicative of possible shallow gas accumulations are interpreted to occur 2,624 ft (800 m) northeast 

of the drill site at a depth of 2,808 ft (856 m) below the seafloor. At the drill site, the potential for shallow gas 

is considered negligible. 

• No shipwrecks or other historical artifacts were observed within the Torpedo J drill site clearance area. No 

evidence of prehistorical archaeological potential was recognized within the Torpedo J drill site clearance area. 

The archaeological assessment concluded that the potential for encountering prehistoric archaeological 

resources at the Torpedo J drill site is very low. 

The report concludes that the seafloor and shallow geologic conditions are favorable for exploration drilling operations. 

(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. 

Activities associated with the proposed modification to the exploration drilling program would take place largely on 

Shell leases located in Federal waters of the OCS. Shell will follow all applicable BOEMRE regulations, 

requirements, and safety standards as indicated in the initial Camden Bay EP and detailed in the revised Camden Bay 

EP. Compliance with applicable regulatory approvals will ensure that the relevant codes and safety standards are 

met. Shell's revised Camden Bay EP complies with all applicable regulatory and safety requirements of BOEMRE 

and the USCG and other federal and state regulatory agencies with jurisdiction over this plan. These activities and 

operations are described in detail in Section 2 of Shell's revised Camden Bay EP. BOEMRE has the regulatory 

jurisdiction to approve EPs that are consistent with Outer Continental Shelf Lands Act (OCSLA) and BOEMRE’s 

implementing regulations, and approved the initial Camden Bay EP on December 7, 2009. The same measures will 

be implemented for the proposed modifications. 
 

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Shell Offshore Inc. 15-24 May 2011

(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? 

Activities associated with the proposed modification to the exploration drilling program would take place largely on 

Shell leases located in Federal waters of the OCS. Shell will follow all applicable BOEMRE regulations, 

requirements, and safety standards as indicated in the initial Camden Bay EP and detailed in the revised Camden Bay 

EP. See response for (d)(1) above. 

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 modification in Shell’s revised Camden Bay EP will not increase, decrease, or otherwise affect public access to, 

from, or along coastal waters. No construction of new, or modification existing coastal facilities are included in the 

initial or revised Camden Bay EP. 

Shell has added two proposed drill sites, Sivulliq G and Torpedo J, which are located within a few miles of the drill 

sites in the initial Camden Bay EP. Sivulliq G is located 16.6 mi (26.7) km from shore, approximately 118 mi (190 

km) east of Nuiqsut, and approximately 60 miles (97 km) west of Kaktovik. Torpedo J is located 23.1 mi (37.2 km) 

from shore, approximately 118 mi (190 km) east of Nuiqsut, and approximately 60 miles (97 km) west of Kaktovik. 

Therefore activities conducted at these sites will have no effect on coastal access. Additional vessel and helicopter 

trips will be required to support the drilling operations at these two additional drill sites, but the increase is not 

substantial, and would occur during a second drilling season thereby not increasing the seasonal impact of the 

project. Vessel and aircraft traffic will occur at the same frequency and duration, and with the same types of vessels 

and aircraft as for the drill sites in the initial Camden Bay EP. Within coastal waters, the vessel traffic will occur 

between the prospects and existing industrial facilities at West Dock and will therefore not affect the public’s access 

to coastal waters. 

Modification to the proposed exploration drilling program includes an OSV, a deck barge and tug, a waste barge and 

tug, and a containment barge/tug/anchor handler, but these vessels will remain offshore and outside the coastal zone, 

and will not affect coastal access. 

The collection, storage, and transport of the selected waste streams will occur offshore and have no affect on coastal 

access. Vessel traffic between the drilling vessel and the deck barge and waste barge where the wastes will be stored 

will occur offshore near the prospects. The deck barge and waste barge will transport the wastes for disposal outside 

the Arctic, via an offshore route, to existing facilities in Washington and Oregon and will have no effect on coastal 

access. 

The use of the Kulluk instead of the Discoverer as the drilling vessel will have no effect on coastal access. The 

drilling vessel will enter and exit the Beaufort Sea via offshore routes and will remain offshore for the duration of the 

drilling season. 

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 industrial requirements; 

(2) site facilities so as to be compatible with existing and subsequent adjacent uses and projected community needs; 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-25 May 2011

(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-of-way, 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:

Modification to the exploration drilling program includes: one or more additional seasons to perform additional 

exploration drilling at two additional drill sites, additional vessels (OSV, deck barge and tug, waste barge and tug, 

and containment barge with tug and anchor handler), collections, storage, and transport of selected waste streams, 

ZVSPs, and use of the Kulluk instead of the Discoverer as the drilling vessel. 

1) The drill site locations were selected based on interpretation and analysis of seismic surveys, and are in 

Federal waters of the OCS within oil and gas leases obtained from BOEMRE during oil and gas lease sales. 

Specific locations of the surface hole and anchor locations were selected based on the results of shallow 

hazards surveys and archeological assessments to minimize safety risks and avoid impacts to cultural 

resources. The additional support vessels, collection and storage of the selected waste streams, ZVSPs, and 

use of either drilling vessel will also be located offshore in the OCS either in or near the referenced lease 

blocks. 

2) The drill sites and associated modification to the EP will be located in the OCS, and primarily on oil and gas 

lease blocks, and are therefore compatible by definition with the primary use of the area. There are few other 

uses in or near these lease blocks. There is no commercial fishing in the OCS waters of the Beaufort Sea and 

probably no recreational fishing. Commercial vessel traffic in the Beaufort Sea is limited largely to a small 

number of barge trips for supply of coastal villages or oil and gas facilities at Prudhoe Bay. This barge traffic 

is typically much closer to the coast than the drill sites. Subsistence activities occur in the area including the 

hunting of waterfowl, seals, and bowhead whales by Nuiqsut and possibly Kaktovik residents, with bowhead 

whales being the most important resource. Mitigation measures developed by Shell in consultation with these 

stakeholders will avoid most or all effects on subsistent, and thus be compatible, the primary mitigation 

measure being the shutdown (and relocation out of the subsistence area) of the drilling operation from 25 

August through the end of the Nuiqsut (Cross Island) and Kaktovik fall whaling season. 
 

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Shell Offshore Inc. 15-26 May 2011

(3-4) There are no other concurrent uses or facilities in the area with which Shell could consolidate. Shell is 

consolidating / sharing the use of some vessels in the proposed modification (containment barge with tug and 

anchor handler) with the planned exploration drilling program in the Chukchi Sea to reduce fleet size. 

5) There are no developers in the area and BOEMRE holds jurisdiction over the submerged lands. Shell is 

cooperating with BOEMRE, and other Federal agencies with jurisdiction over resources in the area including 

NMFS, USFWS, and EPA. This cooperation is evident in the revised Camden Bay EP submitted to 

BOEMRE, the IHA/4MP (Appendix C & D), LOA (Appendix E), and the NPDES NOIs (Appendix B) and air 

permit respectively. 

6) Shell’s planned drill sites are located in OCS lease blocks with sufficient acreage (approximately 5,690 ac) to 

accommodate the planned activities and any future activities with regards to exploration for oil and gas. 

7) The drill sites and associated activities would be located in offshore OCS leases where there is no 

infrastructure. However, the exploration drilling program will be conducted with either of two self-contained 

drilling vessels supported by vessels and aircraft as typically accomplished in offshore oil and gas exploration. 

No new infrastructure is planned. Existing facilities at West Dock and Deadhorse / Prudhoe Bay are sufficient 

and easily accommodate logistical needs for the program, including air, marine and land-based support. 

8) No new harbors or shipping routes are required or planned as part of the modification in the revised Camden 

Bay EP. 

9) All vessel traffic associated with the modification, including the deck barge and tug, waste barge and tug, 

containment barge / tug / anchor handler, and the Discoverer/Kulluk will be coordinated through the use of 

normal USCG and industry vessel communication protocols. Collision avoidance systems include the use of 

shipboard GPS tracking and radar systems. 

10) No site clearing, dredging, or facility construction will be required, or is planned for these modifications. 

MLCs will be constructed at each drill site through a drilling process. MLCs and required by regulation 

everywhere in the Beaufort Sea OCS to protect wellhead equipment from ice, if and when the drilling vessel 

moves off the drill site. 

11) No new shipping routes are required or planned as part of the modification to the revised Camden Bay EP. 

12) No construction of facilities or support infrastructures in coastal areas is required or planned for the 

modification in the revised Camden Bay EP. 

13) The drill sites and associated activities would be located in offshore OCS leases and are not in or near any 

areas of particular scenic, recreational, environmental, or cultural value. 

(14) The drill sites and associated activities would be located offshore in OCS leases. The drill sites were selected 

based on interpretation and analysis of 3-D seismic survey data and shallow hazards and archaeological 

assessments. The drill sites are not within any areas identified as having especially high biological 

productivity, diversity, or vulnerability. The nearest such areas in the offshore is the Stefansson boulder patch 

located approximately 100 mi (161 km) west of the drill sites. Important or productive areas, such as the 

Arctic National Wildlife Refuge, and lagoons are located along the coastline 16.6-23.1 mi (26.7-37.2 km) from 

the drill sites. Air pollutant emissions, discharge effluents, and sound generated by activities at the drill sites 

would have no effect on these areas. No new aircraft or vessel transit routes are planned. As part of the 

modification of the Camden Bay EP, Shell has added a containment barge with additional oil spill response 

capabilities, as well as a capping stack, located on one of the ice management vessels, and associated 

intervention equipment to respond to any well control events or oil spills. 

(15) The drill sites and associated activities would be located offshore in OCS leases where winds and air currents 

would disperse airborne emissions that cannot be captured before escape into the atmosphere. Modeling 

indicates that National Ambient Air Quality Standards (NAAQs) will be met within 1,640 ft (500 m) of either 

drilling vessel. 
 

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Shell Offshore Inc. 15-27 May 2011

(16) The drill sites and associated activities (additional vessels, ZVSPs, waste collection and transport) would be 

located offshore in OCS leases and will not result in overcrowded harbors or interfere with fishing operations 

and equipment. There are no commercial fishing operations in the Beaufort Sea OCS. The addition of two 

drill sites to the plan will result in additional vessel trips to Dutch Harbor and West Dock, but at the same 

drilling seasonal frequency and duration as reviewed for the initial Camden Bay EP. Collection, storage and 

transport of the selected waste streams to Washington / Oregon for onshore disposal will result in the use of 

port facilities in that area. No construction of facilities is planned in any port or harbor as part of these revised 

Camden Bay EP modification. The planned modification will not result in any harbor overcrowding or 

interference with fishing 

(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. 

The proposed exploration drilling program will be conducted in Federal waters of the OCS on leases held by Shell as 

indicated below in Table 6. Shell is submitting the revised Camden Bay EP for approval to conduct exploration 

drilling at the drill sites. Applications for Permits to drill at these locations will be filed with BOEMRE after the 

revised Camden Bay EP is approved and the permits must be obtained before drilling can be conducted. 

Table 6 Federal Leases on Which Exploration Drilling Would Occur

Drill Site Lease Block OCS Lease Sale 

Sivulliq G OCS-Y-1805 Flaxman Island 6658 195 

Torpedo J OCS-Y-1936 Flaxman Island 6559 202 

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. 

Modification to the exploration drilling program as detailed in the revised Camden Bay EP, as well as the initial 

Camden Bay EP, does not involve the construction of any utility routes or facilities. This standard is 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; 

(2) disruption in known or reasonably foreseeable wildlife transit; 

(3) blockage of existing or traditional access. 

Modification to the exploration drilling program as detailed in the revised Camden Bay EP, as well as the initial 

Camden Bay EP, does not involve the construction of any utility routes or facilities. This standard is 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. 
 

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Shell Offshore Inc. 15-28 May 2011

Evaluation: 

Does your activity involve harvesting or processing of timber? Yes No X 

If yes, please explain how your proposed project meets the standards of the State Forest Resources and 

Practices Act. 

Timber harvest and processing is not within the scope of the planned exploration drilling program, therefore this 

standard is not applicable. 

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. 

Sand and gravel will not be used for the planned exploration drilling program. 

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 X No 

If yes, please describe how the proposed project is designed to “avoid or minimize impacts to subsistence uses 

of coastal resources:” 

In review of the initial Camden Bay EP, DCOM granted the NSB’s request for designation of all state waters within 

the area bounded on the west by a longitudinal line at 148°31’40.36” (the longitude of West Dock) due north to 

federal waters to a longitudinal line in the east at 143°36’31” (longitude of Kaktovik) due north to federal waters as 

subsistence use areas for the subsistence species and activities described in bullets below. Modification to the 

exploration drilling program includes: two additional drill sites, additional vessels (OSV, deck barge and tug, waste 

barge and tug, and containment barge with tug and anchor handler), collections, storage, and transport of selected 

waste streams, ZVSPs, and possible use of the Kulluk instead of the Discoverer as the drilling vessel. Shell assumes 

the same designations will apply to the modification in the revised Camden Bay EP. Modification of the project does 

not change the conclusions regarding the evaluation of the revised project versus these subsistence use designations. 

• Marine Mammals: Polar bear, bearded seal, harbor or spotted seal, ribbon seal, ringed seal, walrus, beluga 

whale, and gray whale. Bowhead whale subsistence-use areas are described below. 

• Land Mammals: Black bear, grizzly bear, caribou, moose, and Dall sheep. 
 

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Shell Offshore Inc. 15-29 May 2011

• Fish: Blackfish, capelin, herring, Arctic Char, Arctic cod, ling cod, tom cod, Arctic flounder, grayling, 

northern pike, chum salmon, humpback salmon, Coho salmon, king salmon, sculpin, smelt, sucker, lake 

trout, Arctic cisco, least cisco, Bering cisco, rainbow trout, broad whitefish, humpback whitefish, round 

whitefish, and sheefish. 

• Waterfowl: Eggs, lesser brant, sandhill crane, common eider, king eider, spectacled eider, Steller’s eider, 

Canada goose, lesser snow goose, white-fronted goose, Arctic loon, common, loon, red throated loon, 

common murre, thickbilled murre, oldsquaw, snowy owl, pintail, rock ptarmigan, and willow ptarmigan. 

• Furbearers: Arctic fox, red fox, snowshoe hare, lynx, hoary marmot, mink, porcupine, Arctic ground 

squirrel, weasel, wolf, and wolverine. 

• Gathering: Clams, king crab, tanner crab, shrimp, blueberry, cloudberry, cranberry, crowberry, Hudson's 

Bay tea, salmon berry, sourdock, swamp grass, wild celery, wild chives, wild potato, wild rhubarb, wild 

spinach, willow leaves, alder bark, birch trees, willow brush, driftwood, sod, spruce trees, and timber logs. 

Additionally, DCOM designated the following areas for subsistence uses related to bowhead whales for the initial 

Camden Bay EP. Shell assumes the same designations will apply to the revised Camden Bay EP. Modification of 

the project does not change the conclusions regarding the evaluation of the revised project versus these subsistence 

use designations. 

Barrow Fall Subsistence Area: Excluding federal waters, all state coastal waters within the following areas are 

designated for subsistence use of bowhead whales from September to October: The area circumscribed from the 

mouth of Tuapaktushak Creek due north to the coastal zone boundary, to Cape Halkett due east to the coastal zone 

boundary. 

Nuiqsut: Excluding federal waters, all state coastal waters within the following areas are designated for subsistence 

use of bowhead whales from August to October: The area circumscribed from the Nechelik Channel of the Colville 

River due north to the coastal zone boundary, to the eastern point of Flaxman Island due north to the coastal zone 

boundary and due south to the shore. 

Kaktovik: Excluding federal waters, all state coastal waters within the following areas are designated for subsistence 

use of bowhead whales from August to October: The area circumscribed from Anderson Point in Camden Bay due 

north to the coastal zone boundary, to Humphrey Point due north the coastal zone boundary. 

Point Hope Fall Subsistence Area: Excluding federal waters, all state coastal waters within the following areas are 

designated for subsistence use of bowhead whales from September to October: The area circumscribed from Cape 

Lisburne due north to the coastal zone boundary, to Cape Thompson due south to the coastal zone boundary. 

Activities associated with modification of the Camden Bay EP will occur in Federal waters of the OCS, primarily 

within the lease blocks Flaxman Island 6658 and Flaxman Island 6559, for Sivulliq G and Torpedo J, respectively 

and surrounding OCS areas. The distances from these lease blocks to the subsistence use areas assumed designated 

for the revised Camden Bay EP are provided below in Table 7. 

Table 7 Distances from Flaxman Island Blocks 6658 and 6559 to Designated Subsistence Use Areas 

Subsistence Use Area 

Distance to Nearest Revised Camden Bay EP Lease Block 

Miles Kilometers 

Barrow Fall Subsistence 138.7 223.2 

Nuiqsut Subsistence 9.3 14.9 

Kaktovik Subsistence 37.7 60.6 

The permits and authorizations table included in Section 2.0 lists the authorizations and necessary permits to conduct 

the planned exploration drilling program. Shell will adopt the mitigation measures written into these authorizations, 

and will therefore be working within regulatory requirements. In addition to meeting all regulatory requirements, 

Shell is committed to other mitigation measures including those that will decrease any potential conflicts between 
 

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Shell Offshore Inc. 15-30 May 2011

exploration drilling activities and subsistence harvests. For the Camden Bay exploration drilling program, these 

mitigation measures include:

Communications 

• Shell has developed a Communication Plan and will implement this plan before initiating exploration 

drilling operations to coordinate activities with local subsistence users, as well as Village Whaling Captains’ 

Associations, to minimize the risk of interfering with subsistence hunting activities, and keep current as to 

the timing and status of the bowhead whale hunt and other subsistence hunts. The Communication Plan 

includes procedures for coordination with Com Centers to be located in coastal villages along the Chukchi 

and Beaufort Seas during Shell’s proposed exploration drilling activities. 

• Shell will employ local SAs from the Beaufort and Chukchi Sea villages that are potentially impacted by 

Shell’s exploration drilling activities. The SAs will provide consultation and guidance regarding the whale 

migration and subsistence activities. There will be one per village, working approximately 8-hr per day and 

40-hr weeks during the drilling seasons. 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 

subsistence-related comments, concerns, and information; coordinating with the Com and Call Center 

personnel; and advising how to avoid subsistence conflicts. Subsistence advisors will have a handbook that 

will specify work tasks in more detail. 

Aircraft Travel 

• Aircraft shall not operate below 1,500 ft (457 m) unless the aircraft is engaged in marine mammal 

monitoring, approaching, landing or taking off, in poor weather (fog or low ceilings) in an emergency 

situation. Aircraft engaged in marine mammal monitoring shall not operate below 1,500 ft (457 m) in areas 

of active whaling; such areas to be identified through communications with the Com Centers. 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 south of its offshore destination, then at that point it shall fly 

directly north through the Mary Sachs Entrance to its destination. Shell reserves the option to use an 

alternate flight route in the event that transit through the Mary Sachs Entrance is unsafe due to weather, 

other environmental conditions, or in the event of an emergency. 

• Aircraft and vessels will not operate within 0.5 mi (0.8 km) of walrus or polar bears when observed on land 

or ice. 

• Shell will also implement non-MMO 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. This flight will also help avoid disturbance of and collisions 

with birds. 

Vessel Travel 

• The Kulluk or Discoverer and support vessels will enter the Chukchi Sea through the Bering Strait on or 

after July 1, minimizing effects on marine mammals and birds that frequent open leads and minimizing 

effects on spring and early summer bowhead whale hunting. 

• Exploration drilling activities at the Sivulliq or Torpedo drill sites are planned to begin on or about July 10 

following transit into the Beaufort Sea and run through October 31, with a suspension of all operations 

beginning August 25 for the Nuiqsut (Cross Island) and Kaktovik subsistence bowhead whale hunts. During 

the suspension for the whale hunts the drilling fleet will leave the Camden Bay project area and move to an 

area north of latitude 71o

 25’N and west of longitude 146o 4’W. Shell does not plan to anchor during this 

suspension. Shell will return to resume activities after the subsistence bowhead whale hunts conclude. 

Exploration drilling activities will be completed by October 31, depending on ice and weather. 

• The drilling support fleet transit route will avoid known fragile ecosystems, including the Ledyard Bay 

Critical Habitat Unit, and will include coordination through Com Centers. 
 

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Shell Offshore Inc. 15-31 May 2011

• To minimize impacts on marine mammals and subsistence hunting activities, the drilling vessel and support 

fleet 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 drilling vessel 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. As soon as the fleet transits 

past the ice, it will exit the polynya zone and continue a path in the open sea toward the Camden Bay drill 

sites. 

• MMOs will be aboard the Kulluk or Discoverer and all support vessels (see the 4MP in Appendix D of the 

revised Camden Bay EP). 

• 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 is to be reduced during inclement weather conditions in order to avoid collisions with marine 

mammals. 

• All vessels must maintain cruising speed not to exceed nine knots while transiting the Beaufort Sea. This 

measure would reduce the risk of ship-whale collisions. 

• Shell will communicate and coordinate with the Com Centers regarding all vessel transit. 

Drilling Operations

• Shell will collect all drilling mud and cuttings with adhered mud from all well sections below the 26-in. (20-

in. casing) hole section, as well as treated sanitary waste water, domestic wastes, bilge water and ballast 

water, and transport them outside the Arctic for proper disposal in an EPA-licensed TDS. These waste 

streams will not be discharged to the ocean. 

• Drilling mud will be cooled to mitigate any potential permafrost thawing or thermal dissociation of any 

methane hydrates encountered during drilling, if such materials are present at the drill site. 

• Drilling muds 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) so that the volume of the 

spent mud is reduced. 

• 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 of the hazard at 

the drill site (see COCP in Appendix J of the revised Camden Bay EP). 

• All casing and cementing programs will be certified by a registered professional engineer. 

• Airguns arrays will be ramped up slowly during ZVSPs to warn cetaceans and pinnipeds in the vicinity of 

the airguns and provide time for them to leave the area and avoid potential injury or impairment of their 

hearing abilities. Ramp ups from a cold start when no airguns have been firing will begin by firing a single 

airgun in the array. A ramp up to the required airgun array volume will not begin until there has been a 

minimum of 30 min of observation of the safety zone by MMOs to assure that no marine mammals are 

present. The safety zone is the extent of the 180 dB radius for cetaceans and 190 dB for pinnipeds. The 

entire safety zone must be visible during the 30-min lead-in to an array ramp up. If a marine mammal(s) is 

sighted within the safety zone during the 30-min watch prior to ramp up, ramp up will be delayed until the 

marine mammal(s) is sighted outside of the safety zone or the animal(s) is not sighted for at least 15-30 min: 

15 min for small odontocetes and pinnipeds, or 30 min for baleen whales and large odontocetes. 

• The blowout prevention program will be enhanced through the use of two sets of blind/shear rams, increased 

frequency of BOP performance tests from 14 days to 7 days, a remotely operated vehicle (ROV) control 

panel on the seafloor with sufficient pressured water-based fluid to operate the BOP, a containment system 

that includes treatment and flaring capabilities, capping stack equipment, and a fully-designed relief well 

drilling plan and provisions for a second relief well drilling vessel (Discoverer or Kulluk) to be available to 

drill the relief well if the primary drilling vessel is disabled and not capable of drilling its own relief well. 
 

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Shell Offshore Inc. 15-32 May 2011

• Lighting on the drilling vessel will be shaded and has been replaced with ClearSky lighting. ClearSky 

lighting is designed to minimize the disorientation and attraction of birds to the lighted drilling vessel to 

reduce the possibility of a bird collision (see the Bird Strike Avoidance and Lighting Plan in Appendix I of 

the revised Camden Bay EP).

Ice Management 

• Ice management will involve preferentially redirecting, rather than breaking, ice floes while the floes are 

well away from the drill site (see the Ice Management Plan in Appendix K of the revised Camden Bay EP). 

• Real time ice and weather forecasting will be from the Shell Ice and Weather Advisory Center (SIWAC). 

Oil Spill Response 

• The primary OSR vessel will be on standby at all times when drilling into zones containing oil to ensure that 

oil spill response capability is available within one hour, if needed. 

• Shell will deploy an OSR fleet that is capable of collecting oil on the water up to the calculated Worst Case 

Discharge flowrate of a blowout in the unlikely event that one should occur. The primary OSR vessel will 

be on standby when drilling into zones containing oil to ensure that oil spill response capability is available 

within one hour, if needed. The remainder of the OSR fleet will be fully engaged within 72 hours. 

• In addition to the OSR fleet, oil spill containment equipment will be available for use in the unlikely event 

of a blowout. The barge will be centrally located in the Beaufort Sea and supported by an Invader Class Tug 

and possibly an anchor handler. The containment equipment will be designed for conditions found in the 

Arctic including ice and cold temperatures. This equipment will also be designed for maximum reliability, 

ease of operation, flexibility and robustness so it could be used for a variety of blowout situations. 

• Capping Stack equipment will be stored aboard one of the ice management vessels and will be available for 

immediate deployment in the unlikely event of a blowout. Capping Stack equipment consist of subsea 

devices assembled to provide direct surface intervention capability with the following priorities: 

• Attaching a device or series of devices to the well to affect a seal capable of withstanding the maximum 

anticipated wellhead pressure (MAWP) and closing the assembly to completely seal the well against further 

flows (commonly called “capping and killing”) 

• Attaching a device or series of devices to the well and diverting flow to surface vessel(s) equipped for 

separation and disposal of hydrocarbons (commonly called “capping and diverting”) 

• A polar bear culvert trap has been constructed in anticipation of OSR needs and will be deployed near Point 

Thomson or Kaktovik prior to drilling. 

• Pre-booming is required for all fuel transfers between vessels 

Air Emissions 

Kulluk 

• The Kulluk will have selective catalytic reduction (SCR) as a nitrogen oxide (NOx) tailpipe emission 

control on its primary engines. The primary generators will also have oxidation catalysts installed for 

control of particulate matter less than 2.5 microns (PM2.5), volatile organic compounds (VOC), and carbon 

monoxide (CO). 

• The other engines normally used in the exploration drilling activities (the air compressors, the MLC, 

hydraulic power units (HPU), and cranes) will also have oxidation catalysts as tailpipe control for oxidizing 

all oxidize-able substances, including PM2.5, VOC, and CO. Control of engine emissions is assumed to be 

50 percent for PM2.5, 80 percent for CO, and 70 percent for VOC. 

• Ice management vessels and anchor handlers will have SCR as a nitrogen oxide (NOx) tailpipe emission 

control on its primary engines.. 
 

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Shell Offshore Inc. 15-33 May 2011

• ULSD (0.0015 percent) fuel will be purchased for the Kulluk and support vessels to reduce sulfur dioxide 

(SO2) emissions. 

Discoverer 

• Primary generators on the Discoverer are retrofitted with selective catalytic reduction devices to reduce NOx 

emissions to under 0.5 g/kW-hr, and catalytic oxidation devices to reduce CO, VOCs and PM10. 

• All other engines on the Discoverer will either be Tier 3 (low emissions) or will be retrofitted with Catalytic 

Diesel Particulate Filters devices to reduce CO, VOCs, and HAPs and fine particulate matter. 

• Installation of selective catalyst reduction and oxidation catalyst emission controls on all propulsion and 

generation engines on the primary ice management vessel. 

• ULSD (0.0015 percent) fuel will be purchased for the Discoverer and support vessels to reduce SO2

emissions. 

(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. 

Subsistence resources used by the communities of Kaktovik and Nuiqsut are discussed in Section 3.11.7 under 

Socioeconomic Resources of the EIA. Activities associated with the proposed modifications to the revised Camden 

Bay EP that could potentially affect subsistence activities in these designated areas are discussed in detail in Section 

4.1.2 of the EIA (Appendix F of the EP), and include air pollutant emissions, discharge effluents, sound energy 

generated by drilling, ice management and vessel traffic, ZVSPs, and disturbance due to vessel and aircraft traffic. 

Modeling analysis indicates that criteria air pollutant concentrations will be at or below primary and secondary 

National Ambient Air Quality Standards (NAAQS) within 500 m of the drilling vessel. The emission of air 

pollutants from the activities at the two drill sites should therefore result in only minor temporary impacts to local air 

quality, no effects on subsistence resources, and given the distance from the drill sites to the subsistence use areas 

(Table 7), have no effect on subsistence activities in the designated areas. 

Discharges associated with the modification activities include the discharge of deck drainage, desalination unit 

wastes, BOP fluid, non-contact cooling water, excess cement, and cuttings from MLC construction and drilling of the 

upper hole sections (no drilling mud used). Modification of the Camden Bay EP includes the collection, storage, and 

transportation of the drilling fluids and drill cuttings generated by drilling the lower well sections, treated sanitary 

and domestic water, bilge and ballast water. This modification will reduce the already minor, localized, and 

temporary impacts to water quality and the seafloor associated with drilling waste discharges as evaluated in review 

of the initial Camden Bay EP. The remaining discharges are relatively benign and any effects on water quality would 

be generally restricted to the area within about 330 ft (100 m) of the discharge point. Modeling of the cooling water 

discharge (the discharge of greatest volume), which consists of uncontaminated, heated seawater, indicates that the 

effluent will approach ambient seawater temperatures within about 75 m of the discharge location. The discharge of 

cuttings from MLC construction and drilling the upper well sections will result in short-term impacts to water quality 

– primarily increased total suspended sediments but will be limited to the area within about 1,591 ft (485 m) of the 

discharge location and last only minutes or hours after the discharge is stopped. The discharged cuttings will settle 

on the seafloor over an area of about 0.0095 mi2

 (0.024 km2) below and down-current of the drilling vessel, and 

would result in the smothering of some benthic organisms and slightly elevated concentrations of some metals. 

However, these effects would be ameliorated within a few years by biodegradation and re-colonization. The impact 

is negligible due to the limited area affected. These discharges would have little or no effect on subsistence 

resources, and given the distance from the drill sites to the subsistence use areas (Table 4), would have no effect on 

subsistence activities in the designated areas. 

Noise generated by ice management and vessels traffic, drilling at the two additional drill sites, and by ZVSPs at all 

four drill sites, has the potential to affect lower trophic organisms, fish, marine birds, and marine mammals. These 

effects are discussed in detail in Sections 4.1.5, 4.1.6, 4.1.7, and 4.1.8 in the EIA (Appendix F of the EP). Effects 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-34 May 2011

would be largely limited to behavioral disturbance within the area ensonified by these activities (Table 8). 

Table 8. Extent of Ensonification from Activities Associated with Modification to the Camden Bay EP 

Activity Modeled Distance to Received Sound Level Radii 

Radii Sound Level 

Drilling - Discoverer 3.32 km 120 dB rms 

Drilling - Kulluk 13.27 km 120 dB rms 

ZVSP 3.67 km 160 dB rms 

Exposure of marine mammals to sound energy levels of 160 db rms from impulse sounds such as ZVSPs and 120 dB 

for continuous sounds such as drilling sounds have been shown to sometimes result in disturbance of marine 

mammals, and may be considered takes by NMFS. The modeling results indicate that these levels of ensonification 

may reach some designated subsistence use areas. Any effects on subsistence would be due to disturbance of the 

subsistence resources – primarily marine mammals. Behavioral reactions may make the animals more difficult to 

hunt or deflect their movements away from an area. 

Reasonably foreseeable adverse impacts potentially include the temporary deflection of bowhead whales from their 

migratory route that may result in increased effort, risk, and expenses associated with additional travel to conduct the 

subsistence hunt. The planned exploration 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 bowhead whale is of primary importance because it provides for a cultural basis for sharing and community 

cooperation and is the foundation of the Inupiat sociocultural system (MMS 2003). Impacts on Inupiat bowhead 

whalers may occur if whales are deflected seaward (further from shore) in the traditional hunting areas north of Point 

Thomson in Camden Bay. Some bowhead whales in the vicinity of the planned exploration drilling program might 

be expected to respond to sound by changing their speed and direction, thus avoiding close encounters of these sound 

sources. Bowhead whales exposed to drilling operations could experience temporary, nonlethal effects, and some 

avoidance behavior could persist up to 12 hours (MMS 2003). Whaling crews may have to travel greater distances to 

intercept westward migrating whales, thereby increasing risk for whaling crews and/or limiting chances of 

successfully striking and landing bowheads. 

Seals, beluga whales, polar bears, and walrus may also respond to drilling activity that could potentially interrupt 

subsistence activities. However, these species are often closely associated with ice-covered waters (Burns 1967; 

Kelly 1988; Richard et al. 1998; Durner et al. 2004; Angliss and Outlaw 2005) or use coastal haulouts in the case of 

the spotted seal (Angliss and Lodge 2002). During the drilling season, the planned exploration drilling program will 

be well away from coastal haulouts and likely well away from ice-covered waters. 

Activities associated with the modification to Shell’s Camden Bay exploration drilling program will avoid any 

potential impacts to the Nuiqsut (Cross Island) and Kaktovik fall bowhead whale subsistence hunts through 

mitigation measures. These are the same mitigation measures as considered in the review of the initial Camden Bay 

EP. The primary mitigation measure focused on the bowhead subsistence hunt is that exploration drilling activities at 

the additional drill sites (as was the case for the drill sites in the initial Camden Bay EP) are planned to begin on or 

about 10 July and run through 31 October with a suspension of all operations during the time period when the Cross 

Island and Kaktovik fall bowhead hunts occur. During the suspension for the whale hunts the drilling fleet will leave 

the Camden Bay project area and move to an area north of latitude 71o

 25’N and west of longitude 146o 4’W. The 

suspension will continue until the Cross Island and Kaktovik fall bowhead hunts are over, at which time the vessels 

may transit back to the drill site and continue operations through 31 October. 

(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. 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

Shell Offshore Inc. 15-35 May 2011

Not applicable, the department has designated subsistence use areas as discussed above. 

(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; 

The exploration drilling program has been modified by the addition of two drill sites (Sivulliq G and Torpedo J), 

collection and transport of five waste streams, additional vessels (OSV, deck barge and tug, waste barge and tug, and 

containment barge/tug/anchor handler), ZVSP, and possible use of the Kulluk. All of these activities associated with 

the modification would take place offshore in Federal waters outside the coastal zone and would have no effect on 

surface and groundwater drainage patterns in the coastal zone or elsewhere. No construction of new transportation 

facilities is proposed. 

(2) disruption in known or reasonably foreseeable wildlife transit; and 

The program will not disrupt terrestrial wildlife transit. Sound generated by drilling at the Sivulliq G and Torpedo J 

drill sites could result in the deflection of movements by marine mammals such as bowhead whales, belugas, bearded 

seals, ringed seals, spotted seals or walrus during a subsequent drilling season, but the rate or level is assumed 

consistent for each drilling season. Detailed analyses of the levels and effects of sound generated by the drilling 

vessels, support vessels, and ZVSPs on birds, marine mammals, and threatened and endangered species are provided 

in Sections 4.1.7, 4.1.8, and 4.1.9 respectively in the EIA (Appendix F of the EP). 

Appropriate mitigation measures have been adopted to avoid and/or minimize disruptions or deflections of marine 

mammals. Section 4.0 of the EIA (Appendix F of the EP) details the environmental impacts of the following drilling 

activities: discharges or emissions: vessel traffic; vessel mooring and MLC construction; aircraft traffic; sound 

energy from drilling and ice management; drill cuttings and drilling mud discharges; other permitted discharges; 

hydrocarbon spill; and project air emissions. The environmental impacts of these exploration drilling activities, 

discharges or emissions on wildlife transit are found in the following subsections: 4.1.8 (Marine Mammals); 4.1.7 

(Coastal and Marine Birds); 4.1.6 (Fish); 4.1.8 (Terrestrial Mammals); 4.1.9 (Threatened and Endangered Species 

and Critical Habitat). 

(3) blockage of existing or traditional access. 

The exploration drilling program has been modified by the addition of two drill sites (Sivulliq G and Torpedo J), 

collection and transport of five waste streams, additional vessels (OSV, deck barge and tug, waste barge and tug, and 

containment barge/tug/anchor handler), ZVSP, and possible use of the Kulluk. All of these activities associated with 

the modification would take place offshore in Federal waters and would have no effect on traditional access to and of 

the coastal zone. 

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; 
 

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(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; 

(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 ft on either side of the waterbody; 

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

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

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

Evaluation: 

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

your proposed project. 

The exploration drilling program has been modified by the addition of two drill sites (Sivulliq G and Torpedo J), 

collection and transport of five waste streams, additional vessels (OSV, deck barge and tug, waste barge and tug, and 

containment barge/tug/anchor handler), ZVSP, and possible use of the Kulluk. All of these activities associated with 

the modification would take place offshore in Federal waters outside the coastal zone, and would not take place in or 

near any estuaries; wetlands; tideflats; rocky islands and sea cliffs; barrier islands and lagoons; exposed high energy 

coasts; rivers, streams, and lakes or their floodplains; or important habitats. 

(b) Describe how the proposed project avoids, minimizes, or mitigates impacts to each of the identified 

habitat(s) in section (a) above. 

The only activities associated with the exploration drilling program that would occur within the identified habitats in 

the coastal zone are vessel and aircraft trips between the offshore prospects and the shorebase facilities at West Dock 

near Prudhoe Bay. These activities were evaluated in DCOM’s review of the initial Camden Bay EP and found to be 

consistent with the ACMP. The two additional drill sites may result in one or more drilling seasons but the frequency 

and duration of vessel and aircraft traffic within the coastal zone would remain the same in that subsequent season, 

and the same mitigation measures apply to the exploration drilling at the additional sites and to any associated vessel 

traffic in the coastal zone and elsewhere. 

(c) No response required. 

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? 

To Shell’s knowledge, 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, have not been designated by the 

department. BOEMRE must consult with the SHPO prior to approval of the revised Camden Bay EP. 

(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)? 

Potential cultural resources in the OCS include historic resources such as shipwrecks and prehistoric cultural 

resources such as camp sites in areas that were sub-aerially exposed during the period of human habitation of the 
 

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Shell Offshore Inc. 15-38 May 2011

North Slope. The only potential effects the exploration drilling program could have on historic, prehistoric, and 

archeological resources, are due to seafloor disturbance by such activities as mooring and MLC construction. 

Drilling wells at the two additional drill sites would increase the area of seafloor disturbed by the exploration drilling 

program. 

BOEMRE regulatory requirements for EPs with regards to the protection of archaeological resources are the 

requirements for shallow hazards surveys for all drill sites, and the preparation of archaeological assessments, with 

subsequent avoidance of disturbance of any potential resources identified in the assessment. Shallow hazards surveys 

and archeological assessments have been conducted at each of the drill sites (Sivulliq G and Torpedo J) added to the 

exploration drilling program, and the study areas encompassed all areas where anchors would be placed for the 

drilling vessel and MLCs would be constructed. The site clearance data did not detect any historic, prehistoric or 

archaeological resources at any of the planned locations. Anchor and drill site locations have been selected so that no 

unidentified magnetic anomalies or side-scan sonar contacts would be disturbed. The containment barge may be 

anchored in the event of a spill, but would also be anchored within the shallow hazards survey and archaeological 

assessment study area. Neither of the drill sites is located in OCS blocks identified by BOEMRE as having potential 

for prehistoric archaeological resources. Activities associated with modification to the EP are not anticipated to 

impact historic, prehistoric, or archaeological resources. 

Affected Coastal District Enforceable Policies

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) NSBCMP is not in effect at this time. 

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.

___________________________________________________ May 4, 2011

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.

b) Other Information 

The “information” and “analysis” required are present within the body of the revised Camden Bay EP and 

appended Environmental Impact Analysis (Appendix H). 
 

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Shell Offshore Inc. 16-1 May 2011

SECTION 16.0 ENVIRONMENTAL IMPACT ANALYSIS 

Refer to Appendix F for Environmental Impact Analysis. 

 
 

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SECTION 17.0 ADMINISTRATIVE INFORMATION 

a) Description of Exempted Information (Public Information Copies Only) 

Proprietary geological and geophysical information detailed in Section 3 of this document has been 

excluded from the public information copies of this plan. Appendix A includes OCS Plan Information 

Forms (Form MMS-137) which include specific information for each proposed well. The proprietary 

version of these forms includes information about bottom-hole locations. Public versions of these forms 

do not include the bottom-hole information. 

b) Bibliography 

ADEC. 2008. Alaska’s Final 2008 Integrated Report. Alaska Department of Environmental 

Conservation. April 2008. 

Air Sciences Inc. 2011a. Technical Memorandum: Updates To Air Quality Impact Analysis – Kulluk 

Drillship, Submitted to EPA Region 10 on May 4th, 2011, Attachment A, Page 15. 

Air Sciences Inc. 2011b. Discoverer Drillship Impact Evaluation for SO2 and NO2 Using AERMOD, 

Chukchi and Beaufort Seas, Shell Alaska Exploratory Drilling Program. Project No. 180-20-3. 

Angliss, R.P., and K.L. Lodge. 2002. Alaska Marine Mammal Stock Assessments, 2002. U.S. 

Department Commerce, NOAA Tech. Memo. NMFSAFSC-133, 224 p. 

Angliss, R.P., and R.B. Outlaw. 2005. Alaska Marine Mammal Stock Assessments, 2005. U.S. 

Department Commerce, NOAA Tech. Memo. NMFSAFSC-161, 250 p. 

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 

Burns, J.J. 1967. The Pacific Bearded Seal. Alaska Department of. Fish and Game, Pittman-Robertson 

Project. Rep. W-6-R and W-14-R. 66 pp. 

Dunton, K., S. Schonberg, and N. McTigue. 2009. Impact Assessment for Exploratory Drilling in 

Camden Bay (Sivulliq), Alaska Summer 2008. Re-submitted to: Shell Alaska, Anchorage, Alaska, 6 April 

2009. The University of Texas Marine Science Institute, 750 Channel View Drive, Port Aransas, TX 

78373. 

Durner, G.M., S.C. Amstrup, R. Neilson, and T. McDonald. 2004. The Use of Sea Ice Habitat by Female 

Polar Bears in the Beaufort Sea. U. S. Geological Survey, Alaska Science Center, Anchorage, Alaska. 

OCS Study MMS 2004-014. 

EPA Region 10. 2010. Statement of Basis For Proposed Outer Continental Shelf Prevention of Significant 

Deterioration Permit No. R10OCS/PSD-AK-09-01, Shell Gulf Of Mexico Inc. Frontier Discoverer 

Drillship Chukchi Sea Exploration Drilling Program. January 8, 2010. 

http://www.epa.gov/region10/pdf/permits/shell/chukchi_revised_permit_statement_of_basis_010610.pdf 

Fugro Geoconsultants. 2009a. Shallow Hazards Assessment, Sivulliq G, V, W and Supplemental N 

Wellsites, Blocks 6658, 6659, 6708 and 6709, Flaxman Island Area, Beaufort Sea, Alaska, Report No. 

27.2008-2266 
 

Revised Outer Continental Shelf Lease Exploration Plan Camden Bay, Alaska 

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Fugro Geoconsultants. 2009b. Shallow Hazards Assessment, Torpedo A, B, G, and H Wellsites, Blocks 

6609 and 6610, Flaxman Island Area, Beaufort Sea, Alaska, Report No. 27.2008-2267 

Fugro Geoconsultants. 2011. Drill Site Clearance Letter, Proposed Torpedo J Drill Site, Block 6559 

Flaxman Island, Beaufort Sea Alaska. Report No. 27.2010-2375-10 (submitted to BOEMRE March 

2011) 

Funk, D. W., R. Rodrigues, D. S. Ireland, and W. R. Koski (eds.). 2007. Joint Monitoring Program in the 

Chukchi and Beaufort Seas, July-November 2006. LGL Alaska Report P891-2, Report from LGL Alaska 

Research Associates, Inc., LGL Ltd., Greeneridge Sciences, Inc., Bioacoustics Research Program, Cornell 

University, and Bio-Wave Inc. for Shell Offshore, Inc., ConocoPhillips Alaska, Inc., and GX Technology, 

and National Marine Fisheries Service, U.S. Fish and Wildlife Service. 316 p. plus Appendices. 

Funk., D.W., D.S. Ireland, R. Rodrigues, and W.R. Koski (eds.). 2010. Joint Monitoring Program in the 

Chukchi and Beaufort seas, open-water seasons, 2006–2008. LGL Alaska Report P1050-2, Report from 

LGL Alaska Research Associates, Inc., LGL Ltd., Greeneridge Sciences, Inc., and JASCO Applied 

Sciences, for Shell Offshore, Inc. and Other Industry Contributors, and National Marine Fisheries Service, 

U.S. Fish and Wildlife Service. 462 p. plus Appendices. 

Funk., D.W., D.S. Ireland, R. Rodrigues, and W.R. Koski (eds.). 2011. Joint Monitoring Program in the 

Chukchi and Beaufort seas, open-water seasons, 2006–2009. LGL Alaska Report P1050-2, Report from 

LGL Alaska Research Associates, Inc., LGL Ltd., Greeneridge Sciences, Inc., and JASCO Applied 

Sciences, for Shell Offshore, Inc. and Other Industry Contributors, and National Marine Fisheries Service, 

U.S. Fish and Wildlife Service. 462 p. plus Appendices. 

GeoLLC. 2007. 2007 Exploration Wellsites Geohazards Assessments, Sivulliq Prospect, Beaufort Sea, 

Alaska, Report 12731-005-00. 

GeoLLC. 2008a. 2007 Exploration Wellsites Geohazards Assessments, Sivulliq Prospect, Beaufort Sea, 

Alaska, Addendum 1, Report 12731-001-02 

GeoLLC. 2008b. Exploration Wellsites Geohazards Assessments, Torpedo Prospect, Beaufort Sea, 

Alaska

Hanzlick, D., K. Short, and L. Hachmeister. 1990. Integration of Circulation Data in the Beaufort Sea. 

Anchorage, AK: USDOI, MMS and USDOC, 87 pp. 

Ireland, D.S., D.W. Funk, R. Rodrigues, and W. R. Koski (eds.). 2008. Joint Monitoring Program in the 

Chukchi and Beaufort Seas, July-November 2007. LGL Alaska Report P1050-3, Report from LGL 

Alaska Research Associates, Inc., LGL, Ltd., Greeneridge Sciences, Inc., and JASCO Research, Ltd. and 

for Shell Offshore, Inc., ConocoPhillips Alaska, Inc., and National Marine Fisheries Service, U.S. Fish 

and Wildlife Service. 445 p. plus Appendices. 

Kelly, B.P. 1988. Ringed Seal, (Phoca hispida) in Selected Marine Mammals of Alaska: Species 

Accounts with Research and Management Recommendations. Ed. J. W. Lentfer. Washington, D. C. 

MMC, 57-66. 

MBC Applied Environmental Sciences. 2003. Physical Oceanography of the Beaufort Sea – Workshop 

Proceedings. OCS Study MMS 2003-045. Prepared by MBC Applied Environmental Sciences, Costa 

Mesa, CA. Prepared for the U.S. Dept. of Interior, Minerals Management Service, Alaska OCS Region, 

Anchorage, AK. 26 pp. plus attachments. 
 

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MMS (Minerals Management Service). 2003. Final Environmental Impact Statement, Beaufort Sea 

Planning Area, Oil and Gas Lease Sale 186, 195, 202. Vol. 1. 2003-001. 

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. 

Federal Register 66(26, 7 Feb.):9291-9298. 

Northern Technical Services (Nortec). 1985. Data Report NR6-4, Federal OCS Lease Blocks 624 and 

625, Beaufort Sea Alaska. 

Northern Economics, Inc. and Institute of Social and Economic Research (NEI and ISER). 2009. Economic 

Analysis of Future Offshore Oil and Gas Development: Beaufort Sea, Chukchi Sea and North Aleutian 

Basin. A Report Prepared for Shell Exploration. Released March 2009 in Anchorage Alaska. 

Northern Economics, Inc. and Institute of Social and Economic Research (NEI and ISER). 2011. Potential 

National-Level Benefits of Alaska OCS Development. Prepared for Shell Exploration and Production. 

Richard, P.R., A.R. Martin, and J.R. Orr. 1998. Study of Late Summer and Fall Movements and Dive 

Behavior of Beaufort Sea Belugas, using Satellite Telemetry: 1997. MMS OCS Study 98-0016. 

Anchorage, AK. V + 25 p. 

Trefry, J. H., R. P. Trocine. 2009. Impact assessment for exploratory drilling in Camden Bay (Sivulliq), 

Alaska: Chemical perspective from summer 2008. Florida Institute of Technology, Melbourne, Florida. 

UIC UMIAQ. 2011. 2010 Subsistence Advisor Program, North Slope Alaska. Report prepared by UIC 

UMIAQ for Shell Exploration and Production Company, Anchorage Alaska. 

Voparil, I. 2009. DRAFT 2009 Update: Modeled Drill Mud Impacts from an Exploratory Drilling 

Campaign in the Chukchi Sea and Beaufort Sea, Alaska

 
 

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