Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. March 2015

Revision 2

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Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. i March 2015

Revision 2

TABLE OF CONTENTS

Page

ACRONYMS & ABBREVIATIONS........................................................................................................VII

GLOSSARY OF SELECTED DRILLING TERMS ..................................................................................XI

CROSS-REFERENCE TO APPLICABLE REGULATIONS ................................................................XIV

SECTION 1.0 REVISED EXPLORATION PLAN CONTENTS .......................................................1-1

a) Description, Objectives, and Schedule for the Exploration Drilling Program .............1-5

b) Location........................................................................................................................1-7

c) Drilling Units..............................................................................................................1-16

d) Service Fee .................................................................................................................1-18

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

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

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

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

d) New or Unusual Technology........................................................................................2-3

e) Bonds, Oil Spill Financial Responsibility, and Well Control Statements....................2-3

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

g) Blowout Scenario .........................................................................................................2-4

h) Contact Information......................................................................................................2-5

SECTION 3.0 GEOLOGICAL AND GEOPHYSICAL INFORMATION (PROPRIETARY AND 

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

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

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

b) Classification................................................................................................................4-2

c) Contingency Plan..........................................................................................................4-2

d) Modeling Report...........................................................................................................4-2

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

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

b) Physical Environment Reports.....................................................................................5-4

c) Socioeconomic Study Reports......................................................................................5-8
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SECTION 6.0 SOLID AND LIQUID WASTE AND DISCHARGE INFORMATION.....................6-1

a) Projected Generated Wastes.........................................................................................6-1

b) Ocean Discharges and Disposal Methods ....................................................................6-1

c) NPDES Permits............................................................................................................6-7

d) Modeling Report...........................................................................................................6-9

e) Cooling Water Intake .................................................................................................6-10

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

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

b) Emission Reduction Measures .....................................................................................7-3

c) Processes, Equipment, Fuels, and Combustibles..........................................................7-3

d) Distance to Shore..........................................................................................................7-4

e) Impact from Non-Exempt Drilling Units.....................................................................7-4

f) Modeling Report...........................................................................................................7-5

SECTION 8.0 OIL AND HAZARDOUS SUBSTANCES SPILL INFORMATION .........................8-1

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

b) Location of Primary Oil Spill Equipment Base and Staging Area ...............................8-1

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

d) Calculated Volume of Worst Case Discharge Scenario ...............................................8-2

e) Description of Worst Case Discharge Scenario ...........................................................8-3

f) Modeling Report...........................................................................................................8-3

SECTION 9.0 ALASKA OUTER CONTINENTAL SHELF PLANNING INFORMATION ...........9-1

a) Emergency Plan............................................................................................................9-1

b) Critical Operations and Curtailment Plan and Drilling Ice Management Plan.............9-1

c) Additional Information.................................................................................................9-1

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

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

b) Incidental Takes..........................................................................................................10-2

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

Stipulation No. 1 - Protection of Biological Resources..............................................................11-1

Stipulation No. 2 - Orientation Program.....................................................................................11-2

Stipulation No. 3 - Transportation of Hydrocarbons ..................................................................11-4

Stipulation No. 4 - Industry Site-Specific Bowhead Whale Monitoring Program......................11-4
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

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

Whaling and Other Subsistence Harvesting Activities...............................................................11-9

Stipulation No. 6 - Pre-Booming Requirements for Fuel Transfers.........................................11-14

Stipulation No. 7 - Lighting of Lease Structures to Minimize Effects to Spectacled and 

Steller’s eider............................................................................................................................11-14

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

a) Permits and Authorizations ........................................................................................12-1

b) Protected Species........................................................................................................12-1

c) Mitigation Measures...................................................................................................12-2

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

a) Planned Vessel and Aircraft List................................................................................13-1

b) Air Emissions...........................................................................................................13-11

c) Drilling Fluids and Chemical Products Transportation............................................13-11

d) Solid and Liquid Wastes Transportation ..................................................................13-11

e) Vicinity Map and Travel Routes ..............................................................................13-12

SECTION 14.0 ONSHORE SUPPORT FACILITIES INFORMATION............................................14-1

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

b) Air Emissions.............................................................................................................14-8

c) Unusual Solid and Liquid Wastes ..............................................................................14-9

d) Waste Disposal.........................................................................................................14-10

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

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

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

SECTION 18.0 BIBLIOGRAPHY ......................................................................................................18-1
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

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LIST OF TABLES

Table 1-1 Comparison of the Exploration Drilling Program Under Shell’s Approved EP 

Revision 1 and EP Revision 2.......................................................................................1-4

Table 1.a-1 Shell Lease Blocks and Drill Sites Covered in the EP Revision 2 for the 

Exploration Drilling Program Started in 2012 (Protraction NR03-02, Posey 

Area Block)...................................................................................................................1-6

Table 1.c-1 Specifications of the Discoverer and the Polar Pioneer.............................................1-18

Table 2.a-1 Permit Applications Pending or Approved ...................................................................2-1

Table 2.b-1 Drilling Fluid Type, Quantity and Discharge Rates for MLC (using bit), 

Conductor and Surface-Cased Sections ........................................................................2-2

Table 2.b-2 Drilling Fluid Type, Quantity and Discharge Rates for Well Sections below the 

Surface Casing, after the Riser is Established...............................................................2-2

Table 2.g-1 Calculated Maximum Daily Oil Flow Rates for Wells at Drill Sites............................2-4

Table 6.b-1 NPDES Exploration Facilities GP Waste Streams Generated During Drilling.............6-2

Table 6.b-2 NPDES Exploration Facilities GP Waste Streams Generated Daily.............................6-4

Table 6.b-3 Wastes Generated on the Drilling Units that are not Discharged*................................6-6

Table 6.c-1 Drilling Fluid Components for the Upper Portions of the Well (MLC, 

Conductor and Surface-Cased Sections).......................................................................6-7

Table 6.c-2 Drilling Fluid Components for the lower portions of the well after the riser and 

BOP are established ......................................................................................................6-8

Table 6.e-1 Screen Mesh Size on Water Intakes on the Discoverer ..............................................6-10

Table 6.e-2 Screen Mesh Size on Water Intakes on the Polar Pioneer .........................................6-10

Table 7.a-1 3-Year Project Duration Emissions (tons) 1 ..................................................................7-2

Table 7.e-1 Application of BOEM Exemption Formula to the Discoverer .....................................7-4

Table 7.e-2 Application of BOEM Exemption Formula to the Discoverer and Support 

Vessels...........................................................................................................................7-4

Table 7.e-3 Application of BOEM Exemption Formula to the Polar Pioneer ................................7-5

Table 7.e-4 Application of BOEM Exemption Formula to the Polar Pioneer and Support 

Vessels...........................................................................................................................7-5

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

Sea OSRP......................................................................................................................8-2

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

Regional OSRP with the WCD Calculated for EP Revision 2 for Two Relief 

Well Scenarios...............................................................................................................8-3

Table 10.a-1 Monitoring Equipment on the Polar Pioneer and the Discoverer..............................10-1

Table 10.b-1 Number of Potential Exposures of Marine Mammals to Received Sound Levels 

in the Water of >120 dB re 1 μPa rms Generated by Exploration Drilling and 

>160 dB re 1 μPa rms Generated by ZVSPs during 2015 Exploration Drilling .........10-4
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

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Table 11.0-1 Dates and Locations of Meetings Held Regarding Shell’s Chukchi Sea 

Exploration Drilling Program for the Development of the POC...............................11-13

Table 12.b-1 Species Found in the Northeastern Chukchi Sea and Protected Under the ESA ........12-1

Table 12.b-2 Marine Mammals1 Found in the Northeastern Chukchi Sea and Protected Under 

the MMPA...................................................................................................................12-2

Table 13.a-1 Specifications of Support Vessel Types......................................................................13-2

Table 13.a-2 Specifications of the Major Oil Spill Response Vessels.............................................13-3

Table 13.a-3 Fuel Storage Capacity and Trip Information for Support Vessels and Aircraft........13-10

Table 13.b-1 Project Annual Air Pollutant Emissions (Tons Per Year) from Support Vessels 

Associated with the Drilling Units............................................................................13-11

Table 13.d-1 Onshore Waste Disposal Facilities, Waste Type, Amount, Rate, and Disposal 

Method ......................................................................................................................13-12

Table 14.b-1 Hourly Air Emissions Associated with Onshore Facilities in Barrow, Alaska...........14-8

Table 14.b-2 Annual Air Emissions Associated with Onshore Facilities in Barrow, Alaska...........14-8

LIST OF FIGURES

Figure 1.b-1 Location Map Exploration Drilling Program................................................................1-8

Figure 1.b-2 Burger Prospect Location Map .....................................................................................1-9

Figure 1.b-3 Bathymetry and Planned Drilling Unit Maximum Anchor Radius - Burger A...........1-10

Figure 1.b-4 Bathymetry and Planned Drilling Unit Maximum Anchor Radius - Burger F ...........1-11

Figure 1.b-5 Bathymetry and Planned Drilling Unit Maximum Anchor Radius - Burger J............1-12

Figure 1.b-6 Bathymetry and Planned Drilling Unit Maximum Anchor Radius - Burger R...........1-13

Figure 1.b-7 Bathymetry and Planned Drilling Unit Maximum Anchor Radius - Burger S ...........1-14

Figure 1.b-8 Bathymetry and Planned Drilling Unit Maximum Anchor Radius - Burger V...........1-15

Figure 9.c-1 Containment System and Components..........................................................................9-4

Figure 13.e-1 Marine Vessel Routes................................................................................................13-13

Figure 13.e-2 Flight Corridors.........................................................................................................13-14

Figure 14.a-1 Barrow Camp Locations..............................................................................................14-3

Figure 14.a-2 Barrow Hangar and Passenger Processing Facility.....................................................14-4

Figure 14.a-3 Barrow Proposed Passenger Processing Facility Expansion.......................................14-5

Figure 14.a-4 Barrow 75 Man Camp Location..................................................................................14-6

Figure 14.a-5 Wainwright Camp Location........................................................................................14-7
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

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LIST OF APPENDICES

Appendix A Outer Continental Shelf Plan Information Forms (Form 137)

Appendix B Marine Mammal Monitoring and Mitigation Plan

Appendix C Environmental Impact Analysis

Appendix D Plan of Cooperation 

Appendix E Bird Strike Avoidance and Lighting Plan Chukchi Sea, Alaska

Appendix F Critical Operations and Curtailment Plan

Appendix G Drilling Ice Management Plan

Appendix H Well Control Plan

Appendix I Fuel Transfer Plan

Appendix J Adaptive Approach to Ice Management in Areas Occupied by Pacific Walruses

Appendix K AQRP and NEPA Emissions Inventories
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

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ACRONYMS & ABBREVIATIONS

ACRONYMS & ABBREVIATIONS

~ approximately

o degree(s)

/ per

2D two-dimensional

3D three-dimensional

4MP Marine Mammal Monitoring and Mitigation Plan 

ac acre(s)

ACMP Alaska Coastal Management Program

ACS Alaska Clean Seas

ADEC Alaska Department of Environmental Conservation

ADNR Alaska Department of Natural Resources

AES ASRC Energy Services

AEWC Alaska Eskimo Whaling Commission

APD Application for Permit to Drill

API American Petroleum Institute

APM Application for Permit to Modify

AQRP Air Quality Regulatory Program

ASA Applied Science Associates, Inc.

ASRC Arctic Slope Regional Corporation

bbl barrel(s) – 42 U.S. gallons

BOEM Bureau of Ocean Energy Management

BOP blowout preventer

BSEE Bureau of Safety and Environmental Enforcement

Burger #1 well OCS-Y-1413 (legacy Burger #1 well)

BWASP Bowhead Whale Aerial Survey Project

CDPF catalytic diesel particulate filters 

CESQG Conditionally Exempt Small Quantity Generator

CFR Code of Federal Regulations

CLO community liaison officer

cm centimeter(s)

CO carbon monoxide

COCP Critical Operations and Curtailment Plan 

Com Center Communications and Call Centers

cu yd cubic yard(s)

CZMA Coastal Zone Management Act

dB decibel(s)

DIMP Drilling Ice Management Plan 

Discoverer M/V Noble Discoverer

DNV Det Norske Veritas

DPP development and production plan

E east

EA Environmental Assessment 

EIA Environmental Impact Analysis

EMP Environmental Monitoring Program

ENE east-northeast

EP Exploration Plan
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

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ACRONYMS & ABBREVIATIONS

EP Revision 1 Chukchi Sea Exploration Plan Revision 1 (Shell 2011) 

EP Revision 2 Chukchi Sea Exploration Plan Revision 2 (Shell 2015)

EPA U.S. Environmental Protection Agency

ESA Endangered Species Act

FONSI Finding of No Significant Impact

FR Federal Register

ft. foot/feet

ft3 cubic feet

FTP Fuel Transfer Plan

gal gallon(s)

GEMS Geoscience Earth & Marine Services, Inc.

GOM Gulf of Mexico

GP General Permit

H2S hydrogen sulfide

hp horsepower

hr. hour(s)

HSWUA Hanna Shoal Walrus Use Area

HSSE Health, Safety, Security and Environment

IMO International Maritime Organization

in. inch(s)

Initial Chukchi Sea EP Shell’s initial Chukchi Sea Exploration Plan (Shell 2009) 

IRA Indian Reorganization Act

KDR Kitchen/dining/recreation

KIC Kikiktagruk Inupiat Corporation

kg kilogram(s)

km kilometer(s)

lb. pound(s)

LBCHU Ledyard Bay Critical Habitat Unit

m meter(s)

m3 cubic meter(s)

mi statute mile(s)

mi2 square miles

min minute(s)

MARPOL International Convention for the Prevention of Pollution from Ships

MAWP maximum anticipated wellhead pressure

MD measured depth

MLC mudline cellar 

mm millimeter(s)

MMPA Marine Mammal Protection Act

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

MODU Mobile Offshore Drilling Unit

MSW municipal solid waste

mt metric ton(s)

M/V Motor Vessel

N/A not applicable

NAAQS National Ambient Air Quality Standards

NaCl sodium chloride

NAD 83 North American Datum 1983
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

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ACRONYMS & ABBREVIATIONS

NARL Naval Arctic Research Laboratory

NE northeast

NMFS National Marine Fisheries Service

nmi nautical mile(s)

NNE north-northeast

NOI Notice of Intent 

NOx nitrogen oxide

NPDES National Pollutant Discharge Elimination System

NSB North Slope Borough

NTL Notice to Lessee

NWAB Northwest Arctic Borough

NWP Nationwide Permit

OCS Outer Continental Shelf

OSFR oil spill financial responsibility

OSR oil spill response 

OSRO Oil Spill Removal Organization

OSRP Oil Spill Response Plan

OSRV oil spill response vessel

OST oil storage tanker 

OSV offshore supply vessel

OWS oil-water separator

OxyCat oxidation catalysts

PAEL Preapproved Emission Limit

PM particulate matter

PM2.5 particulate matter less than 2.5 microns

PM10 particulate matter less than 10 microns

ppb parts per billion

ppm parts per million

PPOR potential place of refuge

POC Plan of Cooperation 

Polar Pioneer Mobile Offshore Drilling Unit (MODU) Transocean Polar Pioneer

PSD Prevention of Significant Deterioration

PSO Protected Species Observer(s)

PTD proposed total depth

RKB rotary kelly bushing

rms root mean square

ROV Remotely Operated Vehicle

RQ reportable quantity

RS/FO Regional Supervisor, Field Operations 

SA subsistence advisor

SAPP sodium acid pyrophosphate

SAR Search and Rescue

SCR selective catalytic reduction

sec second(s)

SEPCO Shell Exploration & Production Company

Shell Shell Gulf of Mexico Inc.

SO2 sulfur dioxide

SS subsea
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

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ACRONYMS & ABBREVIATIONS

SSV sound source verification

TA temporarily abandon

TBD to be determined

TD total depth

TDS treatment/disposal/storage

TSP Total Suspended Particulate

TVD true vertical depth

UIC Ukpeaġvik Iñupiat Corporation

ULSD ultra-low sulfur diesel

UN United Nations

U.S. United States

USACE U.S. Army Corps of Engineers

USCG U.S. Coast Guard 

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey

UTM Universal Transverse Mercator

VOC volatile organic compound

V/V volume/volume

VHF-AM very high frequency – amplitude modulation

WBM water based mud

WCD Worst Case Discharge

WCP Well Control Plan

WNW west-northwest

XC Xanthomonas campestris, also known as xanthan gum

YBP years before present

ZVSP zero-offset vertical seismic profile
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GLOSSARY OF SELECTED DRILLING TERMS

GLOSSARY OF SELECTED DRILLING TERMS

Item Definition/Description Source

Annular Blowout 

Preventer

Blowout preventer that uses a shaped elastomeric 

sealing element to seal the space between the tubular 

and the wellbore or to seal an open hole.

API RP 96, Deepwater Well Design 

and Construction, First Edition, March 

2013.

Barrels (bbl) “Barrel (bbl)” means 42 U.S. gallons

Alaska Oil and Gas Conservation 

Commission, Definitions, Alaska 

Admin. Code tit. 20 § 25.990, 

December 7, 2012.

Blind Shear Ram

A closing and sealing component in a ram blowout 

preventer that first shears certain tubulars in the

wellbore and then seals the bore, or acts as a blind 

ram if there is no tubular in the wellbore.

API RP 96, Deepwater Well Design 

and Construction, First Edition, March 

2013.

Blind Ram A closing and sealing component in a ram blowout 

preventer that seals the open wellbore.

API RP 96, Deepwater Well Design 

and Construction, First Edition, March 

2013.

Blowout 

Preventer (BOP)

Equipment installed on the wellhead or wellhead 

assemblies to contain wellbore fluids either in the 

annular space between the casing and the tubulars, or 

in an open hole during well drilling, completion, and 

testing operations.

API RP 96, Deepwater Well Design 

and Construction, First Edition, March 

2013.

Capping Stack

A set of subsea devices (included but not limited to 

ram-type BOPs) assembled to provide direct surface 

intervention with the capability of capping and 

containing a well.

Shell Wells Department

Containment 

System

The containment system is a subsea spill collection 

system that provides the means to intercept 

uncontrolled well flows from subsea blowout 

situations as close to the source as possible. The 

containment system is housed on the Arctic 

Challenger barge and includes the containment dome, 

topside processing facilities, flare boom, an ROV, two 

workboats, and living quarters.

Shell Emergency Response 

Department
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Revision 2

GLOSSARY OF SELECTED DRILLING TERMS

Item Definition/Description Source

Lower Marine 

Riser Package 

(LMRP)

The upper section of a two-section subsea BOP stack 

consisting of the hydraulic connector, annular BOP, 

ball/flex joint, riser adapter, jumper hoses for the 

choke, kill and auxiliary lines and subsea control 

modules. The LMRP interfaces with the lower subsea 

BOP stack.

API SPEC 16D, Specification for 

Control Systems for Drilling Well 

Control Equipment and Control 

Systems for Diverter Equipment, 

Upstream Segment, Second Edition,

July 2004. 

Maximum 

Anticipated 

Surface Pressure 

(MASP)

A design load that represents the maximum pressure 

that can occur at the surface during well construction 

or production.

API RP 96, Deepwater Well Design 

and Construction, First Edition, March 

2013.

Maximum 

Anticipated 

Wellhead 

Pressure 

(MAWP)

The highest pressure predicted to be encountered at 

the wellhead in a subsea well. The MAWP may be 

calculated for each hole section during well 

construction.

API STD 53, Blowout Prevention 

Equipment Systems for Drilling Wells, 

Upstream Segment, Fourth Edition, 

November 2012.

Mobile Offshore 

Drilling Unit 

(MODU)

Facilities designed or modified to engage in drilling 

and exploration activities. The term MODU includes 

drilling vessels, semisubmersibles, submersibles, jackups, and similar facilities that can be moved without 

substantial effort. These facilities may or may not 

have self-propulsion equipment on board and may 

require dynamic positioning equipment or mooring 

systems to maintain their position.

API RP 54, Recommended Practice 

for Occupational Safety for Oil and 

Gas Well Drilling and Servicing 

Operations, Third Edition, August 

1999 (2007).

Mudline Cellar

(MLC)

A hole or excavation in the seafloor designed to 

protect the wellhead and attached BOP in areas where 

the seafloor is prone to scouring from ice floes 

(typically shallow waters in Arctic areas). The MLC 

(aka well cellar [30 CFR 250.451(h)]) is sufficiently

deep such that the top of any wellhead equipment or a 

BOP attached to the wellhead situated in the MLC is 

sufficiently below the mudline and out of reach for 

potential ice scour from ice floes. 

Shell Regulatory Affairs Department

& 30 CFR 250.451 (h)

Permanent 

Guidebase

Structure that sets alignment and orientation relative 

to the wellhead system and provides entry guidance 

for running equipment on or into the wellhead 

assembly.

API STD 65 – Part 2, Isolating 

Potential Flow Zones During Well 

Construction, Upstream Segment, 

Second Edition, December 2010

Pipe Ram Rams whose ends are contoured to seal around pipe to 

close the annular space.

API SPEC 16D, Specification for 

Control Systems for Drilling Well 

Control Equipment and Control 

Systems for Diverter Equipment, 

Upstream Segment, Second Edition, 

July 2004.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. xiii March 2015

Revision 2

GLOSSARY OF SELECTED DRILLING TERMS

Item Definition/Description Source

Ram BOP

BOP that uses two opposing metal elements (rams) 

with integral elastomer seals to contain pressure 

within a wellbore. Rams may be designed to close on 

a specific pipe size (fixed pipe rams), a range of pipe 

sizes (variable bore rams), or open hole (blind or 

blind/shear rams).

API RP 96, Deepwater Well Design 

and Construction, First Edition, March 

2013.

Riser See Lower Marine Riser Package

Rotary Kelly 

Bushing

(RKB)

Bushing that sits on top of the rotary table. It 

transmits torque from the rotary table to the kelly and 

is commonly used as a reference for vertical 

measurements from the drill-floor.

ISO 13624-1:2009, Petroleum and 

natural gas industries – Drilling and 

production equipment – Part 1: Design 

and operation of marine drilling riser 

equipment.

Semisubmersible

A floating offshore drilling vessel which is ballasted 

at the drilling location and conducts drilling 

operations in a stable, partly submerged position.

API RP 64, Recommended Practice 

for Diverter Systems Equipment and 

Operations, Second Edition, 

November 2001 (March 1, 2007).

Shear Ram BOP 

(Blind/Shear 

Rams)

Rams having cutting blades that will shear tubulars 

that may be in the wellbore. Shearing blind rams 

additionally close and seal against the pressure below. 

Casing shear rams are designed specifically to shear 

casing, and may not seal the well bore.

API SPEC 16D, Specification for 

Control Systems for Drilling Well 

Control Equipment and Control 

Systems for Diverter Equipment, 

Upstream Segment, Second Edition, 

July 2004.

Variable Bore 

Ram A pipe ram that seals on more than one pipe size.

API RP 96, Deepwater Well Design 

and Construction, First Edition, March 

2013.

Zero-Offset 

Vertical Seismic 

Profiling

(ZVSP)

A geophysical technology for measuring the seismic 

properties in a profile of the earth using a set of 

sources and receivers, either of which are placed 

along the depth (vertical) axis and where the source is 

near the well-head above the vertical receiver array.

Rector, J. and M. Mangriotis. 2011. 

Encyclopedia of Solid Earth 

Geophysics. Harsh K. Gupta (ed.) 

Department of Civil and 

Environmental Engineering, 

University of California at Berkeley, 

Berkeley, CA, USA. Applied 

Geophysics, Institute of Engineering 

Seismology and Earthquake 

Engineering (ITSAK), Thessaloniki, 

Greece.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. xiv March 2015

Revision 2

CROSS-REFERENCE TO APPLICABLE REGULATIONS

Regulation Section Regulatory Information Exploration Plan (EP)

Section

Bureau of Ocean Energy Management (BOEM)

30 Code of Federal 

Regulations (CFR) 550.211

What must the EP include Section 1.0

(a) Description, objectives and schedule Section 1.0 b)

(b) Location Section 1.0 c)

(c) Drilling Unit Section 1.0 d)

(d) Service fee Section 1.0 e)

30 CFR 550.212 What information must accompany the EP Sections 2.0-17.0

(a) General information required by 550.213 Section 2.0

(b) Geological and geophysical (G&G) information required by 

550.214 Section 3.01

(c) Hydrogen sulfide information required by 550.215 Section 4.0

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

550.216

Section 5.0 

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

water intake information required by 550.217

Section 6.0

(f) Air emissions information required by 550.218 Section 7.0

(g) Oil and hazardous substance spills information required by 

550.219 Section 8.0

(h) Alaska planning information required by 550.220 Section 9.0

(i) Environmental monitoring information required by 550.221 Section 10.0

(j) Lease stipulations information required by 550.222 Section 11.0

(k) Mitigation measures information required by 550.223 Section 12.0

(l) Support vessel and aircraft information required by 550.224 Section 13.0

(m) Onshore support facilities information required by 550.225 Section 14.0

(n) Coastal zone management information required by 550.226 Section 15.0

(o) Environmental impact analysis information required by 550.227 Section 16.0

(p) Administrative information required by 550.228 Section 17.0

30 CFR 550.213 General Information Section 2.0 

(a) Applications and permits Section 2.0 a) 

(b) Drilling fluids Sections 2.0 b), and 6.0

(c) Chemical products Section 2.0 c)

(d) New or unusual technology Section 2.0 d) 

(e) Bonds, oil spill financial responsibility (OSFR), 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 (30 CFR 553) 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 Sections 2.0 f) and 9.0

(g) Blowout scenario Sections 2.0 g) and 8.0 e)

(h) Contact Section 2.0 h)

30 CFR 550.2141 G&G Information Required by 550.2141 Section 3.01

(a) Geological description Section 3.0 a) 

(b) Structure contour maps Section 3.0 b)

(c) Two-dimensional (2D) and three-dimensional (3D) seismic lines Section 3.0 c)

(d) Geological cross-sections Section 3.0 d)

(e) Shallow hazards reports Sections 3.0 e), 3.0 f)
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. xv March 2015

Revision 2

CROSS-REFERENCE TO APPLICABLE REGULATIONS

Regulation Section Regulatory Information Exploration Plan (EP)

Section

(f) Shallow hazards assessments Section 3.0 f) 

(g) High resolution seismic lines Section 3.0 g)

(h) Stratigraphic column Section 3.0 h)

(i) Time-vs-depth charts Section 3.0 i)

(j) Geochemical information Section 3.0 j)

(k) Future G&G activities Section 3.0 k)

30 CFR 550.215 Hydrogen Sulfide (H2S) Information Section 4.0

(a) Concentration Section 4.0 a)

(b) Classification Section 4.0 b)

(c) Contingency plan Section 4.0 c)

(d) Modeling report Section 4.0 d)

(d)(1) Site specific and area analysis not applicable (N/A)

(d)(2) H2S emissions N/A

30 CFR 550.216 Biological, Physical and Socioeconomic Information Section 5.0

(a) Biological environment reports Section 5.0 a)

(b) Physical environment reports Section 5.0 b)

(c) Socioeconomic study reports Section 5.0 c)

30 CFR 550.217 Solid and Liquid Wastes and Discharges Information and 

Cooling Water Intake Information 

Section 6.0 

(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 a) 

(c) National Pollutant Discharge Elimination System (NPDES) permit Section 6.0 c)

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

(c)(2) Copy of the application Not part of this submission

(d) Modeling report Section 6.0 d)

(e) Projected cooling water intake Section 6.0 e)

30 CFR 550.218 Air Emissions Information Section 7.0

(a) Projected emissions Section 7.0 a)

(a)(1) For each source on the drill rig list the following:

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

(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) 

(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 a) 

(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 550.219 Oil and Hazardous Substance Spills Information Section 8.0 
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. xvi March 2015

Revision 2

CROSS-REFERENCE TO APPLICABLE REGULATIONS

Regulation Section Regulatory Information Exploration Plan (EP)

Section

(a) Oil spill response planning Section 8.0 a) 

(a)(1) Oil Spill Response Plan (OSRP) 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 b)

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

personnel

Section 8.0 c), OSRP

(a)(2)(iv) Calculated volume of the worst case discharge (WCD) Sections 2.20 g) ,3.0 l), 8.0

d), e)

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

(b) Modeling report Section 8.0 f)

30 CFR 550.220 Alaska Planning Information Section 9.0

(a) Emergency plans Section 9.0 a)

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

30 CFR 550.221 Environmental Monitoring Information Section 10.0

(a) Monitoring systems Section 10.0 a)

(b) Incidental takes Section 10.0 b)

(b)(1) Threatened and endangered species list under the Endangered 

Species Act (ESA)

Section 12.0 b)

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

(c) Flower Garden Banks National Marine Sanctuary N/A

30 CFR 550.222 Lease Stipulations Information Section 11.0 

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

30 CFR 550.223 Mitigation Measures Information Section 12.0

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

(b) Mitigation measures to avoid/minimize incidental takes of: Section 12.0 c)

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

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

30 CFR 550.224 Support Vessel and Aircraft Information Section 13.0

(a) General Section 13.0 a)

(b) Air emissions Section 13.0 b)

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

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

(e) Vicinity map Section 13.0 e)

30 CFR 550.225 Onshore Support Facilities Information Section 14.0

(a) General Section 14.0 a)

(a)(1) Onshore facility existing, to be constructed or expanded Section 14.0 a)

(a)(2) Onshore facilities in the western Gulf of Mexico (GOM) N/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)

30 CFR 550.226 Coastal Zone Management Information Section 15.0, N/A
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. xvii March 2015

Revision 2

CROSS-REFERENCE TO APPLICABLE REGULATIONS

Regulation Section Regulatory Information Exploration Plan (EP)

Section

(a) Consistency certification N/A

(b) Other information N/A

30 CFR 550.227 Environmental Impact Analysis Information Section 16.0

(a) General requirements Appendix C

(a)(1) Assess the potential environmental impacts Appendix C 

(a)(2) Be project specific Appendix C 

(a)(3) Be as detailed as necessary

(b) Resources, conditions and activities Appendix C 

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

(b)(2) Air and water quality Appendix C 

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

marine birds, fish and shellfish, and plant life

Appendix C 

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

(b)(5) Sensitive biological resources or habitats Appendix C 

(b)(6) Archaeological resources Appendix C 

(b)(7) Socioeconomic resources Appendix C 

(b)(8) Other coastal and marine uses Appendix C 

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

Regional Supervisor

N/A

(c) Environmental impacts Appendix C 

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

(c)(2) Analyze and potential cumulative impacts Appendix C 

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

implications

Appendix C 

(c)(4) Describe potential mitigation measures Appendix C 

(c)(5) Summarize information incorporated by reference Appendix C 

(d) Consultation Appendix C 

(e) References cited Appendix C 

30 CFR 550.228 Administrative Information Section 17.0

(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 not submitted with EP Section 17.0 b)

Notice to Lessee (NTL)-

2015-N01

Blowout scenario required by 30 CFR 550.213 and 219 Section 2.0 d), and Section 8 

Assumptions & calculations used to determine WCD volume Section 3.0 l), Section 8 d)

United States (U.S.) Environmental Protection Agency (EPA) – NPDES

40 CFR 122.21 Application for a permit Separate document

National Marine Fisheries Service (NMFS)

MMPA Sections 101(a)(5)

(D)

Marine Mammal Protection Act Incidental Take Authorization for 

Whales & Seals

Separate document

U.S Fish and Wildlife Service (USFWS)

MMPA Sections 

101(a)(5)(A) and (D)

Marine Mammal Protection Act Incidental and Intentional Take 

Authorizations for Polar Bear & Pacific Walruses

Separate document

U.S. Army Corps of Engineers (USACE)

33 CFR 325.1 Applications for permits Separate document 1 Section 3 is not included in the public version of the Chukchi Sea EP Revision 2 (See Proprietary Version)
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 1-1 March 2015

Revision 2

SECTION 1.0 REVISED EXPLORATION PLAN CONTENTS

Shell Gulf of Mexico Inc. (Shell) submitted its initial Chukchi Sea Exploration Plan (EP) (Initial Chukchi 

Sea EP; Shell 2009) to the former U.S. Department of the Interior Minerals Management Service (MMS),

now Bureau of Ocean Energy Management hereinafter collectively referred to as BOEM, in May of 2009. 

The initial Chukchi Sea EP was deemed submitted by BOEM on 20 October 2009. BOEM subsequently 

prepared a draft Environmental Assessment (EA) wherein it analyzed the potential impacts of the 

proposed exploration drilling program, and it released that draft for public review and comment. On 7 

December 2009, following the close of public comment, BOEM issued a final EA and Finding of No 

Significant Impact (FONSI), and approved Shell’s initial Chukchi Sea EP. In that initial Chukchi Sea EP, 

Shell identified seven Outer Continental Shelf (OCS) lease blocks (Posey Area Blocks 6713, 6714, 6763, 

6764, 6912 and Karo Area Blocks 6864 and 7007) of interest in three prospects (Burger, Crackerjack, and 

Southwest Shoebill) that contained five potential drill sites (Burger C, F, J, Southwest Shoebill C, and 

Crackerjack C). The exploration drilling activities contemplated by the initial Chukchi Sea EP included 

the drilling of an exploration well at up to three of the above-referenced potential drill sites using the 

drillship Motor Vessel (M/V) Frontier Discoverer, which is now known as the M/V Noble Discoverer

(Discoverer). Shell planned to initiate exploration drilling activities under the initial Chukchi Sea EP in 

the summer of 2010, but the exploration drilling activities were postponed when BOEM suspended all 

exploration drilling activities in the Arctic following the Deepwater Horizon (BP Macondo blowout) 

incident in the Gulf of Mexico (GOM).

In 2011, Shell submitted to BOEM a revised EP (EP Revision 1, Shell 2011). This revision included 

Shell’s plan to drill six exploration wells at only the Burger Prospect starting in 2012. This EP was 

subsequently approved by the BOEM 16 December 2011. In 2012, Shell mobilized the Discoverer and its 

support vessels to the Burger A drill site on the Burger Prospect. Burger A was drilled to a depth of 1,505 

feet (ft.) and was temporarily abandoned (TA) according to the Bureau of Safety and Environmental 

Enforcement (BSEE) regulations at 30 CFR 250.1721-1723. In accordance with the terms and conditions 

of BOEM’s prior approval of EP Revision 1, Shell plans to continue exploration drilling operations at its 

Burger Prospect (Figures 1.b-1 and 1.b-2).

This final document (EP Revision 2) includes Shell’s plans to resume drilling operations at the currently 

approved drill sites located at the Burger Prospect (Table 1.a-1). A draft version of EP Revision 2 was 

submitted to BOEM on 28 August 2014 for review. Where appropriate, Shell has addressed BOEM 

review comments into the final version of EP Revision 2 and its appendices. EP Revision 2 includes the 

addition of another drilling unit, the Mobile Offshore Drilling Unit (MODU) Transocean Polar Pioneer

(Polar Pioneer), plus some additional support vessels. Differences between this EP Revision 2 and the 

approved EP Revision 1 are included in Table 1-1.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 1-2 March 2015

Revision 2

Differences between EP Revision 1 and EP Revision 2

The following are the most salient differences between EP Revision 1 and EP Revision 2. A larger list of 

changes is located in Table 1-1.

Additional Drilling Unit

Under Chukchi Sea EP Revision 2, Shell plans to drill all six exploration wells using either the 

Discoverer and/or the Polar Pioneer. EP Revision 2 includes simultaneous use of both drilling units 

whereas in EP Revision 1 only the drillship Discoverer was used. The Discoverer is ice-strengthened for 

operating in Arctic OCS waters. The Discoverer includes state of the art drilling and well control 

equipment. The Polar Pioneer is a non-self-propelled semi-submersible drilling unit capable of drilling in 

harsh environments, and also includes state of the art drilling and well control equipment. In the event of 

a well control incident that requires drilling a relief well, each drilling unit will serve as its own primary 

relief well drilling unit and as the secondary relief well drilling unit for the other drilling unit.

Additional Support Vessels and Trip Frequencies 

Vessel changes between EP Revision 1 and EP Revision 2 include the use of additional support vessels 

and oil spill response (OSR) equipment for Shell’s exploration drilling program in the Chukchi Sea

(Table 1-1). These adjustments have been made in direct response to Shell’s experiences during the 2012 

season, the planned use of a second drilling unit, and discharge monitoring requirements under the new 

National Pollutant Discharge System (NPDES) exploration facilities general permit (GP). Vessel types 

identified may be used to support exploration drilling activities in the Chukchi Sea (e.g., ice management, 

anchor handling, offshore supply, and OSR augmentation) and are therefore included in the Chukchi Sea 

EP Revision 2. The use of all vessel types identified is analyzed in the Environmental Impact Analysis

(EIA) (Appendix C). EP Revision 2 also includes the potential use of a mudline cellar (MLC) Remotely

Operated Vehicle (ROV) system housed on an offshore supply vessel (OSV). The MLC ROV system, if 

permissible under applicable permits or authorizations and available, will be capable of constructing an

MLC prior to the arrival of a drilling unit.

Under EP Revision 2, the expected frequency of visits by OSVs to the drilling units has been increased 

from 17 round trips per season to 30 round trips per season.

There have also been changes in the designated locations of some support vessels and the frequency of 

their use, with some being moored in Kotzebue Sound. Further information regarding the location and 

specifications of all vessel types proposed for use is provided in Section 13.

Additional Aircraft and Flight Frequencies 

Under EP Revision 2, Shell plans to utilize an additional helicopter for crew changes from Barrow to the 

Burger Prospect and increase the frequency of crew change flights from 12 round trips per week up to an 

estimated 40 round trips per week (Table 13.a-3). An additional fixed wing aircraft is provided for in EP

Revision 2 as the platform for conducting ice reconnaissance flights. Further information regarding the 

location and specifications of all aircraft types proposed for use is provided in Section 13.

Exploration Drilling Changes

Under EP Revision 2, Shell will not recycle drilling fluids from one drill site to the next. Spent drilling 

fluids will be discharged after each well is drilled to total depth (TD) because of space restrictions on the 

drilling units and the need for multiple types of drilling fluids.

Also under EP Revision 2, drilling fluid will not be cooled. This mitigation measure was removed as no 

permafrost has been observed in the five historical wells, recognized in the modern shallow hazards 

surveys, or encountered in the Burger A well during exploration drilling in 2012. A drilling fluid chiller 

will be present on both drilling units in the event that it is needed.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 1-3 March 2015

Revision 2

A third change involves Shell’s blowout prevention program. Shell will modify the blowout preventer 

(BOP) pressure test frequency from once every 7 days to once every 14 days. This change is consistent 

with 30 CFR 250.447(b), which requires a BOP system test before 14 days have elapsed since the last 

pressure test.

Similarities between EP Revision 1 and EP Revision 2

In comparison to the differences noted between EP Revision 1 and EP Revision 2, many aspects of the 

proposed drilling program remain similar. The following are the most salient items that have not changed 

from EP Revision 1 to EP Revision 2:

• Burger Prospect drill sites – the number (six) and locations (Table 1.a-1 and Figure 1.b-1) of drill 

sites, remain the same;

• Worst Case Discharge (WCD) – the calculated WCD flow rates and volumes (Table 2.g-1) for 

each of the six potential Burger Prospect wells remain the same;

• Oil Spill Response Plan (OSRP) – although some administrative changes are noted in the 

Chukchi Sea OSRP and the addition of the second drilling unit Polar Pioneer (Section 8), Shell’s 

response in the event of a loss of well control remains the same;

• Well Control Plan (WCP) – the WCP was changed to incorporate language more familiar to 

Shell’s well engineers and responders to a well control event; however, there have been no 

changes to the substance of Shell’s well control procedures (Appendix H);

• Critical Operations and Curtailment Plan (COCP) – the text has been updated to include the

second drilling unit Polar Pioneer, key personnel titles have changed, and the curtailment 

decision protocol has been updated to include the new key personnel; however, there have been 

no changes to the quality or substance of Shell’s COCP (Appendix F); and

• Drilling Ice Management Plan (DIMP) – contains minor changes and updates; ice management 

objectives and principles are clearly defined, the drilling units and attending ice management 

vessels have been updated; however, there have been no changes to the quality or substance of 

Shell’s approach to ice management (Appendix G).

In addition to the EP changes, since EP Revision 1 was approved, several actions from the federal 

government may shape how Shell will operate under EP Revision 2. These actions include:

• Polar Bear Critical Habitat was vacated in January 2013 when the U.S. District Court for the 

District of Alaska ruled that the U.S. Fish and Wildlife Service (USFWS proposed critical habitat 

designation did not meet the requirements of the Endangered Species Act (ESA);

• Change in ESA status of certain ice seals – the bearded seal (Beringia distinct population 

segment) and the ringed seal were listed as threatened in December 2012; in July 2014 the 

threatened listing for the bearded seal was vacated and remanded by the U.S. District Court for 

the District of Alaska to NMFS;

• Addition of the Hanna Shoal Walrus Use Area (HSWUA) – this is a large area (approximately 

9,500 square miles [mi2

]) to the northeast of the Burger Prospect that the USFWS designated as 

an area utilized by Pacific walrus during the summer months (Incidental Take Regulations 

Federal Register (FR) notice 78 FR 35364, 12 June, 2013); and

• Air emissions regulations are now administered by BOEM rather than the Environmental 

Protection Agency (EPA). In December 2011, jurisdiction for regulating air emissions for 

projects on the OCS in areas off the coast of the North Slope Borough (NSB) in Alaska was 

changed from the EPA to BOEM (Consolidated Appropriations Act, Page 1048). As a result, the 
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 1-4 March 2015

Revision 2

air permit for the Discoverer drill ship in the Chukchi Sea was terminated by the EPA in January 

2014 (79 FR, Page 2442). Shell now seeks authorization from BOEM for air pollutants emitted 

during the activities described in EP Revision 2.

Table 1-1 Comparison of the Exploration Drilling Program Under Shell’s Approved EP Revision 

1 and EP Revision 2

Parameter Approved EP Revision 1 EP Revision 2

Drilling Units Discoverer Discoverer and Polar Pioneer

MLC 

Construction

Discoverer Discoverer, Polar Pioneer, MLC ROV system

Support 

Vessels

Drilling Support Vessels:

• Ice Management vessel (x1)

• Anchor handler (x1)

• OSVs (x2)

• Shallow water landing craft (x1)

Oil Spill Response Support Vessels:

• Oil spill response vessel (OSRV) (x1)

• OSR tug (x1) and barge (x1)

• Oil storage tanker (OST) for recovered 

liquids (x1)

• Oil spill containment system tug (x1) and 

barge (x1)

• Oil spill containment system Anchor 

handler (x1)

Drilling Support Vessels:

• Ice Management Vessels (x2)

• Anchor Handlers (x3)

• Supply Tugs (x2) and barges (x2)

• OSVs (x3)

• Support Tugs (x2) 

• Science vessels (x2)

• Shallow water vessels (x2)

• MLC ROV system vessel (x1)

Oil Spill Response Support Vessels:

• OSRV (x1)

• OSR tug (x1) and barge (x1)

• OSTs (x2)

• Oil spill containment system tugs (x2) and 

barge (x1)

• OSR tug (x1) and barge for nearshore response 

(x1)

Aircraft • S-92 or AW139 for crew change

• S-61, S92 or EC225 for Search and 

Rescue (SAR)

• Fixed wing aircraft for protected species 

observer (PSO) flights

• Fixed-wing aircraft – crew change from 

Wainwright to regional jet service in 

Barrow

• S-92 Helicopters (or similar) for crew change

(x3)

• S-92 Helicopter (or similar) for SAR

• Fixed wing aircraft for PSO and ice monitoring 

flights (x2)

• Fixed-wing– crew change from Wainwright to 

regional jet service in Barrow

Aircraft 

Flights

• Helicopter Crew Change FlightsApproximately 12 round trips/week for 

crew change/resupply

• Fixed wing aircraft for PSO

• Fixed wing aircraft crew change between 

Barrow & Wainwright up to 4 times per 

week

• Helicopter Crew Change FlightsApproximately 40 round trips/week for crew 

changes/resupply

• Fixed wing aircraft for PSO and ice monitoring 

flights daily

• Fixed wing aircraft crew change between 

Barrow and Wainwright once every 3 weeks

Drilling Unit

Discharges

Discharges as listed in Section 6 of EP 

Revision 1

Revised discharges volumes/rates in Section 6 of 

EP Revision 2

Drilling Unit

Authorizations

Burger drill sites were authorized under

National Pollutant Discharge Elimination 

System (NPDES) exploration facilities 

General Permit (GP) AKG-28-0000 

Notices of Intent (NOI) to discharge certain wastes 

at the Burger drill sites werefiled under the new 

NPDES exploration facilities GP AKG-28-8100 

Drilling Fluid 

Components

List of approved components are in Table 

6.c-1 of EP Revision 1

Additional drilling components have been added 

and are in Tables 6.c-1 and 6.c-2 of EP Revision 
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 1-5 March 2015

Revision 2

Table 1-1 Comparison of the Exploration Drilling Program Under Shell’s Approved EP Revision 

1 and EP Revision 2

Parameter Approved EP Revision 1 EP Revision 2

Drilling Fluid 

Recycling

Drilling fluids to be recycled from well to 

well as practicable.

Drilling fluids will not be recycled from well to 

well.

Drilling Fluid 

Cooling

Drillings fluids will be cooled. Drilling fluids will not be cooled.

BOP Test 

Frequency

Performance (pressure) test every 7 days Pressure test every 14 days as per BSEE regulation 

30 CFR 250.447(b)

Shorebase Barrow – 75 person man camp • Barrow – lease 40 person man camp; add a 

kitchen unit to the 75 person man camp; add 

hangar space for an additional helicopter

• Wainwright – additional existing yard space 

has been leased for response equipment storage 

Secondary 

Relief Well 

Unit for the 

Discoverer

Kulluk Polar Pioneer will serve as secondary relief well 

unit for Discoverer, and Discoverer will serve as 

secondary relief well unit for Polar Pioneer

Air Emissions 

Authorization

Air emissions approved by EPA under 

authorization R10OCS/PSD-AK-09-01

Jurisdiction for regulating air emissions for 

projects on the OCS in areas off the coast of the 

NSB in Alaska was changed from EPA to BOEM 

(Consolidated Appropriations Act)

Containment 

System 

Location

Centrally located in the Chukchi Sea or 

Beaufort Sea

Located in or near Goodhope Bay within Kotzebue 

Sound

H2S 

Classification

Requested ‘H2S Unknown’ classification Requests ‘H2S Absent’ classification; H2S 

Contingency Plan removed

As required by 30 CFR 550.212-228, details of the planned exploration drilling program are provided in 

the following sections and associated appendices. While this submission is a plan revision, Shell

acknowledges that pursuant to 30 CFR 550.285(c), the plan revision could be subject to all of the 

procedures under 30 CFR 550.231 through 30 CFR 550.235, and has provided a complete EP that meets 

all the requirements of 30 CFR 550.212. This EP Revision 2 also meets the requirements of NTL 2015-

N01.

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

This EP Revision 2 and its appendices, including the comprehensive EIA (Appendix C), describe the 

exploration drilling activities Shell plans to resume in 2015 at six lease blocks within the Burger Prospect 

for its exploration drilling program in the Chukchi Sea (Figure 1.b-1). Each of the identified lease blocks 

(Fig 1.b-2) contain a single drill site (Table 1.a-1) which are described and analyzed herein. Shallow 

hazards data has been collected at each of these drill sites and each drill site has been reviewed for 

potential shallow hazards and archaeological evidence. Formal shallow hazards reports and 

archaeological assessments have been submitted to the BOEM in advance of this submission under 

separate cover for each of the drill sites.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 1-6 March 2015

Revision 2

Table 1.a-1 Shell Lease Blocks and Drill Sites Covered in the EP Revision 2 for the 

Exploration Drilling Program Started in 2012 (Protraction NR03-02, Posey 

Area Block)

Proposed 

Drill Site

Block Lease 

Number

Coordinates (meters [m])

1

X Y 

Latitude Longitude

Burger A 6764 OCS-Y-2280 563945.26 7912759.34 N71° 18' 30.92" W163° 12' 43.17"

Burger F 6714 OCS-Y-2267 564063.30 7915956.94 N71° 20' 13.96" W163° 12' 21.75"

Burger J 6912 OCS-Y-2321 555036.01 7897424.42 N71° 10' 24.03" W163° 28' 18.52"

Burger R 6812 OCS-Y-2294 553365.47 7907998.91 N71° 16' 06.57" W163° 30' 39.44"

Burger S 6762 OCS-Y-2278 554390.64 7914198.48 N71° 19' 25.79" W163° 28' 40.84"

Burger V 6915 OCS-Y-2324 569401.40 7898124.84 N71° 10' 33.39" W163° 04' 21.23" 1 Coordinate system is North American Datum 1983 (NAD 83) UTM Zone 3

' = minute

" = second

The drilling units will move through the Bering Strait and into the Chukchi Sea on or about 1 July and 

then onto the Burger Prospect as soon as ice and weather conditions allow. Exploration drilling activities 

will continue until on or about 31 October, and the drilling units and support vessels will exit the Chukchi 

Sea at the conclusion of each exploration drilling season.

1

Shell plans to drill exploration wells to a TD below objective depth at each of the six possible drill sites.

Shell may also elect to construct additional MLCs, using the drilling units or the MLC ROV system, and

upper hole segments (i.e., “partial holes”) using the drilling units, depending on the available time 

remaining through the drilling season. The purpose of the MLC is to ensure that the top of any portion of 

the wellhead and BOP is located below the maximum ice keel gouge depth, as per 30 CFR 250.451(h). 

Shallow hazards surveys (GEMS 2009; Fugro GeoConsulting, Inc. 2010a,b,c,d,e,f; Fugro GeoConsulting, 

Inc. 2011a,b) conducted in the area of the planned exploration drill sites in the Burger area, indicate a 

maximum ice keel gouge depth of about 5.0 ft. (1.5 m) below the seafloor. If the final well in a drilling 

season cannot reach objective depth by the end of the drilling season, the well will be suspended in 

compliance with applicable BSEE regulations and with the approval of the Regional Supervisor, Field 

Operations (RS/FO)2

.

No unfinished wellbore will remain open at the end of the final drilling season except in an emergency, 

but any well drilled during any season will be left at the end of any season in a status approved by the 

RS/FO of BSEE. If a hazardous condition occurs while drilling and requires curtailment of critical 

operations (or prevents initiating them, depending on the time available) per the provisions of the COCP 

(Appendix F), the well will either be drilled to objective well depth or secured and permanently 

abandoned prior to lease termination. Any well on which exploration drilling operations are suspended at 

the end of any drilling season will be secured and permanently abandoned prior to lease termination.

 

1 Shell may, depending on seasonal ice conditions, marine mammal distributions, and planned subsistence harvest in 

the area of interest, request permission from the USFWS and the NMFS to transit through the Bering Strait and into 

the Chukchi Sea prior to 1 July.

2 During the 2012 exploration drilling season, Shell initiated drilling at the Burger A well. The well was drilled to a 

MD of 1,505 feet (ft.) rotary kelly bushing (RKB) and is TA according to the BSEE regulations at 30 CFR 

250.1721-1723.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 1-7 March 2015

Revision 2

A well may also be started, TA due to ice, weather, or other conditions, and finished later in the same 

drilling season during the period covered by this EP Revision 2. This was an operational reality during the 

1989–1991 Chukchi Sea exploration drilling campaign.

The actual number of wells that will be drilled in a season will depend upon ice conditions and the length 

of time available in each exploration drilling season. The predicted “average” drilling season, constrained 

by prevailing ice conditions and regulatory restrictions, is long enough for a drilling unit to drill an

exploration well from spud to proposed total depth (PTD) and possibly construct an additional MLC or 

drill and secure a partial well. Once the objective intervals are fully evaluated, each exploration well will 

be plugged and abandoned in compliance with BSEE regulations.

Shell plans to drill six exploration wells to TD over the duration of this EP Revision 2. Any or all of these 

six possible drill sites may be permitted for drilling by BSEE via Applications for Permits to Drill (APD)

to allow for operational flexibility in the event sea ice conditions prevent access to one or more locations.

b) Location

OCS Lease Sale 193 was held in February 2008 and Shell was subsequently awarded 275 OCS leases 

(blocks) through a competitive bidding process. The locations of these lease blocks in the Burger Prospect 

are depicted in Figure 1.b-1 and listed above in Table 1.a-1. Locations of the six drill sites within the 

blocks are depicted in Figure 1.b-2. Planned drilling unit maximum anchor radii and bathymetry are 

indicated for each drill site in Figure 1.b-3 through Figure 1.b-8. Surface and bottomhole coordinates, OCS 

area name and block number, lease number, distance from block line, and other information for each of the 

drill sites are provided on the respective OCS Plan Information Forms (BOEM-0137) attached to this EP 

Revision 2 in Appendix A. Public and proprietary versions of the BOEM-0137 forms are part of this EP 

Revision 2 submission. Proprietary information withheld from the public version includes bottomhole 

location, true vertical depth (TVD) and measured depth (MD).

Shell is aware that under 30 CFR 550.160 Shell must submit a request to BOEM for right-of-use and 

easement authorization if Shell wants to place one or more anchors on an adjacent lease block. Regarding 

the Burger S drill site (Figure 1.b-7), Shell will apply for right-of-use and easement if any proposed anchor 

location would reside on an adjacent lease block.

Resupply will be from Dutch Harbor using OSVs. Additional resupply support may be provided via 

Kotzebue Sound. Aviation operations will be conducted primarily from Barrow. These are the plans only 

for the exploration drilling program covered by this EP Revision 2.
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Shell Gulf of Mexico Inc. 1-8 March 2015

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Figure 1.b-1 Location Map Exploration Drilling Program
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 1-9 March 2015

Revision 2

Figure 1.b-2 Burger Prospect Location Map
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 1-10 March 2015

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Figure 1.b-3 Bathymetry and Planned Drilling Unit Maximum Anchor Radius - Burger A 
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 1-11 March 2015

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Figure 1.b-4 Bathymetry and Planned Drilling Unit Maximum Anchor Radius - Burger F 
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 1-12 March 2015

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Figure 1.b-5 Bathymetry and Planned Drilling Unit Maximum Anchor Radius - Burger J 
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Shell Gulf of Mexico Inc. 1-13 March 2015

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Figure 1.b-6 Bathymetry and Planned Drilling Unit Maximum Anchor Radius - Burger R
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Shell Gulf of Mexico Inc. 1-14 March 2015

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Figure 1.b-7 Bathymetry and Planned Drilling Unit Maximum Anchor Radius - Burger S
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Shell Gulf of Mexico Inc. 1-15 March 2015

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Figure 1.b-8 Bathymetry and Planned Drilling Unit Maximum Anchor Radius - Burger V
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Shell Gulf of Mexico Inc. 1-16 March 2015

Revision 2

c) Drilling Units

All planned exploration drilling in the identified lease blocks will be conducted with the Discoverer and 

the Polar Pioneer.

The Discoverer is a turret moored self-propelled drillship. Station keeping is accomplished using a turretmoored, 8-point anchor system. The underwater fairleads prevent ice fouling of the anchor lines. Turret 

mooring allows orientation of the vessel’s bow into the prevailing metocean conditions to present 

minimum hull exposure to drifting ice. The vessel is rotated around the turret by hydraulic jacks. Rotation 

can be augmented by the use of the fitted bow and stern thrusters. Ice-strengthened sponsons have been 

retrofitted to the drillship’s hull.

The Discoverer is classed by Det Norske Veritas (DNV) as a MODU for worldwide service. It is a “1A1 

Ship-Shaped Drilling Unit l” and is capable of performing drilling operations offshore of Alaska. The 

Discoverer has been issued with a DNV Appendix to Class stating:

“The structural strength and material quality of the ‘Ice Belt’ formed by the sponsons below the 8,950 

mm A/B level, have been reviewed against the requirements for the DNV ICE-05 Additional Class 

Notation and found to meet those requirements (as contained in DNV Rules for Classification of Ships, Pt 

5 Ch. 1, July 2006) for a design temperature of -15 degrees C.”

The Polar Pioneer is classed by DNV as a MODU for worldwide service. It is a non-self-propelled, 

“SPM thruster assisted” semisubmersible offshore drilling unit of twin-hull configuration. The rig is a “+ 

A1 Column Stabilized Unit” and is capable of performing drilling operations offshore of Alaska.

Positioning is accomplished with a combination of an eight-point all chain catenary mooring system and 

thruster assisted mooring system. 

The Polar Pioneer was built in 1985, with unlimited operation area, in accordance with the Norwegian 

Maritime Directorate and to DNV regulations, current at that time. While operating in Norwegian waters, 

the installation, with its inventory, equipment, crew and machinery was required to comply with current 

rules and regulations for operation on the Continental Shelf of Norway. The Polar Pioneer is generally 

used in waters that are at least 230 ft. (70 m) in depth. However, the Polar Pioneer is able to operate in 

waters shallower than 230 ft. (70 m), such as those at the Burger Prospect, with a completed riser analysis 

and mooring analysis. These analyses are proprietary documents and are submitted to BSEE as part of the 

Application for Permit to Drill.

Both drilling units will comply with all of the regulations of DNV, the International Maritime 

Organization (IMO), and the U.S. Coast Guard (USCG). All exploration drilling operations will be 

conducted under the provisions of 30 CFR Part 250 Subpart D, and other applicable regulations and 

notices including those regarding the avoidance of potential drilling hazards, safety and pollution control.

The drilling units will undergo inspections by BSEE, DNV and USCG before entering the theater. 

Procedures for monitoring and reacting to ice in the prospect areas are provided in the COCP and the

DIMP which are attached as Appendices F and G, respectively.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 1-17 March 2015

Revision 2

Discoverer

Polar Pioneer
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Shell Gulf of Mexico Inc. 1-18 March 2015

Revision 2

Table 1.c-1 Specifications of the Discoverer and the Polar Pioneer

Specification Discoverer Polar Pioneer

Dimensions

Hull Length 514 ft. (156.7 [m]) 279 ft. (85 m)

Hull Width 85 ft. (26.0 m) 233 ft. (71 m)

Height 274 ft. (83.2 m) 319 ft. (97.3 m)

Derrick Height 175 ft. (53.3 m) 170 ft. (51.8 m)

Draft

Transit Draft 26.9 ft. (8.2 m) 30 ft. (9.15 m)

Operating Draft at Load line 26.9 ft. (8.2 m) 75.4 ft. (23 m)

Berths 124 berths 114 berths

Storage Capacity

Potable Water 1,670 barrels (bbl) 

(266 cubic meters [m3

]) 4,843 bbl (770 m3

)

Drill Water 5,798 bbl (922 m3) 11,140 bbl (1,770 m3)

Liquid Mud 2,400 bbl (382 m3) 6,180 bbl (982 m3)

Bulk Cement 6,400 cubic feet (ft3) (180 m3) 12,678 ft3 (359 m3)

Fuel 6,497 bbl (1,033 m3) 11,290 bbl (1,794 m3)

Propulsion Engines (1) MAN Diesel B&W l

6,480 horsepower (hp) Not Applicable 

Power Plant (6) Caterpillar 3512 1,476 hp (5) Bergen KVG-18 3,890 hp

Mooring

Anchors 9 – 15 metric ton (mt) Stevshark, 8 each 9 – 15 mt Stevshark, 8 each

Anchor Lines

2.75-inch (in.) (7-centimeters [cm]) wire 

rope

2.5- in. (6-cm) chain

3.3 in (88 mm) K-4 chain

Anchor Line Length (8 each) 2,750 ft. (838 m) wire + 1,150 ft. 

(351 m) chain (useable) per anchor

(8 each) 6,458 to 6,675 ft. (1,969 

to 2,035 m) chain per anchor

Transit Speed 8.0 knots N/A (non-self-propelled)

Marine Sanitation Device OMNIPURE Series 55 Piranha WRS-40

d) Service Fee

The required permit fee of $20,652 (six drill sites at $3,442 each) has been paid in full.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 2-1 March 2015

Revision 2

SECTION 2.0 GENERAL INFORMATION

a) Application and Permits 

Table 2.a-1 lists permit and authorization applications or plans that have or will be submitted that will 

support this EP Revision 2, for the wells to be drilled in the Burger Prospect under EP Revision 2. Some 

permits have already been obtained, and some existing permits need renewal or extension. 

Table 2.a-1 Permit Applications Pending or Approved

Permits & 

Authorizations Agency Submittal Date Authorization 

Date

Document 

Location

Chukchi Sea Exploration 

Plan Revision 2 BOEM March 2015

EP Revision 1 

approved 15 

December 2011

This document

APD BSEE

Six (6) Burger APD 

applications submitted 

– Jan-Sep 2012

Dates to seek 

amendments to APDs 

to be determined (TBD)

Burger A – 30 

August 20121

Burger J – 27 

September 20121

Burger V – 18 

October 20121

Amendment 

authorizations TBD

Separate cover

OSRP BSEE

Biennial review updates 

submitted on 18 

December 2013

Administrative updates 

to be filed following 

submittal of EP 

Revision 2

17 February 2012; 

Biennial review 

updates approved 

June 2014 Separate cover 

NPDES GP AKG-28-

8100 – Notice of Intent

(NOI)

EPA 23 January 2015 To be determined Separate cover

Marine Mammal 

Protection Act (MMPA) 

Authorization – Whales 

and Seals

NMFS 18 September 2014 To be determined Separate cover

MMPA Authorization –

Incidental Take of Polar 

Bear and Pacific Walrus

USFWS 17 September 2014 To be determined Separate cover

MMPA Authorization –

Intentional Take of Polar 

Bear and Pacific Walrus

USFWS 17 September 2014 To be determined Separate cover

Section 10/404 

Nationwide Permit 

(NWP) #8

United States 

Army Corps of 

Engineers 

(USACE)

30 September 2014 13 February 2015 Separate cover

Section 10 Letter of 

Permission2 USACE 30 March 2015 To be determined Separate cover

Land Use Permit –

Dutch Harbor area2

Alaska Department 

of Natural 

Resources (ADNR)

24 December 2014 1 March 2015 Separate cover

Land Use Permit –

Kotzebue Sound area2 ADNR 12 February 2015 To be determined Separate cover
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 2-2 March 2015

Revision 2

1 BSEE approved APDs for three wells Burger A, J, and V; all only to the bottom of the 20-in casing in each well. These three APDs, plus the 

APD applications for the remaining three Burger wells (Burger F, R and S) will be amended with applications to seek drilling to TD. Dates to 

seek amendment are TBD. 2 Permission and permits are for activities outside the Lease Sale 193 Planning Area. These approvals are not required to conduct exploration 

drilling activities.

b) Drilling Fluids

Projected drilling fluid volumes and discharge rates for each drill site are listed in Tables 2.b-1 and 2.b-2. 

Further details regarding waste stream volumes, discharge rates, mud additives and other information can 

be found in Section 6.0. Drilling fluid constituents are listed in Tables 6.c-1 and 6.c-2.

Table 2.b-1 Drilling Fluid Type, Quantity and Discharge Rates for MLC (using bit), Conductor

and Surface-Cased Sections

Drill Site Drilling 

Fluid Type

Projected Drilling Fluid

Quantity

Projected Drilling Fluid Discharge 

Rate1

Burger A already complete already complete

Burger F

Sea Water 

and Gel 

Sweeps

3,124 bbl 29.5 bbl/hour (hr.)

Burger J 3,207 bbl 30.3 bbl/hr.

Burger R 3,121 bbl 29.4 bbl/hr.

Burger S 3,123 bbl 29.5 bbl/hr.

Burger V 3,207 bbl 30.3 bbl/hr. 1 discharge occurs only during drilling; assume 106 drilling hours (does not include non-drilling time); the MLC ROV system if used in lieu of drilling units and as 

specified will not use drilling fluids

Table 2.b-2 Drilling Fluid Type, Quantity and Discharge Rates for Well Sections below the 

Surface Casing, after the Riser is Established

Drill Site Drilling 

Fluid Type1

Projected Drilling Fluid

Quantity2

Projected Drilling Fluid Discharge 

Rate3,4

Burger A WBM 6,231 bbl 69.2 bbl/hr.

Burger F WBM 6,184 bbl 68.7 bbl/hr.

Burger J WBM 5,546 bbl 61.6 bbl/hr.

Burger R WBM 6,352 bbl 70.6 bbl/hr.

Burger S WBM 6,340 bbl 70.4 bbl/hr.

Burger V WBM 6,736 bbl 74.8 bbl/hr. 1 WBM – water based mud; see Section 6 for list of components 2 Cutting not included in this total 3 Discharge occurs only during drilling; assume 90 drilling hours (does not include non-drilling time) 4 Does not include reserve pit volumes (Discoverer – 1,500 bbl and Polar Pioneer – 2,427 bbl) discharged at the end of the well at a rate not 

exceeding 1000 bbl/hr.

In addition to the WBM constituents listed in Section 6, potassium chloride (shale inhibitor) may be used 

but not discharged to the ocean. This product may be part of the drilling fluid that will be pumped in the 

hole prior to cementing. This fluid will remain in the hole behind the casing.

c) Chemical Products

Ethylene glycol and caustic soda (sodium hydroxide) quantities are likely to exceed the reportable 

quantity (RQ) as defined under 40 CFR 302. However, in order for these chemicals to be discharged to 

the sea, they will meet the toxicity requirements specified in the NPDES permit. 

Ethylene glycol (RQ is 5,000 pounds (lb.) or 2,273 kilograms [kg]) is an antifreeze agent that will be used 

in the BOP fluid and will be discharged to the seafloor in compliance with NPDES exploration facilities 
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Shell Gulf of Mexico Inc. 2-3 March 2015

Revision 2

GP AKG-28-8100. Caustic soda (RQ is 1,000 lb. or 455 kg) may be used in the drilling fluid as pH 

control and will also be discharged to the seafloor in compliance with NPDES exploration facilities GP 

AKG-28-8100. Chemical products on the drilling vessels will be stored in United Nations (UN)

Specification Packaging. Materials Safety Data Sheets, or Safety Data Sheets for drilling fluid chemical

will be available on the drilling units and they will be available on the support vessels used to transport 

the chemicals.

d) New or Unusual Technology

Shell is proposing to potentially use a MLC ROV system when able, under applicable permits or 

authorizations, and available in addition to the current MLC bit system, to excavate new MLCs.

The subsea (SS) MLC ROV system will be deployed by a dedicated OSV and will sit on the sea floor and 

may use a number of different implements to mobilize the seafloor sediments. These sediments will then 

be pumped away via use of a pump mounted on the MLC ROV system and discharged on the seafloor 

away from the excavation site. The implements used could include an excavator bucket, a rotating cutter, 

auger, drill, and/or rock hammer. The MLC ROV system will require a slope, currently estimated at 15o

, 

to maintain its stability while excavating the MLC.

Examples of MLC ROV Systems

The MLC ROV system vehicle would be deployed from a vessel rather than a drilling unit. The MLC 

ROV system would not require any pumping from the surface into the sea, which greatly decreases the 

discharge of foreign fluids into the water column. Because the geometry of the MLC excavated using the 

MLC ROV system would be different than a MLC excavated using a MLC bit system deployed from a 

drilling unit, any well using this new technology would correspondingly yield a larger volume of cuttings 

deposited on the seafloor (Table 6.b-1). The increased volume of the MLC afforded by the MLC ROV

system would eliminate the need for a remote SS control panel for well control and allow for SS pumps to

be used to clear sediment from the MLC without the utilization of cutting tools.

This specific technology has not been put to use for construction of MLCs, but similar technology has 

been used for very similar work elsewhere. The technology being proposed is commonly used for the 

trenching of SS pipelines and cable runs. 

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

BOEM has determined that Shell has the financial capacity to allow BOEM to waive supplemental bond 

requirements of Shell (Operator No. YK02117). Shell also has an area wide exploration bond for 

$1,000,000 with Federal Insurance Company, Bond #8216-14-86.

Shell is of sound financial strength and reliability and has demonstrated oil spill financial responsibility 

(OSFR) according to 30 CFR 553 for the facilities planned in the EP Revision 2. In accordance with 30 

CFR 553.30(d), Shell is indemnified for $150,000,000. This financial reliability ensures that Shell has the 

capability to deal with all emergency situations such as blowout control including relief well drilling and 

kill operations, if such an unlikely event should occur. This OSFR is current and valid and is renewed 

yearly when Shell submits audited financial information to BOEM.
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Shell Gulf of Mexico Inc. 2-4 March 2015

Revision 2

This is a planned exploration drilling program with temporary seasonal operations. Drilling unit

anchoring systems employed during operations will be removed upon permanent abandonment of each 

well. Permanent facilities will be limited to the casing, wellhead housings and the permanent guide base 

remaining after well abandonment. MLC excavations to protect the wellhead, casing and BOPs from 

potential ice gouge events will remain. Any well on which exploration drilling is suspended is secured in 

compliance with BSEE regulations and with the approval of the RS/FO, whether it is permanently 

abandoned (30 CFR 250.1710 through 1717) or TA (30 CFR 250.1721-1723).

f) Suspension of Operations

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

operations during implementation of the proposed exploration drilling program detailed in EP Revision 2. 

These plans and mitigation measures are in reference to suspension of operations as cited under 30 CFR 

550.213(f) and not to be confused with suspension of operations as cited under BSEE regulations at 30 

CFR 250.168 through 177. Forced suspension of operations could result from weather, ice conditions, 

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

suspension of operations, Shell has drafted several operational plans containing suspension procedures 

and protocols in accordance with 30 CFR 550.220, including a COCP, which is discussed in Section 9.0

and attached as Appendix F. 

g) Blowout Scenario

A blowout scenario was developed for Shell’s approved Chukchi Sea Regional OSRP based on 30 CFR 

254.47(b). The blowout scenario is described in Section 8.0(d) and (e) of this EP Revision 2 as required 

by 30 CFR 550.219. This blowout scenario is the same scenario as described in EP Revision 1. The 

approved OSRP has been prepared to accommodate this same blowout scenario, the change of a second 

drilling unit (the Kulluk will not be drilling in the Beaufort Sea but the Polar Pioneer will be drilling near 

the Discoverer on the Burger Prospect), the change in name of an OSR contractor, and other 

administrative changes. Calculation of a WCD is also required by 30 CFR 550.213(g) and NTL 2015-

N01, and is discussed below and in Section 8.

WCD – Maximum Flow Rate, Duration and Total Volume

Shell calculated WCD flow rates and volumes for a well at each of the drill sites identified in the EP 

Revision 1 using a combination of nodal analysis and numerical simulation techniques. Burger J was 

found to have the calculated maximum flow rate (Table 2.g-1). As stated previously, the WCD 

calculations remain the same in EP Revision 2. The total volume from a WCD from Burger J was 

calculated for both 34 days (603,564 bbl) and 38 days (669,479 bbl). These volumes were calculated from 

an initial flow rate of 23,100 bbl/day which diminishes over time.

Table 2.g-1 Calculated Maximum Daily Oil Flow Rates for Wells at Drill Sites

Drill Site Lease Estimated WCD Maximum Daily Oil Flow rate 

(bbl/day)

Burger J OCS-Y-2321 23,100

Burger S OCS-Y-2278 19,127

Burger A OCS-Y-2280 19,031

Burger V OCS-Y-2324 13,812

Burger F OCS-Y-2267 11,763

Burger R OCS-Y-2294 8,689

The assumptions and basis for calculation of the WCD are provided in Section 3.0 of the Proprietary 

version of EP Revision 2. The OSRP blowout planning scenario used for OSR planning (25,000 bbl/day 

for 30 days – 750,000 bbl) exceeds the WCD calculated for Burger J, as further discussed in Section 8.0.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 2-5 March 2015

Revision 2

Potential for Well Bridging

For calculation of the WCD, Shell has assumed uncontrolled flow to the mudline with no drill pipe in the 

hole, and no formation bridging. There has been only one penetration of the reservoir and it produced 

insufficient petrophysical data to be considered sufficient for determining bridging tendency at other sites.

Surface Intervention

Well control is discussed in Section 9.0 of this document and a WCP is provided in Appendix H. Shell 

will have a capping stack and a separate containment system tugs and barge available for the exploration 

drilling program. Surface intervention and capping and containment are discussed specifically in Section 

9.0. The capping stack system will be carried as equipment on an ice management vessel so will remain in 

the vicinity of the drilling units, and the containment system tugs and barge will be located in Kotzebue 

Sound where it can respond if required.

Relief Well Drilling Unit – Availability, Constraints, and Days to Drill and Kill Flow

Shell’s WCP is attached as Appendix H. Well control is the process of maintaining positive hydrostatic 

pressure in the drilled wellbore greater than that in any drilled formation, a process called positive 

pressure drilling, that prevents gas or fluids from underground reservoirs escaping from the wellbore in an 

uncontrolled manner.

In the unlikely event of a well blowout, the primary drilling unit will serve as its own relief well drilling 

unit. If the primary drilling unit is undamaged and capable of drilling its own relief well, drilling 

operations could begin in as little as three days, with the relief well drilled and flow from the blowout 

being killed in about 31 days (the estimated total duration after mooring of the relief well drilling unit to 

well kill would be approximately 28 days for a blowout at a Burger site). If the primary drilling unit 

cannot be used to drill the relief well, the secondary drilling unit would be brought in for that purpose.

The Polar Pioneer will serve as the secondary relief well drilling unit for the Discoverer, and the 

Discoverer will serve as the secondary relief well drilling unit for the Polar Pioneer. EP Revision 2 

assumes that both drilling units will be drilling at the Burger Prospect, in which case the estimated 

duration of flow prior to drilling a relief well to intersection with the original wellbore and killing the 

flow is approximately 34 days (six days to mobilize and moor and 28 days to kill the well). Should one 

drilling unit be as far away as Dutch Harbor, an additional four days will be required for the relief well, 

bringing total duration of uncontrolled flow to 38 days (10 days to mobilize and moor and 28 days to kill 

the well).

h) Contact Information

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

or via e-mail at Susan.Childs@Shell.com.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 3-1 March 2015

Revision 2

SECTION 3.0 GEOLOGICAL AND GEOPHYSICAL 

INFORMATION (PROPRIETARY AND 

CONFIDENTIAL)
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 4-1 March 2015

Revision 2

SECTION 4.0 HYDROGEN SULFIDE INFORMATION 

a) Concentration

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

recorded while drilling in open-hole conditions in any of the five wells: OCS-Y 1482 Klondike #1, OCSY 1275 #1 (Popcorn), OCS-Y 1413 #1 (legacy Burger #1 well), OCS-Y 1320 #1 (Crackerjack) and 

Chevron OCS-Y 0996 #1 (Diamond). However, two occurrences of minor amounts of H2S, related to the 

bacterial digestion of the XC (Xanthomonas campestris, also known as xanthan gum) polymer in the mud 

that was left inside the casing during an extended period of operational suspension, were recorded and are 

described below. In early October 1989, a string of 13 3⁄8-in. (340 mm) casing was set and cemented at 

5,516 ft. (1,681 m) in the legacy Burger #1 well. The cement was displaced by the same XC polymerbased drilling mud as that used to drill the 17 1⁄2-in. (445 mm) hole below 20-in. (508 mm) casing set at 

1,440 ft. (439 m). The cement was displaced to the float collar some 43 ft. (13 m) above the casing shoe 

leaving a cement plug in the bottom of the casing along with two check valves (i.e., floats). The cement 

plugs and floats, along with the hydrostatic pressure from the mud column within the 20-in. (508 mm) 

casing, prevented formation fluids from entering the casing. The well was TA with a corrosion cap set on 

top of the wellhead after pressure testing the wellhead hanger. The well remained in this configuration 

until it was re-entered.

In August 1990, the MLC was cleaned out on the legacy Burger #1 well and the corrosion cap was 

removed. Then a 121⁄4-in. (311 mm) bit was run through the old mud to the top of the cement plug inside 

the casing. The old mud was then displaced out of the 20-in. (508 mm) casing with newly mixed drilling 

mud. When the bottom portion of the old mud reached the surface, a maximum H2S concentration of 30

parts per million (ppm) was detected at the shale shaker. As the new mud circulated to surface, the H2S 

concentration returned to zero. Once the H2S concentration returned to zero the 121⁄4-in. (311 mm) bit 

then drilled through the cement plug and both check valves. It then proceeded to drill new formation on 

its way to the main objective target. 

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

contained within the 20-in. (508 mm) casing. There had been no H2S detected while drilling the 17 1⁄2-in. 

(445 mm) hole and the casing was sealed during the 10-month time between depositing the mud inside 

the casing and circulating it out. No other H2S was recorded while drilling the remaining hole segments to 

the well’s final TD of 8,202 ft. (2,500 m).

In October 1990, the 13 3⁄8-in. (340 mm) surface casing was set and cemented in the OCS-Y 1320 #1 

(Crackerjack) well at 5,448 ft. (1,661 m) in a 17 1⁄2-in. (445 mm) hole below the 20-in. (508 mm) casing 

set at 1,326 ft. (404 m). On this casing string, two joints of casing separated the float collar at 5,363 ft. 

(1,635 m) from the float shoe at 5,448 ft. (1,661 m), leaving at least 85 ft. (26 m) of cement inside the 

base of the pipe. Again, the cement was displaced with the same XC polymer mud used to drill the 17 1⁄2-

in. (445 mm) hole. The combination of the cement plug and the floats along with the hydrostatic pressure 

from the mud column within the 133⁄8-in. (340 mm) casing, prevented formation fluids from entering the 

casing. In addition, an H2S scavenger, Sulf-X ES at a concentration of 1.0 parts per billion (ppb) was 

added to the mud to prevent bacterial degradation of the mud (as seen at the legacy Burger #1 well). The 

Crackerjack well was TA, without drilling out cement inside the surface casing, using a corrosion cap.

In late July 1991, the rig returned to the OCS-Y 1320 #1 (Crackerjack) well and re-entered the TA well. 

A 121⁄4-in. (311 mm) bit was run to the top of cement inside the 133⁄8-in. (340 mm) casing and the old mud 

was circulated out of the hole. The returned mud was monitored for H2S by a safety specialist and by mud 

loggers. When mud from approximately 4,000 ft. (1,219 m) in the well reached the surface, H2S in trace 

concentrations was released at the shakers. As the old mud was displaced with new mud, the H2S 

concentration fell to zero prior to drilling out the cement plug and floats, and into new formation. No 
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other H2S was recorded while drilling the remaining hole segments to the well’s final TD of 9,573 ft. 

(2,918 m).

Again, it is concluded that the H2S in this well was the product of bacterial digestion of the XC polymer 

in the old mud. There was no H2S encountered while drilling the 17 1⁄2-in. (445 mm) hole and none was 

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

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

after about the same on-bottom time.

No H2S was detected or released while drilling any of the other wells in the Chukchi Sea during the 1989-

1991 campaign. This reinforces the conclusion that the source of H2S detected in these two wells was 

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

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

In 2012, H2S scavenger and corrosive inhibitor were not used in the drilling fluid. In the event of reentering a well that was started in 2012, that was TA the following procedure will be used. Once the 

drilling unit is moored, the drill pipe will be run into the surface plug and drill it out. Once the surface 

plug is drilled out, continue to trip in the hole to the surface casing shoe track and tag the top of cement. 

The drilling unit will pick up off bottom and circulate the well to the sea floor. This will ensure that if 

there is any H2S build up it is circulated to the seafloor rather than the drilling unit topsides. Once the 

well has been circulated, the drilling unit will pull the drill pipe out of the hole and commence running the 

BOPs and riser.

b) Classification

H2S is not expected in any hole segment in any exploration well planned in Shell’s EP Revision 2. This is 

based on the absence of H2S in any previously drilled exploration well in the Chukchi Sea, the Beaufort 

Sea or the Canadian Beaufort Sea, and the fact that no H2S was encountered while drilling the legacy 

Burger #1 well. The legacy Burger #1 well was drilled through the targeted Cretaceous objective at a TD

in the Jurassic Kingak Formation at 8,202 ft. (2,500 m). All of the planned exploration wells described in 

this EP Revision 2 will be targeting the same Cretaceous objective interval, as encountered in the legacy 

Burger #1 well, and would reach TD above the Kingak Formation.

All of the Burger Prospect drill sites covered by Shell’s EP Revision 2 are requested to be classified as 

“H2S absent” from the BSEE Regional Supervisor because none of the wells is projected to be drilled 

below the equivalent stratigraphic interval penetrated by the depth of the legacy Burger #1 well, 8,202 ft. 

(2,500 m).

c) Contingency Plan

Shell is requesting “H2S Absent” classification from the BSEE Regional Supervisor in this EP Revision 2;

therefore a contingency plan is no longer included.

d) Modeling Report

All of the Burger Prospect drill sites covered by Shell’s EP Revision 2 are requested to be classified as 

“H2S absent”; therefore a modeling report has not been developed.
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SECTION 5.0 BIOLOGICAL, PHYSICAL, AND 

SOCIOECONOMIC INFORMATION

a) Biological Environment Reports

Results of the shallow hazards surveys indicate that the seafloor at all six drill sites is relatively level and 

smooth with the exception of ice gouges. Seafloor sediments consist largely of silts and clays. No 

evidence was observed of hard bottom or other special habitats. 

Shell partially funded other types of baseline studies since 2008 as part of a multi-faceted study to gather 

data regarding resources in the project area, and plans to continue these studies. The studies’ focus 

includes a 30 x 30 nautical mile (nmi) study area (56 x 56 km) encompassing Shell’s Burger Prospect. 

The data collected during the course of these programs were used in the EIA (Appendix C). Final reports 

are currently available for the following studies:

• Benthic ecology of the Burger and Klondike survey areas: 2008 environmental studies program in 

the northeastern Chukchi Sea (Blanchard et al. 2010a).

• Benthic ecology of the Burger and Klondike survey areas: 2009 environmental studies program in 

the northeastern Chukchi Sea (Blanchard et al. 2010b).

• Oceanographic assessment of the planktonic communities in the Klondike and Burger survey 

areas of the Chukchi Sea: report for survey year 2008 (Hopcroft et al. 2009).

• Oceanographic assessment of the planktonic communities in the Klondike and Burger survey 

areas of the Chukchi Sea: report for survey year 2009 (Hopcroft et al. 2010).

• Oceanographic assessment of the planktonic communities in the northeastern Chukchi Sea: report 

for survey year 2010 (Hopcroft et al. 2011).

• Oceanographic assessment of the planktonic communities in northeastern Chukchi Sea: report for 

survey year 2011 (Hopcroft et al. 2012).

• Oceanographic assessment of the planktonic communities in northeastern Chukchi Sea: report for 

survey year 2012. (Hopcroft et al. 2013)

• Oceanographic assessment of the planktonic communities in northeastern Chukchi Sea: report for 

survey year 2013. (Hopcroft et al. 2014)

• Distribution and abundance of seabirds in the northeastern Chukchi Sea, 2008 (Gall and Day 

2009).

• Distribution and abundance of seabirds in the northeastern Chukchi Sea, 2008 and 2009 (Gall and 

Day 2010).

• Marine mammal surveys at the Klondike and Burger survey areas in the Chukchi Sea during the 

2008 open water season (Brueggeman 2009).

• Marine mammal surveys at the Klondike and Burger survey areas in the Chukchi Sea during the 

2009 open water season (Brueggeman 2010).

• Passive acoustic monitoring of marine mammals in the Chukchi Sea 9 September – 14 October 

2008 (The Cornell Lab of Ornithology 2010).

• Marine mammal distribution and abundance in the northeastern Chukchi Sea during summer and 

early fall, 2008-2012 (Aerts et al. 2013).
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• Distribution and Abundance of Seabirds in the Northeastern Chukchi Sea, 2008-2012 (Gall and 

Morgan, 2013).

• Distribution and abundance of seabirds in the northeastern Chukchi Sea, 2008 – 2013 (Gall et al. 

2014).

• Oceanographic assessment of the planktonic communities in the northeastern Chukchi Sea

(Hopcroft et al. 2013).

• Acoustic Survey of Fishes in the Chukchi Sea Environmental Studies Program in 2012 (Goodman 

et al. 2013).

• Chukchi Sea Environmental Studies Program 2008-2012: Benthic Ecology of the Northeastern

Chukchi Sea (Blanchard and Knowlton, 2013).

• Northeastern Chukchi Sea Joint Acoustic Monitoring Program 2011–2012 (Delarue et al. 2013).

• Continental Shelf Research. Seasonal and inter-annual dynamics of the northeastern Chukchi Sea 

Ecosystem (Hopcroft and Day, 2013).

• Seasonal observations of carbonate chemistry and ocean acidification in 2013 (Mathis and 

Monacci 2014)

• Marine mammal distribution and abundance in the northeastern Chukchi Sea from shipboard 

surveys during summer and early fall 2008-2013 (Aerts et al. 2014).

• Deep Sea Research Part II: Topical Studies in Oceanography. The Northern Chukchi Sea Benthic 

Ecosystem: Characterization, Biogeochemistry and Trophic Linkages (Dunton et al. 2014).

• Physical oceanographic measurements in the northeastern Chukchi Sea: 2013 (Weingartner et al. 

2014).

In addition to the baseline surveys described above, Shell has partially funded U.S. Geological Survey 

(USGS) walrus tagging studies in the Chukchi Sea and ringed seal tagging studies in Kotzebue Sound 

with the Native Village of Kotzebue. 

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

Chukchi Sea, including the area of Shell’s Burger Prospect, through its marine mammal monitoring 

program associated with open water activities. Data collected are summarized in the following reports:

• 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. 

•
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• 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 P1050-3, 

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

JASCO Research, Ltd., for Shell Offshore, Inc. and Other Industry Contributors, and National 

Marine Fisheries Service, U.S. Fish and Wildlife Service. 499 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. 

• Funk, D.W., C.M. Reiser, D.S. Ireland, R. Rodrigues, and W.R. Koski (eds.). 2013. Joint 

Monitoring Program in the Chukchi and Beaufort seas, 2006–2010. LGL Alaska Final Report 

P1213-2, Report from LGL Alaska Research Associates, Inc., LGL Ltd., Greeneridge Sciences, 

Inc., and JASCO Research, Ltd., for Shell Offshore, Inc. and Other Industry Contributors, and 

National Marine Fisheries Service, U.S. Fish and Wildlife Service. 592 p. plus Appendices.

• Funk, D., D Hannay, D. Ireland, R. Rodrigues, W. Koski. (eds.) 2008. Marine mammal 

monitoring and mitigation during open water seismic exploration by Shell Offshore Inc. in the 

Chukchi and Beaufort Seas, July–November 2007: 90-day report. LGL Rep. P969-1. Rep. from 

LGL Alaska Research Associates Inc., LGL Ltd., and JASCO Research Ltd. for Shell Offshore 

Inc., National Marine Fisheries Service, and U.S. Fish and Wildlife Service. 218 pp plus 

appendices.

• Ireland, D.S., D.W. Funk., R. Rodrigues, and W.R. Koski (eds.), 2009. Joint Monitoring Program 

in the Chukchi and Beaufort seas, open water seasons, 2006–2007. LGL Alaska Report P971–2, 

Report from LGL Alaska Research Associates, Inc., Anchorage, AK, LGL Ltd., environmental 

research associates, King City, Ont., JASCO Research, Ltd., Victoria, BC, and Greeneridge 

Sciences, Inc., Santa Barbara, CA, for Shell Offshore, Inc., Anchorage, AK, ConocoPhillips 

Alaska, Inc., Anchorage, AK, and the National Marine Fisheries Service, Silver Springs, MD, and 

the U.S. Fish and Wildlife Service, Anchorage, AK. 485 p. plus Appendices.

• Ireland, D.S., R. Rodrigues, D. Funk, W. Koski, D. Hannay. (eds.) 2009. Marine mammal 

monitoring and mitigation during open water seismic exploration by Shell Offshore Inc. in the 

Chukchi and Beaufort Seas, July–October 2008: 90-day report. LGL Rep. P1049-1. Rep. from 

LGL Alaska Research Associates Inc., LGL Ltd., and JASCO Research Ltd. for Shell Offshore 

Inc., National Marine Fisheries Service, and U.S. Fish and Wildlife Service. 277 pp, plus 

appendices.

• LGL Alaska Research Associates, Inc., JASCO Applied Sciences, Inc., and Greeneridge 

Sciences, Inc. 2013. Joint Monitoring Program in the Chukchi and Beaufort Seas, 2012. LGL 

Alaska Report P1272-2 for Shell Offshore, Inc. ION Geophysical, Inc., and Other Industry 

Contributors, National Marine Fisheries Service, and U.S. Fish and Wildlife Service. 320 p. plus 

Appendices.

• LGL Draft Rep. P891-1. Rep. from LGL Alaska Research Associates Inc., Anchorage, AK, LGL 

Ltd., King City, Ont., and Greeneridge Sciences Inc., Goleta, CA, for Shell Offshore Inc., 

Houston, TX, and National Marine Fisheries Service, Silver Spring, MD. 199 p.

• Patterson, H., S.B. Blackwell, B. Haley, A. Hunter, M. Jankowski, R. Rodrigues, D. Ireland and 

D. W. Funk. 2007. Marine mammal monitoring and mitigation during open water seismic 

exploration by Shell Offshore Inc. in the Chukchi and Beaufort Seas, July–September 2006: 90-

day report. 
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• Reiser, C. M, D. W. Funk, R. Rodrigues, and D. Hannay. (eds.) 2010. Marine mammal 

monitoring and mitigation during open water seismic exploration by Shell Offshore, Inc. in the 

Alaskan Chukchi Sea, July–October 2009: 90-day report. LGL Rep. P1112-1. Rep. from LGL 

Alaska Research Associates Inc. and JASCO Research Ltd. for Shell Offshore Inc., National

Marine Fisheries Service, and U.S. Fish and Wildlife Service. 104 pp, plus appendices.

• Reiser, C.M, D.W. Funk, R. Rodrigues, and D. Hannay. (eds.) 2011. Marine mammal monitoring 

and mitigation during marine geophysical surveys by Shell Offshore, Inc. in the Alaskan Chukchi 

and Beaufort seas, July–October 2010: 90-day report. LGL Rep. P1171E–1. Rep. from LGL 

Alaska Research Associates Inc., Anchorage, AK, and JASCO Applied Sciences, Victoria, BC 

for Shell Offshore Inc., Houston, TX, National Marine Fisheries Service, Silver Spring, MD, and 

U.S. Fish and Wildlife Service, Anchorage, AK. 240 pp, plus appendices.

• Bisson, L.N., H.J. Reider, H.M. Patterson, M. Austin, J.R. Brandon, T. Thomas, and M.L. 

Bourdon. 2013. Marine mammal monitoring and mitigation during exploratory drilling by Shell 

in the Alaskan Chukchi and Beaufort Seas, July–November 2012: Draft 90-Day Report. D.W. 

Funk, C.M. Reiser, and W.R. Koski, editors. LGL Rep. P1272D–1. Rep. from LGL Alaska 

Research Associates Inc., Anchorage, AK, USA, and JASCO Applied Sciences, Victoria, BC, 

Canada, for Shell Offshore Inc., Houston, TX, USA, National Marine Fisheries Service, Silver 

Spring, MD, USA, U.S. Fish and Wildlife Service, Anchorage, AK, USA. 266 pp, plus 

appendices.

• Reider, H.J., L.N. Bisson, M. Austin, A. McCrodan. J. Wladichuk, C.M. Reiser, K.B. Matthews, 

J.R. Brandon, K. Leonard, and H.M. Patterson. 2013. Marine mammal monitoring and mitigation 

during Shell’s activities in the Chukchi Sea, July–September 2013: 90-Day Report. LGL Report 

P1272D–2. Report from LGL Alaska Research Associates Inc., Anchorage, AK, USA, and 

JASCO Applied Sciences, Victoria, BC, Canada, for Shell Gulf of Mexico, Houston, TX, USA, 

National Marine Fisheries Service, Silver Spring, MD, USA, and U.S. Fish and Wildlife Service, 

Anchorage, AK, USA. 198 pp, plus appendices.

b) Physical Environment Reports

Archaeological Assessments

Shell has conducted shallow hazards surveys at the six drill sites. Archaeological resource assessments 

were conducted for each drill site based on geophysical data collected during the surveys. The shallow 

hazards survey reports and archaeological assessments have been submitted to BOEM under separate 

cover as listed below.

• Fugro GeoConsulting, Inc. 2010a. Shallow Hazards and Archaeological Assessment Burger Site 

Survey 1 OCS Lease Sale 193 area Chukchi Sea, Alaska. Report No. 27.2009-2327 V. 1 & 2, 

prepared by Fugro GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

• Fugro GeoConsulting, Inc. 2010b. Drill Site Clearance Letter Proposed Burger A Drill Site Block 

6764 OCS-Y-2280 Posey Area, Chukchi Sea, Alaska. Report No. 27.2010-2375-1 prepared by Fugro 

GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

• Fugro GeoConsulting, Inc. 2010c. Drill Site Clearance Letter Proposed Burger F Drill Site Block 

6714 OCS-Y-2267 Posey Area, Chukchi Sea, Alaska. Report No. 27.2010-2375-3 prepared by Fugro 

GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

• Fugro GeoConsulting, Inc. 2010d. Drill Site Clearance Letter Proposed Burger S Drill Site Block 

6762 OCS-Y-2278 Posey Area, Chukchi Sea, Alaska. Report No. 27.2010-2375-4 prepared by Fugro 

GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.
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• Fugro GeoConsulting, Inc. 2010e. Shallow Hazards and Archaeological Assessment Burger Site 

Survey 3 OCS Lease Sale 193 area Chukchi Sea, Alaska. Report No. 27.2010-2342 V. 1 & 2, 

prepared by Fugro GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

• Fugro GeoConsulting, Inc. 2010f. Drill Site Clearance Letter Proposed Burger V Drill Site Block 

6915 OCS-Y-2324 Posey Area, Chukchi Sea, Alaska. Report No. 27.2010-2375-6 prepared by Fugro 

GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

• Fugro GeoConsulting, Inc. 2011a. Shallow Hazards and Archaeological Assessment Burger Site 

Survey 4 OCS Lease Sale 193 area Chukchi Sea, Alaska. Report No. 27.2010-2343 prepared by 

Fugro GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

• Fugro GeoConsulting, Inc. 2011b. Drill Site Clearance Letter Proposed Burger R Drill Site Block 

6812 OCS-Y-2294 Posey Area, Chukchi Sea, Alaska. Report No. 27.2010-2375-7 prepared by Fugro 

GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

• Geoscience Earth & Marine Services (GEMS), Inc. 2009. Shallow Hazards and Archeological 

Assessment, Burger J Drill Site Posey Block NR03-02 6912, Chukchi Sea, Alaska. Prepared by 

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

Results of the shallow hazards surveys are summarized in Section 3.0 of the Proprietary version of EP 

Revision 2. The results of the archaeological assessments are discussed below and in more detail in 

Section 3.0 of the EIA (Appendix C) and in the shallow hazards and archaeological assessment reports for 

Burger J Site Survey (GEMS 2009), Site Survey 1 (Fugro GeoConsulting, Inc. 2010a), Site Survey 3 

(Fugro GeoConsulting, Inc. 2010e), and Site Survey 4 (Fugro GeoConsulting, Inc. 2011a).

None of the EP blocks for this EP Revision 2 or drill sites are located in areas that BOEM has identified 

as having high potential for occurrence of historic archaeological resources. No potential archaeological 

resources were identified at or near the Burger A, F, J, R, S, or V drill sites. No facilities, shipwrecks, 

significant debris, or other man-made seafloor obstructions were detected during the shallow hazards 

surveys. The only man-made object around the proposed sites is the legacy Burger #1 well and wet stored 

anchors at Burger A set in 2012. The legacy Burger #1 well was drilled in 1989-1990 in Posey Area 

Block 6814 (Figure 3.0-2 of the Proprietary version of EP Revision 2). The historic well was plugged and 

abandoned in 1990, with all surface wellhead equipment contained well below the seafloor at the bottom 

of the MLC. None of the observed unidentified side-scan sonar contacts and unidentified magnetic 

anomalies is believed to be of archaeological significance. Fugro GeoConsulting Inc. (2011a) recognized 

a cluster of seven unidentified magnetic anomalies in the southern portion of Burger Site Survey 4 and 

thought that they could represent debris of unknown origin and recommended they be avoided. The seven 

magnetic anomalies are outside the planned drill site area (Burger R drill site) and thus will be avoided. 

All of the side-scan sonar contacts and magnetic anomalies will be avoided during the exploration drilling 

operations.

All the EP blocks and drill sites are located in water depths of less than 200 ft. (60 m), which is generally 

considered to be the low stand of sea level approximately 13,000 years before present (YBP). Recent 

research in the Bering Sea suggests that the sea level was about 164 ft. (50 m) lower than present 

approximately 11,000 years ago. Between 9,000 YBP and 7,500 YBP the sea level rose from 

approximately 144 ft. (44 m) to 59 ft. (18 m) lower than present (GEMS 2009). These rising marine 

waters would have inundated all of the planned drill site locations on the Burger Prospect. Early humans 

could have traversed presently inundated areas within the planned drill sites up until about 9,000 YBP; 

therefore, these areas, which were sub-aerially exposed prior to 9,000 YBP, could hold prehistoric 

archaeological resources. Such resources are most likely to occur along relict terrestrial landforms such as 

preserved levees or terraces associated with paleo-river channels or shorelines.

Pleistocene buried channels have been identified in the area of the Burger A, F, and S drill sites. In all 

three of these cases, the possible levees that might have been constructed on the sides of these subsurface 
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channel features have likely been eroded during the last sea-level rise, and covered in turn by Holocene 

aged materials, thus the possibility of preserved archaeologically significant sites has been decreased and 

the potential for disturbance of any such sites by exploration drilling operations is very low. No 

Pleistocene channels were identified near the Burger J, R, and V drill sites. Both Fugro and GEMS 

concluded that the potential for the occurrence and preservation of both prehistoric and historic cultural 

resources at the identified Burger A, F, J, R, S, and V drill sites is very low.

Other Studies of the Physical Environment

Shell participated in the funding of a number of other types of baseline studies in 2008 through 2013 as 

part of a multi-faceted study to gather data regarding resources in the project area, and Shell is continuing

these studies. The study focused on a 30 x 30 nmi study area (56 x 56 km) encompassing Shell’s Burger 

Prospect. The data collected during the course of these programs were used in the EIA. Final reports are 

currently available for the following:

• Physical oceanographic measurements in the Klondike and Burger survey area of the Chukchi Sea: 

2008 and 2009 (Weingartner and Danielson 2010)

• Environmental studies in the Chukchi Sea 2008: chemical characterization (Neff et al. 2010)

• Chukchi Sea environmental studies baseline program: 2009 fish sampling chemistry results 

(Exponent 2010)

• Physical Oceanographic Measurements in the Northeastern Chukchi Sea: 2012 (Weingartner et al. 

2013)

• Seasonal Observations of carbonate chemistry and ocean acidification in 2012 (Mathis 2013)

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

Burger in 2008-2013 as described above. Shell:

• Deployed meteorological buoys (including wave and current sensors) in the Chukchi Sea near the 

Burger Prospect from 2008 through 2012 (a buoy was not placed at the Burger Prospect in 2013 due 

to ice but a buoy was placed at the Popcorn and Crackerjack Prospects) and plans to continue to 

deploy these buoys yearly.

• Deployed an acoustical wave and current meter in the Chukchi Sea near the Burger Prospect in 2008-

2010; no current plans to continue this deployment of this particular instrument. However, Shell 

continues to deploy a seafloor mooring capable of measuring waves and currents at the site.

Shell intends to reestablish a meteorological and air quality monitoring station at Wainwright. Data have

been collected and reported for November 2008 through December 2013 in the following reports, which 

indicate that measured concentrations of air pollutants are well below National Ambient Air Quality 

Standards (NAAQS).

• AECOM, Inc. 2009a. Wainwright near-term ambient air quality monitoring program first quarter data 

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

for ConocoPhillips Alaska, Inc., Anchorage, AK.

• AECOM, Inc. 2009b. Wainwright near-term ambient air quality monitoring program second quarter 

data report February through April 2009 final. Document No. 01865-104-3220 prepared by AECOM, 

Inc., for ConocoPhillips Alaska, Inc., Anchorage, AK.

• AECOM, Inc. 2009c. Wainwright near-term ambient air quality monitoring program third quarter 

data report May through July 2009 final. Document No. 01865-104-3230 prepared by AECOM, Inc., 

for ConocoPhillips Alaska, Inc., Anchorage, AK.
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• AECOM, Inc. 2009d. Wainwright near-term ambient air quality monitoring program fourth quarter 

data report August through October 2009 final. Document No. 60136620-3240 prepared by AECOM, 

Inc., for ConocoPhillips Alaska, Inc., Anchorage, AK.

• AECOM, Inc. 2010a. Wainwright near-term ambient air quality monitoring program annual data 

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

for ConocoPhillips Alaska, Inc., Anchorage, AK.

• AECOM, Inc. 2010b. Wainwright permanent ambient air quality monitoring program first quarter 

data report January through March 2010 final. Unpublished report prepared by AECOM, Inc., for 

ConocoPhillips Alaska, Inc., Anchorage, AK.

• AECOM, Inc. 2010c. Wainwright permanent ambient air quality monitoring program second quarter 

data report April through June 2010 draft. Unpublished report prepared by AECOM, Inc., for 

ConocoPhillips Alaska, Inc., Anchorage, AK.

• AECOM, Inc. 2010d. Wainwright permanent ambient air quality monitoring program third quarter 

data report July through September 2010 draft. Unpublished report prepared by AECOM, Inc., for 

ConocoPhillips Alaska, Inc., Anchorage, AK.

• AECOM, Inc. 2011a. Wainwright permanent ambient air quality monitoring program fourth quarter 

data report October through December 2010 draft. Unpublished report prepared by AECOM, Inc., for 

ConocoPhillips Alaska, Inc., Anchorage, AK.

• AECOM, Inc. 2011b. Wainwright permanent ambient air quality monitoring program annual data 

report January 2010 through December 2010 final. Unpublished report prepared by AECOM, Inc. for 

ConocoPhillips Alaska, Inc. Anchorage, AK.

• SLR International Corp. 2013a. Wainwright permanent ambient air quality monitoring program 

annual data report January 2012 through December 2012 final. Unpublished report prepared by SLR 

International Corp. for ConocoPhillips Alaska, Inc. Anchorage, Alaska.

• SLR International Corp. 2013b. Wainwright permanent ambient air quality monitoring program 

quarterly data report January 2013 through March 2013 final. Unpublished report prepared by SLR 

International Corp. for ConocoPhillips Alaska, Inc. Anchorage, Alaska.

• SLR International Corp. 2013c. Wainwright permanent ambient air quality monitoring program 

quarterly data report April 2013 through June 2013 final. Unpublished report prepared by SLR 

International Corp. for ConocoPhillips Alaska, Inc. Anchorage, Alaska.

• SLR International Corp. 2013d. Wainwright permanent ambient air quality monitoring program 

quarterly data report July 2013 through September 2013 final. Unpublished report prepared by SLR 

International Corp. for ConocoPhillips Alaska, Inc. Anchorage, Alaska.

Meteorological and air quality data were also collected at Point Lay as detailed in the following reports:

• Point Lay Comprehensive Ambient Air and Meteorological Monitoring Program, Annual Data 

Summary for June 1, 2010 – May 31, 2011. Unpublished report by SLR Consulting, Inc. for Shell 

Offshore Inc., Anchorage, Alaska, Sep. 2011 (SLR 2011).

• 2012 Annual Data Report, Point Lay Comprehensive Ambient Air and Meteorological Monitoring 

Program, Jan. 1 – Dec. 31, 2012. Unpublished report by SLR Consulting, Inc. for Shell Gulf of 

Mexico Inc., Anchorage, Alaska, Feb. 2013 (SLR 2013b).

• 2013 Annual Data Report, Point Lay Comprehensive Ambient Air and Meteorological Monitoring 

Program, Jan. 1 – Dec. 31, 2013. Unpublished report by SLR Consulting, Inc. for Shell Gulf of 

Mexico Inc., Anchorage, Alaska, Feb. 2014 (SLR 2014).
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c) Socioeconomic Study Reports

Shell continues with its Plan of Cooperation (POC) meetings, as required by the National Marine 

Fisheries Service (NMFS), USFWS and BOEM in order to gather comments and questions and to address 

the concerns of the communities that are potentially affected by the planned exploration drilling program.

In addition, Shell offers several programs that involve the training and subsequent hiring of local 

residents. Programs include the following:

• Protected Species Observer (PSO) Program: The PSO program involves intensive training for marine 

mammal identification and documentation, computer use, and health and safety. Some PSOs are 

recruited locally from North Slope communities to work during exploration drilling activities, 

including the planned exploration drilling program. 

• Subsistence Advisor (SA) Program: In the SA program, potentially affected villages are represented 

by one of its residents to relay subsistence information and issues to Shell. The SA speaks with other 

village members and documents subsistence information. This information may then be integrated 

into Shell’s exploration drilling program.

• Community Liaison Officer (CLO) Program: The CLO program plans to include community liaisons 

in Wainwright, Point Hope, Point Lay, Barrow, Kaktovik, Nuiqsut, Kotzebue, Nome, and Dutch 

Harbor that serve as Shell’s point of contact for questions regarding Shell activities and programs in 

the area.

• Cultural Awareness Program: Shell and contractor personnel involved in field operations (i.e., 

deployed north of Fairbanks, either onshore or offshore) during the planned exploration drilling 

program will attend an initial and annual refresher orientation, 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 regarding 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 program is discussed in more detail in 

Section 11.

Shell collected information on the use of coastal areas along the Chukchi Sea for subsistence through its 

SA Program. Data were collected through a number of person-to-person interviews. Subsistence users 

from Barrow, Wainwright, Point Lay, and Point Hope were interviewed. Reports were prepared 

summarizing and mapping the results of these interviews.

The following Arctic Slope Regional Corporation (ASRC) Energy Services (2009, 2010) and UMIAQ 

(2011, 2012, 2013 and 2014) SA reports were previously submitted to BOEM.

• ASRC Energy Services. 2009. Subsistence advisor program summary, North Slope, Alaska. Report 

prepared for Shell Exploration and Production Company, Houston, TX by ASRC Energy Services, 

Anchorage, AK.

• ASRC Energy Services. 2010. 2009 Subsistence Advisor Program Annual Summary North Slope, 

Alaska. Prepared for Shell Exploration and Production Company. Anchorage, AK by ASRC Energy 

Services, Anchorage, AK. December 2009.

• UMIAQ. 2011. 2010 Subsistence advisor program North Slope, Alaska. Report prepared by UMIAQ, 

Anchorage, AK for Shell Exploration & Production Company, Anchorage, AK.

• UMIAQ. 2012. 2011 Subsistence advisor program North Slope, Alaska. Report prepared by UMIAQ, 

Anchorage, AK for Shell Exploration & Production Company, Anchorage, AK.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 5-9 March 2015

Revision 2

• UMIAQ. 2013. 2012 Subsistence advisor program North Slope, Alaska. Report prepared by UMIAQ, 

Anchorage, AK for Shell Exploration & Production Company, Anchorage, AK.

• UMIAQ. 2014. 2013 Subsistence advisor program North Slope, Alaska. Report prepared by UMIAQ, 

Anchorage, AK for Shell Exploration & Production Company, Anchorage, AK.

Shell conducted interviews with residents of Barrow, Wainwright, Point Lay, and Point Hope to 

supplement existing formal environmental and resource data for the Chukchi Sea coastline. Data collected 

pertained to hunting, fishing, land use, and coastal processes such as erosion, ice movement and melting, 

and coastal dynamics. A report was prepared summarizing and mapping the results of these interviews. 

The report (Sound Enterprises and Associates, LLC 2008) has been submitted to the BOEM. Results of 

these interviews were used in the preparation of the EIA (Appendix C).

• Sound Enterprises and Associates, LLC. 2008. Shell Exploration & Production Company (SEPCO) 

Chukchi Village interview program. Report prepared for Shell Exploration and Production Company 

Houston, TX by Sound Enterprises, LLC, Bainbridge, WA.

Shell also conducted an economic analysis of future oil and gas exploration and development in the 

Beaufort Sea, Chukchi Sea, and North Aleutian Basin. The results (Northern Economics 2009, Northern 

Economics, Inc. and Institute of Social and Economic Research 2011) of the analyses have been 

presented to BOEM and were used in preparation of the EIA, where summaries can be found.

• Northern Economics Inc. 2009. Economic analysis of future offshore oil and gas development: 

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

Anchorage Alaska for Shell Exploration and Production, Houston, TX.

• Northern Economics, Inc. and Institute of Social and Economic Research. 2011. Potential NationalLevel Benefits of Alaska OCS Development. Report prepared by Northern Economics, Inc. and 

Institute of Social and Economic Research, Anchorage, AK for Shell Exploration & Production, 

Anchorage, AK.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 6-1 March 2015

Revision 2

SECTION 6.0 SOLID AND LIQUID WASTE AND DISCHARGE 

INFORMATION

a) Projected Generated Wastes

The type, composition, and amount of solid and liquid waste projected to be generated on the drilling 

units during the planned exploration drilling program at the planned drill sites are listed below. Waste and 

discharge volumes were calculated based on empirical information and past experience; therefore, the 

actual generated amounts and ocean discharge volumes may differ from these projections.

b) Ocean Discharges and Disposal Methods

The type, composition, and amount of solid and liquid waste projected to be generated on the drilling 

units during the planned exploration drilling program and discharged to the ocean are listed below in 

Tables 6.b-1 and 6.b-2. Regarding Table 6.b-1, drilling fluids and cuttings can be further divided into the 

following six drilling intervals, as noted in the EIA (Appendix C), based on the section of the well being 

drilled:

• Interval 1 – MLC (and ramp if the MLC ROV System is used) (discharged at the seafloor)

• Interval 2 – conductor casing (discharged at the seafloor)

• Interval 3 – surface casing (discharged at the seafloor)

• Interval 4 – intermediate casing (discharged near the surface)

• Interval 5 – drilling liner (discharged near the surface)

• Interval 6 – open hole (discharged near the surface)

NPDES exploration facilities GP AKG-28-8100 discharge 013 (D013) includes the discharges from 

intervals 1 through 3, and discharge 001(D001) includes the discharges from intervals 4 through 6.

The ocean discharge information has been submitted to the EPA to support NOIs for authorization to 

conduct these discharges under NPDES exploration facilities GP AKG-28-8100. The projected wastes 

and discharges listed in these tables are applicable only to the drilling units. Discharges from support 

vessels will be made pursuant to the International Convention for the Prevention of Pollution from Ships 

(Marine Pollution or International Convention for the Prevention of Pollution from Ships [MARPOL]) 

standards and requirements as well as the NPDES Vessel GP.

Additional details regarding the transportation and final disposal location for wastes that will not be 

discharged to the ocean (Table 6.b-3) are provided in Section 13.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 6-2 March 2015

Revision 2

Table 6.b-1 NPDES Exploration Facilities GP Waste Streams Generated During Drilling

NPDES GP Discharge 

No. and Composition

Discharge 

Location

Projected 

Discharge Rate Projected Season Volume Disposal

D0011

Water-based drilling 

fluids and drill cuttings 

(Intervals 4 - 6)

Burger A 81 bbl/hr. while 

drilling;

1000 bbl/hr. for 

reserve pit 

volume

Cuttings - 1,052 bbl

Fluids – 6,231 bbl

Total while drilling – 7,283 bbl

Reserve pit fluid volume –2,427 bbl 

Total with reserve – 9,710 bbl

Discharged to the 

ocean through a 

disposal caisson 

Burger F 80 bbl/hr. while 

drilling;

1000 bbl/hr. for 

reserve pit 

volume

Cuttings - 1,043 bbl 

Fluids – 6,184 bbl

Total while drilling – 7,227 bbl

Reserve pit fluid volume – 2,427 bbl 

Total with reserve – 9,654 bbl

Discharged to the 

ocean through a 

disposal caisson 

Burger J 72 bbl/hr. while 

drilling;

1000 bbl/hr. for 

reserve pit 

volume

Cuttings – 915 bbl 

Fluids – 5,546 bbl

Total while drilling – 6,461 bbl

Reserve pit fluid volume –2,427 bbl 

Total with reserve – 8,888 bbl

Discharged to the 

ocean through a 

disposal caisson 

Burger R 83 bbl/hr. while 

drilling;

1000 bbl/hr. for 

reserve pit 

volume

Cuttings - 1,077 bbl

Fluids – 6,352 bbl

Total while drilling – 7,429 bbl

Reserve pit fluid volume –2,427 bbl 

Total with reserve – 9,856 bbl

Discharged to the 

ocean through a 

disposal caisson 

Burger S 82 bbl/hr. while 

drilling;

1000 bbl/hr. for 

reserve pit 

volume

Cuttings - 1,074 bbl

Fluids – 6,340 bbl

Total while drilling – 7,414 bbl

Reserve pit fluid volume – 2,427 bbl

Total with reserve – 9,841 bbl

Discharged to the 

ocean through a 

disposal caisson 

Burger V 88 bbl/hr. while 

drilling;

1000 bbl/hr. for 

reserve pit 

volume

Cuttings - 1,153 bbl

Fluids – 6,736 bbl

Total while drilling – 7,889 bbl

Reserve pit fluid volume – 2,427 bbl

Total with reserve – 10,316 bbl

Discharged to the 

ocean through a 

disposal caisson 

D012

Excess cement slurry 

(rinsate from cement 

tank)

Each drill 

site

5 bbl/casing 

string and when 

setting plugs

Discoverer - 45 bbl Discharged to the 

ocean through a 

disposal caisson

5 bbl/casing 

string and when 

setting plugs

Polar Pioneer – 45 bbl

D0132,3

Muds, cuttings, cement 

at the seafloor 

(Intervals 1 - 3)

Burger A 47.4 bbl/hr. 

while drilling

Estimated at 5,007 bbl (this section 

completed in 2012)

Discharged at the 

ocean floor

Burger F 77 bbl/hr. while 

drilling

MLC Cuttings – 3,703 bbl;

Conductor and Surface Casing Cuttings –

1,303 bbl; 

Fluids – 3,124 bbl; 

Cement - 45 bbl;

Total while drilling using MLC bit –

8,175 bbl

Discharged at the 

ocean floor

162 bbl/hr. MLC cuttings only if using the MLC ROV 

system4 – 27,197 bbl

Discharged at the 

ocean floor
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 6-3 March 2015

Revision 2

Table 6.b-1 NPDES Exploration Facilities GP Waste Streams Generated During Drilling

NPDES GP Discharge 

No. and Composition

Discharge 

Location

Projected 

Discharge Rate Projected Season Volume Disposal

D0132,3

Muds, cuttings, cement 

at the seafloor 

(Intervals 1- 3)

Burger J 79 bbl/hr. while 

drilling

MLC Cuttings – 3,703 bbl

Conductor and Surface Casing Cuttings –

1,386 bbl; 

Fluids – 3,207 bbl; 

Cement - 45 bbl; 

Total while drilling using MLC bit –

8,341 bbl

Discharged at the 

ocean floor

162 bbl/hr. MLC cuttings only if using the MLC ROV 

system4– 27,197 bbl

Discharged at the 

ocean floor

Burger R 77 bbl/hr. while 

drilling

MLC Cuttings – 3,703;

Conductor and Surface Casing Cuttings –

1,300 bbl; 

Fluids – 3,121 bbl; 

Cement - 45 bbl;

Total while drilling using MLC bit –

8,169 bbl

Discharged at the 

ocean floor

162 bbl/hr. MLC cuttings only if using the MLC ROV 

system4– 27,197 bbl

Discharged at the 

ocean floor

Burger S 77 bbl/hr. while 

drilling

MLC Cuttings – 3,703;

Conductor and Surface Casing Cuttings –

1,302 bbl; 

Fluids – 3,123 bbl; 

Cement - 45 bbl;

Total while drilling using MLC bit –

8,173 bbl

Discharged at the 

ocean floor

162 bbl/hr. MLC cuttings only if using the MLC ROV 

system4– 27,197bbl

Discharged at the 

ocean floor

Burger V 79 bbl/hr. while 

drilling

MLC Cuttings – 3,703;

Conductor and Surface Casing Cuttings –

1,386 bbl; 

Fluids – 3,207 bbl; 

Cement - 45 bbl;

Total while drilling using MLC bit –

8,341 bbl

Discharged at the 

ocean floor

162 bbl/hr. MLC cuttings only if using the MLC ROV 

system4– 27,197 bbl

Discharged at the 

ocean floor 1 Estimated time to drill these bottomhole sections is 90 hr. drilling time (does not include non-drilling time) 2 Estimated time to drill these tophole sections is 106 hr. drilling time (does not include non-drilling time). Reserve pit volume (2,427 bbl) is for the Polar 

Pioneer; the Discoverer has a reserve pit volume of 1,500 bbl. This table assumes the greatest possible pit volume will be discharged. The EIA (Appendix 

C) also assumes the larger pit volume in its analyses. 3 MLC construction time using the MLC ROV system is estimated at 168 hr. 4 MLC ROV system cuttings volumes and rates are only for the potential construction of the MLC using this technology; MLC ROV system is not capable 

of drilling the conductor and surface casing sections
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 6-4 March 2015

Revision 2

Table 6.b-2 NPDES Exploration Facilities GP Waste Streams Generated Daily

Type of Waste

NPDES GP 

Discharge

Composition Projected 

Discharge Rate

Projected Season 

Volume1

Treatment, Storage, and 

Disposal

D002

Deck Drainage

Uncontaminated 

fresh or seawater

Discoverer – 33 bbl/day 3,960 bbl Uncontaminated water discharged 

overboard; contaminated water is 

treated in an oil-water separator

(OWS); oily water stored aboard, 

transported by boat to approved 

treatment/disposal/storage (TDS) 

site

Polar Pioneer - 70 bbl/day 8,400 bbl Uncontaminated water discharged 

overboard; contaminated water is 

treated in an OWS; oily water 

stored aboard, transported by boat 

to approved TDS site

D003

Sanitary Wastes

Black water Discoverer – 29.5 bbl/day 

discharge (based on 124 

persons; 10 gallons 

[gal]/person/day)

3,540 bbl Discharged through disposal 

caisson after treatment in a 

marine sanitation device

Polar Pioneer – 14.3 

bbl/day (based on 114 

persons; 5.3 

gal/person/day)

1,716 bbl

D004

Domestic 

Wastes

Gray water 

(laundry, galley, 

lavatory)

Discoverer - 295 bbl/day 

discharge (based on 124 

persons)

35,400 bbl Discharged through disposal 

caisson 

Polar Pioneer - 271 

bbl/day (based on 114 

persons)

32,520 bbl

D005

Desalination 

Unit Wastes

Rejected water from 

watermaker unit

Discoverer - 1,742 bbl/day 209,040 bbl Discharged through disposal 

Polar Pioneer - 377 caisson 

bbl/day

45,286 bbl

D006

BOP Fluid

Freshwater, 

concentrate and 

monoethylene 

glycol 

Discoverer - 16.6 bbl/test 150 bbl (based 

on 3 function 

tests, 3 pressure 

test and 3 

retests)

Discharged to the ocean

Polar Pioneer - 20 bbl/test 180 bbl (based 

on 3 function 

tests, 3 pressure 

test and 3 

retests)

D007

Boiler 

Blowdown

Water and minerals 

drained from boiler 

drums

Discoverer - 1.3 bbl/day 151 bbl Discharged through disposal 

caisson 

Polar Pioneer - 6 bbl/day 754 bbl Discharged directly overboard

D008

Fire Control 

System Test 

Water

Uncontaminated 

seawater

Discoverer - 36 bbl/test

(tested weekly)

607 bbl Discharged directly overboard

Polar Pioneer - 36 bbl/test

(tested monthly)

607 bbl
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 6-5 March 2015

Revision 2

Table 6.b-2 NPDES Exploration Facilities GP Waste Streams Generated Daily

Type of Waste

NPDES GP 

Discharge

Composition Projected 

Discharge Rate

Projected Season 

Volume1

Treatment, Storage, and 

Disposal

D009

Non-contact 

cooling water

Uncontaminated 

seawater

Discoverer – 107,314 

bbl/day discharge while 

drilling; 55,200 bbl/day 

discharge while not drilling

Range of 

6,624,000 –

12,877,680 bbl

Discharged overboard to ocean 

waters at several sites around the 

hull

Polar Pioneer –

21,385 bbl/day

2,566,240 bbl Discharged to ocean through a 

number of outlets 

D010

Uncontaminated 

ballast water

Uncontaminated 

seawater

Discoverer – variable 37,915 bbl Discharged through disposal 

Polar Pioneer – caisson 

719 bbl/day plus 

85,655 bbl when the 

drilling unit is moved

171,935 bbl 

D011

Bilge water

Seawater that 

collects in internal 

parts of the drilling 

vessel hull

Discoverer - 754 bbl/day 90,514 bbl Treated in OWS, uncontaminated 

water discharged through disposal 

caisson, oily water stored aboard, 

transported by boat to approved 

TDS site

Polar Pioneer -

714 bbl/day

85,714 bbl

1 Based on an assumed drilling season of approximately 120 days
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 6-6 March 2015

Revision 2

Table 6.b-3 Wastes Generated on the Drilling Units that are not Discharged*

Type of Waste Composition Projected Generated 

Amount Treatment / Storage/ Disposal

Household Trash Refuse generated through 

domestic living activities

(includes food wastes).

8,500 lb./month/drilling 

unit stored and 

transported for 

disposal;

6,000 lb./month/drilling 

unit incinerated 

onboard - resulting ash 

weight of 200 lb.

included in nonhazardous waste 

monthly total

Not discharged to ocean waters; burned 

in on-board incinerator or stored aboard 

in approved waste containers until 

removed at port and transferred to an 

approved TDS site 

Non-Hazardous 

Waste

(solid and liquid)

Non-hazardous waste 

liquids and solids such as 

used oils, oily rags, vessel 

slops; incinerator ash; steel 

(to be recycled); generated 

through vessel cleaning, 

maintenance and drilling 

operations.

62,500 

lb./month/drilling unit

Not discharged to ocean waters; stored 

aboard in approved waste containers 

until removed at port and transferred to 

an approved TDS site

Hazardous Waste

(Conditionally 

Exempt Small 

Quantity Generator 

[CESQG])

Expired or spent chemicals 

left over from cleaning, 

maintenance and drilling 

operations. 

50 lb./month/drilling 

unit (CESQG status is 

anticipated)

Not discharged to ocean waters; stored 

aboard in approved UN rated waste 

containers until removed at port and 

transferred to an approved TDS site

*Solid and hazardous wastes are portrayed differently in this Table 6.b-3 than they were in EP Revision 1. EP Revision 1 reported the nondischarged wastes on a per well basis, measured in barrels. EP Revision 2 reports the non-discharged wastes on a monthly basis, measured in 

pounds.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 6-7 March 2015

Revision 2

c) NPDES Permits

All discharges from the drilling units while anchored at a drill site during the exploration drilling program 

(as itemized above in Tables 6.b-1 and 6.b-2) will be made in accordance with the EPA NPDES 

exploration facilities GP AKG-28-8100. 

Drilling support vessels in excess of 300 gross registered tons or having a ballast capacity of 2,133

gallons (gal) (8 m3

) or greater, must acquire authorization to discharge under the Vessel GP for 

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

Authorizations to discharge under this Vessel GP for discharges incidental to normal operations will be 

undertaken by the vessel owner and/or operator and is not a part of Shell’s required permit and 

authorization application submittals.

Drilling Fluid Products

Products that may be part of the drilling fluid are provided in Tables 6.c-1 and 6.c-2, on a per well basis. 

This component list and the respective volumes have been designed for drilling depth from the MLC to 

PTD.

Table 6.c-1 Drilling Fluid Components for the Upper Portions of the Well (MLC, Conductor and 

Surface-Cased Sections)

Generic Description Product Name Maximum Concentration

BASE FLUID

Biopolymer DUOVIS 5 lb./bbl

Bentonite M-I GEL 35 lb./bbl

Bentonite extender GELEX 0.05 lb./bbl

Polyanionic cellulose Polypac Supreme UL 5 lb./bbl

ADDITIVES

Crushed nut hulls NUT PLUG 20 lb./bbl

CONTINGENCY PRODUCTS

Barite M-I WATE 160 lb./bbl

Defoamer DEFOAM-X 0.3 lb./bbl

Dye Sodium Fluoresceine Green Dye 0.5 gal/bbl in

seawater

Caustic soda stock product 8 lb./bbl

Citric acid stock product 5 lb./bbl

Sodium acid pyrophosphate (SAPP) stock product TBD

Soda ash stock product 13 lb./bbl

Biocide Busan 1060 0.4 lb./bbl

NaCl brine Sodium chloride brine 100 lb./bbl

Hydrogen sulfide scavenger SAFE-SCAV HS 0.1 lb./bbl

Surfactant SCREENKLEEN 2% v/v

Lubricant DRILLZONE 7% v/v
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 6-8 March 2015

Revision 2

Table 6.c-2 Drilling Fluid Components for the lower portions of the well after the riser and BOP 

are established

Generic Description Product Name Maximum Concentration

BASE FLUID

Soda ash stock product 12 lb./bbl

Acrylic polymer IDCAP D 5 lb./bbl

Shale/clay inhibitor EMI-2009 20 lb./bbl

Shale/clay inhibitor KLA-STOP 20 lb./bbl

Biopolymer DUOVIS 2 lb./bbl

Biopolymer Flowzan 2 lb./bbl

Polyanionic cellulose POLYPAC SUPREME UL 5 lb./bbl

Sodium hydroxide Caustic Soda 8 lb./bbl

Barite M-I WATE 160 lb./bbl

Sodium chloride in brine Salt/NaCl 100 lb./bbl

ADDITIVES

Copolymeric shale stabilizer POROSEAL 19 lb./bbl

Deflocculant CF Desco®II 4 lb./bbl

Sodium bicarbonate stock product 10 lb./bbl

Citric acid stock product 4 lb./bbl

Liquid defoamer DEFOAM-X 0.3 lb./bbl

Liquid defoamer DF-9065 0.3 lb./bbl

Crushed nut hulls NUT PLUG MED 40 lb./bbl

Crushed nut hulls NUT PLUG FINE 40 lb./bbl

Vegetable, polymer fiber blend MI SEAL 40 lb./bbl

Cellulose fiber MIX II Fine 25 lb./bbl

Cellulose fiber MIX II MED 25 lb./bbl

Graphite G-SEAL 20 lb./bbl

Calcium carbonate SAFECARB-20 200 lb./bbl

Calcium carbonate SAFECARB-40 200 lb./bbl

Calcium carbonate SAFECARB-250 200 lb./bbl

Sodium chloride stock product 100 lb./bbl

Resinated lignite RESINEX 10 lb./bbl

Sulfonated asphalt ASPHASOL SUPREME 8 lb./bbl

CONTINGENCY PRODUCTS

Mixture FORM-A-BLOK 40 lb./bbl

Cellulose FORM-A-SET AK Formulation pill

H2S Scavenger Sulf-X 2.5 lb./bbl

Biocide Busan 1060 0.4 lb./bbl

Mixture Pipelax ENV WH 4% v/v

Mixture LUBE 945 3% v/v

Mixture CLEAN SPOT 4% v/v

Surfactant SCREENKLEEN 2% v/v

Lubricant DRILLZONE 7% v/v

Mixture SAFE-SCAV HS 0.1 lb./bbl
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 6-9 March 2015

Revision 2

Cement Composition

Two types of cement discharges are expected. One of these discharges involves bulk cement plus 

additives, which are circulated around the conductor and surface casing, and collect in the base of the 

MLC. The cement cures to a hardened mass surrounding the conductor. The second type of cement 

discharge involves small volumes of cement washed from the cement pump and lines on the drilling unit

at the surface after cementing operations. The cement slurry to be discharged to the ocean (Table 6.b-1, 

D012) consists of the following primary components and additives, or their equivalents:

• Type C Permafrost cement

• API Class G “Premium” cement

• Econolite L (fly ash, calcium oxide) in small amounts

• Halad-344EXP (fluid loss additive) in very small amounts

• Calcium sulfate hemihydrate (accelerator) very small amounts

• Sodium chloride (accelerator) in very small amounts

• Calcium chloride (accelerator) in very small amounts

• SCR-100 (sodium citrate retarder) in very small amounts

• Dual Spacer (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 SS 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 (LMRP). The fluid is discharged at the 

device after use rather than bringing it back to the surface in a closed loop system. This reduces backpressure and increases the potential that the devices will function quickly. Only small volumes of BOP 

fluid are discharged within and just above the MLC (or directly to the ocean if a test is done on the 

drilling unit deck prior to installation) which dilute and diffuse quickly in the seawater column. It is 

estimated that nine BOP tests will occur during the drilling of each well for a total of 113 bbl 

(Discoverer) and 180 bbl (Polar Pioneer) of BOP fluid per well (Table 6.b-2, D006). The BOP fluid will 

be a mixture of fresh water (~ 45%), concentrate (~5%) and monoethylene glycol (~50%). The 

concentrates may contain, but not limited to, Stack Magic, Erifon HD603, and/or Pelagic.

d) Modeling Report

All requested exploration facility NPDES permitted discharges will be carried out in federal waters of the 

OCS. No expanded mixing zones or zones of deposit are being requested and no modeling was conducted 

in support of such requests. Shell has carried out modeling of the expected discharges of drill cuttings and 

drilling fluids and of the projected discharges of cooling water for impact assessment purposes. The 

results of these modeling efforts are discussed in Section 4 of the EIA (Appendix C).
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 6-10 March 2015

Revision 2

e) Cooling Water Intake

Discoverer

A saltwater service system supplies the Discoverer’s requirement for saltwater, including that for the 

exploration drilling operations. The system is primarily used to supply cooling water to equipment heat 

exchangers. The amount of seawater that will be used for non-contact cooling water while drilling is 

estimated at 107,314 bbl/day and 55,200 bbl/day discharge while not drilling. This volume includes 

cooling water for hydraulic coolers, air-conditioning coolers and all other cooling water service lines. 

This does not include the seawater volume that would be supplied by the fire water pumps to provide 

firefighting capability in an emergency situation. 

The saltwater service system consists of saltwater pumps, four sea-suctions (each with strainer having 

holes 5 mm in diameter), and associated distribution piping. Screen mesh sizes on the water intakes are 

provided below in Table 6.e-1.

Table 6.e-1 Screen Mesh Size on Water Intakes on the Discoverer

Sea-suction Screen Mesh Size

Pump room 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. per minute (ft./min)

(12.2 m/min).

Polar Pioneer

Non-contact cooling water is supplied to the Polar Pioneer via a general services seawater loop. Seawater 

is pumped from four screened sea chests; located on the inboard side of the Polar Pioneer’s four 

pontoons (Table 6.e-2). The amount of seawater that will be used for non-contact cooling water is 

estimated at 21,385 bbl per day.

Table 6.e-2 Screen Mesh Size on Water Intakes on the Polar Pioneer

Sea-suction Screen Mesh Size

Aft Starboard 0.75 in. (19 mm) Height; 25.75 in. (654 mm) width

Forward Starboard 0.75 in. (19 mm) Height; 25.75 in. (654 mm) width

Aft Port 0.75 in. (19 mm) Height; 25.75 in. (654 mm) width

Forward Port 0.75 in. (19 mm) Height; 25.75 in. (654 mm) width

The calculated velocity of intake water across the screen mesh is calculated to be 0.8 ft./min (0.25 

m/min).
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 7-1 March 2015

Revision 2

SECTION 7.0 AIR EMISSIONS INFORMATION

This section identifies the sources of air emissions and projected emissions from Shell’s EP Revision 2. The 

information presented in this section is supported by detailed emission information in Appendix K, AQRP 

and NEPA Emission Inventories. In accordance with BOEM’s Air Quality Regulatory Program (AQRP) (30 

CFR Part 550, Subpart C), facility-wide maximum projected emissions generated from the proposed 

exploration activities are calculated and compared to the BOEM exemption formulas established in 30 CFR 

550.303(d). Shell includes in this assessment emissions from the Discoverer and Polar Pioneer drilling 

units and all support vessels operating within 25 mi (40 km) of the Discoverer and Polar Pioneer while each 

are anchored at a drill site. The following is a list of the vessel types that are included for the air emissions 

evaluation under 30 CFR 550.303(d):

• Drilling Unit – Discoverer (x1)

• Drilling Unit – Polar Pioneer (x1)

• Ice Management Vessels (x2)

• Anchor handlers (x3)

• OSVs (x2)

• Science Vessels (x2)

• OSRV (x1)

• OSR tug (x1) and barge (x1)

• Support tugs (x2)

• Supply tug (x1; used for support purposes)

• OST (x1)

• MLC ROV system vessel (x1)

As required under 30 CFR 550.224, information on support vessels and aircraft that may be used in the 

exploration drilling program is described in Section 13. Information on the onshore support facilities as 

required under 30 CFR 550.225 is included in Section 14.

a) Projected Emissions

For the BOEM AQRP, an AQRP emissions inventory is provided in Appendix K that includes detailed 

documentation of projected emissions including the basis for all calculations (30 CFR 550.218(a)(2)) 

attributable to operation of the Discoverer, Polar Pioneer and support vessels operating within 25 mi (40 

km) of the drilling units while each are anchored at a drill site. For purposes of evaluating air emissions 

under the AQRP, it is estimated that up to two wells may be drilled per season to complete the six wells in a 

total of three years. Appendix K (Table A-1 of Attachment A) includes peak hourly emissions for the AQRP 

as required under 30 CFR 550.218(a)(1)(i). The peak hourly emissions presented in Table A-1 of 

Attachment A in Appendix K are representative of peak emissions in each of the three years.

Appendix K provides the annual emissions as required by 30 CFR 550.218(a)(1)(ii). Annual emissions are 

based on a maximum 120-day drilling season per year. The information in these tables provides a summary 

of emissions from each source category type for each drilling unit and support vessel. Details on the 

components that contribute to emissions (e.g., propulsion engines, generation engines, boilers, and 

incinerators) as well as the operational assumptions applied in the emission estimates are provided in 

Appendix K. A summary of annual emissions for the AQRP emissions inventory from Appendix K is 

presented in Tables 7.e-1 through 7.e-4 of EP Revision 2.

30 CFR 550.218(a)(1)(iii) requires that “emissions over the duration of the proposed exploration 

activities” be included under the EP. As previously mentioned, Shell estimates it will require three years 
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 7-2 March 2015

Revision 2

to complete the six wells described and the annual/seasonal emissions are provided in Tables 7.e-1 

through 7.e-4. Table 7.a-1 provides the emissions over the duration of the proposed exploration activities 

that are scaled appropriately (three times increase) to reflect the anticipated project duration total 

emissions. The AQRP emissions inventory detailed in Appendix K and summarized in Tables 7.e-1 

through 7.e-4 represents a conservative assessment of Discoverer, Polar Pioneer and support vessels

emissions in any year. 

At this time, Shell cannot distinguish between activities (and air emissions) in one year versus those in 

other years. Consequently, Shell has estimated “Project Duration Total” emissions by assuming the same 

conservative representation of emissions for each of the three seasons.

Table 7.a-1 3-Year Project Duration Emissions (tons) 1

Parameter Discoverer Discoverer and 

Support Vessels Polar Pioneer Polar Pioneer and 

Support Vessels

Carbon Monoxide (CO) 300 1,109 227 1,166

Total Suspended Particulate 

(TSP) 

(particulate matter less than 2.5 

microns [PM2.5] & particulate 

matter less than 10 microns 

[PM10])

47 222 74 238

sulfur dioxide (SO2) 8 33 8 31

nitrogen oxide (NOx) 1,183 4,460 1,444 4,838

volatile organic compound 

(VOC) 67 258 71 274

1 Aggregate emissions are based on rounded annual emissions.

Shell presents a conservative depiction of emissions for the purpose of demonstrating its exemption from the 

AQRP (i.e., the emissions presented overstate what is expected to occur during normal operations). This 

conservative approach is required by 30 CFR 550.218(a)(3), which requires Shell to base the projected 

emissions on the maximum rated capacity of the equipment on the proposed drilling units under its physical 

and operational designs. For example, the AQRP analysis assumes all emission units are operating at the 

same time every hour of the season, which will not occur during normal operation. Further, this analysis, 

includes the Discoverer propulsion engine even though actual operation of the propulsion engine will be 

minimal (if it operates at all) while the drilling unit is completely anchored. Section 2.3 of Appendix K 

provides additional background on the conservative assumptions applied in the AQRP emissions summary.

Appendix K discusses the activity of various emissions units as required by 30 CFR 550.218(a)(1)(iv). As 

further discussed in Appendix K, diesel-fueled engines are the primary source of emissions associated with 

the exploration drilling activity. Analogous to how automobiles are driven, diesel engines are not expected 

to continuously operate at maximum rated power during the proposed exploration activity. In calculating 

emissions for this exemption analysis, Shell conservatively assumed the engines on the Discoverer and 

Polar Pioneer were operating at maximum load, 100 percent of the season. In these calculations, maximum 

load is based on engine nameplate rating, modified by operational limitations established from a 

combination of safety policies and good engine care policies. Such “good engine care policies” are 

implemented by vessel owners and operators to extend equipment life. In practice, maximum continuous 

power ratings of marine engines are typically 10 to 20 percent below “name-plate” power ratings .Thus, in 

calculating emissions for this exemption analysis, the maximum operating rate for each engine is limited to

80 percent of the name-plate rating.
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Shell Gulf of Mexico Inc. 7-3 March 2015

Revision 2

When calculating emissions from engines of the support vessels in order to determine cumulative emissions, 

Shell included fuel restrictions on most of the propulsion and generator engines. For those support vessel 

engines not subject to a fuel restriction, emissions were based on continuous operation all season. As 

discussed in Appendix K, emissions from the smaller engines are based on the same 80 percent power 

operating assumption applied to the drilling rig engines.

Maximum projected uncontrolled emissions are compared to AQRP exemption formula criteria under 

Tables 7.e-1 through 7.e-4.

b) Emission Reduction Measures

Shell employs emission reduction measures on the Discoverer, Polar Pioneer, and on some of the support 

vessels that are candidates for use with the drilling units in the Chukchi Sea. These emission reduction 

measures include the following:

• Procuring ultra-low sulfur diesel (ULSD) fuel or a fuel with equal or lower sulfur content to reduce SO2

emissions for each of the drilling units and all vessels operating as part of the exploration drilling 

program; and

• Establishing fuel restrictions on most of the propulsion and generators engines for the support vessels.

Appendix K provides a summary of the emission reduction measures and resulting emissions reductions, as 

applied in the AQRP analysis. Shell will monitor compliance by obtaining certification documentation of 

fuel sulfur content from fuel terminals and suppliers upon each fueling and by measuring annual fuel 

consumption of the support vessels with fuel restrictions.

Shell has elected to present maximum projected emissions in the AQRP emissions inventory for the 30 CFR 

550.303(d) exemption formula analyses without consideration of existing emission controls on the 

Discoverer’s primary generation units or any of the support vessels as emission reduction measures. These 

emission controls include the following:

• Use of selective catalytic reduction (SCR) emission controls to reduce NOX emissions on Discoverer’s 

primary generation units and certain units on support vessels;

• Use of catalytic diesel particulate filters (CDPF) emission controls to reduce CO, particulate matter 

(PM), and VOC emissions on the Discoverer’s primary generation units and certain units on support 

vessels; and

• Use of oxidation catalysts (OxyCat) emission controls to reduce CO, PM, and VOC emissions on 

certain units on support vessels.

The 30 CFR 550.303(d) exemption analyses in Section 7(e) conservatively assume the emission controls are 

not employed as emission reduction measures. As a result, Shell is not required to operate these controls, but 

is voluntarily committing to do so. Therefore, emissions reductions resulting from the voluntary 

commitment to operate the controls are not quantified in the AQRP emission inventories presented in 

Appendix K and thus no corresponding monitoring is proposed for these emission controls.

c) Processes, Equipment, Fuels, and Combustibles

The Discoverer and Polar Pioneer engines generate electrical, compressed air, and hydraulic energy for 

drilling operations. All other processes are secondary and related to general purpose heating (using 

boilers), transfer of materials about the deck (using cranes), pumping of cement, and incineration 

(primarily domestic waste). All engines on the Discoverer, Polar Pioneer and support vessels will be 

powered by a fuel purchased with sulfur content at or below 15 ppm. Additional descriptions of these 

processes and emissions units are provided in Appendix K.
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Shell Gulf of Mexico Inc. 7-4 March 2015

Revision 2

d) Distance to Shore

The minimum distance from a drill site to the shoreline is 64.7 mi (104 km).

e) Impact from Non-Exempt Drilling Units

As required by 30 CFR 550.218(e), Table 7.e-1 compares projected annual emissions from the Discoverer

with the exemption criteria at 30 CFR 550.303(d). The comparison confirms the exploration program is 

exempt from further air quality review, pursuant to 30 CFR 550.303(d).

Table 7.e-1 Application of BOEM Exemption Formula to the Discoverer

Parameter BOEM formula at 30 

CFR 250.303(d)1

BOEM Exemption 

Threshold 

(Emissions in 

tons/year)

Total Projected

Drilling Unit 

Emissions Discoverer

(tons/year)2

Exempt?

CO E=3400D2/3 54,796 100 Yes

TSP (PM2.5 & PM10) E=33.3D 2,155 16 Yes

SO2 E=33.3D 2,155 3 Yes

NOx E=33.3D 2,155 394 Yes

VOC E=33.3D 2,155 22 Yes 1 D=distance from the closest of the six candidate drill sites to the nearest point of land (Icy Cape) in statute miles (64.7 mi [104 km]) 2 As provided in Appendix K.

Table 7.e-2 compares projected annual emissions from the Discoverer and its support vessels with the 

exemption criteria at 30 CFR 550.303(d). The comparison confirms the exploration program even with 

projected support vessel emissions included, is exempt from further air quality review, pursuant to 30 

CFR 550.303(d).

Table 7.e-2 Application of BOEM Exemption Formula to the Discoverer and Support Vessels

Parameter BOEM formula at 30 

CFR 250.303(d)1

BOEM Exemption 

Threshold 

(Emissions in 

tons/year)

Total Projected 

Emissions Discoverer

and Support Vessels

(tons/year)2

Exempt?

CO E=3400D2/3 54,796 370 Yes

TSP (PM2.5 & PM10) E=33.3D 2,155 74 Yes

SO2 E=33.3D 2,155 11 Yes

NOx E=33.3D 2,155 1,487 Yes

VOC E=33.3D 2,155 86 Yes 1 D=distance from the closest of the six candidate drill sites to the nearest point of land (Icy Cape) in statute miles (64.7 mi [104 km]) 2 As provided in Appendix K.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 7-5 March 2015

Revision 2

Table 7.e-3 compares projected annual emissions from the Polar Pioneer with the exemption criteria at 30 

CFR 550.303(d). The comparison confirms the exploration program is exempt from further air quality 

review, pursuant to 30 CFR 550.303(d).

Table 7.e-3 Application of BOEM Exemption Formula to the Polar Pioneer

Parameter BOEM formula at 30 

CFR 250.303(d) 1

BOEM Exemption 

Threshold 

(Emissions in 

tons/year)

Total Projected 

Drilling Unit 

Emissions Polar 

Pioneer

(tons/year) 2

Exempt?

CO E=3400D2/3 54,796 76 Yes

TSP (PM2.5 & PM10) E=33.3D 2,155 25 Yes

SO2 E=33.3D 2,155 3 Yes

NOx E=33.3D 2,155 481 Yes

VOC E=33.3D 2,155 24 Yes 1 D=distance from the closest of the six candidate drill sites to the nearest point of land (Icy Cape) in statute miles (64.7 mi [104 km]) 2 As provided in Appendix K.

Table 7.e-4 compares projected annual emissions from the Polar Pioneer and its support vessels with the 

exemption criteria at 30 CFR 550.303(d). The comparison confirms the exploration program even with 

projected support vessel emissions included, is exempt from further air quality review, pursuant to 30 

CFR 550.303(d).

Table 7.e-4 Application of BOEM Exemption Formula to the Polar Pioneer and Support Vessels

Parameter BOEM formula at 30 

CFR 250.303(d) 1

BOEM Exemption 

Threshold 

(Emissions in 

tons/year)

Total Projected 

Emissions

Polar Pioneer and 

Support Vessels 

(tons/year) 2

Exempt?

CO E=3400D2/3 54,796 389 Yes

TSP (PM2.5 & PM10) E=33.3D 2,155 79 Yes

SO2 E=33.3D 2,155 10 Yes

NOx E=33.3D 2,155 1,613 Yes

VOC E=33.3D 2,155 91 Yes 1 D=distance from the closest of the six candidate drill sites to the nearest point of land (Icy Cape) in statute miles (64.7 mi [104 km]) Cape) in 

statute miles (64.7 mi [103 km])

2 As provided in Appendix K.

f) Modeling Report 

According to 30 CFR 550.218(f), results of the modeling and impact analysis are required to be included 

only if 30 CFR 550.303 requires the use of an approved air quality model to model projected air 

emissions in developing EP Revision 2. As discussed in the previous section, the exploration drilling 

program is exempt from further air quality review using the exemption formula found at 30 CFR 

550.303(d); therefore, an impact analysis and use of an approved air quality model is not required under 

the AQRP.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 8-1 March 2015

Revision 2

SECTION 8.0 OIL AND HAZARDOUS SUBSTANCES SPILL 

INFORMATION

a) Oil Spill Response Planning

Shell prepared a Chukchi Sea Regional Exploration Program OSRP as a fundamental component of the 

planned exploration drilling program when it submitted EP Revision 1. BSEE approved that Chukchi Sea 

OSRP 17 February 2012. As per 30 CFR 254.30(a) Shell conducted a biennial review of the Chukchi Sea 

OSRP and submitted to BSEE administrative changes to the Chukchi Sea OSRP on 18 December 2013. 

In June 2014, BSEE confirmed that the OSRP is in compliance with 30 CFR 250.30(a). Shell will submit 

to BSEE additional administrative changes to the approved OSRP to reflect additional operational 

changes consistent with EP Revision 2. These additional administrative changes will reflect the change of 

a second drilling unit (the Kulluk will not be drilling in the Beaufort Sea but the Polar Pioneer will be 

drilling near the Discoverer on the Burger Prospect), change in name of an OSR contractor, and other 

administrative changes.

Despite the very low likelihood of a large oil spill event, Shell has designed a response program based 

upon a regional capability of responding to a range of spill volumes, from small operational spills up to 

and including an OSRP WCD for planning purposes from an exploration well blowout. Shell’s program is 

developed to fully satisfy federal oil spill planning requirements. The OSRP presents specific information 

on the response program that includes a description of personnel and equipment mobilization, the incident 

management team organization, and the strategies and tactics used to implement effective and sustained 

spill containment and recovery operations.

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

achieve this goal, oil spill prevention is a priority in all operations. Prevention practices include personnel 

training programs and strict adherence to procedures and management practices. All project personnel, 

including employees and contractors, involved in oil spill contingency response would receive discharge 

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

periodically to familiarize personnel with on-site equipment, proper deployment techniques, and 

maintenance procedures.

b) Location of Primary Oil Spill Equipment Base and Staging Area

One dedicated OSR barge and on-site oil spill response vessel (OSRV) will be staged in the vicinity of 

the drilling unit(s) when drilling into potential liquid hydrocarbon bearing zones. The OSRV will be 

positioned within 10 nmi (19 km, approximately 1 hour transit time) of the drilling unit(s) and an OSR 

tug and barge will be positioned approximately 25 nmi (46 km) from the drilling unit(s) (approximately 3 

hours transit time). The OSR barge, associated tug, and OSRV possess, in total, greater than 25,000 bbl 

capacity; therefore providing containment, recovery and storage for the initial 24 hours until an OST 

arrives.

An OST will be staged such that it will arrive at the recovery site on the Burger Prospect within 24 hours 

of departure from its staging location. Response personnel will conduct maintenance, training and other 

activities to ensure continued readiness in the event they are needed. The OST will possess enough 

storage capacity to store all recovered liquids (oil and emulsified oil/water) for the initial response or until 

the second relief OST arrives to supplement the response for the full 30 days. The total storage capacity 

between the two tankers available for the 30 day response is > 750,000 bbl. By hour 42, two additional 

dedicated Vessels of Opportunity Skimming Systems would arrive at the spill site to support skimming 

capacity at the site. The OSR tug and barge, OSRV, and vessels would work in conjunction to sustain 

containment and skimming operations and transfer recovered fluids to the OSTs for the duration of the 

response.
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Shell Gulf of Mexico Inc. 8-2 March 2015

Revision 2

An additional ice-strengthened OSR tug and barge with skimming capability, and an associated tug, will 

be mobilized from its staging location near Kotzebue Sound and re-located to the nearshore zone of the 

Chukchi Sea within 96 hours for shoreline protection and cleanup support, if necessary. It will be 

mobilized to arrive prior to the earliest projected time oil could arrive in the Chukchi nearshore zone. The 

OSR tug and barge would possess storage capacity of 17,000 bbl for recovered liquids. It will also carry 

response equipment, including one 47 ft. (14 m) skimming vessel, 34 ft. (10 m) workboats, mini-barges, 

boom and duplex skimming units for nearshore recovery and possibly support nearshore protection. The 

OSR tug and barge, will carry designated response personnel and will mobilize to recovery areas, deploy 

equipment and begin operations.

c) Name(s) of Spill Removal Organization(s) for Both Equipment and Personnel

Shell’s OSRP is supported by three Oil Spill Removal Organizations (OSROs). AES-Response 

Operations, UIC-Arctic Response Services and Alaska Clean Seas (ACS) are Shell’s primary response 

action contractors supporting the program. The OSROs would lead the spill response efforts in the 

offshore, nearshore, and shoreline environments. The OSROs response personnel and OSR equipment 

would be maintained on standby while critical exploration drilling operations into liquid hydrocarbon 

bearing zones are underway and provide offshore, nearshore, and shoreline response operations in the 

unlikely event of an actual oil spill incident. Additionally, each OSRO provides program oversight for 

their particular scope, overall spill management team support, response training, and additional 

responders through the Auxiliary Contract Response Teams, North Slope Spill Response Team, and 

Village Response Teams.

Shell provides dedicated response vessels, skimmers, and equipment for the nearshore and offshore 

operations. Response activities will be conducted using the Shell or ACS tactics as defined in the Shell’s 

Beaufort and Chukchi Seas Regional Tactics Manual and/or ACS’ Technical Manual, or otherwise as 

defined in the OSRP.

d) Calculated Volume of Worst Case Discharge Scenario 

The planning volume (25,000 bbl/day) of a WCD scenario for the Chukchi OSRP is provided in Table 

8.d-1. The WCD planning volume for EP Revision 2 has not changed from the WCD planning volume 

used for EP Revision 1.

Table 8.d-1 Oil Volume of the Worst Case Discharge Planning Scenario* for the Chukchi Sea 

OSRP

Element Capacity (bbl) Reference

Possible Daily Volume of Highest 

Capacity Well 25,000 30 CFR 254.47(b)

Total Worst Case Discharge (Daily 

Volume X 30-day Duration of 

Blowout)

750,000 30 CFR 254.47(b)

Total Storage Capacity 

Requirements 750,000 30 CFR 254.47(b)

* WCD scenario planning volume, which exceeds the calculated WCD volume established under BOEM NTL No. 2015-N01. The calculated 

daily WCD is established for Burger J at 23,100 bbl/day initially but diminishes over the 30 days.

The WCD planning scenario provided above in Table 8.d-1 exceeds the WCD calculated for EP Revision 

2 as indicated in Table 8.d-2.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 8-3 March 2015

Revision 2

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

Regional OSRP with the WCD Calculated for EP Revision 2 for Two Relief Well 

Scenarios

OSRP WCD 

Planning Scenario

EP Revision 2 Calculated 

WCD – Two Drilling Units 

in the Chukchi Sea

EP Revision 2 Calculated 

WCD – One Drilling Unit as far 

away as Dutch Harbor

Maximum Flow 

Rate 25,000 bbl 23,100 bbl1 23,100 bbl1

Total Duration 30 days 34 days 38 days

Total Oil Volume 750,000 bbl 603,564 bbl 669,479 bbl 1 Calculated WCD for Burger J; flow rate diminishes over time

e) Description of Worst Case Discharge Scenario

For exploration drilling operations, the WCD scenario is equal to the daily volume possible from an 

uncontrolled blowout for period of 30 days. In order to address BOEM NTL 2015-N01 and 30 CFR 

254.47, the total WCD planning volume was based upon BSEE’s planning requirement for a 30-day 

blowout, and the Chukchi Sea OSRP assumes as a planning standard a maximum flow rate of 25,000 

bbl/day resulting in a WCD scenario volume of 750,000 bbl (119,237 m3

) of oil during 30 days. This is 

the same conservative planning standard volume as assumed in EP Revision 1.

f) Modeling Report

The WCD scenario is based upon a spill simulation model of a 25,000 bpd well blowout at the seafloor 

(or mudline) in the Burger Prospect at Latitude 71° 16’ 37.2”, Longitude 163° 19’ 48.0”, the site of the 

legacy Burger #1 well, in approximately 138-144 ft. (42-44 m) of water. Modeling of the oil plume 

trajectory was conducted by Applied Science Associates, Inc. (ASA), using historical wind data and the 

BOEM hydrodynamic ocean-ice current model. The ASA trajectory model includes algorithms for 

spreading, evaporation, emulsification, and entrainment, all of which are input parameters based on the 

properties of an Alaska North Slope crude oil with an American Petroleum Institute (API) gravity of 

30.6°.

The ASA’s OILMAP software was used to run the trajectory model based on environmental conditions 

including predominate winds and currents. Oil on the ocean’s surface is assumed to move as the sum of 

vectors: surface currents plus 3.5 percent of the wind speed in the downwind direction. Oil plume 

migration is driven by ocean currents and prevailing winds for the 30-day duration of this scenario. Wind 

data used for the trajectory modeling were collected by Shell from 22 locations in the Chukchi Sea during 

June through November for the years 1980, 1982, and 1983. Data from these three years were used for 

stochastic modeling. Wind data for the period of 7 August to 6 September was used in the trajectory 

modeling.

Based upon the collected data, the offshore winds originated from the northeast to southeast 54 percent of 

the time and the northwest to southwest 23 percent of the time during the June through November period. 

Three predominant wind directions had a measured frequency of occurrence greater than 10 percent of the 

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

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

June through November period:

• ENE wind = 14.6 percent frequency

• NE wind = 13.8 percent frequency

• E wind = 13.0 percent frequency
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Shell Gulf of Mexico Inc. 8-4 March 2015

Revision 2

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

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

at the closest station for the 7 August to 6 September time period and the BOEM ocean-current 

information.

The trajectory shows the oil plume moving into open ocean away from shorelines in a southwesterly 

direction. From Day 1 through Day 3, the oil movement is directed by winds predominantly from the NE 

and the predicted current. Through Day 12, the oil movement is away from land into the open ocean. If 

not intercepted by containment and recovery operations, oil is predicted to begin drifting to the northnortheast (NNE) and toward shorelines by Day 14. The earliest oil is predicted to possibly contact 

shorelines is Day 25 in the area between Peard Bay and Kasegaluk Lagoon. Following Day 25, 

unrecovered oil would continue drifting to the NE, offshore and north of land.

In the very unlikely event that strong, sustained winds develop out of the west-northwest (WNW), the 

trajectory modeling estimates that Day 6 is the earliest possible time oil could reach shore. For planning 

response mobilization, the WCD scenario assumes oil could intercept the shoreline in no less than six 

days in the event sustained northwesterly winds develop, potentially affecting the shorelines from Peard 

Bay to Kasegaluk Lagoon, SW of Wainwright. The WNW wind is used for planning purposes and does 

not correspond to the actual prevailing E, NE, and ENE winds typical in the area. As a precaution, Shell 

response would include nearshore and shoreline protection strategy and tactics, and OSROs would be 

mobilized to implement predesigned protection strategies at priority resource sites.
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Revision 2

SECTION 9.0 ALASKA OUTER CONTINENTAL SHELF 

PLANNING INFORMATION

a) Emergency Plan

Shell has drafted various plans to respond to emergency situations such as a blowout (well control event), 

the loss or disablement of a drilling unit, and the loss or damage to a support vessel.

Shell’s WCP describes how Shell would respond to a well control event. (Appendix H). The WCP is 

focused on the prevention of a blowout using pressure control equipment and operational monitoring. 

Well control is the process of maintaining barriers in the drilled wellbore that prevent gas or fluids from 

underground reservoirs escaping from the wellbore in an uncontrolled flow.

The WCP describes measures to control the flow of a blowout including if the primary drilling unit is lost 

or disabled. A capping stack will be available and can be used to cap the well and stop the flow (a process 

called ‘cap and contain’). If the capping stack is not able to stop the flow, then a separate containment 

system, will be available to capture the flow and divert the recovered liquid for storage and processing (a 

process called ‘cap and flow’). Additional detail on the capping stack and the containment system is 

available in Section 9c. Also, a relief well drilling unit will be available and can be mobilized to the 

blowout site to drill a relief well.

Note that the WCP attached to EP Revision 2 is worded differently from that attached to EP Revision 1. It 

was changed to incorporate language more familiar to Shell’s well engineers and responders to a well 

control event; however, there have been no changes to reduce the substance of Shell’s well control 

procedures.

Shell’s proposed COCP (Appendix F) describes precautionary measures to minimize the likelihood and 

consequence of an oil spill while drilling exploration wells in the Chukchi Sea and to protect personnel, 

equipment and the environment. The COCP defines planned and unplanned critical operations. In the

event that a support vessel, such as an ice management vessel, is unavailable, drilling operations may be 

curtailed depending on circumstances.

b) Critical Operations and Curtailment Plan and Drilling Ice Management Plan

A copy of Shell’s proposed COCP for the Chukchi Sea is attached in Appendix F and a copy of Shell’s 

DIMP is provided in Appendix G. These plans are complementary documents that address the methods 

by which Shell will cease, limit, or not initiate specific critical operations due to operational status and

environmental conditions that may be encountered at the exploration drill sites. However, the scope of the 

DIMP is limited to approaching hazardous ice and its potential effects on exploration drilling operations 

and the drilling unit’s safety.

The text of the COCP has been updated to include the Polar Pioneer, key personnel titles have changed, 

and the curtailment decision protocol has been updated to include the new key personnel.

The DIMP contains minor changes and updates from the version submitted with EP Revision 1. Ice 

management objectives and principles are clearly defined and the drilling units and attending ice 

management vessels have been updated.

c) Additional Information

Fuel Transfer Plan

Shell has prepared a Fuel Transfer Plan (FTP) that covers activities with its planned exploration drilling 

program in the Chukchi Sea. A copy of the FTP is provided in Appendix I. Shell has revised the attached 

FTP that was submitted to BOEM with EP Revision 1 to include a variety of booming scenarios 

depending on whether the fuel transfer is from vessel-to-vessel, vessel-to-drilling unit or dock-to-vessel.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 9-2 March 2015

Revision 2

Partial Wells

Two scenarios exist that could result in partial wells being drilled in a multi-year exploration plan:

• Exploration drilling and/or evaluation of the deepest primary objective has not been concluded on 

a well by the end of the drilling season; or

• A hazardous condition (e.g., ice) forces suspension of the exploration drilling operations, 

temporary abandonment of a wellbore in a safe and secure manner, and drilling unit

demobilization from the Chukchi Sea with no opportunity to return before the end of the drilling 

season

These scenarios are discussed in more detail below.

Initial Drilling Season

If exploration drilling and/or evaluation of the initial or a subsequent well has not been concluded (i.e., 

the deepest primary objective has not been penetrated and/or evaluated), before the end of a drilling 

season, Shell plans to stop the exploration drilling operations, TA the well in compliance with BSEE 

regulations and leave the drill site for the winter.

Operations may begin on additional wells during the drilling season if there is sufficient time prior to the 

onset of the end of the drilling season. This work could include MLC construction (using either a drilling 

unit with a MLC bit or the MLC ROV system), or drilling additional hole sections and cementing casing 

strings during the time remaining in the drilling season.

The best way to suspend a well is to run casing, cement it in the hole, then set a mechanical plug near the 

top of the well and cap the well. This provides multiple barriers to prevent unexpected flows and leave the 

well suitable for safe re-entry. The proposed suspension procedure on any unfinished, or partial well, will 

be provided via submission of an Application for Permit to Modify (APM) for BSEE approval. The MLC 

for each well is constructed such that the ram-type BOP stack (i.e., the bottom section of the stack) can 

remain installed on the high-pressure wellhead housing as part of the TA procedure with the upper most 

portion below the LMRP remaining below the maximum ice keel scour depth. Efforts will be made to 

preferentially provide a sufficient number of independent verified barriers in the wellbore (a minimum of 

two) to ensure that the well cannot leak or flow while TA without the lower stack remaining on the well. 

These barriers can include cement not drilled out from the bottom joints of casing after cementing it in 

place, double float valves inside the casing, wellhead seal assembly between casing strings, cement plugs, 

mechanical plugs and sealed hang-off tools. These techniques and barriers are also described in the COCP 

in Appendix F. If there are a sufficient number of quality barriers left in the well when it is TA, the entire 

BOP stack will be recovered for repair and testing during the winter season in preparation for the next 

drilling season.

If a hazardous condition requires curtailment of critical operations (or prevents initiation of them, 

depending on time available) per the provisions of the COCP (Appendix F), the well will be suspended 

and secured using a BSEE approved procedure, moorings will be recovered if possible and the drilling 

unit will move to a safe area. Once the hazardous condition has passed, the drilling unit will return to the 

drill site and conclude exploration 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 any drilling season, the well 

will remain TA until the next drilling season. The drilling unit may return to the suspended well and 

finish exploration drilling/evaluation operations during a subsequent drilling season prior to permanently 

abandoning the well.
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Subsequent Drilling Seasons

In a subsequent season, Shell may choose to return to an unfinished drill site where a well has been left 

TA from a previous season, or Shell may choose to go to a new drill site covered by this EP Revision 2 

and start a new well that will meet the exploration program objectives. Once all objectives have been 

satisfied, all wells will be successfully plugged and permanently abandoned according to BSEE 

regulations, as were the legacy wells drilled from 1989 through 1992.

All wells are planned to be temporarily or permanently abandoned in accordance with BSEE regulations

during the season they are drilled. An exception to this plan involves the inability to return to the drill site 

following an emergency evacuation, such as, but not limited to, an approaching ice hazard. If a well 

cannot be abandoned due to ice, it will be properly suspended per BSEE approval before the drilling unit 

evacuates. At the beginning of a subsequent drilling season, the drilling unit may return to the drill site to 

permanently abandon the unfinished well or continue exploration drilling/evaluation of the well. All wells 

will be permanently abandoned prior to the end of the exploration program.

Surface Intervention – Capping and Containment System

In the unlikely event of a blowout in the Chukchi Sea, Shell’s capping and containment capabilities are

provided by a combination of a 1) SS capping stack and 2) surface separation equipment, i.e. a 

containment system. The capping stack equipment will be stored aboard one of the ice management 

vessels and will be available for deployment within 24 hours, depending on ice, weather and location, in 

the unlikely event of a blowout. The containment system, located on the Arctic Challenger barge and 

accompanied by a tug (Corbin Foss or similar) is planned to be stationed in Kotzebue Sound and could 

arrive at the scene of a blowout and be capable of receiving liquid hydrocarbons in eight days, depending 

on weather and the characteristics of the blowout.

The capping stack will be lowered onto the BOP to shut off oil leaks in the event that the BOP fails to 

shut off the flow. The capping stack is meant to seal a leaking wellhead provided that the well’s integrity 

has not been compromised. It is part of the efforts to control the outflow of liquid hydrocarbons from the 

well in an uncontrolled blowout but it is separate from the containment system. The containment system 

is another oil spill collection system that will be available. The containment system will provide the 

means to collect uncontrolled well flows from SS blowout situations as close to the source as possible, 

thereby minimizing surface oil slicks. The containment system is housed on the Arctic Challenger barge 

and includes the containment dome, topside processing facilities, flare boom, an ROV, two workboats, 

and living quarters (Figure 9.c-1).

Surface intervention involves work done on the wellhead of a SS well. Surface intervention in the OCS 

involves SS devices used on the top of the well or some device connected thereto (e.g., the BOP stack or 

wellhead).

A set of SS devices has been assembled for the drilling seasons 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 (this intervention process is commonly called “Cap and Contain”)

• Attaching a device or series of devices to the well and diverting flow to surface vessel(s) equipped for 

separation and disposal of hydrocarbons (this intervention process is commonly called “Cap and 

Flow”)
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These devices form what is generally known as a capping stack. The devices on the capping stack include 

ram-type BOP bodies equipped with blind 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.

This equipment will be stored aboard a designated vessel in Alaska with a marine crew aboard, warmstored and ready for use. It is anticipated that surface intervention efforts will successfully stop the flow 

from a blowout.

Various crossovers, spools, ram sets, and other equipment (including demolition tools for clearing debris 

away from the well) are included on the designated vessel. Extra studs, nuts, gaskets, hydraulic wrenches 

and other tools are 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.

The equipment on the containment system tugs and barge is designed for reliability, ease of operation, 

flexibility and robustness so it could be used for a variety of blowout situations.

Efforts to contain the blowout will begin when the equipment arrives to clear debris from the well and a

capping stack will be attached as necessary. If these efforts fail to capture all the oil, Shell’s OSR support 

vessels 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 OSR vessels would 

remain and oil spill cleanup would continue, as necessary, until the blowout is under control.

Figure 9.c-1 Containment System and Components
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SECTION 10.0 ENVIRONMENTAL MONITORING

a) Monitoring Systems

The drilling units will be equipped with the following equipment (or similar, but of equal or superior 

specifications) used to monitor conditions at the location of either drilling unit:

Table 10.a-1 Monitoring Equipment on the Polar Pioneer and the Discoverer

Equipment Polar Pioneer Discoverer

Navigation Radar Furuno FAR-2127BB Furuno ARPA FAR - 28 X 7 SERIES; 

Furuno FAR - 21 X 7 (-BB) SERIES

Communications

very high frequency – amplitude 

modulation (VHF-AM) aeronautical radio

Aeronautical non-directional beacon

Sailor, Compact-GMDSS station

V-SAT, phone/fax/data

Iridium Scanset-7701 satellite phone

GMDSS EQUIPMENT

Sailor HC 4500 MF / HF control 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

Satellite Phone Sailor TT3622B

Positioning

Kongsberg K-Pos DPM 11 – Positioning 

mooring system

Kongsberg Simrad HPR 309

Furuno GPS/WAAS Navigator GP32

Furuno GPS Navigator GP – 150

AIS L3 Communications

Simrad GL 80 / 85

Furuno FE 700 echo sounder

Cassen & Plath GmbH Type 12 Reflector 

compass

Standard clinometer model MOELLER 5 / 15 

degs 

Anchor Tensions

APM 3000 (SIMRAD/ Kongsberg Albatross)

computer system for indications of tensions 

and alarm at specified levels

Plimsoll Anchor tension monitoring system 

Meteorological

Meteorology instruments installed in 

compliance with all relevant requirements

(Environmental Management System); 

measuring wind, barometric pressure, water 

temperature

Young Marine Wind Tracker model 06206 

Sato Sigma - II Barograph model NS II – BR

Barometer Hanseatic Instruments 

Laser mounted flute to measure seawater 

inlet temperature
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Environmental Monitoring at Drill Sites While Drilling 

As part of the requirements under the NPDES exploration facilities GP, Shell will conduct an 

Environmental Monitoring Program (EMP) that meets the objectives in the permit AKG-28-8100. The 

specific details around this monitoring program have been submitted with the NPDES NOI; however, the 

EMP will generally consist of a 4 phase monitoring program.

• Phase I establishes the baseline conditions of the drill site prior to exploration drilling activities and 

will either be supported with historical data or supplemental data collected prior to exploration 

drilling activities. The baseline data generally consist of benthic samples, receiving water chemistry, 

sediment characteristics, and a visual assessment of the sea floor.

• Phase II requires monitoring to be conducted while exploration drilling activities are occurring and 

consists of discharge plume monitoring, metals analysis of the drilling fluid, and Phases III and IV are 

similar in nature and are conducted once exploration drilling activities are completed. Phase III 

monitoring will occur shortly after exploration drilling operations cease at a drill site. Phase IV is 

conducted no later than 15 months after exploration drilling operations cease. Benthic samples, 

sediment characteristics, and a sea bottom survey will be completed during these phases.

The results from this monitoring program will be submitted to EPA as required in permit AKG-28-8100.

Bird and mammal observations will be made from all transiting surface operation vessels throughout 

exploration drilling activities in accordance with the Marine Mammal Monitoring and Mitigation Plan

(4MP) located in Appendix B and the Bird Strike Avoidance and Lighting Plan located in Appendix E.

b) Incidental Takes

Applications have been submitted for the following MMPA authorizations:

• NMFS – Non-lethal, Incidental Take of Whales and Seals 

• USFWS – Non-lethal, Incidental Take of Polar Bears and Pacific Walrus

• USFWS – Non-lethal, Intentional Take of Polar Bears and Pacific Walrus 

During the planned exploration drilling program, the two drilling units and transiting support vessels will 

each have PSOs onboard to observe for marine mammals and record all observations. The PSO program 

is described in the 4MP (Appendix B) submitted in support of the NMFS and USFWS MMPA non-lethal, 

incidental take authorization applications.

Species for which a MMPA authorization is sought from NMFS are:

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

• Odontocetes: beluga, narwhal, killer whale, and harbor porpoise

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

Table 12.b-2 lists these species and provides the current ESA designation.

Under current guidelines, NMFS assumes that marine mammals exposed to pulsed airgun sounds with 

received levels ≥160 decibels (dB) root mean square (rms) or continuous sounds from vessel activities 

with received levels ≥120 dB rms have the potential to be disturbed. As a result, these sound level 

thresholds are currently used by NMFS to define acoustic disturbance criteria, also known as the Level B 

thresholds. Shell plans to conduct a geophysical survey with airguns referred to as a zero-offset vertical 

seismic profile (ZVSP) survey at each drill site where a well is drilled to PTD. The numbers of marine 

mammals that may potentially be exposed to pulsed sound levels of >160 dB (rms) while conducting 

ZVSP surveys, and continuous sound levels >120 dB rms during exploration drilling, ice management, 
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anchor handling, MLC construction, and supply vessels using dynamic positioning in a drilling season are 

summarized in Table 10.b-1. Shell recognized that NMFS has recently issued draft acoustic guidance 

(NMFS, 2013) for all sound sources which are specific for the onset of Temporary Threshold Shift which 

is considered Level B harassment and Permanent Threshold Shift which is considered Level A 

harassment. The criteria for Level B behavioral disturbance have not been developed. Until such time as 

the acoustic criteria are finalized and released, Shell will utilize the current threshold criteria.

The estimates shown in Table 10.b-1 reflect the results of a multistep process for calculating the exposure 

of animals to Level B thresholds. The first of these steps estimates the number of marine mammals that 

may be present in areas exposed to Level B thresholds for a range of activity scenarios and sums them 

together. Estimates from this method do not account for animal avoidance, movements into or out of 

exposed areas, or new animals moving through (i.e., turnover) that might occur during the course of each 

season. The second step for estimating exposures produces conservative estimates and takes into account 

assumptions of turnover rates of animals in the project area and avoidance rates. For all species except 

bowhead whales, it is assumed that there is 100% replacement of individual marine mammals with zero 

avoidance every 24 hours. This is likely to overestimate exposure in most cases, resulting in over 

estimation of the number of individuals that would actually be exposed to Level B thresholds. For 

bowhead whales, we conservatively assumed that zero whales will avoid the area ensonified by drilling 

program sounds in excess of 120 dBand also assumed a 48 hour turnover rate. 

The results are exposure estimates that are larger than prior years, but as stated are considered an 

overestimate. Though the aggregate activity level will increase from 2012, the resulting impacts to the 

affected marine mammal populations, as described in the EIA (Appendix C), would be temporary and 

result in only short-term disturbance or displacement. From a historical perspective, the temporary 

activity of offshore exploration drilling and associated support vessel activities, collectively and 

individually, have not resulted in impacts of biological significance to marine mammals of the Arctic, or 

interference with the subsistence harvest of those marine mammals by the residents of the communities 

along the Beaufort and Chukchi Seas.

Many animals exposed to continuous sound levels near 120 dB rms would not react, particularly 

pinnipeds, and exposure to this sound level should not be considered as “takes by harassment” in such 

cases. 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 prior decisions by NMFS. See 77 Fed. Reg. 27283, 27290 May 9, 2012. In regard to the 

subsistence harvest of bowhead whale, as a consequence of Shell’s planned mitigation measures (see 

Section 12.0) any effects on the bowhead whale as a subsistence resource also will be negligible.

Species for which MMPA incidental and intentional take authorizations are sought from USFWS are:

• Carnivora – Polar bears

• Pinnipedia – Pacific walrus

Table 12.b-2 lists these species and provides the current ESA designation.

The MMPA applications provides an outline of the planned exploration drilling program and includes an 

updated, drilling program-specific bear and walrus plan titled: Polar Bear, Pacific Walrus and Grizzly 

Bear Avoidance and Encounter/Interaction Plan, Chukchi Sea, Alaska, Exploration Drilling Program.

Shell is currently in discussion with USFWS with respect to the approach to operations that may occur in 

and around the HSWUA during and related to drilling activities. The details of the monitoring and 

mitigation measures that are to be utilized in relation to the HSWUA will be fully documented in the 

MMPA authorization.
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Table 10.b-1 Number of Potential Exposures of Marine Mammals to Received Sound Levels in the 

Water of >120 dB re 1 μPa rms Generated by Exploration Drilling and >160 dB re 1 

μPa rms Generated by ZVSPs during 2015 Exploration Drilling

Species

Number of Individuals 

Potentially Exposed to 

Continuous Sounds ≥120 

dB re 1 μPa (rms) or 

Pulsed Sounds ≥160 dB

re 1 μPa (rms)

Percent of Estimated 

Population

Odontocetes

Monodontidae

Beluga 974 2.3

Narwhal 1 0.0

Delphinidae

Killer whale 14 0.7

Phocoenidae

Harbor porpoise 294 0.6

Mysticetes

Bowhead whale 2,582 13.2

Fin whale 14 0.8

Gray whale 2,581 13.5

Humpback whale 14 0.1

Minke whale 41 5.1

Pinnipeds

Bearded seal 1,722 1.1

Ribbon seal 96 0.2

Ringed seal 50,433 16.8

Spotted seal 1,007 0.7
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SECTION 11.0 LEASE STIPULATIONS INFORMATION

The source for the italicized text below is the OCS Chukchi Sea Planning Area Oil and Gas Lease Sale 

193.

Stipulation No. 1 - Protection of Biological Resources

If previously unidentified biological populations or habitats that may require additional protection are 

identified in the lease area by the Regional Supervisor, Field Operations (RS/FO), the RS/FO may 

require the lessee to conduct biological surveys to determine the extent and composition of such 

biological populations or habitats. The RS/FO shall give written notification to the lessee of the RS/FO’s 

decision to require such surveys. 

Based on any surveys that the RS/FO may require of the lessee or on other information available to the 

RS/FO on special biological resources, the RS/FO may require the lessee to:

1) Relocate the site of operations;

2) Establish to the satisfaction of the RS/FO, on the basis of a site-specific survey, either that such 

operations will not have a significant adverse effect upon the resource identified or that a special 

biological resource does not exist;

3) Operate during those periods of time, as established by the RS/FO, that do not adversely affect the 

biological resources; and/or

4) Modify operations to ensure that significant biological populations or habitats deserving protection 

are not adversely affected.

If any area of biological significance should be discovered during the conduct of any operations on the 

lease, the lessee shall immediately report such findings to the RS/FO and make every reasonable effort to 

preserve and protect the biological resource from damage until the RS/FO has given the lessee direction 

with respect to its protection.

The lessee shall submit all data obtained in the course of biological surveys to the RS/FO with the 

locational information for drilling or other activity. The lessee may take no action that might affect the 

biological populations or habitats surveyed until the RS/FO provides written directions to the lessee with 

regard to permissible actions.

Shell Proposed Actions:

The BOEM has not requested that Shell conduct any biological resource surveys in the area of the 

planned drill sites. No new areas of special biological significance have been identified within or near the 

blocks identified in this EP Revision 2.

In addition to the shallow hazards surveys, which provide detailed information on the seafloor sediments 

and relief, Shell conducted or participated in the funding or in the facilitation of several types of 

environmental studies in and near the prospects in 2008 through 2014 to gather baseline data regarding 

resources. These studies included coastline surveys to assess the relative environmental sensitivity of 

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

studies, bird and marine mammal surveys, assessments of the benthic invertebrate communities, 

oceanographic studies, and sediment quality assessments at the planned drill sites. The results of the 

marine mammal and bird surveys are summarized in the EIA in Appendix C.

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

the drill sites. Video reconnaissance surveys were conducted at historical drill sites at Burger in 1989, and 

the results were submitted to BOEM at that time. These surveys also found a relatively flat and featureless 
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seafloor, with a silty substrate and a benthic fauna typical of the Lease Sale 193 Area (Finney 1989,

Boudreau 1989).

Stipulation No. 2 - Orientation Program

The lessee shall include in any exploration plan (EP) or development and production plan (DPP) 

submitted under 30 CFR 550.211 and 550.241 a proposed orientation program for all personnel involved 

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

contractors, and subcontractors) for review and approval by the RS/FO. The program shall be designed 

in sufficient detail to inform individuals working on the project of specific types of environmental, social, 

and cultural concerns that relate to the sale and adjacent areas. The program shall address the 

importance of not disturbing archaeological and biological resources and habitats, including endangered 

species, fisheries, bird colonies, and marine mammals and provide guidance on how to avoid 

disturbance. This guidance will include the production and distribution of information cards on 

endangered and/or threatened species in the sale area. The program shall be designed to increase the 

sensitivity and understanding of personnel to community values, customs, and lifestyles in areas in which 

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

avoidance of conflicts with subsistence activities and pertinent mitigation.

The program shall be attended at least once a year by all personnel involved in onsite exploration or 

development and production activities (including personnel of the lessee’s agents, contractors, and 

subcontractors) and all supervisory and managerial personnel involved in lease activities of the lessee 

and its agents, contractors, and subcontractors.

The lessee shall maintain a record of all personnel who attend the program onsite for so long as the site 

is active, not to exceed 5 years. This record shall include the name and date(s) of attendance of each 

attendee.

Shell Proposed Actions

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

contractor personnel involved in Shell’s Alaska Venture exploration drilling program that was first 

approved by the Alaska OCS Region of the BOEM RS/FO on 15 February 2007. An outline of the 

program was again submitted to BOEM with the initial Chukchi Sea EP, and found by the BOEM RS/FO 

on 7 December 2009 to satisfy the requirements of Stipulation No. 2. Shell revised the orientation 

program based on BOEM comments regarding the 2009 orientation program, and submitted the complete 

orientation program to BOEM for approval on 9 June 2011. The orientation program was approved on 13 

June 2012. Shell will periodically make minor changes to the orientation program content to maintain its 

currency (e.g., updates in safety statistics, permitting requirements) and those changes will be rolled into 

EP revisions as required. Another update to the approved orientation program will be submitted to BOEM 

for approval prior to beginning the next drilling season. This update will be substantially the same as the 

current approved orientation program.

All Shell and contractor personnel involved in field exploration drilling activities will attend an initial 

training orientation for all personnel and an annual refresher for field deployed personnel. All Alaska 

office-based Shell and contractor personnel will attend the program at least once at the time they join the 

team. Field deployed personnel traveling to onshore or offshore locations north of Fairbanks, Alaska will 

attend annual refresher training. Visitors traveling to land locations (i.e., trips performing low-risk 

activities less than three days) will receive an abbreviated fit-for purpose orientation as related to their 

visit. Contractors hired by Shell who reside in an area north of Fairbanks (i.e., a village) may receive a 

slightly modified version of the cultural awareness orientation that is fit for purpose or allow comparable 

training (e.g., attendance at Alaska Federation of Natives convention).
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Shell will retain and maintain a record, for at least 2 years, of all personnel who attend the program, 

including relevant attendee and program information. Shell has designed a specific program that 

addresses environmental, social, and cultural concerns related to the project area. The program is 

designed to increase sensitivity and understanding by Shell and its contractors of community values, 

customs, and lifestyles in the area they will be working, and how to avoid conflicts with subsistence 

activities. The program stresses the importance of not disturbing archaeological and biological resources 

and habitats, including endangered species, fisheries, bird colonies, and marine mammals and provides 

guidance on how to avoid disturbance.

Shell’s Cultural Awareness Program addresses the following:

• Alaska Native Ethnic Breakdown

• Brief history of land claims

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

• History of the North Slope

• Cultural diversity

• Comparison of cultural values Patterns of language

• Communication skills and body language

• Guidelines on cultural artifacts

• Local community values and customs

• Whaling 

Shell has developed a very robust Health, Safety, Security and Environment (HSSE) Awareness Program, 

of which the requirements listed in Lease Stipulation 2 are a component of this training. The following 

areas are highlighted to address the requirement in Lease Stipulation 2.

• Environmental Awareness

o 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

The awareness level orientations may be given as face-to-face training, video and computer slides, or via 

computer based training. Annual refreshers will include the general content noted above but adapted for 

those already familiar with basic information.
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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 benefits in the form of increased 

environmental protection or reduced multiple-use conflicts. The lessor specifically reserves the right to 

require that any pipeline used for transporting production to shore be placed in certain designated 

management areas. In selecting the means of transportation, consideration will be given to 

recommendations of any Federal, State, and local governments and industry.

Following the development of sufficient pipeline capacity, no crude oil production will be transported by 

surface vessel from offshore production sites, except in the case of an emergency. Determinations as to 

emergency conditions and appropriate responses to these conditions will be made by the RS/FO.

Shell Proposed Action

Not applicable to the activities described in this EP Revision 2. 

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

A lessee proposing to conduct exploration operations, including ancillary seismic surveys, on a lease 

within the blocks identified below during the periods of subsistence use related to bowhead whales, 

beluga whales, ice seals, walrus, and polar bears will be required to conduct a site-specific monitoring 

program approved by the RS/FO; unless, based on the size, timing, duration, and scope of the proposed 

operations, the RS/FO, in consultation with appropriate agencies and co-management organizations, 

determines that a monitoring program is not necessary. Organizations currently recognized by the 

National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (USFWS) for the comanagement of the marine mammals resources are the Alaska Eskimo Whaling Commission, the Alaska 

Beluga Whale Committee, the Alaska Eskimo Walrus Commission, the Ice Seal Commission, and the 

Nanuuq Commission. The RS/FO will provide the appropriate agencies and co-management 

organizations a minimum of 30 calendar days, but no longer than 60 calendar days to review and 

comment on a proposed monitoring program prior to Minerals Management Service (MMS) approval. 

The monitoring program must be approved each year before exploratory drilling operations can be 

commenced.

The monitoring program will be designed to assess when bowhead and beluga whales, ice seals, walrus, 

and polar bears are present in the vicinity of lease operations and the extent of behavioral effects on 

these marine mammals due to these operations. In designing the program, the lessee must consider the 

potential scope and extent of effects that the type of operation could have on these marine mammals. 

Experiences relayed by subsistence hunters indicate that, depending on the type of operations, some 

whales demonstrate avoidance behavior at distances of up to 35 miles. The program must also provide 

for the following:

1) Recording and reporting information on sighting of the marine mammals of concern and the extent of 

behavioral effects due to operations;

2) Coordinating the monitoring logistics beforehand with the MMS Bowhead Whale Aerial Survey 

Project (BWASP) and other mandated aerial monitoring programs;

3) Inviting a local representative to be determined by consensus of the appropriate co-management 

organizations to participate as an observer in the monitoring program;

4) Submitting daily monitoring results to the RS/FO;
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5) Submitting a draft report on the results of the monitoring program to the RS/FO within 90 days 

following the completion of the operation. The RS/FO will distribute this draft report to the 

appropriate agencies and co-management organizations; 

6) Allowing 30 days for independent peer review of the draft monitoring report; and

7) Submitting a final report on the results of the monitoring program to the RS/FO within 30 days 

after the completion of the independent peer review. The final report will include a discussion 

of the results of the peer review of the draft report. The RS/FO will distribute this report to the 

appropriate agencies and co-management organizations.

The RS/FO may extend the report review and submittal timelines if the RS/FO determines such an 

extension is warranted to accommodate extenuating circumstances. 

The lessee will be required to fund an independent peer review of a proposed monitoring plan and the 

draft report on the results of the monitoring program for bowhead whales. The lessee may be required to 

fund an independent peer review of a proposed monitoring plan and the draft report on the results of the 

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

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

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

peer reviewers will be selected by the RS/FO from experts recommended by the appropriate agencies and 

co-management resource organizations. The results of these peer reviews will be provided to the RS/FO 

for consideration in final MMS approval of the monitoring program and the final report, with copies to 

the appropriate agencies and co-management organizations.

In the event the lessee is seeking a Letter of Authorization (LOA) or Incidental Harassment Authorization 

(IHA) for incidental take from NMFS and/or USFWS, the monitoring program and review process 

required under the LOA or IHA may satisfy the requirements of this stipulation. The lessee must advise 

the RS/FO when it is seeking an LOA or IHA in lieu of meeting the requirements of this stipulation and 

provide the RS/FO with copies of all pertinent submittals and resulting correspondence. The RS/FO will 

coordinate with the NMFS and/or USFWS and will advise the lessee if the LOA or IHA will meet these 

requirements. 

The MMS, NMFS, and USFWS will establish procedures to coordinate results from site-specific surveys 

required by this stipulation and the LOA’s or IHA’s to determine if further modification to lease 

operations are necessary.

This stipulation applies to the following blocks:

NR02-06, Chukchi Sea

6624, 6625, 6674, 6675, 6723-6725, 6773-6775, 6822, 6823, 6872

NR03-02, Posey

6872, 6873, 6918-6923, 6967-6973, 7016-7023, 7063-7073, 7112-7123

NR03-03, Colbert

6674, 6723, 6724, 6771-6774, 6820-6824, 6869-6874, 6918-6924, 6966-6974,

7015-7024, 7064-7074, 7113-7124

NR03-04, Solivik Island

6011-6023, 6060-6073, 6109-6122, 6157-6171, 6206-6219, 6255-6268, 6305-6317,

6354-6365, 6403-6414, 6453-6462, 6502-6511, 6552-6560, 6601-6609, 6651-6658,

6701-6707, 6751-6756, 6801-6805, 6851-6854, 6901-6903, 6951, 6952, 7001
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NR03-05, Point Lay West

6014-6024, 6062-6073, 6111-6122, 6160-6171, 6209-6221, 6258-6269, 6307-6317,

6356-6365, 6406-6414, 6455-6462, 6503-6510, 6552-6558, 6602-6606, 6652-6655, 6702, 6703

NR04-01, Hanna Shoal

6223, 6267-6273, 6315-6323, 6363-6373, 6411-6423, 6459-6473, 6507-6523,

6556-6573, 6605-6623, 6654-6671, 6703-6721, 6752-6771, 6801-6819, 6851-6868,

6901-6916, 6951-6964, 7001-7010, 7051-7059, 7101-7107

NR04-02, Barrow

6003-6022, 6052-6068, 6102-6118, 6151-6164, 6201-6214, 6251-6262, 6301-6312,

6351-6359, 6401-6409, 6451-6456, 6501-6506, 6551, 6552, 6601, 6602

NR04-03, Wainwright

6002-6006, 6052, 6053

NS04-08, (Unnamed)

6816-6822, 6861-6872, 6910-6922, 6958-6972, 7007-7022, 7055-7072, 7104-7122

This stipulation applies during the time periods for subsistence-harvesting described below for each 

community.

Subsistence Whaling and Marine Mammal Hunting Activities by Community 

Barrow: Spring bowhead whaling occurs from April to June; Barrow hunters hunt from ice leads from 

Point Barrow southwestward along the Chukchi Sea coast to the Skull Cliff area. Fall whaling occurs 

from August to October in an area extending from approximately 10 miles west of Barrow to the east side 

of Dease Inlet. Beluga whaling occurs from April to June in the spring leads between Point Barrow and 

Skull Cliff; later in the season, belugas are hunted in open water around the barrier islands off Elson 

Lagoon. Walrus are harvested from June to September from west of Barrow southwestward to Peard Bay. 

Polar bear are hunted from October to June generally in the same vicinity used to hunt walrus. Seal 

hunting occurs mostly in winter, but some open water sealing is done from the Chukchi coastline east as 

far as Dease Inlet and Admiralty Bay in the Beaufort Sea.

Wainwright: Bowhead whaling occurs from April to June in the spring leads offshore of Wainwright, 

with whaling camps sometimes as far as 10 to 15 miles from shore. Wainwright hunters hunt beluga 

whales in the spring lead system from April to June but only if no bowheads are in the area. Later in the 

summer, from July to August, belugas can be hunted along the coastal lagoon systems. Walrus hunting 

occurs from July to August at the southern edge of the retreating pack ice. From August to September, 

walrus can be hunted at local haulouts with the focal area from Milliktagvik north to Point Franklin. 

Polar bear hunting occurs primarily in the fall and winter around Icy Cape, at the headland from Point 

Belcher to Point Franklin, and at Seahorse Island.

Point Lay: Because Point Lay’s location renders it unsuitable for bowhead whaling; beluga whaling is 

the primary whaling pursuit. Beluga whales are harvested from the middle of June to the middle of July. 

The hunt is concentrated in Naokak and Kukpowruk Passes south of Point Lay where hunters use boats to 

herd the whales into the shallow waters of Kasegaluk Lagoon where they are hunted. If the July hunt is 

unsuccessful, hunters can travel as far north as Utukok Pass and as far south as Cape Beaufort in search 

of whales. When ice conditions are favorable, Point Lay residents hunt walrus from June to August along 

the entire length of Kasegaluk Lagoon, south of Icy Cape, and as far as 20 miles offshore. Polar bear are 

hunted from September to April along the coast, rarely more than 2 miles offshore.
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Point Hope: Bowhead whales are hunted from March to June from whaling camps along the ice edge 

south and southeast of the point. The pack-ice lead is rarely more than 6 to 7 miles offshore. Beluga 

whales are harvested from March to June in the same area used for the bowhead whale hunt. Beluga 

whales can also be hunted in the open water later in the summer from July to August near the southern 

shore of Point Hope close to the beaches, as well as areas north of the point as far as Cape Dyer. 

Walruses are harvested from May to July along the southern shore of the point from Point Hope to 

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

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

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

after consultation with appropriate agencies.

Shell Proposed Actions

Although none of the blocks listed in Stipulation No. 4 are included in those planned for exploration 

drilling in Shell’s EP Revision 2, Shell voluntarily submitted to the BOEM a site-specific 4MP with EP 

Revision 1, and provided the 4MP to support its application for a MMPA authorization. The 4MP has 

been updated to reflect the revised drilling program in EP Revision 2, but remains substantially the same 

as the 4MP that is part of the approved EP Revision 1. The 4MP is located in Appendix B. Shell’s POC, 

4MP, and other mitigation measures are designed to address this change in areas of subsistence activities.

Shell intends to use contractors based in the NSB, Northwest Arctic Borough (NWAB) and potentially 

the Bering Straits region that will in turn provide job opportunities to local residents, including 

recruitment and training of SAs and PSOs. Summaries of key components of the program are presented 

below. 

Protected Species Observers 

Vessel-based monitoring for marine mammals will be done throughout the period of exploration drilling 

operations to comply with expected provisions in the MMPA authorizations that Shell receives. Those 

provisions will be implemented during the exploration drilling program by a team of trained PSOs. The 

presence of PSOs onboard drilling and transiting support vessels will be a core component of compliance 

with the 4MP. The PSOs will be responsible for collecting basic data on observations of marine mammals 

and for implementing mitigation measures including vessel avoidance measures and factored into 

decisions concerning operational shutdown. The observations made by PSOs serve as the primary basis 

for estimation of impacts to marine mammals. Because their ranks include representatives of the Alaska 

Native community, the PSOs also serve as an important means of providing local hire and local oversight 

of the monitoring program. PSOs will be stationed on both drilling units, ice management vessels, anchor 

handlers and other drilling support vessels engaged in transit to and between drill sites, and other 

operational and intermittent activities to monitor for marine mammals.

Aerial Survey Program

Offshore aerial wildlife monitoring photographic surveys (aka PSO flights) are proposed to start as soon 

as the ice management, anchor handler and drilling units are at or near the first drill site and would 

continue throughout the drilling period and until the drilling related vessels have left the exploration 

drilling area. In the event vessels enter the Chukchi Sea on or about 1 July, surveys would be initiated on 

or about 3 July. This start date differs from past practices of beginning five days prior to initiation of an 

activity and continuing until five days after cessation of the activity because the presence of vessels with 

helidecks in the area where overflights will occur is one of the main mitigations that will allow for 

supporting a safe operation of the overflight program this far offshore. A nearshore/coastal saw-tooth 

pattern also may be flown. The offshore aerial wildlife monitoring photographic surveys will be based out 

of Barrow and the same aircraft will conduct the offshore surveys around the drilling units and the 

nearshore/coastal saw-tooth pattern.
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Photographic surveys are proposed to be flown daily, weather permitting, throughout the drilling 

program. The offshore survey transects over the drilling area would be the default priority each day, as 

opposed to the nearshore/coastal sawtooth pattern. The nearshore/coastal survey pattern would be flown 

only in instances when conditions offshore are not conducive for flying and coastal conditions would, 

however, support an overflight. There also may be isolated instances during the season when the 

nearshore/coastal survey would be identified as the priority due to a unique biological or operational 

scenario (e.g., walrus aggregations).

Acoustic Recorders

A combination of acoustic recorder technologies will be employed to document the distribution of marine 

mammals; the distribution of marine mammals in relation to activities; to add clarity to the 

characterization of exploration drilling sound levels, character, and propagation; and to document 

presence of marine mammals in subsistence hunting areas. This will be accomplished by deploying 

several acoustic recorder buoys in a wide area surrounding the planned locations. Acoustic monitoring 

instruments have been deployed in the Chukchi Sea in past years in late July. With drilling proposed to 

commence in early July, the deployment date would be pushed forward to occur after ice out and before 

exploration drilling. Over-wintering sonobuoys have also been located in the proposed exploration 

drilling area since 2007. In that early drilling related activities would be initiated upon arrival and while 

the arrays are being deployed, these over-wintered recorders would capture the sound associated with 

early activities.

Sound Modeling

Sound modeling will be conducted during the exploration drilling program in the Chukchi Sea.

Sound Source Verification

Field measurement of sound propagation profiles of vessels and the drilling units will be conducted 

during different operational modes, so as to determine those activities that produce the greatest 

opportunities for mitigation. Shell plans to conduct sound source verification (SSV) on the vessels which 

did not have a prior SSV in the Chukchi Sea. Since sound levels generated by drilling operations do not 

exceed sound levels where mitigation measures are required, the utility of SSVs, which are normally used 

to verify and adjust mitigation distances, is limited. Shell is also utilizing distributed arrays around the 

drilling location to measure cumulative sound impacts throughout the drilling process. These arrays are 

generating more useful information than individual SSVs.

Regarding the drilling units, as noted in the 4MP, exploration drilling sounds are expected to vary 

significantly with time due to variations in the level of operations and the different types of equipment 

used at different times onboard the drilling units. The goals of these measurements are to quantify the 

absolute sound levels produced by exploration drilling and to monitor its variations with time, distance 

and direction from the drilling unit; and to measure the sound levels produced by an end-of-hole ZVSP 

survey using a stationary sound source.

Additional Studies

Shell plans to participate in additional studies of marine resources in the Chukchi Sea to enable us to 

increase our understanding of: (1) baseline conditions and the distribution of critical resources; (2) 

interactions between industry activities and marine resources; and (3) resource status and 

conservation/management needs. The list of potential studies and monitoring projects includes:

• Baseline studies of the air quality, oceanography, sediment chemistry, benthic and planktonic 

communities, fish, marine birds, and marine mammals in the Burger Prospect area;
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Shell Gulf of Mexico Inc. 11-9 March 2015

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• Marine mammal distribution and response to industry activities in the northeastern Chukchi Sea;

• Participation in, and funding of, walrus and ringed seal tagging studies;

• Collection of subsistence use of coastal and offshore waters though a system of SAs; and

• Drilling waste discharge and benthic community monitoring.

With the exception of the discharge monitoring for the NPDES exploration facilities GP, Shell has been 

participating in these studies since 2006. Reports summarizing the methods and findings of the studies are 

listed in Section 5.0. Discharge monitoring studies Shell expects to conduct are described in Section 10.0.

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

and Other Subsistence Harvesting Activities

Exploration and development and production operations shall be conducted in a manner that prevents 

unreasonable conflicts between the oil and gas industry and subsistence activities. This stipulation 

applies to exploration, development, and production operations on a lease within the blocks identified 

below during periods of subsistence use related to bowhead whales, beluga whales, ice seals, walruses, 

and polar bears. The stipulation also applies to support activities, such as vessel and aircraft traffic, that 

traverse the blocks listed below or Federal waters landward of the sale during periods of subsistence use 

regardless of lease location. Transit for human safety emergency situations shall not require adherence to 

this stipulation. This stipulation applies to the following blocks:

NR02-06, Chukchi Sea

6624, 6625, 6674, 6675, 6723-6725, 6773-6775, 6822, 6823, 6872

NR03-02, Posey

6872, 6873, 6918-6923, 6967-6973, 7016-7023, 7063-7073, 7112-7123

NR03-03, Colbert

6674, 6723, 6724, 6771-6774, 6820-6824, 6869-6874, 6918-6924, 6966-6974,

7015-7024, 7064-7074, 7113-7124

NR03-04, Solivik Island

6011-6023, 6060-6073, 6109-6122, 6157-6171, 6206-6219, 6255-6268, 6305-6317,

6354-6365, 6403-6414, 6453-6462, 6502-6511, 6552-6560, 6601-6609, 6651-6658,

6701-6707, 6751-6756, 6801-6805, 6851-6854, 6901-6903, 6951, 6952, 7001

NR03-05, Point Lay West

6014-6024, 6062-6073, 6111-6122, 6160-6171, 6209-6221, 6258-6269, 6307-6317,

6356-6365, 6406-6414, 6455-6462, 6503-6510, 6552-6558, 6602-6606, 6652-6655,

6702, 6703

NR04-01, Hanna Shoal

6223, 6267-6273, 6315-6323, 6363-6373, 6411-6423, 6459-6473, 6507-6523,

6556-6573, 6605-6623, 6654-6671, 6703-6721, 6752-6771, 6801-6819, 6851-6868,

6901-6916, 6951-6964, 7001-7010, 7051-7059, 7101-7107
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Shell Gulf of Mexico Inc. 11-10 March 2015

Revision 2

NR04-02, Barrow

6003-6022, 6052-6068, 6102-6118, 6151-6164, 6201-6214, 6251-6262, 6301-6312,

6351-6359, 6401-6409, 6451-6456, 6501-6506, 6551, 6552, 6601, 6602

NR04-03, Wainwright

6002-6006, 6052, 6053

NS04-08, (Unnamed)

6816-6822, 6861-6872, 6910-6922, 6958-6972, 7007-7022, 7055-7072, 7104-7122

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

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

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

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

timing, and methods of proposed operations and safeguards or mitigating measures that could be 

implemented by the operator to prevent unreasonable conflicts. Organizations currently recognized by 

the NMFS and the USFWS for the co-management of the marine mammals resources are the Alaska 

Eskimo Whaling Commission, the Alaska Beluga Whale Committee, the Alaska Eskimo Walrus 

Commission, the Ice Seal Commission, and the Nanuuq Commission. Through this consultation, the 

lessee shall make every reasonable effort, including such mechanisms as a conflict avoidance agreement, 

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

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

subsistence harvests.

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

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

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

scheduled and located to prevent unreasonable conflicts with subsistence activities. The lessee shall also 

include a discussion of multiple or simultaneous operations, such as ice management and seismic 

activities, that can be expected to occur during operations in order to more accurately assess the 

potential for any cumulative effects. Communities, individuals, and other entities who were involved in 

the consultation shall be identified in the plan. The RS/FO shall send a copy of the exploration plan or 

development and production plan (including associated oil-spill response plans) to the directly affected 

communities and the appropriate co-management organizations at the time the plans are submitted to the 

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

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

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

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

conflict and attempt to resolve the issues. The RS/FO will invite appropriate parties to a meeting if the 

RS/FO determines such a meeting is warranted and relevant before making a final determination on the 

adequacy of the measures taken to prevent unreasonable conflicts with subsistence harvests. The lessee 

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

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

necessary to prevent unreasonable conflicts with local subsistence hunting activities. In enforcing this 

stipulation, the RS/FO will work with other agencies and the public to assure that potential conflicts are 

identified and efforts are taken to avoid these conflicts. Subsistence-harvesting activities occur generally 

in the areas and time periods listed below.
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Revision 2

Subsistence Whaling and Marine Mammal Hunting Activities by Community

Barrow: Spring bowhead whaling occurs from April to June; Barrow hunters hunt from Ice leads from 

Point Barrow southwestward along the Chukchi Sea coast to the Skull Cliff area; fall whaling occurs 

from August to October in an area extending from approximately 10 miles west of Barrow to the east side 

of Dease Inlet. Beluga whaling occurs from April to June in the spring leads between Point Barrow and 

Skull Cliff; later in the season, belugas are hunted in open water around the barrier islands off Elson 

Lagoon. Walrus are harvested from June to September from west of Barrow southwestward to Peard Bay. 

Polar bear are hunted from October to June generally in the same vicinity used to hunt walruses. Seal 

hunting occurs mostly in winter, but some open-water sealing is done from the Chukchi coastline east as 

far as Dease Inlet and Admiralty Bay in the Beaufort Sea.

Wainwright: Bowhead whaling occurs from April to June in the spring leads offshore of Wainwright, 

with whaling camps sometimes as far as 10 to 15 miles from shore. Wainwright hunters hunt beluga 

whales in the spring lead system from April to June but only if no bowheads are in the area. Later in the 

summer, from July to August, belugas can be hunted along the coastal lagoon systems. Walrus hunting 

occurs from July to August at the southern edge of the retreating pack ice. From August to September, 

walruses can be hunted at local haulouts with the focal area from Milliktagvik north to Point Franklin. 

Polar bear hunting occurs primarily in the fall and winter around Icy Cape, at the headland from Point 

Belcher to Point Franklin, and at Seahorse Island.

Point Lay: Because Point Lay’s location renders it unsuitable for bowhead whaling, beluga whaling is 

the primary whaling pursuit. Beluga whales are harvested from the middle of June to the middle of July.

The hunt is concentrated in Naokak and Kukpowruk Passes south of Point Lay where hunters use boats to 

herd the whales into the shallow waters of Kasegaluk Lagoon where they are hunted. If the July hunt is 

unsuccessful, hunters can travel as far north as Utukok Pass and as far south as Cape Beaufort in search 

of whales. When ice conditions are favorable, Point Lay residents hunt walruses from June to August 

along the entire length of Kasegaluk Lagoon, south of Icy Cape, and as far as 20 miles offshore. Polar 

bears are hunted from September to April along the coast, rarely more than 2 miles offshore.

Point Hope: Bowhead whales are hunted from March to June from whaling camps along the ice edge 

south and southeast of the point. The pack-ice lead is rarely more than 6 to 7 miles offshore. Beluga 

whales are harvested from March to June in the same area used for the bowhead whale hunt. Beluga 

whales can also be hunted in the open water later in the summer from July to August near the southern 

shore of Point Hope close to the beaches, as well as areas north of the point as far as Cape Dyer.

Walruses are harvested from May to July along the southern shore of the point from Point Hope to 

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

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

Shell Proposed Actions:

Shell has actively engaged the NSB, NWAB, and the subsistence communities of Kaktovik, Nuiqsut, 

Barrow, Wainwright, Point Lay, Point Hope, Kivalina, Kotzebue, Shishmaref, Kiana, Savoonga, and 

Gambell, and co-management organizations, including the Alaska Eskimo Whaling Commission 

(AEWC), Alaska Beluga Whale Committee, the Alaska Eskimo Walrus Commission, the Ice Seal 

Commission, and the Alaska Nanuuq Commission, to discuss potential conflicts between planned oil and 

gas activities and subsistence use activities. Shell’s EP lease blocks do not lie within the stipulation area, 

but support activities associated with the exploration drilling program will transit the stipulation area.
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Plan of Cooperation 

Shell began consulting with potentially affected subsistence communities, stakeholders and federal, state, 

and local agencies in 2006 and prepared a POC for its Chukchi Sea open water activities (3D seismic 

activities and vessel transit) in November 2007. Shell has continued to consult through the date of 

submitting the final Revised EP 2. Shell will continue to engage with subsistence stakeholders to build 

on its past efforts to inform and engage the communities that could be potentially affected by exploration 

drilling activities in the Chukchi Sea. It is also noted that a POC is required for MMPA authorizations 

from NMFS and USFWS. Shell’s POC, 4MP, and other mitigation measures are designed to minimize 

adverse impacts to subsistence use activities.

Shell met with public and community leaders beginning in January-April 2009 specifically to discuss the 

planned 2010 exploration drilling program in the Chukchi Sea, as detailed in the initial Chukchi Sea EP, 

and to hear their concerns. Shell prepared a written POC based on that effort, which described when and 

where the meetings were held, what was presented by Shell, the comments received, and Shell’s 

responses to these comments. The POC also identified mitigation measures that Shell prepared in 

response to these concerns. A copy of the POC was attached as an appendix to the initial Chukchi Sea EP, 

and was forwarded to NMFS as part of the MMPA application. Shell’s consultation efforts have 

continued since that time, and in February-April of 2011, Shell held a series of meetings specifically to 

discuss the exploration drilling activities outline in the EP Revision 1. The dates and locations of the 

meetings held since 2012 as part of consultation effort associated with exploration drilling in the Chukchi

Sea, along with the persons Shell met with, are listed below in Table 11.0-1. Shell has prepared an 

addendum to the POC originally submitted. The POC addendum included with EP Revision 2 provides 

information on the meetings held specifically to address the EP Revision 2. The POC addendum is 

attached in Appendix D of this document.
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Revision 2

Table 11.0-1 Dates and Locations of Meetings Held Regarding Shell’s Chukchi Sea Exploration 

Drilling Program for the Development of the POC

2012 Meeting Location Meeting Attendees

23 October Point Lay Plan of Cooperation Community Meeting

24 October Wainwright Plan of Cooperation Community Meeting

26 October Kaktovik Plan of Cooperation Community Meeting

29 October Barrow Plan of Cooperation Community Meeting

30 October Nuiqsut Plan of Cooperation Community Meeting

6 November Barrow NSB Assembly Workshop Meeting

2013 Meeting Location Meeting Attendees

29 July Kotzebue NWAB, City of Kotzebue, KIC (Kikiktagruk Inupiat Corporation) & 

IRA(Indian Reorganization Act) representatives

5 November Barrow NSB Assembly

5 November Wainwright Plan of Cooperation Community Meeting

6 November Point Lay Plan of Cooperation Community Meeting

8 November Barrow Plan of Cooperation Community Meeting

12 November Point Hope Plan of Cooperation Community Meeting

2014 Meeting Location Meeting Attendees

28 January Kotzebue Plan of Cooperation Community Meeting

16 June Barrow Stakeholder Meeting

16 June Wainwright Stakeholder Meeting

30 June Barrow Plan of Cooperation Community Meeting

1 July Wainwright Plan of Cooperation Community Meeting

7 July Point Lay Plan of Cooperation Community Meeting

8 July Point Hope Plan of Cooperation Community Meeting

9 July Kotzebue Plan of Cooperation Community Meeting

17 July Deering Plan of Cooperation Community Meeting

3 November Barrow Plan of Cooperation Community Meeting

6 November Point Lay Plan of Cooperation Community Meeting

2015 Meeting Location Meeting Attendees – Position

12 January Kotzebue Plan of Cooperation Community Meeting

13 January Wainwright Plan of Cooperation Community Meeting

22 January Buckland Plan of Cooperation Community Meeting

22 January Deering Plan of Cooperation Community Meeting
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Marine Mammal Co-Management Groups

Shell facilitated meetings with the co-management groups including the AEWC, Alaska Beluga Whale 

Committee, the Alaska Eskimo Walrus Commission, the Ice Seal Commission, and the Alaska Nanuuq 

Commission beginning in June 2006, and continues to meet with these groups. Shell continues to meet

with representatives of these co-management groups to discuss our exploration drilling plans to inform 

them of Shell’s planned activities and discuss potential conflicts that could arise with regards to the siting, 

timing, and method of the planned operations as well as mitigation measures designed to avoid or 

minimize any such effects.

Stipulation No. 6 - Pre-Booming Requirements for Fuel Transfers

Fuel transfers (excluding gasoline transfers) of 100 barrels or more will require pre-booming of the fuel 

barge(s). The fuel barge must be surrounded by an oil-spill-containment boom during the entire transfer 

operation to help reduce any adverse effects from a fuel spill. The lessee’s oil-spill-response plans must 

include procedures for the pre-transfer booming of the fuel barge(s).

Shell Proposed Action: 

Shell has prepared a FTP that covers activities with its planned exploration drilling program in the 

Chukchi Sea. A copy of the plan is provided in Appendix I. Shell has revised the attached FTP from that 

was submitted to BOEM with EP Revision 1 to include a variety of booming scenarios depending on 

whether the fuel transfer is from vessel-to-vessel, vessel-to-drilling unit and dock-to-vessel.

Stipulation No. 7 - Lighting of Lease Structures to Minimize Effects to Spectacled and Steller’s 

eider

This stipulation will minimize the likelihood that spectacled and Steller’s eiders will strike drilling 

structures or vessels. The stipulation also provides additional protection to eiders within the blocks listed 

below and Federal waters landward of the sale area, including the Ledyard Bay Critical Habitat Area, 

during times when eiders are present.

(A) General conditions: The following conditions apply to all exploration activities.

(1) An EP must include a plan for recording and reporting bird strikes. All bird collisions (with 

vessels, aircraft, or drilling structures) shall be documented and reported within 3 days to MMS. 

Minimum information will include species, date/time, location, weather, identification of the vessel, 

and aircraft or drilling structure involved and its operational status when the strike occurred. Bird 

photographs are not required, but would be helpful in verifying species. Lessees are advised that the 

USFWS does not recommend recovery or transport of dead or injured birds due to avian influenza 

concerns.

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

drilling.

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

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

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

maximum extent practicable. If surface vessels must traverse this area during this period, 

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

(including at least three Breco buoys or similar devices) and personnel trained in its use; 

hazing equipment may located onboard the vessel or on a nearby oil spill response 

vessel, or in Point Lay or Wainwright. Lessees are required to provide information 

regarding their operations within the area upon request of MMS. The MMS may request 

information regarding number of vessels and their dates of operation within the area.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 11-15 March 2015

Revision 2

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

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

Critical Habitat Area between July 1 and November 15. Vessel travel within the Ledyard 

Bay Critical Habitat Area for emergencies or human/navigation safety shall be reported 

within 24 hours to MMS.

(c) Aircraft supporting drilling operations will avoid operating below 1,500 feet above 

sea level over the listed blocks or Federal waters between the listed blocks and the 

coastline between April 15 and June 10, or the Ledyard Bay Critical Habitat Area 

between July 1 and November 15, to the maximum extent practicable. If weather 

prevents attaining this altitude, aircraft will use pre-designated flight routes. 

Predesignated flight routes will be established by the lessee and MMS, in collaboration 

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

or human safety shall be reported within 24 hours to MMS.

(B) Lighting Protocols: The following lighting requirements apply to activities conducted between April 

15 and November 15 of each year.

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

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

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

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

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

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

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

exploration/delineation structures while operating on a lease or if staged within nearshore Federal 

waters pending lease deployment.

Measures to be considered include but need not be limited to the following:

• Shading and/or light fixture placement to direct light inward and downward to living and work 

structures while minimizing light radiating upward and outward;

• Types of lights;

• Adjustment of the number and intensity of lights as needed during specific activities;

• Dark paint colors for selected surfaces;

• Low-reflecting finishes or coverings for selected surfaces; and

• Facility or equipment configuration.

Lessees are encouraged to consider other technical, operational, and management approaches that 

could be applied to their specific facilities and operations to reduce outward light radiation. Lessees 

must provide MMS with a written statement of measures that will be or have been taken to meet the 

lighting objective, and must submit this information with an EP when it is submitted for regulatory 

review and approval pursuant to 30 CFR 550.203.

(2) Support Vessels: Surface support vessels will minimize the use of high-intensity work lights, 

especially when traversing the listed blocks and federal waters between the listed blocks and the 

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

during periods of darkness or inclement weather (such as rain or fog), otherwise they will be turned 

off. Interior lights and lights used during navigation could remain on for safety.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 11-16 March 2015

Revision 2

For the purpose of this stipulation, the listed blocks are as follows:

NR02-06, Chukchi Sea

6624, 6625, 6674, 6675, 6723-6725, 6773-6775, 6822, 6823, 6872

NR03-02, Posey

6872, 6873, 6918-6923, 6967-6973, 7016-7023, 7063-7073, 7112-7123

NR03-03, Colbert

6674, 6723, 6724, 6771-6774, 6820-6824, 6869-6874, 6918-6924, 6966-6974,

7015-7024, 7064-7074, 7113-7124

NR03-04, Solivik Island

6011-6023, 6060-6073, 6109-6122, 6157-6171, 6206-6219, 6255-6268, 6305-6317,

6354-6365, 6403-6414, 6453-6462, 6502-6511, 6552-6560, 6601-6609, 6651-6658,

6701-6707, 6751-6756, 6801-6805, 6851-6854, 6901-6903, 6951, 6952, 7001

NR03-05, Point Lay West

6014-6024, 6062-6073, 6111-6122, 6160-6171, 6209-6221, 6258-6269, 6307-6317,

6356-6365, 6406-6414, 6455-6462, 6503-6510, 6552-6558, 6602-6606, 6652-6655,

6702, 6703

NR04-01, Hanna Shoal

6223, 6267-6273, 6315-6323, 6363-6373, 6411-6423, 6459-6473, 6507-6523,

6556-6573, 6605-6623, 6654-6671, 6703-6721, 6752-6771, 6801-6819, 6851-6868,

6901-6916, 6951-6964, 7001-7010, 7051-7059, 7101-7107

NR04-02, Barrow

6003-6022, 6052-6068, 6102-6118, 6151-6164, 6201-6214, 6251-6262, 6301-6312,

6351-6359, 6401-6409, 6451-6456, 6501-6506, 6551, 6552, 6601, 6602

NR04-03, Wainwright

6002-6006, 6052, 6053

NS04-08, (Unnamed)

6816-6822, 6861-6872, 6910-6922, 6958-6972, 7007-7022, 7055-7072, 7104-7122

Nothing in this stipulation is intended to reduce personnel safety or prevent compliance with other 

regulatory requirements (e.g., U.S. Coast Guard (USCG) or Occupational Safety and Health 

Administration) for marking or lighting of equipment and work areas.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 11-17 March 2015

Revision 2

Shell Proposed Actions:

Stipulation No.7 has four parts. Part A(1) mandates that EPs for exploration drilling anywhere in the 

Chukchi include a plan for recording and reporting bird strikes, and therefore applies to Shell. Parts A(2) 

and B(2) place restrictions and lighting requirements on vessel and aircraft operations in certain listed 

blocks, in federal waters shoreward of those blocks, and in the Ledyard Bay Critical Habitat Unit 

(LBCHU), during specific dates. These restrictions would apply to any activities associated with Shell’s 

EP Revision 2 that would take place in these areas during these dates. Part B(1) places lighting 

requirements on drilling structures and applies to the use of drilling structures anywhere in the Chukchi 

Sea, and therefore applies to Shell’s EP Revision 2. Part B(2) also places restrictions on the use of lights 

on support vessels in the listed blocks and federal waters shoreward of these blocks, and these restrictions 

would apply to any vessel traffic associated with Shell’s EP Revision 2 that would occur in these specific 

areas.

Shell has developed a Bird Strike Avoidance and Lighting Plan (Appendix E) that covers the planned 

exploration drilling program. In developing the plan, Shell considered all the measures identified for 

consideration in the stipulation, and selected the most proven and practical measures to minimize the 

likelihood that marine birds will strike the drilling units or support vessels.

Shell’s plan includes:

• Bird strike monitoring will include recording and reporting bird strikes for the collection of 

information on bird strikes and lighting configuration. This information can be used to better 

understand methods to reduce bird strikes;

• Installing shading and directing some lights on drilling units inward and downward to living and 

work structures to minimize the amount of light radiating from the drilling units;

• Minimizing the use of high-intensity work lights on support vessels; and

• Restricting aircraft and vessel traffic such as restrictions on travel routes and flight altitudes, 

including: the avoidance of travel within the LBCHU between 1 July and 15 November by the 

drilling units and all support vessels.

The risk of Shell’s exploration drilling program having an effect on marine birds, especially Steller’s 

eiders and spectacled eiders, due to collisions, is minimal because exploration drilling would occur after 

the spring migration of most of these species, and more than 64 mi (103 km) offshore where the bird 

presence is relatively low.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 12-1 March 2015

Revision 2

SECTION 12.0 ENVIRONMENTAL MITIGATION MEASURE 

INFORMATION

a) Permits and Authorizations

The General Information section (Section 2.0) identifies the permits and authorizations required for the 

planned exploration drilling program. Shell will adhere to the mitigation measures required by these 

permits and authorizations. In addition to the permits and authorizations, Shell has met with marine 

mammal co-management groups, including the AEWC, Whaling Captains Associations, NSB and 

NWAB community members, to discuss their concerns regarding marine mammal subsistence resources 

including the bowhead whale, beluga whale, walrus, ice seal, and polar bear.

b) Protected Species

Species that occur within the northeastern Chukchi Sea and are listed under the ESA as either threatened or 

endangered are listed below in Table 12.b-1. The Kittlitz’s murrelet, yellow-billed loon, and Pacific walrus 

are included in the table only as candidate species. NMFS published a final rule listing the Arctic, Okhotsk, 

and Baltic subspecies of ringed seals as threatened and the Ladoga subspecies as endangered under the 

ESA (77 FR 76706-76738 December 28, 2012). The only subspecies that occurs in the northeastern 

Chukchi Sea is the Arctic subspecies.

Potential effects on these species due to activities associated with the planned exploration drilling program

in EP Revision 2, which includes the addition of simultaneous drilling by a second drilling unit, are 

analyzed in the EIA provided in Appendix C. The proposed mitigation measures, which have been designed

to avoid or minimize any effects on these species, are described below in Section 12.0(c).

Table 12.b-1 Species Found in the Northeastern Chukchi Sea and Protected Under the ESA

Common Name Scientific Name ESA Status Extralimital3 (Yes/No)

spectacled eider Somateria fischeri threatened No

Steller’s eider Polysticta stelleri threatened No

bearded seal 1,2

Erignathus barbatus (Beringia 

distinct population segment) candidate No

ringed seal Phoca hispida threatened No

Pacific walrus2 Odobenus rosmarus divergens candidate No

polar bear Ursus maritimus threatened No

bowhead whale Balaena mysticetus endangered No

fin whale Balaenoptera physalus endangered Yes

humpback whale Megaptera novaeangliae endangered Yes 1 Treated as candidate – threatened status vacated. 2 Pacific walrus and bearded seals are included in table only as a candidate species, which receive no protection under the ESA. 3 Extralimital - not found within a given geographic area

No critical habitat has been designated for the fin whale, humpback whale, and bowhead whale. Critical 

habitat has been designated for the Steller’s eider but none is located in the Chukchi Sea. Critical habitat has

been designated for the spectacled eider, with the nearest critical habitat being located in Ledyard Bay more 

than 54 mi (87 km) from the Burger Prospect. NMFS proposed critical habitat for the Arctic ringed seal in 

the northern Bering, Chukchi, and Beaufort Seas off of Alaska in December 2014.

The USFWS issued a final rule on 7 December 2010 designating three types of critical habitat for the polar 

bear; sea ice habitat, barrier island habitat, and terrestrial denning habitat; this polar bear critical habitat 

designation has since been vacated. Potential effects on critical habitat due to activities associated with the 

planned exploration drilling program are analyzed in the EIA provided in Appendix C.

The planned exploration drilling program would have no effect on spectacled eider critical habitat.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 12-2 March 2015

Revision 2

Table 12.b-2 Marine Mammals1 Found in the Northeastern Chukchi Sea and Protected Under the 

MMPA

Common Name Scientific Name ESA Status MMPA Status Extralimital 

(Yes/No)

beluga whale1 Delphinapterus leucas not listed -- No

narwhal Monodon monoceros not listed -- Yes

killer whale Orcinus orca not listed -- No

harbor porpoise Phocoena phocoena not listed -- No

bowhead whale Balaena mysticetus endangered depleted No

gray whale Eschrichtius robustus not listed -- Yes

fin whale Balaenoptera physalus endangered depleted Yes

minke whale Balaenoptera acutorostrata not listed -- Yes

humpback whale Megaptera novaeangliae endangered depleted Yes

bearded seal Erignathus barbatus (Beringia 

distinct population segment) candidate depleted No

spotted seal1 Phoca largha

Arctic population 

segments not 

listed

-- No

ringed seal Phoca hispida threatened depleted No

ribbon seal Histriophoca fasciata not listed No

Pacific walrus2 Odobenus rosmarus divergens candidate -- No

polar bear Ursus maritimus threatened depleted No 1 Populations of some species identified as not listed, such as beluga & spotted seal, are listed but those populations are not found in the Chukchi Sea.

2 Pacific walrus has been petitioned for listing under ESA, has undergone status review, and listing was found to be warranted but precluded by higher 

priorities – and is therefore considered a candidate species by USFWS.

In accordance with the MMPA, a walrus use area has been designated over Hanna Shoal (i.e. the HSWUA) 

located adjacent to Shell’s Burger Prospect. The HSWUA is a large area (approximately 9,500 mi2

) to the 

northeast of the Burger Prospect that the USFWS designated as an area utilized by Pacific walrus during the 

summer months.

The planned exploration drilling program will likely involve the non-lethal incidental take of marine 

mammals. The projected incidental takes are provided in Section 10.0 of this document. Shell has

submitted a MMPA application to the NMFS for the incidental take of whales and seals, and MMPA 

applications to the USFWS for the non-lethal incidental take of polar bears and Pacific walrus and 

intentional take of polar bears and Pacific walrus. The MMPA applications contain a 4MP, which is 

attached in Appendix B. The USFWS MMPA applications contain 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 E). All three of these documents describe mitigation measures that Shell 

will implement to minimize any effects on protected species. The authorizations may also contain added 

mitigation measures to help avoid or minimize incidental takes. A summary of mitigation measures that 

will be undertaken by Shell is provided below.

c) Mitigation 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 adhere to the mitigation measures required 

by these authorizations.

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. The preface of the EIA (Appendix C) provides details on mitigation measures that 

have been deleted, those that have been changed and those that have been added. The following is the 

current list of mitigation measures for EP Revision 2.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 12-3 March 2015

Revision 2

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 

Communications and Call Centers (Com Centers) to be located in coastal villages along the 

Chukchi Sea during Shell’s proposed exploration drilling activities.

• Shell will employ local subsistence advisors (SAs) from the Chukchi Sea villages that may be

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 SA per 

village, working approximately 8-hr per day and 40-hr weeks during the drilling seasons. The SA

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

the community and provide advice on ways to minimize and mitigate potential negative impacts 

to subsistence resources during the drilling season. Responsibilities include reporting any 

subsistence concerns or conflicts; coordinating with subsistence users; reporting subsistencerelated comments, concerns, and information; coordinating with the Com and Call Center 

personnel; and, advising how to avoid subsistence conflicts.

Aircraft Travel

• Aircraft over land or sea shall not operate below 1,500 ft. (457 m) altitude unless engaged in 

marine mammal monitoring, approaching, landing or taking off, in poor weather (fog or low 

ceilings), or 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 and 

SAs.

• Except in an emergency, aircraft will not operate at an altitude lower than 1,500 ft. (457 m) 

within 0.5 mi. (0.8 km) of polar bears when observed on land or ice.

• Helicopters will not operate at an altitude lower than 3,000 ft. (914 m) within 1 mi. (1.6 km) of 

walrus groups observed on land, and fixed-wing aircraft will not, except in an emergency, operate 

at an altitude lower than 1,500 ft. (457 m) within 0.5 mi. (805 m) of walrus groups observed on 

ice, or within 1 mile (1,610 m) of walrus groups observed on land.

• If aircraft must be operated below 1,500 ft. (457 m) because of weather, the operator will avoid 

areas of known walrus and polar bear concentrations and will take precautions to avoid flying 

directly over or within flying within 0.5 mi. (805 m) of these areas..

Vessel Travel

• The drilling units and support vessels anticipate they will enter the Chukchi Sea through the 

Bering Strait on or about 1 July4

, minimizing effects on marine mammals and birds that frequent 

open leads and minimizing effects on spring and early summer bowhead whale hunting.

• The transit route for the drilling units and drilling support vessels will avoid known fragile 

ecosystems and the LBCHU, and will include coordination through Com Centers.

 

4 See supra fn. 1.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 12-4 March 2015

Revision 2

• PSOs will be aboard the drilling units and all transiting support vessels.

• Except in an emergency, vessels will not approach within 0.5 mi. (0.8 km) of walruses or polar 

bears when observed on ice.

• Except in an emergency, vessels will not approach within 1.0 mi. (1.6 km) of groups of walruses 

or 0.5 mi. (0.8 km) of polar bears when observed on land.

• When within 900 ft. (274 m) of whales, vessels will reduce speed, avoid separating members 

from a group and avoid multiple changes of direction. 

• Vessels should take all reasonable precautions (i.e., reduce speed, change course heading) to 

maintain a minimum operational exclusion zone of 0.5 mi (0.8 km) around groups of 12 or more 

walruses in the water. 

• Vessel speed will be reduced during inclement weather conditions in order to avoid collisions 

with marine mammals.

• Shell will communicate and coordinate with the Com Centers regarding all vessel transits.

• Use of some lighting on the drilling units and support vessels will be minimized and shaded to 

reduce potential disorientation and attraction of birds and to reduce the possibility of a bird 

collision (Bird Strike Avoidance and Lighting Plan, Appendix E, EP Revision 2).

Exploration Drilling Operations

• 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 finish the critical operation before the arrival of the 

hazard at the drill site (Appendix F).

• The blowout prevention program will be enhanced through the use of two sets of blind/shear 

rams.

• For drill sites at which a MLC is drilled by bit, a ROV control panel will be SS, linked to the 

BOP by an umbilical, with sufficient pressured water-based fluid to operate the BOP. In the event 

the MLC is drilled by the MLC ROV system, no additional SS control panel is required as an 

ROV will have direct access to the BOP panel located in the MLC.

• Provisions for a second relief well drilling unit will be in-place in the event that the primary 

drilling vessel is disabled and not capable of drilling its own relief well. Both the Discoverer and 

Polar Pioneer will serve as its own primary relief well drilling unit. If the Discoverer or the Polar 

Pioneer cannot be used to drill a relief well, the other drilling unit (secondary relief well drilling 

unit) would be used for that purpose. The drilling units will be in the Lease Sale 193 Area 

operating as primary drilling units, or one may be no further distant than Dutch Harbor when the 

other drilling unit is drilling in hydrocarbon bearing zones. In either case, the secondary relief 

well drilling unit could be mobilized to the location in the Burger Prospect, moored, and drill a 

relief well and kill the flow within 38 days.

• Airgun arrays will be ramped up slowly during ZVSP surveys 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 PSOs 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 to 30 min: 15 min 

for small odontocetes and pinnipeds, or 30 min for baleen whales and large odontocetes.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 12-5 March 2015

Revision 2

Ice Management

• Real time ice and weather forecasting will be from the Shell Ice and Weather Advisory Center.

• Shell has developed and will implement an Adaptive Approach to Ice Management in Areas 

Occupied by Pacific Walruses (Appendix J).

Oil Spill Response

• The primary OSRV will be on standby at all times when drilling into zones capable of flowing 

liquid hydrocarbons in measurable quantities to ensure that OSR capability is available within 

one hour, if needed.

• Shell will deploy OSR support vessels capable of collecting oil on the water in excess of the 

calculated WCD flow rate of a blowout in the unlikely event that one should occur. The 

remaining OSR support vessels will be fully engaged within 72 hours.

• In addition to the OSR support vessels, oil spill containment equipment will be available for use 

in the unlikely event of a blowout. The containment system tugs and barge will be located in or 

near Goodhope Bay, Kotzebue Sound. This equipment is designed for maximum reliability, ease 

of operation, flexibility and robustness so it could be used for a variety of blowout situations. It is

anticipated that the containment system could arrive at the scene of a blowout and be capable of 

receiving hydrocarbons in eight days, depending on weather and the characteristics of the 

blowout.

• Capping stack equipment will be stored aboard one of the ice management vessels and will be 

available for deployment within 24 hours, depending on ice, weather and location, in the unlikely 

event of a blowout. Capping stack equipment consist of SS devices assembled to provide direct 

surface intervention capability with the following priorities:

o Attaching a device or series of devices (i.e. the capping stack) to the well to affect a seal 

capable of withstanding the MAWP and closing the assembly to completely seal the well 

against further flows (this intervention process is commonly called “Cap and Contain”), 

and

o Attaching a device or series of devices (i.e. the capping stack) to the well and diverting 

flow to surface vessel(s) (i.e. the containment system on the Arctic Challenger barge)

equipped for separation and disposal of hydrocarbons (this intervention process is 

commonly called “Cap and Flow”).

• A polar bear culvert trap has been constructed in anticipation of OSR needs and will be available 

prior to exploration drilling.

• Pre-booming will be conducted for all fuel transfers between vessels.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 12-6 March 2015

Revision 2

Air Emissions

• Procuring ULSD fuel or a fuel with equal or lower sulfur content to reduce SO2 emissions for each 

of the drilling units and all vessels operating as part of the exploration drilling program; and

• Establishing fuel restrictions on most of the propulsion and generators engines for the support 

vessels.

Appendix K provides a summary of the emission reduction measures and the resulting emissions reductions,

as applied in the AQRP analysis.

Shell has elected to present maximum projected emissions in the AQRP emissions inventory for the 30 CFR 

550.303(d) exemption formula analyses without consideration of existing emission controls as reduction 

measures on the Discoverer’s primary generation units or any of the support vessels. These emission 

controls include the following:

• selective catalytic reduction (SCR) emission controls to reduce NOX emissions on Discoverer’s primary 

generation units and certain units on support vessels;

• catalytic diesel particulate filters (CDPF) emission controls to reduce CO, particulate matter (PM), and 

VOC emissions on the Discoverer’s primary generation units and certain units on support vessels; and

• OxyCat emission controls to reduce CO, PM, and VOC emissions on certain units on support vessels.

The 30 CFR 550.303(d) exemption analyses in Section 7(e) conservatively assume the emission controls are 

not employed as emission reduction measures. As a result, Shell is not required to operate these controls, 

but is voluntarily committing to do so. Therefore, emissions reductions resulting from the voluntary 

commitment to operate the controls are not quantified in the AQRP emission inventories presented in 

Appendix K and thus no corresponding monitoring is proposed for these emission controls.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-1 March 2015

Revision 2

SECTION 13.0 SUPPORT VESSELS AND AIRCRAFT 

INFORMATION

a) Planned Vessel and Aircraft List

• Drilling units: Discoverer and Polar Pioneer

• Ice management vessels (x2) 

• Anchor handlers (x3) 

• OSVs (x3)

• Science vessels (x2)

• MLC ROV system vessel 

• Support tugs (x2)

• Shallow water vessels (x2) 

• Supply tugs (x2) and barges (x2) (one tug of which may have temporary duties 

accompanying the Discoverer during transiting to and from a drill site)

• OSRV (x1)

• OSR tugs (x2) and barges (x2)

• OSTs (x2)

• Containment system (tug [x2]and barge [x1]

• SAR helicopter

• Crew change/resupply helicopters (x3)

• Fixed wing aircraft for ice reconnaissance

• Fixed wing aircraft for PSO flights

• Fixed wing aircraft for crew change between Barrow and Wainwright

Drilling Units

The Discoverer and the Polar Pioneer will be the drilling units used to drill the wells on the Burger 

Prospect. The specifications for these drilling units are listed in Section 1c).

Support Vessels

The drilling units will be supported by the types of vessels listed in Table 13.a-1.

Oil Spill Response Vessels

The OSR support vessels will consist of those types of vessels listed in Table 13.a-2.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-2 March 2015

Revision 2

Table 13.a-1 Specifications of Support Vessel Types

Specification

Ice 

Management 

Vessels

(x2)1,2

Anchor

Handlers 

(x3)1,3

OSVs 

(x3)1,4

Science 

Vessels

(x2)1,5

Shallow 

Water Vessels

(x2)1,6

Support 

Tugs (x2)1,7

Supply Tug and 

Barges (x2)1,8

MLC 

ROV 

System 

Vessel Tug (x2) 1,9 Barge

(x2)

Length 380 ft.

(116 m)

361 ft.

(110 m)

300 ft.

(91.5 m)

300 ft.

(91.5 m)

85 ft.

(25.9 m)

146 ft.

(44.5 m)

150 ft.

(45.7 m)

400 ft.

(122 m)

280 ft. 

(85.3 m)

Width 85 ft.

(26 m)

80 ft.

(24.4 m)

64 ft.

(19.5 m)

64 ft.

(19.5 m)

20 ft.

(6.1 m)

46 ft.

(14 m)

40 ft.

(12.2 m)

99.5 ft.

(30.3 m)

60 ft.

(18.3 m)

Draft 27 ft.

(8.4 m)

28 ft.

(8.5 m)

19.6 ft.

(5.9 m)

19.6 ft.

(5.9 m)

4.5 ft.

(1.4 m)

21 ft.

(6.4 m)

19.5 ft.

(5.9 m)

25 ft.

(7.6 m)

16.5 ft.

(5 m)

Accommodations 77 64 50 50 50 13 11 -- 26

Maximum Speed 16 knots

(30 km/hr.)

15 knots

(28 km/hr.)

13 knots

(24 km/hr.)

13 knots

(24 km/hr.)

20 knots

(37 km/hr.)

16 knots

(30 km/hr.)

12 knots

(22 km/hr.) -- 13 knots

(24 km/hr.)

Available Fuel Storage 14,192 bbl

(2,256 m3

)

11,318 bbl

(1,799 m3)

5,786 bbl

(920 m3)

5,786 bbl

(920 m3)

43 bbl

(6.8 m3)

5,030 bbl

(799 m3)

4,800 bbl

(774 m3) -- 6,233 bbl

(991 m3

)

1 Or similar vessel

2 Based on Nordica 

3 Based on Aiviq 4 Based on the Harvey Champion 5 Based on the Harvey Champion 6 Based on the King C (formerly the Diana G) 7 Based on the tug Ocean Wave 8 Based on the Lauren Foss (tug) and Tuuq (barge) 9 Based on the Harvey Spirit
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-3 March 2015

Revision 2

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

Specifications OSRV 1,2

(x1)

Offshore OSR 1,3 Nearshore OSR 1,4 OST 1,5 (x1) OST 1,6 (x1) Containment System 1,7

Tug (x1) Barge (x1) Tug (x1) Barge (x1) Tug (x2) Barge (x1)

Length 301 ft.

(91.9 m)

136 ft.

(41.4 m)

333 ft.

(101.5 m)

90 ft.

(27.4 m)

205 ft.

(62.5 m)

748 ft.

(228 m)

813 ft.

(248 m )

150 ft.

(45.7 m)

316.5 ft.

(96.5 m)

Width 60 ft.

(18.3 m)

37 ft.

(11.2 m)

76 ft.

(23.1 m)

32 ft.

(9.8 m)

90 ft.

(27.4 m)

105 ft.

( 32 m)

141 ft.

(48 m)

40 ft.

(12.2 m)

105 ft.

(32 m)

Draft 19 ft.

(5.8 m)

20 ft.

(6.0 m)

22 ft.

(6.7 m)

10 ft.

(3 m)

15 ft.

(4.6 m)

66 ft.

(20 m)

69 ft.

(21 m)

19.5 ft.

(5.9 m)

12.5 ft.

(3.8 m)

Accommodations 41 10 -- 8 -- 25 25 11 72

Maximum Speed 16 knots

(30 km/hr.)

12 knots

(22 km/hr.) -- 12 knots

(22 km/hr.) -- 15 knots

(28 km/hr.)

15 knots

(28 km/hr.)

10 knots

(19 km/hr.) --

Available Fuel 

Storage

7,692 bbl

(1,223 m3

)

3,690 bbl

(586 m3)

3,857 bbl

(616 m3)

1,286 bbl

(204.5 m3) -- 16,121 bbl

(2,563 m3

)

20,241 bbl

(3,218 m3)

4,800 bbl

(763 m3)

6,630 bbl

(1,054 m3)

Available Liquid 

Storage

12,245 bbl

(1,947 m3

) -- 76,900 bbl

(12,226 m3

) -- 17,000 bbl

(5,183 m3

)

106,000 bbl8

(16,852 m3

)

670,000 bbl

(106,518 m3) -- --

Workboats (3) 34 ft.

work boats -- -- --

(1) skim boat 

47 ft. (14 m)

(3) work 

boats 34 ft. 

(10 m)

(4) minibarges

-- -- -- --

1 Or similar vessel

2 Based on the Nanuq 3 Based on the tug Guardsman (tug) and Klamath (barge) 4 Based on the Point Oliktok (tug) and Endeavor (barge) 5 Based on a Panamax type tanker

6 Based on an Aframax type tanker

7 Based on the Corbin Foss (tug), Arctic Challenger (barge) 8 Total available storage is 350,000 bbl; however, 244,000 bbl of ULSD or a fuel with equal or lower sulfur content (used to refuel the drilling units and support vessels) will take up storage space, 

leaving 106,000 bbl for recovered liquid ds. Storage space for recovered liquids will increase as fuel is dispensed for refueling.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-4 March 2015

Revision 2

Photograph of an Ice Management Vessel

Two primary ice management vessels will support the 

drilling units (photograph of the M/V Nordica). These 

vessels will enter and exit the Chukchi Sea with the drilling 

units or before and will generally remain in the vicinity of 

the drilling units during the drilling season. Ice management 

and ice reconnaissance is expected to occur at distances of 

20 mi (32 km) and 30 mi (48 km) respectively. However, 

these vessels may have to expand beyond these ranges 

depending on the ice conditions.

Photograph of an Anchor Handler

Three anchor handlers (photograph of the Aiviq) will support 

the drilling units and the containment system tugs and barge. 

These vessels will enter and exit the Chukchi Sea with the 

drilling units or before, and will generally remain in the 

vicinity of the drilling units during the drilling season. When 

not anchor handling, these vessels will be available to 

provide other general support if needed.

Photograph of an OSV

The planned exploration drilling operations will require 

three OSVs for resupply of the drilling units and 

support vessels. Drilling materials, food, fuel and other 

supplies will be picked up in Dutch Harbor (with 

possible minor resupply coming out of Kotzebue) and 

transported to the drilling units and support vessels.

Shell plans to use up to two science vessels to monitor 

discharges from the drilling units during drilling. The 

science vessel specifications are based on a large OSV 

(Harvey Champion [photograph] or similar) but may be 

a smaller vessel. This vessel will help sample drilling 

discharges that are defined in the EPA NPDES 

exploration facilities GP AKG-28-8100.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-5 March 2015

Revision 2

Photograph of a Shallow Water Vessel

Photograph of a Support Tug

Two support tugs will tow the Polar Pioneer to the Burger 

Prospect (photograph of the Ocean Wave). After the Polar

Pioneer is moored, the tugs will remain in the vicinity of 

the drilling units to help move them in the event that either 

drilling unit has to be moved off a drilling site due to ice or 

any other event. 

Photograph of a Supply Tug

Shell plans to use two tugs and supply barges (photograph 

of the tug Lauren Foss) that may be based in Kotzebue 

Sound. The barges will house well material for the drilling 

vessels and for the containment system tugs and barge, 

provide contingency accommodations for personnel in 

Kotzebue Sound, and carry mooring equipment for the 

containment system barge.

Shell also plans to use an OSV type vessel to support an 

MLC ROV system that may be used to construct some of 

the MLCs. If used, this vessel will be located at a drill site 

on the Burger Prospect. When not in use, the vessel will be 

outside of the Chukchi Sea lease sale planning area.

Shell plans to use two shallow water vessels, based in 

Kotzebue Sound (photograph of the Diana G, now 

known as the King C). These vessels will be used to 

transport supplies and crew between Kotzebue and the 

vessels moored in Kotzebue Sound. These vessels will 

have a shallow draft and be capable of entering shallow 

water. 
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-6 March 2015

Revision 2

Photographs of OSRV

An OSRV such as the Nanuq (or similar) will be 

staged in the vicinity of the drilling units when 

either is drilling in liquid hydrocarbon bearing 

zones. This will enable the OSRV to 

immediately respond to a spill and provide 

containment, recovery, and storage for the initial 

operational period following a spill event.

Photographs of Offshore OSR Tug and Barge

An OSR tug and barge, (photograph of the Guardsman tug and Klamath barge), will be staged in the 

Chukchi Sea. Together with the OSRV, it will have sufficient containment, recovery, and storage capacity 

for the initial operational period in the event of a spill.

Photograph of an OST

Shell plans to use up to two OSTs (photograph of a Panamax 

tanker). As planned, one OST with specifications of a 

Panamax tanker will be staged in the vicinity of the Burger 

Prospect. This tanker will hold fuel for Shell’s drilling units 

and support vessels in addition to storage space to store 

collected recovered liquids if there is a well control event. A 

second OST, with specifications of an Aframax tanker, will 

be stationed in the Chukchi Sea lease sale planning area. The 

Aframax tanker will be sited such that it will be able to 

respond to a well control event before the Panamax tanker 

reaches its recovered liquid capacity.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-7 March 2015

Revision 2

Photograph of a nearshore Tug and Barge

A tug and barge (Photograph of the Endeavor barge) 

will be used for nearshore OSR. It will carry a 47 ft. (14

m) skimming vessel, three 34 ft. (10 m) workboats, four 

mini-barges, boom, and duplex skimming units for 

nearshore recovery. This tug and barge will be moored 

in or near Goodhope Bay in Kotzebue Sound.

Photograph of containment system barge

Shell’s oil spill containment system, housed on the Arctic 

Challenger barge, will be accompanied by two tugs, 

likely the Corbin Foss and a similar tug. The 

containment system tugs and barge will be moored in or 

near Goodhope Bay in Kotzebue Sound.

Kotzebue Sound Mooring Location

There are four proposed mooring locations for vessels that will be stationed in Goodhope Bay, Kotzebue 

Sound. These locations are in the vicinity of the potential place of refuge (PPOR) in the Northwest Alaska 

Subarea Plan (e.g., approximately 66° 13’ N 163° 28’ W), which is in excess of 7 mi (11 km) from land,

in a water depth of approximately 30 ft. (9 m). The proposed mooring locations are:

• Approximately longitude 66o 13.658’ N and latitude 163o 28.138’ W

• Approximately longitude 66o 12.986’ N and latitude 163o 27.989’ W

• Approximately longitude 66o 13.037’ N and latitude 163o 26.305’ W

• Approximately longitude 66o 13.704’ N and latitude 163o 26.523’ W

Setting of four mooring buoys is anticipated with each buoy having up to three anchors. The vessels 

expected to moor in this location include the containment system tugs and barge, nearshore OSR tug and 

barge, and two supply tugs and barges.

The mooring locations in Goodhope Bay in the western portion of Kotzebue Sound were selected based 

on detailed evaluations of environmental and traditional knowledge information regarding subsistence 

activities in this area of southwest Kotzebue Sound. The site of these four, closely spaced, temporary 

mooring locations were selected in large part because the area has been selected and approved by the 

State of Alaska as a potential place of refuge (PPOR) in addition to traditional knowledge. The review 

process for selecting PPORs considers the existence of sensitive resources such as historic properties. SS

surveys have not been conducted at the location, but it is the conclusion of an archaeological review 
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-8 March 2015

Revision 2

requested by Shell that there is low potential for any effects to historic resources from the planned 

moorings and staging in Goodhope Bay. Shell visited the local communities in January 2014 (Kotzebue), 

July 2014 (Kotzebue and Deering) and in January 2015 (Kotzebue, Deering and Buckland) and informed 

local residents of Shell’s proposed activities, including the mooring of vessels in Goodhope Bay, 

southwest Kotzebue Sound. During these community meetings (Appendix D) the residents did not raise 

concerns that the mooring of the vessels would cause disturbance to subsistence resources or subsistence 

use. Shell will employ SAs and CLOs in nearby communities to mitigate potential disturbances to 

subsistence issues that may arise. In addition, Shell will establish a Communication Center (Com Center) 

in Kotzebue. The SAs and CLOs will be hired, and the Com Center established prior to Shell vessels 

entering Kotzebue Sound.

Shell selected the area in large part because it has been selected and approved as a PPOR. The review 

process for selecting PPORs considers the existence of sensitive resources such as historic properties. 

Subsea surveys have not been conducted at the location, but it is the conclusion of an archaeological 

review requested by Shell that there is low potential for any effects to historic resources from the planned 

moorings and staging in Goodhope Bay.

Vessels will remain compliant with the existing waste management plan, MARPOL regulations, and 

NPDES Vessel GP for any discharge of gray water or effluent. Crew changes will occur throughout the 

season using shallow water vessels (yet to be contracted) transiting out from Kotzebue to the vessel 

locations in Kotzebue Sound. Vessels may also receive resupply of food stores via a shallow water vessel.

Shell plans to refuel the support vessels moored in or near Goodhope Bay, Kotzebue Sound at least once 

during the drilling season. It is anticipated that the support vessels will require approximately 250,000 gal 

(5,950 bbl) of ULSD (or other fuel with equivalent or lower sulfur content). Refueling will be done with 

an OSV or other support vessel capable of transferring fuel and will follow the procedures outlined in the 

FTP. The shallow water landing crafts may be fueled dockside at Kotzebue by a commercial entity.

Aircraft

Offshore operations will be serviced by up to three helicopters operated out of an onshore support base in 

Barrow. Sikorsky S-92s (or similar) will be used to transport crews between the onshore support base and 

the drilling units and support vessels with helidecks. The helicopters will also be used to haul small 

amounts of food, materials, equipment, samples between vessels and the shorebase. Approximately 40 

Barrow-Burger Prospect round trip flights will occur each week (up from approximately 12/week in EP 

Revision 1) to support the additional crew change necessities for another drilling unit and support vessels 

and required sampling and analytical requirements under the NPDES exploration facilities GP.

Generalized flight corridors over the onshore and nearshore areas are indicated on Figure 13.e-2. The 

route chosen will depend on weather conditions and whether subsistence users are active on land or at sea. 

These routes may be modified depending on weather and subsistence uses.

Shell will also have a dedicated helicopter for Search and Rescue (SAR). The SAR helicopter is expected 

to be a Sikorsky S-92 (or similar). This aircraft will stay grounded at the Barrow shorebase location 

except during training drills, emergencies, and other non-routine events. The SAR helicopter and crews 

plan training flights for approximately 40 hr./month.

A fixed wing propeller or turboprop aircraft, such as Saab 340-B, Beechcraft 1900, or De Havilland Dash

8, will be used to transport crews, materials, and equipment between Wainwright and hub airports such as 

Barrow or Fairbanks. Additionally, rotary winged S-92s (or similar) in Barrow may provide crew 

transport between Barrow and Wainwright. It is anticipated that there will be one round trip flight every 

three weeks.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-9 March 2015

Revision 2

A fixed wing aircraft, Gulfstream Aero Commander (or similar), will be used for PSO flights (aka 

offshore aerial wildlife monitoring flights). PSO flights will take place daily depending on weather 

conditions. PSO flight paths are located in the 4MP (Appendix B).

An additional Gulfstream Aero Commander will be used to provide ice reconnaissance flights to monitor 

ice conditions around the Burger Prospect. Typically, the flights will focus on the ice conditions within 50 

mi (80 km) of the drill sites, but more extensive ice reconnaissance may occur beyond 50 mi (80 km). 

These flights will occur at an altitude of approximately 3,000 ft. (915 m).

Fuel Storage Information and Frequency of Trips

The frequencies of trips the above-referenced marine vessels and aircraft would be expected to make 

during the planned exploration drilling program are listed below in Table 13.a-3.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-10 March 2015

Revision 2

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

Vessel Type

Maximum Fuel Tank 

Storage Capacity

(each vessel)

Trip Frequency or Duration/Location

Marine Support Vessels (or similar)

Ice management vessels (x2) 14,192 bbl

(2,256 m3)

Will remain in the vicinity of the drilling 

units until its mission is finished

Anchor handlers (x3) 11,318 bbl

(1,799 m3

)

Will remain in the vicinity of the drilling 

units until its mission is finished; may 

occasionally assist in Kotzebue Sound

OSVs (x3) 5,786 bbl

(920 m3

)

Up to 30 round trips (combined for all 

OSVs) for resupply between drilling unit 

and Dutch Harbor/Kotzebue during each 

exploration drilling season 

Supply Tugs (x2) and barges (x2) 4,800 bbl

(774 m3

)

Will generally remain in Kotzebue 

Sound for storage; one tug may 

accompany the Discoverer when 

transiting to/from a drill site

Support Tugs (x2) 5,585 bbl

(888 m3) Support for the Polar Pioneer

Science Vessel (x2) 5,786 bbl

(920 m3)

Will remain in the vicinity of the drilling 

units until its mission is finished

MLC ROV system vessel 6,233 bbl

(991 m3)

Located on the prospect establishing 

MLCs ahead of the drilling units

Shallow water vessels (x2) 43 bbl

(6.8 m3)

Occasional trips as needed in vicinity of 

Kotzebue 

OSR Support Vessels (or similar)

OSRV 7,692 bbl

(1,223 m3)

Will remain in the vicinity of the drilling 

units until its mission is finished

OSR tug (x1) and barge (x1) (offshore) 1,786 bbl

(284 m3)

Will remain in the vicinity of the drilling 

units until its mission is finished

OSR tug (x1) and barge (x1) (nearshore) 1,286 bbl

(204.5 m3) Staged in Kotzebue Sound

OST (Panamax) 16,121 bbl

(2,563 m3)

Will remain in the vicinity of the drilling 

units until its mission is finished

OST (Aframax) 20,241 bbl

(3,218 m3)

Stationed in the Chukchi Sea lease sale 

planning area

Containment system tugs (x2) and barge (x1) 6,630 bbl

(1,054 m3) Staged in Kotzebue Sound

Aircraft (or similar)

Saab 340 B, Beechcraft 1900, or Dash 8 

fixed-wing or similar (x1) – transport from 

shorebase to regional jet service in Barrow

9 bbl

(1.4 m3

)

1 trip every 3 weeks between 

Wainwright and Barrow or Anchorage

Gulfstream 690 Aero Commander (or 

similar) (x2)

9 bbl

(1.4 m3

)

PSO flights and ice reconnaissance; both 

to occur daily when possible

Helicopter S-92 (or similar) (x3) for crew 

rotation & groceries/supply

18 bbl

(2.9 m3

)

Approximately 40 trips/ week between 

Barrow and the Burger Prospect 

(approximately 3.0 hr./trip)

Helicopter S-92 (or similar) – Search-andRescue (x1)18 bbl

(2.9 m3

)

Stationed in Barrow – 40 hr./month for 

proficiency training & trips made in 

emergency
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-11 March 2015

Revision 2

b) Air Emissions

Projected air emissions from support vessels are indicated below in Table 13.b-1 and are discussed in 

more detail in Section 7.0 and Appendix K of this document.

Table 13.b-1 Project Annual Air Pollutant Emissions (Tons Per Year) from Support Vessels 

Associated with the Drilling Units

Vessels NOx CO PM10 PM2.5 VOC SO2

Ice Management Vessels (x2) 234 79 12 12 11 2

Anchor Handler Vessels (x3) 423 90 18 18 25 3

Science Vessels (x2) 111 45 5 5 10 1

Support Tugs (x2) & Supply Tug (x1) 172 22 6 6 13 1

OSVs (x2) 70 14 7 7 5 1

OSRV 117 44 8 8 6 1

OSR Workboats (x3) 18 5 0.4 0.4 5 0.2

OSR Tug (x1) and Barge (x1) 60 13 3 3 3 0.2

Oil Storage Tanker 156 35 12 12 8 2

MLC ROV system Vessel 145 44 3 3 6 1

Attachment A of Appendix K lists the source, composition, frequency and duration of air emissions 

associated with support vessels that will be within 25 mi (40 km) of the drilling units while each are 

anchored at a drilling location. 

c) Drilling Fluids and Chemical Products Transportation

Each drilling unit will be preloaded with drilling fluids and other chemicals (Section 6.0) to be used for 

exploration drilling before being mobilized to the Burger Prospect at the start of each exploration drilling 

season. Any required additional drilling fluid components will be transported to the drilling unit via an 

OSV or tug and barge.

d) Solid and Liquid Wastes Transportation

An incinerator will be aboard each drilling unit and will be used to dispose of combustible municipal 

solid wastes. Authorized wastes will be discharged to the Chukchi Sea under the NPDES exploration 

facilities GP. The remaining wastes will be transported out of the Chukchi Sea by OSVs and disposed of 

at an approved disposal facility. Food wastes associated with the drilling vessels will be incinerated but, if 

conditions warrant, may be shipped out of the Arctic for disposal at a licensed facility. Descriptions of the 

transportation methods and a brief description of the composition, quantities, and destinations of the solid 

and liquid wastes to be transported by vessel from the drilling units are provided below in Table 13.d-1.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-12 March 2015

Revision 2

Table 13.d-1 Onshore Waste Disposal Facilities, Waste Type, Amount, Rate, and Disposal Method

Name/Location of 

Disposal Facilities Type of Waste Amount Disposal Method

Waste Management Inc. 

Columbia Ridge Landfill, 

Arlington, OR (Subtitle D 

landfill)

Household trash (municipal 

solid waste [MSW]) only

Drilling Units: 17,000 lb. 

(8,500 lb./ month/drilling unit)

Support Vessels: 23,454 

lb./month

Landfill

Waste Management Inc. 

Chemical Waste 

Management, Arlington, 

OR (Subtitle C landfill)

Non-hazardous waste solids 

– including CESQG-exempt 

wastes (oily rags, unused 

chemicals, aerosols, 

batteries, lamps, cement, 

incinerator ash, etc.)

Drilling Units: 12,100 lb. 

(6,050 lb./ month/drilling unit -

includes approximately 50 

lb./month/ drilling unit of 

CESQG-exempt waste)

Support Vessels: 4,765 

lb./month

Landfill or 

Recycle

Marine Vacuum Service 

Inc. Seattle WA, - or 

Emerald Services, Inc., 

Seattle, WA or Thermo 

Fluids Portland, OR

Non-hazardous liquids in 

bulk shipments (bilge water, 

vessel slops, brine water)

Drilling Units: 100,000 lb. 

(50,000 lb./ month/drilling unit)

Support Vessels: 123,975 lb. 

/month

Treat and Recycle

Seattle Iron & Metals 

Corp. Seattle WA, or 

Schnitzer Steel Industries, 

Anchorage, AK

Non Hazardous Waste 

Solids - Scrap Metal 

(uncontaminated scrap steel 

only)

Drilling Units: 13,000 lb. 

(6,500 lb./ month/drilling unit)

Support Vessels: 1,220 

lb./month

Recycle

e) Vicinity Map and Travel Routes

The locations of the planned exploration drilling activities relative to the shoreline and shorebase facilities 

and the primary route of the drilling units and routes of support vessels when entering and exiting the 

Chukchi Sea are indicated in Figure 13.e-1. Generalized flight corridors that helicopters would take 

between the shorebase and the Burger Prospect are indicated in Figure 13.e-2. The primary helicopter 

route between shorebase and the Burger Prospect is from the Barrow airport, directly offshore to the 

Burger Prospect. Helicopters would alternatively travel between Wainwright and the Burger Prospect 

under special circumstances. The planned use of Wainwright as a shorebase facility is only for the drilling 

seasons covered by EP Revision 2, and do not necessarily reflect Shell’s planned shorebase operations in 

the extended term.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-13 March 2015

Revision 2

Figure 13.e-1 Marine Vessel Routes
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13-14 March 2015

Revision 2

Figure 13.e-2 Flight Corridors
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 14-1 March 2015

Revision 2

SECTION 14.0 ONSHORE SUPPORT FACILITIES 

INFORMATION

a) General

Barrow Facilities

Shell plans to 1) maintain the existing 75-person man camp and kitchen/dining/recreation (KDR) area; 

and 2) lease / utilize additional accommodation opportunities in Barrow, which may include an existing 

40-person Ukpeaġvik Iñupiat Corporation (UIC) construction camp. Additional blocks of hotel rooms and 

other accommodations may be used if required. The two pads where the 75-person and 40-person camps 

are located are in the Naval Arctic Research Laboratory (NARL) area approximately 4.0 mi from the 

center of Barrow, and are located approximately 0.75 mi from each other (Figure 14.a-1). Passenger 

processing facility expansion is planned for the Barrow airport area, to be completed prior to the 

commencement of the next exploration drilling season (Figures 14.a-2 and -3).

Shell’s 75-person man camp consists of skid-mounted modular buildings. The camp is supported by a 

KDR unit, capable of providing meals for up to 200 persons, is approximately 166 ft. long by 64 ft. wide 

and is located on the pad at the southwest corner of the existing accommodations (Figure 14.a-4). The 

KDR provides service to all Shell and contractor employees in Barrow supporting Shell’s exploration 

drilling program.

The 75-person camp and KDR unit have been permitted by UIC with the NSB with a Development 

Permit and a fill permit, and with the SOA Fire Marshal. In addition, UIC has obtained a Preapproved 

Emission Limit (PAEL) from the Alaska Department of Environmental Conservation (ADEC). The 

PAEL establishes an annual limit on diesel fuel usage for the 75-person camp and KDR unit which limits 

potential emissions below permitting thresholds. No State or Federal permits were required.

The UIC 40-person construction camp will be relocated by UIC from its existing location in Barrow to a 

similar sand pad constructed by the U.S. Navy in 1940’s (Figure 14.a-1). The modular accommodations 

owned by UIC are currently unused and reside in Barrow. They will be moved to the pad and installed on 

pad pilings. Permitting of this facility is not Shell’s responsibility as the facilities are not Shell’s. Shell 

will only lease the facilities once installed at the new location.

Solid and liquid wastes that will be generated by these facilities are discussed in Section 14 c).

Wainwright Facilities

Shell reserves rooms at the existing Olgoonik Oil Field Services Camp in Wainwright (Figure 14.a-5). 

Shell’s OSR group will be housed and fed at these facilities. Shell may utilize a larger camp of up to 55 

accommodations to accommodate certain contingencies such as Shell conducting crew changes through 

Wainwright, or onshore environmental studies in the area. At this time this would involve only the 

potential reservation of additional rooms. 

An existing secure yard approximately 100’ x 300’ has been leased from Olgoonik Oilfield Services, 

owned by Olgoonik Corporation, for storage of OSR equipment and load staging for the marine vessels in 

Wainwright. An additional existing yard space approximately 150 ft. x 200 ft. has been leased from 

Olgoonik Oilfield Services, owned by Olgoonik Corporation, for additional response equipment storage.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 14-2 March 2015

Revision 2

Kotzebue Facilities

To service vessels moored in Goodhope Bay (Kotzebue Sound), Shell will conduct crew changes between 

the vessels via Kotzebue. In addition to these vessels, Kotzebue Sound may also be used to resupply and 

crew change OSVs. Shell may utilize approximately 25 rooms in Kotzebue. Shell will lease storage 

facilities for groceries and materials in Kotzebue.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 14-3 March 2015

Revision 2

Figure 14.a-1 Barrow Camp Locations
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 14-4 March 2015

Revision 2

Figure 14.a-2 Barrow Hangar and Passenger Processing Facility
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 14-5 March 2015

Revision 2

Figure 14.a-3 Barrow Proposed Passenger Processing Facility Expansion
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 14-6 March 2015

Revision 2

Figure 14.a-4 Barrow 75 Man Camp Location
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 14-7 March 2015

Revision 2

Figure 14.a-5 Wainwright Camp Location
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 14-8 March 2015

Revision 2

b) Air Emissions

Air emissions are attributable to the operation of the man camp, airport facilities and vehicle use in 

Barrow, Alaska. Table 14.b-1 provides the anticipated hourly air emissions associated with the onshore 

facilities in Barrow. Table 14.b-2 provides the anticipated seasonal (or annual) air emissions associated 

with the Barrow onshore facilities. Shell will have oil spill contingency response personnel stationed in 

Wainwright but there are no planned major activities that will contribute to air emissions. Shell onshore 

support activities in Kotzebue will utilize existing infrastructure and therefore will not contribute to air 

emissions beyond normal use. Appendix K provides a detailed explanation of the activities and lists the 

source, composition, frequency and duration of air emissions.

Table 14.b-1 Hourly Air Emissions Associated with Onshore Facilities in Barrow, Alaska

Emission Unit NOX

lb./hr.

CO

lb./hr.

PM10

lb./hr.

PM2.5

lb./hr.

VOC

lb./hr.

SO2

lb./hr.

Aircraft Support 5.2 33.5 1.1 1.1 24.8 1.5

Hangar/Storage 

Building 0.5 0.4 3.7E-2 3.7E-2 2.7E-2 2.9E-3

NARL

Man Camp 17.6 6.8 0.5 0.5 2.3 0.1

Vehicles 1.3E-2 1.1E-2 4.5E-5 4.5E-5 1.7E-3 3.4E-5

Table 14.b-2Annual Air Emissions Associated with Onshore Facilities in Barrow, Alaska

Emission Unit NOX

ton/year

CO

ton/year

PM10

ton/year

PM2.5

tons/year

VOC

ton/year

SO2

ton/year

Aircraft Support 0.6 4.3 0.1 0.1 4.4 0.2

Hangar/Storage 

Building 0.4 0.3 2.7E-2 2.7E-2 1.9E-2 2.1E-3

NARL Man 

Camp 29.2 8.2 0.7 0.7 2.6 0.2

Vehicles 5.7E-3 4.3E-3 2.6E-5 2.6E-5 6.3E-4 2.0E-5
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 14-9 March 2015

Revision 2

c) Unusual Solid and Liquid Wastes

Barrow Facilities

Blackwater (sewage) and graywater (showers, kitchen) from the two camps will be held in holding tanks 

at each site. Based on a camp occupancy of 100 percent of capacity, and average per capita waste 

generation factors provided by the local utility, Shell expects to generate about 2,300 gal of combined 

blackwater and graywater wastes per day. These wastes will be picked up by the NSB during routine 

service and treated in their waste water plant. These wastes generated by camps with temporary 

population of 115 persons, will not tax Barrow’s municipal wastewater treatment system, which 

accommodates a population of over 4,000 people, and consists of a series of large water treatment 

lagoons.

Household trash from the camps will be stored in bear proof containers or areas for all locations. These 

household wastes will be set up for collection by NSB’s regular dumpster service, and will be disposed of 

at the NSB Landfill. Shell estimates, based on 2012 Barrow operations and accounting for the additional 

planned camp accommodations, that the two man camps may generate up to 600 cubic yards (cu yd) of 

household trash per season, which represents less than 1.3 percent of the average annual volumes 

disposed of at the landfill.

Non-household waste generated at the camps will be stored in a 20 ft. shipping container set up as a waste 

accumulation area located behind the primary camp. The accumulation area will hold any hazardous, nonhazardous and liquid wastes. All of Shell’s Barrow facilities are operated as a CESQGs of Hazardous 

Waste by the EPA, and therefore a permit is not required and hold times do not apply. These wastes will 

be transported out of the Arctic and disposed of at licensed facilities.

Wainwright Facilities

With the exception of food waste from the camp kitchen, all wastes generated at the Wainwright camp 

(Figure 14.a-5) will be containerized and transported out of the Arctic to a licensed facility. Food wastes 

from the kitchen will be disposed in the Wainwright landfill. This approach to waste handling will 

minimize the impact to the community, including the landfill. Based on water usage information provided 

by the Alaska Department of Environmental Conservation (ADEC) website, it is estimated that Shell’s 

OSR group housed in Wainwright will generate less than 200 gal of black and gray water per day on 

average. This equates to approximately 2% of the estimated average generation rate for the entire village, 

based on a 2012 population of 575.

All wastes generated at the Wainwright OSR yard will be containerized and transported out of the Arctic 

to an approved disposal facility. This approach to waste handling will minimize the impact to the 

community, including the landfill.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 14-10 March 2015

Revision 2

Kotzebue Facilities

Waste generated on the marine vessels supporting Shell’s operations in Kotzebue Sound will be collected, 

segregated, stored, labeled and manifested onboard the vessels in accordance with each vessel’s Waste 

Management Plan. Each vessel will store household waste in super sacks, which will be removed, as 

needed, in coordination with resupplies and transported to the Port of Kotzebue. The household trash will 

be unloaded to dedicated dumpsters for transportation to the Kotzebue landfill. All other waste will 

remain on the vessels to be containerized and transported to a Shell approved disposal facility in the 

Pacific Northwest at the end of the season. All hazardous waste will be consolidated, stored and 

transported to an approved subtitle C landfill at the end of the season.

While operating in Kotzebue Sound, all vessels will discharge effluent within compliance of USCG 

regulations and the Vessel GP.

Shell does not plan to generate waste onshore in Kotzebue as there are no dedicated camps or facilities.

Shell plans to have support personnel staying at local hotels, but wastes generated would be managed by 

the hotel.

d) Waste Disposal

The anticipated volumes and types of wastes that may be generated by the exploration drilling program 

and transported to shore for disposal, along with the disposal location/facility, are indicated in Table 13.d1.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 15-1 March 2015

Revision 2

SECTION 15.0 COASTAL ZONE MANAGEMENT ACT

The State of Alaska did not pass legislation required to extend the Alaska Coastal Management Program 

(ACMP), allowing the ACMP to sunset at 12:01 AM, Alaska Standard Time, on 1 July 2011. Therefore 

no Coastal Project Questionnaire and Certification Statement or Other Information required as part of the 

Coastal Zone Management Act (CZMA) is provided.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 16-1 March 2015

Revision 2

SECTION 16.0 ENVIRONMENTAL IMPACT ANALYSIS

The EIA is provided in Appendix C.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 17-1 March 2015

Revision 2

SECTION 17.0 ADMINISTRATIVE

Exempted Information (public information copies only)

The following information is considered proprietary and has been removed from the public copies of the 

EP Revision 2:

• Bottomhole location, TVD and MD of proposed wells in the Form 137 OCS Plan Information Forms 

(Appendix A)

• All of Section 3 including:

o Geologic descriptions, surface location & bathymetry maps (Section 3.a)

o Structure contour maps (Section 3.b)

o Key seismic lines (Section 3.c)

o Geologic cross-section maps (Section 3.d)

o Shallow hazards reports (Section 3.e)

o Shallow hazards assessments (Section 3.f)

o High resolution seismic lines (Section 3.g)

o Stratigraphic columns (Section 3.h)

o Time/depth tables (Section 3.i)

o Geochemical information (Section 3.j)

o Future G&G activities (Section 3.k)

o Basis for calculation of WCD (Section 3.l)
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 18-1 March 2015

Revision 2

SECTION 18.0 BIBLIOGRAPHY

Appendix C, EIA has its own bibliography describing study reports, survey reports or other material used.

AECOM, Inc. 2009a. Wainwright near-term ambient air quality monitoring program first quarter data 

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

Inc., for ConocoPhillips Alaska, Inc., Anchorage, AK. 

AECOM, Inc. 2009b. Wainwright near-term ambient air quality monitoring program second quarter data 

report February through April 2009 final. Document No. 01865-104-3220 prepared by AECOM, 

Inc., for ConocoPhillips Alaska, Inc., Anchorage, AK.

AECOM, Inc. 2009c. Wainwright near-term ambient air quality monitoring program third quarter data 

report May through July 2009 final. Document No. 01865-104-3230 prepared by AECOM, Inc., 

for ConocoPhillips Alaska, Inc., Anchorage, AK.

AECOM, Inc. 2009d. Wainwright near-term ambient air quality monitoring program fourth quarter data 

report August through October 2009 final. Document No. 60136620-3240 prepared by AECOM, 

Inc., for ConocoPhillips Alaska, Inc., Anchorage, AK.

AECOM, Inc. 2010a. Wainwright near-term ambient air quality monitoring program annual data report 

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

for ConocoPhillips Alaska, Inc., Anchorage, AK.

AECOM, Inc. 2010b. Wainwright permanent ambient air quality monitoring program first quarter data 

report January through March 2010 final. Unpublished report prepared by AECOM, Inc., for 

ConocoPhillips Alaska, Inc., Anchorage, AK.

AECOM, Inc. 2010c. Wainwright permanent ambient air quality monitoring program second quarter data 

report April through June 2010 draft. Unpublished report prepared by AECOM, Inc., for 

ConocoPhillips Alaska, Inc., Anchorage, AK.

AECOM, Inc. 2010d. Wainwright permanent ambient air quality monitoring program third quarter data 

report July through September 2010 draft. Unpublished report prepared by AECOM, Inc., for 

ConocoPhillips Alaska, Inc., Anchorage, AK.

AECOM, Inc. 2011a. Wainwright permanent ambient air quality monitoring program fourth quarter data 

report October through December 2010 draft. Unpublished report prepared by AECOM, Inc., for 

ConocoPhillips Alaska, Inc., Anchorage, AK.

AECOM, Inc. 2011b. Wainwright permanent ambient air quality monitoring program annual data report 

January 2010 through December 2010 final. Unpublished report prepared by AECOM, Inc. for 

ConocoPhillips Alaska, Inc. Anchorage, Alaska.

Aerts, L.A.M., W. Hetrick, S. Sitkiewicz, C. Schudel, D. Snyder, and R. Gumtow. 2013. Marine mammal 

distribution and abundance in the northeastern Chukchi Sea during Summer and early fall, 2008-

2012. Final Report prepared by LAMA Ecological for ConocoPhillips Company, Shell 

Exploration and Production Company and Statoil USA E&P, Inc.

Aerts, L.A.M., C.L. Christman, C.A. Schudel, W. Hetrick, and D. Snyder. 2014. Marine mammal 

distribution and abundance in the northeastern Chukchi Sea from shipboard surveys during 

summer and early fall, 2008–2013. Final report prepared by LAMA Ecological, Anchorage, AK 

for ConocoPhillips Company, Shell Exploration & Production Company, and Statoil USA E&P, 

Inc., Anchorage, AK. 71 pp.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 18-2 March 2015

Revision 2

ASRC Energy Services. 2009. Subsistence advisor program summary, North Slope, Alaska. Report 

prepared for Shell Exploration and Production Company, Houston, TX by ASRC Energy 

Services, Anchorage, AK.

ASRC Energy Services. 2010. 2009 Subsistence advisor program annual summary North Slope, Alaska. 

Prepared for Shell Exploration and Production Company. Anchorage, AK. by ASRC Energy 

Services, Anchorage, AK. December 2009.

Bisson, L.N., H.J. Reider, H.M. Patterson, M. Austin, J.R. Brandon, T. Thomas, and M.L. Bourdon. 2013. 

Marine mammal monitoring and mitigation during exploratory drilling by Shell in the Alaskan 

Chukchi and Beaufort Seas, July–November 2012: Draft 90-Day Report. D.W. Funk, C.M. 

Reiser, and W.R. Koski, editors. LGL Rep. P1272D–1. Rep. from LGL Alaska Research 

Associates Inc., Anchorage, AK, USA, and JASCO Applied Sciences, Victoria, BC, Canada, for 

Shell Offshore Inc., Houston, TX, USA, National Marine Fisheries Service, Silver Spring, MD, 

USA, and U.S. Fish and Wildlife Service, Anchorage, AK, USA. 266 p. + app.

Blanchard, A.L., and A. Knowlton. 2013. Chukchi Sea Environmental Studies Program 2008-2012: 

Benthic Ecology of the Northeastern Chukchi Sea. Final report prepared by Institute of Marine 

Sciences, University of Alaska Fairbanks for ConocoPhillips Company, Shell Exploration and 

Production Company and Statoil USA E&P, Inc.

Blanchard, A., H. Nichols, and C. Parris. 2010a. Benthic ecology of the Burger and Klondike survey 

areas: 2008 environmental studies program in the Chukchi Sea. Annual Report prepared for 

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

Anchorage, AK, by the Institute of Marine Science, University of Alaska, Fairbanks. 72 pp.

Blanchard, A., C. Parris, and H. Nichols. 2010b. Benthic ecology of the Burger and Klondike survey 

areas: 2009 environmental studies program in the northeastern Chukchi Sea. Annual Report 

prepared for ConocoPhillips Alaska Inc., Anchorage, AK, Shell Exploration & Production 

Company, Anchorage, AK, and Statoil USA E&P, Anchorage, AK by the Institute of Marine 

Science, University of Alaska, Fairbanks. 86 pp.

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

from Regional Supervisor, Field Operations, Minerals Management Service, Alaska OCS Region 

to District Office Supervisor.

Brueggeman, J. 2009. Marine mammal surveys at the Klondike and Burger survey areas in the Chukchi 

Sea during the 2008 open water season. Prepared for ConocoPhillips Alaska, Inc. and Shell 

Exploration and Production, Anchorage, AK by Canyon Creek Consulting LLC, Seattle, WA. 46 

pp.

Brueggeman, J. 2010. Marine mammal surveys at the Klondike and Burger survey areas in the Chukchi 

Sea during the 2009 open water season. Prepared for ConocoPhillips Alaska, Inc. and Shell 

Exploration and Production, Anchorage, AK by Canyon Creek Consulting LLC, Seattle, WA. 55 

pp.

Delarue, J., J. Vallarta, H. Frouin-Mouy, J. Wladichuk, B. Martin, X. Mouy, and D. Hannay. 2013. 

Northeastern Chukchi Sea Joint Acoustic Monitoring Program 2011–2012. JASCO Document 

00533, Version 3.0. Technical report for ConocoPhillips Company, Shell Exploration & 

Production Company, and Statoil USA E&P, Inc. by JASCO Applied Sciences.

Dunton, K.H, J.M. Grebmeier and J.H. Trefry (eds.). 2014. Deep Sea Research Part II: Topical Studies in 

Oceanography. The Northern Chukchi Sea Benthic Ecosystem: Characterization, 

Biogeochemistry and Trophic Linkages. Volume 102, pages 1-164 (April 2014).
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 18-3 March 2015

Revision 2

Exponent, Inc. 2010. Chukchi Sea environmental studies baseline program 2009 fish sampling –

chemistry results. Final Report prepared for ConocoPhillips Alaska Inc., Anchorage, AK, Shell 

Exploration & Production Company, Anchorage, AK, and Statoil USA E&P Inc., Anchorage by 

Exponent Inc. 60 pp. plus app.

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

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

Inc., Houston, Texas to Shell Western E&P Inc., Houston Texas.

Fugro GeoConsulting, Inc. 2010a. Shallow Hazards and Archaeological Assessment Burger Site Survey 

1 OCS Lease Sale 193 area Chukchi Sea, Alaska. Report No. 27.2009-2327 v. 1 & 2, prepared

by Fugro GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

Fugro GeoConsulting, Inc. 2010b. Drill Site Clearance Letter Proposed Burger A Drill Site Block 6764 

OCS-Y-2280 Posey Area, Chukchi Sea, Alaska. Report No. 27.2010-2375-1 prepared by Fugro 

GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

Fugro GeoConsulting, Inc. 2010c. Drill Site Clearance Letter Proposed Burger F Drill Site Block 6714 

OCS-Y-2267 Posey Area, Chukchi Sea, Alaska. Report No. 27.2010-2375-3 prepared by Fugro 

GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

Fugro GeoConsulting, Inc. 2010d. Drill Site Clearance Letter Proposed Burger S Drill Site Block 6762 

OCS-Y-2278 Posey Area, Chukchi Sea, Alaska. Report No. 27.2010-2375-4 prepared by Fugro 

GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

Fugro GeoConsulting, Inc. 2010e. Shallow Hazards and Archaeological Assessment Burger Site Survey 

3 OCS Lease Sale 193 Area Chukchi Sea, Alaska. Report No. 27.2010-2342 prepared by Fugro 

GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

Fugro GeoConsulting, Inc. 2010f. Drill Site Clearance Letter Proposed Burger V Drill Site Block 6915 

OCS-Y-2324 Posey Area, Chukchi Sea, Alaska. Report No. 27.2010-2375-6 prepared by Fugro 

GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

Fugro GeoConsulting, Inc. 2011a. Shallow Hazards and Archaeological Assessment Burger Site Survey 

4 OCS Lease Sale 193 Area Chukchi Sea, Alaska. Report No. 27.2010-2343, v. 1 & 2, prepared 

by Fugro GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

Fugro GeoConsulting, Inc. 2011b. Drill Site Clearance Letter Proposed Burger R Drill Site Block 6812 

OCS-Y-2294 Posey Area, Chukchi Sea, Alaska. Report No. 27.2010-2375-7 prepared by Fugro 

GeoConsulting, Inc., Houston, TX for Shell Gulf of Mexico Inc., Houston, TX.

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 pp. plus Appendices. 

Funk, D., D Hannay, D. Ireland, R. Rodrigues, W. Koski. (eds.) 2008. Marine mammal monitoring and 

mitigation during open water seismic exploration by Shell Offshore Inc. in the Chukchi and 

Beaufort Seas, July–November 2007: 90-day report. LGL Rep. P969-1. Rep. from LGL Alaska 

Research Associates Inc., LGL Ltd., and JASCO Research Ltd. for Shell Offshore Inc., National 

Marine Fisheries Service, and U.S. Fish and Wildlife Service. 218 pp plus appendices.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 18-4 March 2015

Revision 2

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 P1050-3, 

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

JASCO Research, Ltd., for Shell Offshore, Inc. and Other Industry Contributors, and National 

Marine Fisheries Service, U.S. Fish and Wildlife Service. 499 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.

Funk, D.W., C.M. Reiser, D.S. Ireland, R. Rodrigues, and W.R. Koski (eds.). 2013. Joint Monitoring 

Program in the Chukchi and Beaufort seas, 2006–2010. LGL Alaska Final Report P1213-2, 

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

JASCO Research, Ltd., for Shell Offshore, Inc. and Other Industry Contributors, and National 

Marine Fisheries Service, U.S. Fish and Wildlife Service. 592 p. plus Appendices.

Gall, A. and R. Day. 2009. Distribution and abundance of seabirds in the northeastern Chukchi Sea, 

2008. Final Report prepared for ConocoPhillips Alaska Inc., Anchorage, AK and Shell 

Exploration & Production Company, Anchorage, AK by ABR, Inc. – Environmental Research & 

Services, Fairbanks, AK. 55 pp.

Gall, A. and R. Day. 2010. Distribution and abundance of seabirds in the northeastern Chukchi Sea, 

2008-2009. Prepared for ConocoPhillips Alaska Inc., Anchorage, AK, Shell Exploration & 

Production Company, Anchorage, AK, and Statoil USA E&P, Inc., Anchorage, AK by ABR, Inc. 

– Environmental Research & Services, Fairbanks, AK. 68 pp.

Gall, A.E, R.H. Day, and T.C. Morgan. 2013. Distribution and Abundance of Seabirds in the Northeastern 

Chukchi Sea, 2008-2012. Final report prepared by ABR Inc. for ConocoPhillips Company, Shell 

Exploration and Production Company and Statoil USA E&P, Inc.

Gall A., T.C. Morgan, and B. Day. 2014. Distribution and Abundance of Seabirds in the Northeastern 

Chukchi Sea, 2008-2013. Prepared for ConocoPhillips Company, Shell Exploration & 

Production Company, and Statoil USA E&P, Inc., Anchorage AK by ABR, Inc. Environmental 

Services, Fairbanks, AK. 94 pp.

GEMS (Geoscience Earth & Marine Services, Inc.) 2009. Shallow Hazards and Archaeological 

Assessment, Burger J Drill Site Posey Block NR03-02 6912, Chukchi Sea, Alaska. Prepared by 

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

TX.

Goodman, S.E., J. June, K. Antonelis and A. Antonelis. 2013. Acoustic Survey of Fishes in the Chukchi 

Sea Environmental Studies Program in 2012. Final report prepared by Natural Resources 

Consultants, Inc. for Olgoonik Fairweather, LLC.

Hopcroft, B, J. Questel, and C. Clarke-Hopcroft. 2009. Oceanographic assessment of the planktonic 

communities in the Klondike and Burger survey areas of the Chukchi Sea: report for survey year 

2008. Report prepared for ConocoPhillips Alaska Inc., Anchorage, AK and Shell Exploration & 

Production Company, Anchorage, AK by the Institute of Marine Science, University of Alaska, 

Fairbanks. 52 pp.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 18-5 March 2015

Revision 2

Hopcroft, B, J. Questel, and C. Clarke-Hopcroft. 2010. Oceanographic assessment of the planktonic 

communities in the Klondike and Burger survey areas of the Chukchi Sea: report for survey year 

2009. Report prepared for ConocoPhillips Alaska Inc., Anchorage, AK, Shell Exploration & 

Production Company, Anchorage, AK, and Statoil USA Exploration & Production Company, 

Anchorage, AK by the Institute of Marine Science, University of Alaska, Fairbanks. 54 pp.

Hopcroft, R., J. Questel, and C. Clarke-Hopcroft. 2011. Oceanographic assessment of the planktonic 

communities in the northeastern Chukchi Sea: report for survey year 2010. Prepared for 

ConocoPhillips Alaska, Inc., Shell Exploration & Production Company, and Statoil E&P USA, 

Anchorage, AK by the Institute of Marine Science, University of Alaska, Fairbanks.

Hopcroft, R., J. Questel, P. Hariharan, C. Stark, and C. Clarke-Hopcroft. 2012. Oceanographic assessment 

of the planktonic communities in northeastern Chukchi Sea: report for survey year 2011. Prepared 

for ConocoPhillips Alaska, Inc., Shell Exploration & Production Company, and Statoil E&P 

USA, Anchorage, AK by the Institute of Marine Science, University of Alaska, Fairbanks.

Hopcroft, R.R., P. Hariharan, J. Questal, J. Lamb, E. Lessard, M. Foy and C. Clarke-Hopcroft. 2013. 

Oceanographic assessment of the planktonic communities in the northeastern Chukchi Sea. Final 

Report prepared by Institute of Marine Sciences, University of Alaska Fairbanks and School of 

Oceanography, University of Washington Seattle for ConocoPhillips Company, Shell Exploration 

and Production Company and Statoil USA E&P, Inc.

Hopcroft R.R and R.H. Day (eds). 2013. Continental Shelf Research. Seasonal and interannual dynamics 

of the northeastern Chukchi Sea Ecosystem. Volume 67, pages 1-166 (15 September 2013).

Hopcroft, R., J. Questel, J. Lamb, and C. Clarke-Hopcroft. 2014. Oceanographic assessment of the 

planktonic communities in northeastern Chukchi Sea: report for survey year 2013. Prepared for 

ConocoPhillips Alaska, Inc., Shell Exploration & Production Company, and Statoil E&P USA, 

Anchorage, AK by the Institute of Marine Science, University of Alaska, Fairbanks.

Ireland, D.S., D.W. Funk., R. Rodrigues, and W.R. Koski (eds.). 2009. Joint Monitoring Program in the 

Chukchi and Beaufort seas, open water seasons, 2006–2007. LGL Alaska Report P971–2, Report 

from LGL Alaska Research Associates, Inc., Anchorage, AK, LGL Ltd., environmental research 

associates, King City, Ont., JASCO Research, Ltd., Victoria, BC, and Greeneridge Sciences, Inc., 

Santa Barbara, CA, for Shell Offshore, Inc., Anchorage, AK, ConocoPhillips Alaska, Inc., 

Anchorage, AK, and the National Marine Fisheries Service, Silver Springs, MD, and the U.S. 

Fish and Wildlife Service, Anchorage, AK. 485 p. plus Appendices. 

Ireland, D.S., R. Rodrigues, D. Funk, W. Koski, D. Hannay. (eds.) 2009. Marine mammal monitoring 

and mitigation during open water seismic exploration by Shell Offshore Inc. in the Chukchi and 

Beaufort Seas, July–October 2008: 90-day report. LGL Rep. P1049-1. Rep. from LGL Alaska 

Research Associates Inc., LGL Ltd., and JASCO Research Ltd. for Shell Offshore Inc., National 

Marine Fisheries Service, and U.S. Fish and Wildlife Service. 277 pp, plus appendices.

LGL Alaska Research Associates, Inc., JASCO Applied Sciences, Inc., and Greeneridge Sciences, Inc. 

2013. Joint Monitoring Program in the Chukchi and Beaufort Seas, 2012. LGL Alaska Report 

P1272-2 for Shell Offshore, Inc. ION Geophysical, Inc., and Other Industry Contributors, 

National Marine Fisheries Service, and U.S. Fish and Wildlife Service. 320 p. plus Appendices.

LGL Draft Rep. P891-1. Rep. from LGL Alaska Research Associates Inc., Anchorage, AK, LGL Ltd., 

King City, Ont., and Greeneridge Sciences Inc., Goleta, CA, for Shell Offshore Inc., Houston, 

TX, and National Marine Fisheries Service, Silver Spring, MD. 199 p.
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 18-6 March 2015

Revision 2

Mathis, J.T. 2013. Seasonal Observations of carbonate chemistry and ocean acidification in 2012. Final 

report prepared by Ocean Acidification Research Center, University of Alaska Fairbanks for 

ConocoPhillips Company., Shell Exploration and Production Company and Statoil USA E&P, 

Inc.

Mathis, J.T. and N.M. Monacci. 2014. Seasonal Observations of Carbonate Chemistry and Ocean 

Acidification in the Northeastern Chukchi Sea in 2013. Prepared for ConocoPhillips Company, 

Shell Exploration and Production Company, Statoil USA E&P, Inc. by Ocean Acidification 

Research Center. School of Fisheries and Ocean Sciences. University of Alaska Fairbanks. 

August 2014.

Neff, J., G. Durell, J. Trefry, and J. Brown. 2010. Environmental studies in the Chukchi Sea 2008: 

chemical characterization. Final Report prepared for ConocoPhillips Alaska Inc., Anchorage, AK 

and Shell Exploration & Production Company, Anchorage, AK by Battelle Memorial Institute, 

Exponent Inc., Florida Institute of Technology, and NMFS & Associates.135 pp.

NMFS. 2013. Draft guidance for assessing the effects of anthropogenic sound on marine mammals: 

acoustic threshold levels for onset of permanent and temporary threshold shifts. NOAA draft 

report, 23 December 2013.

Northern Economics. 2009. Economic analysis of future offshore oil and gas development: Beaufort Sea, 

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

Alaska for Shell Exploration and Production, Houston, TX.

Northern Economics, Inc. and Institute of Social and Economic Research. 2011. Potential National-Level 

Benefits of Alaska OCS Development. Report prepared by Northern Economics, Inc. and 

Institute of Social and Economic Research, Anchorage, AK for Shell Exploration & Production, 

Anchorage, AK.

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Funk. 2007. Marine mammal monitoring and mitigation during open water seismic exploration 

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