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ALASKA STAND ALONE PIPELINE/ASAP PROJECT West Dock Dredge and Disposal Plan ASAP-22-PLN-WWW-DOC-00004 July 12, 2016

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Page 1: ALASKA STAND ALONE PIPELINE/ASAP PROJECT · dredge and disposal plan document no: asap-22-pln- date: july 12, 2016 page iii notice – this document contains confidential and proprietary

ALASKA STAND ALONE

PIPELINE/ASAP

PROJECT

West Dock Dredge and Disposal Plan

ASAP-22-PLN-WWW-DOC-00004 July 12, 2016

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Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page ii NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

NOTICE

THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND

SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY

PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING.

©2016 Alaska Gasline Development Corporation. All rights reserved.

Alaska Gasline Development Corporation

3201 C Street, Suite 200

Anchorage, AK 99503

www.agdc.us

907-330-6300

Page 3: ALASKA STAND ALONE PIPELINE/ASAP PROJECT · dredge and disposal plan document no: asap-22-pln- date: july 12, 2016 page iii notice – this document contains confidential and proprietary

Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page iii NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

REVISION HISTORY

Revision Date Description of Revision Author

Approval

Company Preparing Report

ASAP Senior Project Manager

1 06-14 Draft Plan for agency review 003-14-915-004

AES

2 04-15 Draft Plan for agency review ASAP KS / MT

3 05/5/2015 Draft Plan for agency review ASAP KS / MT

4 12/23/2015 For Agency Review ASAP KS / MT

5 7/12/2016 Admin corrections to formatting ASAP KS / MT

Page 4: ALASKA STAND ALONE PIPELINE/ASAP PROJECT · dredge and disposal plan document no: asap-22-pln- date: july 12, 2016 page iii notice – this document contains confidential and proprietary

Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page iv NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

ACRONYMS AND ABBREVIATIONS

AAC Alaska Administrative Code

ADEC Alaska Department of Environmental Conservation

ADF&G Alaska Department of Fish and Game

ADNR Alaska Department of Natural Resources

AEWC Alaska Eskimo Whaling Commission

AGDC Alaska Gasline Development Corporation

ASAP Alaska Stand Alone Pipeline

BP British Petroleum

BPXA BP Exploration (Alaska), Inc.

CFR Code of Federal Regulations

CWA Clean Water Act

dB re 1 μPa decibel per micro Pascal

DH2 Dockhead 2

DH3 Dockhead 3

DRO diesel range organic

ESA Endangered Species Act

ft feet/foot

GCF Gas Conditioning Facility

GRO gasoline range organic

MBTA Migratory Bird Treaty Act

mg/kg milligram per kilogram

MLLW mean lower low water

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Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page v NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

MMPA Marine Mammal Protection Act

N/A not applicable

NC not calculated

NOAA Fisheries National Oceanic and Atmospheric Association - National Marine Fisheries Service

NSB North Slope Borough

OCSP open cell sheet pile

OHA Office of History and Archaeology, Division of Parks & Outdoor Recreation

PBU Prudhoe Bay Unit

RRO residual range organic

s/ton short ton

SPMT self-propelled module transporter

STP Seawater Treatment Plant

TOC total organic carbon

USACE U.S. Army Corps of Engineers

USFWS U.S. Fish & Wildlife Service

WDSP West Dock staging pad

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 1 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

TABLE OF CONTENTS

Notice .............................................................................................................................................. ii

Revision History ........................................................................................................................... iii

Acronyms and Abbreviations ....................................................................................................... iv

1. Introduction .............................................................................................................................. 3

1.1 Purpose ............................................................................................................................. 3 1.2 Background of West Dock ................................................................................................ 8 1.3 Design Assumptions ......................................................................................................... 8 1.4 Permits and Authorizations ............................................................................................... 9

2. Gas Conditioning Facility Module Offload ......................................................................... 10

2.1 Barges ............................................................................................................................. 10 2.2 Tugs ................................................................................................................................ 11

2.2.1 Ocean-Going Tugs .............................................................................................. 11 2.2.2 Shallow-Draft Tugs ............................................................................................ 11

2.3 Module Offland Process ................................................................................................. 11 2.3.1 Mobilization from Open Water Marshalling Area ............................................. 11 2.3.2 Rotational Offload Plan ...................................................................................... 12 2.3.3 Temporary Barge Bridge Construction .............................................................. 12 2.3.4 Docking and Ballasting at Dockhead 3 .............................................................. 12 2.3.5 Module Offloading Procedure ............................................................................ 13 2.3.6 Transportation of Modules to Construction Site ................................................ 13 2.3.7 Demobilization ................................................................................................... 13 2.3.8 Avoidance and Minimization of Impacts to Fish ............................................... 14 2.3.9 Avoidance and Minimization of Impacts to Subsistence Whaling ..................... 14

3. Dredging ................................................................................................................................. 15

3.1 Winter Dredging ............................................................................................................. 15 3.2 Sediment Sampling and Testing Prior to Dredging ........................................................ 16 3.3 Screeding ........................................................................................................................ 18

4. Dredge Disposal ...................................................................................................................... 19

4.1 Dredge Disposal Background ......................................................................................... 19 4.2 Physical Composition of Sediments within Prudhoe Bay .............................................. 19 4.3 Timing of Disposal ......................................................................................................... 19 4.4 Disposal Location ........................................................................................................... 19

5. Dock and Causeway Upgrades ............................................................................................. 22

5.1 Causeway Widening and Upgrades ................................................................................ 23 5.2 Pile-driving ..................................................................................................................... 23 5.3 Dockhead 3 Construction Improvements........................................................................ 24

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 2 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

5.4 Regulatory Considerations for Dockhead 3 and Causeway Upgrades ........................... 25 5.5 Stakeholder Engagement ................................................................................................ 25

6. References ............................................................................................................................... 27

Attachment 1 - Screening for Port and Dock Site Selection, Dredge Material Disposal, and

Offload Methodology

Attachment 2 - BP Exploration (Alaska), Inc. West Dock Permit Modification

Attachment 3 – Review of West Dock and Beaufort Sea Fisheries

Attachment 4 – Authorities Applicable to The Proposed Action

Attachment 5 – West Dock Boring Logs

LIST OF TABLES

Table 1. Barge Specifications .................................................................................................. 10

Table 2. Ocean-Going Tug Specifications ............................................................................... 11

Table 3. Shallow-Draft Tug Specifications .............................................................................. 11

Table 4. West Dock Sediment Environmental Organic Compound Results ........................... 16

Table 5. West Dock Sediment Environmental Inorganic Compound Results ......................... 17

LIST OF FIGURES

Figure 1. West Dock Causeway Vicinity Map ............................................................................. 4

Figure 2. Dredging Limits of Navigational Channel to Dockhead 3 ........................................... 5

Figure 3. Dredging Channel, Profile View of Seafloor ................................................................ 6

Figure 4. Planned Use of Infrastructure at Dockhead 3, West Dock, Prudhoe Bay ..................... 7

Figure 5. West Dock, South Facing Near Dockhead 3................................................................. 9

Figure 6. Approximate Disposal Location within Prudhoe Bay ................................................ 20

Figure 7. Overview of Planned Upgrades and Modifications to West Dock Causeway ............ 22

Figure 8. Bulkhead Infrastructure Placement Leading to Temporary Bridge ............................ 23

Figure 9. Mooring Dolphin Infrastructure Placement ................................................................ 24

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 3 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

1. INTRODUCTION

1.1 PURPOSE

This Dredge and Disposal Plan supports the Alaska Stand Alone Pipeline (ASAP) (or the Project)

Joint Application for Permit (404/10) by detailing the proposed dredging and disposal activities at

and around West Dock - Dockhead 3 (DH3). This plan also describes proposed modifications to

West Dock to facilitate the offload and transport of Gas Conditioning Facility (GCF) modules.

The Project will require an accessible and well-functioning dock facility near Prudhoe Bay, Alaska

that will receive and accommodate an expedient offload from 23 barges in a single-year sea lift.

The port must accommodate barges carrying a maximum payload of 5,500 short tons (s/tons) and

maximum draft of 7.6 feet. These barges will transport 53 large, prefabricated modules that will

collectively comprise the ASAP GCF on the North Slope, approximately 6 miles to the south of

the base of the West Dock causeway, within the Prudhoe Bay Unit (PBU). The GCF will receive

and condition the gas to the appropriate composition, pressure, and temperature that is require for

the ASAP pipeline. The screening process for selecting the port and dock to be used in the sealift,

the dredge spoil disposal location, and the module offloading procedures are provided in Attach-

ment 1.

DH3 (Figure 1 is the ideal location for offloading the ASAP GCF modules because of its existing

Project-compatible infrastructure, its previous use for modular sealift offloading, its proximity to

the GCF location, its relatively low dredging requirements, and because its use would result in

minimal environmental impacts. DH3 presents the fewest limitations and risks associated with the

modular offload.

DH3 is situated on the eastern side of the West Dock causeway between Dockhead 2 (DH2) and

the Seawater Treatment Plant (STP). The selection of DH3 achieves the following:

Allows for module delivery into an already industrialized area (Figure 1)

Minimizes road use and travel distance for self-propelled module transporters (SPMTs), as

opposed to other dock locations around the North Slope

Uses a navigational channel (Figures 2 and 3) already permitted for dredging by BP Ex-

ploration (Alaska), Inc. (BPXA) (Attachment 2)

Maximizes the use of existing dock infrastructure components, including three barge berths

and a bulkhead for module offload (Figure 4), that are compatible with the needs of the

ASAP Project

Allows for an expedient rotational offload of modules from barges, thereby minimizing

impacts to fish, marine mammals, and subsistence activities

Requires dredging about 250,000 cubic yards of material from the navigational channel

leading into the dock, to a water depth of 9 feet (ft), or -9ft below mean lower low water

Has a minimal impact on BPXA operations at West Dock and within the PBU

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 4 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

Figure 1. West Dock Causeway Vicinity Map

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 5 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

Figure 2. Dredging Limits of Navigational Channel to Dockhead 3

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 6 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

Figure 3. Dredging Channel, Profile View of Seafloor

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 7 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

Figure 4. Planned Use of Infrastructure at Dockhead 3, West Dock, Prudhoe Bay

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 8 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

The navigational channel leading into West Dock - DH3 will be dredged during the winter before

the sealift. Approximately 250,000 cubic yards of dredge material will be placed in the nearshore

environment of Prudhoe Bay over bottomfast ice (see Section 4, below). Disposal will occur in a

location landward of the Territorial Sea boundary at the opening to Prudhoe Bay and will, therefore,

fall under the jurisdiction of the U.S. Army Corps of Engineers (USACE) and will be included as

part of ASAP’s Clean Water Act (CWA), Section 404 permit.

1.2 BACKGROUND OF WEST DOCK

West Dock is a solid-fill gravel causeway structure located on the northwest shore of Prudhoe Bay,

Alaska (Figure 1; Figure 5). West Dock lies within the PBU and is operated by BPXA. This mul-

tipurpose facility is commonly used to offload heavy marine cargo to support Prudhoe Bay oilfield

development. In 1993 and 1994, large modules similar to those proposed for the ASAP Project

were delivered to West Dock - DH3, with an estimated barge payload weight of 5,400 s/tons.

The West Dock causeway was constructed in multiple phases between 1974 and 1981. The original

section was built between 1974 and 1975. The first section of West Dock was constructed to be

3,995ft long, extending from land to DH2. During late summer 1975, the causeway was extended

5,274ft to DH3. In 1981, a third extension elongated the causeway an additional 5,010ft to accom-

modate the STP construction.

A 50ft channel breach was included during the construction of the third extension of West Dock.

However, the effects of the causeway on coastal currents and nearshore marine resources remained

a concern because of the causeway’s size and location (Fechhelm et al., 1999). Therefore, a 650ft

breach and a causeway bridge were installed between DH2 and DH3 during 1995 and 1996, ap-

proximately 21 years after the causeway was constructed out to DH3. This breach is considered to

have had a positive effect on nearshore fish movements and fish populations (Fechhelm et al., 1999;

see also a review of West Dock and Beaufort Sea fisheries studies in Attachment 3).

1.3 DESIGN ASSUMPTIONS

ASAP’s proposed dredging methods, module movements, and construction needs were designed

by Arctic Solutions, a facilities contractor to the Alaska Gas Development Corporation (AGDC).

The proposed methods were developed based on expert engineering and design knowledge, histor-

ical records, scientific literature, and cost-benefit evaluations.

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 9 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

Figure 5. West Dock, South Facing Near Dockhead 3

1.4 PERMITS AND AUTHORIZATIONS

The following permits and authorizations could be required for this work and are described in fur-

ther detail in Attachment 4:

Rivers and Harbors Act, Section 10 – USACE

CWA Section 404 – USACE

CWA Section 401 – Alaska Department of Environmental Conservation (ADEC)

Alaska Pollutant Discharge Elimination System for Stormwater Pollution Prevention Plan

– ADEC

Bridge Permit – U.S. Coast Guard Bridge Administration

Cultural, Historical, and Archaeological Resources Section 106 Consultation – USACE

and Office of History and Archaeology State of Alaska Historic Preservation Office

Endangered Species Act (ESA) Section 7 Consultation, Essential Fish Habitat Consulta-

tion, and Migratory Bird Treaty Act (MBTA) Consultation – U.S. Fish and Wildlife Ser-

vice (USFWS)

Incidental Take Authorization (USFWS / NOAA Fisheries)

Temporary Land Use Permit for upland, non-marine waters, and tidal and submerged lands

– Issued to BP from the Alaska Department of Natural Resources (ADNR)

Mineral Sale Contract, ADNR

North Slope Borough (NSB) Development Permit

Inupiat History, Language, and Culture Clearance – NSB

Letter of non-objection from BPXA

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 10 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

2. GAS CONDITIONING FACILITY MODULE OFFLOAD

2.1 BARGES

The proposed activity will require a single-season sealift involving 23 barges that will transport 53

prefabricated modules to Prudhoe Bay. The barges will use the three existing barge berths at West

Dock DH3 during module offload. The maximum loaded barge weight for the sealift is expected

to be 5,500 s/tons. Barges will arrive at the ASAP Project area when they reach the open water

marshalling area, a deep water location approximately 3 to 5 miles offshore from West Dock.

Barges will vary in dimensions, deadweight capacity, and draft. The projected barge specifications

are provided in Table 1, below.

Table 1. Barge Specifications

BARGE TYPE (DIMENSIONS)

BARGE NO.

BARGE LOADED DRAFT

(BARGE + MODULE) (FT)

BARGE LIGHTSHIP WEIGHT

(BARGE WEIGHT ONLY)

(S/TONS)

BARGE LIGHTSHIP

DRAFT (BARGE ONLY)

(FT)

Crowley 455 Series (400ft x 105ft x 25ft)

Barge 1 5.9 3,865 3.75

Barge 2 5.3 3,865 3.75

Barge 3 6.6 3,865 3.75

Barge 4 5.4 3,865 3.75

Barge 5 6.6 3,865 3.75

Barge 6 7.6 3,865 3.75

Barge 7 5.7 3,865 3.75

Labroy (330ft x 100ft x 20ft) Ballastable Barge

Barge 8 6.7 2,030 3.52

Barge 9* 6.5 2,030 3.52

Barge 10* 6.5 2,030 3.52

Barge 11 6.5 2,030 3.52

Barge 12 6.1 2,030 3.52

Barge 13 5.6 2,030 3.52

Barge 14 5.8 2,030 3.52

Barge 15 5.8 2,030 3.52

Gunderson (360ft x 120ft x 20ft) Deck Cargo Barge

Barge 16 5 3,120 2.4

Barge 17 5.7 3,120 2.4

Barge 18 5.9 3,120 2.4

Barge 19 6.7 3,120 2.4

Barge 20 6.5 3,120 2.4

Barge 21 6.5 3,120 2.4

Barge 22 5.7 3,120 2.4

Barge 23 5.8 3,120 2.4

* = Denotes barges to be used for the temporary barge bridge ft = feet s/ton = short ton

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 11 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

2.2 TUGS

2.2.1 Ocean-Going Tugs

As stated above, ocean-going tugs will tow the barges into the designated open water marshalling

area offshore from West Dock. Two classes of deep-draft, ocean-going tugs will tow the barges;

current class specifications are listed in Table 2, below.

Table 2. Ocean-Going Tug Specifications

OCEAN-GOING TUGS (ASIA TO PRUDHOE BAY)

TUG CLASS TUG LENGTH

(FT) TUG WIDTH

(FT) TUG DRAFT

(FT) ENGINE QUANTITY AND TYPE

Foss Arctic Class 132 41 18 (2) Caterpillar C-280-8

Titan Class 120 46 21 (2) GE 8L250

ft = feet

2.2.2 Shallow-Draft Tugs

Six shallow-draft tugs will be used to transport the barges from the open water marshalling area

into DH3. These vessels will be characteristic of the list in Table 3.

Table 3. Shallow-Draft Tug Specifications

SHALLOW-DRAFT TUGS (PRUDHOE BAY TO DH3)

VESSEL NAME TUG LENGTH

(FT) TUG WIDTH

(FT) TUG DRAFT

(FT) ENGINE QUANTITY AND TYPE

Emmett Foss 72.6 32 4.3 (3) Caterpillar C18

Captain Frank Moody 70 32 3.6 (3) Caterpillar C18

Millie Cruz 92 36 3.9 (3) Caterpillar C18

ft = feet

2.3 MODULE OFFLAND PROCESS

2.3.1 Mobilization from Open Water Marshalling Area

American and foreign-flagged vessels will be used in the sealift to deliver the ASAP GCF modules.

Ballast compartments will have been cleaned and verified by a Marine Warranty Surveyor Prior to

arrival at Prudhoe Bay. Activities necessary to offload the modules will have been completed prior

to arrival of the barges, including winter dredging and summer screeding of the navigational chan-

nel, lifting the face of one of the existing DH3 berths, installation of sheet piling and mooring

dolphins, and preparation of ramps for module offload.

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 12 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

Upon arrival at Prudhoe Bay the barge and tug combinations will remain offshore until they are

brought to DH3 for offload. While waiting to be brought to DH3, they will either “lay on their

wire” or “jog” further offshore. “Laying on their wire” is a condition where the tugs allow the tow

cable to go slack and sink to the sea bed. This creates enough resistance to keep the barges in place,

similar to being anchored. “Jogging” describes when the tugs keep a steady strain on the tow cable

and travel in circles. Because it takes a much larger area to “jog,” “jogging” will be employed

further offshore and only when the weather conditions are not favorable to laying on their wires.

2.3.2 Rotational Offload Plan

The timing of the ASAP Project will depend on sea ice and weather conditions; however, barges

are expected to reach the open water marshalling area around August 1 in the year of the sealift. A

rotational three-barge offload will be implemented to minimize the total offload time and reduce

environmental impacts: as one barge is preparing to dock and offload, another will be offloading,

while a third will have completed offloading and will be demobilizing to make room for the next

inbound barge.

2.3.3 Temporary Barge Bridge Construction

The first two barges to offload modules will be Labroy class barges. These barges will be pushed

by shallow draft tugs up to the face of DH3, offloaded, and moved southward to the causeway

breach between DH3 and DH2 where they will be used as a temporary bridge, paralleling the ex-

isting weight-limited bridge spanning the breach. The barge bridge will be able to withstand the

weight of modules being transported to the GCF construction location.

The two barges will be placed bow-to-bow and ballasted to the seafloor, which will have been

leveled using gravel fill. The barge rakes will angle upward and touch at their adjoining point,

leaving a 52.5ft gap at the seafloor between the barges. The stern of each barge will angle sharply

upward at each end of the bridge, leaving an additional 10ft gap at the seafloor at each end. This

equates to a total of 72.5ft of gap space at the seafloor to allow water flow and fish passage. Con-

structing the temporary bridge from barges at the proposed time and for the proposed duration is

not expected to have a substantial impact on fish movements (see Attachment 3).

Construction and deconstruction of the temporary barge bridge are expected to take 3 days each.

The temporary bridge barges will be held in place by the mooring dolphins, which will have been

driven deep into the seafloor (see Section 5, below). The barges will not be secured or connected

to the bulkheads abutting the causeway. The temporary bridge will be in place for as little as 21

days and as many as 39 days, depending on weather conditions and logistics.

2.3.4 Docking and Ballasting at Dockhead 3

Shallow draft tugs will assist the barges into DH3, one at a time for offload. A total of six shallow

draft assist tugs will be on hand. Three tugs will be used to move each barge. Once barge offloading

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commences, the operation will be a 24-hour-per-day task using all three of the berths at DH3 until

offload is complete.

To stabilize the barges during offload at DH3, barges will be ballasted to the seafloor. This will

require internal barge compartments to be filled with seawater by using portable pumps and hoses

inserted into utility holes on the barge decks. Environmental impacts will be minimized or elimi-

nated by using only local seawater during this process. Stability will be verified before the modules

are offloaded.

2.3.5 Module Offloading Procedure

Modules will be moved from the barges onto DH3 using SPMTs. Before the SPMTs are put into

operation, all components will be checked for leaks and pressure-tested to the maximum operating

pressure. Hoses will be wrapped in absorbent material, and drip trays will be placed under the

power packs. SPMT configuration will be adjusted to fit the particular module being moved (i.e.,

made shorter or longer to fit each module) during barge ballasting. The SPMTs will then be moved

onto the barge and hydraulically lowered and moved into position underneath the module. When

modules are in place on the SPMTs, they will be lifted from the barge deck and transported onto

the dock. Extra absorbent material and absorbent booms will be available for each SPMT unit used

while in transit.

The modules will be delivered to the West Dock staging pad (WDSP) at the base of West Dock as

they come off the barges. Storage at this site will require authorization from ADNR. At the WDSP,

the modules will be removed from SPMTs by lowering them onto their stub columns, resting on

rig mats. While at the WDSP, crews will prepare the modules for transport to the GCF by removing

temporary siding. Pipe covers will be left in place until the module is in its final location to prevent

intrusion of birds and debris. The modules will be transported from the WDSP to the GCF in the

sequence needed for efficient installation of the facility.

2.3.6 Transportation of Modules to Construction Site

Moving each SPMT from DH3 to the WDSP will take approximately 3 hours. All SPMTs will be

accompanied by a field crew to guide and aid in spill response, as well as by mechanics, where

necessary, on the road for safe transport. Causeway and land roads will be surveyed for damage,

erosion, and appropriate width before module movement. Gravel will be used for all maintenance

purposes, including widening the roads. All maintenance will occur after snowmelt is complete.

2.3.7 Demobilization

Having offloaded modules at DH3, each barge will be deballasted — a process that will reverse the

ballast intake method. After the offload activities are complete, vessels and equipment, the DH3

gravel ramp, and the temporary barge bridge will be transported out of Prudhoe Bay with the barge

fleet. The mooring dolphins and abutments will remain, but the original 650ft breach will not be

impeded.

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2.3.8 Avoidance and Minimization of Impacts to Fish

The West Dock breach is a biologically significant area of Prudhoe Bay (Fechhelm et al. 1999;

Fechhelm et al. 2001). Before the West Dock causeway breach was constructed in 1996, water

current, nutrients, and fish movements were limited by the closed causeway (Craig and Griffiths

1981; Fechhelm et al. 2001). The breach is considered to have had a positive effect on fish popu-

lations near West Dock, primarily because of the changes observed in salinity levels, post-breach

(Fechhelm et al. 2001). Species of interest that may use the West Dock breach include Arctic cisco

(Coregonus autumnalis), least cisco (C. sardinella), broad whitefish (C. nasus), humpback white-

fish (C. pidschian) and Dolly Varden (Salvelinus malma) (Craig and Griffiths 1981; Fechhelm et

al. 1999).

As noted above, the temporary barge bridge will reduce the size of the existing 650ft breach to

72.5ft of cumulative gap space at the seafloor. However, impacts on fish attributed to the temporary

barge bridge are likely to be minimal due to the following: the timing of bridge placement, the

location and movements of migratory fish at the time the temporary bridge is used in construction

phase activities, the relatively short length of time the bridge will be in place, the remaining 72.5ft

of cumulative gap space for fish passage, and the fact that fish also move around the STP at the

terminus of West Dock during the fall migration (see Attachment 3 for additional details).

2.3.9 Avoidance and Minimization of Impacts to Subsistence Whaling

Moving vessels after August 25 have the potential to affect subsistence whaling activities by

Nuiqsuit and Barrow whalers. Nuiqsut whalers stage out of Cross Island in late August, while Bar-

row whalers stage out of the town of Barrow in September. Both harvest bowhead whales (Balaena

mysticetus), which migrate east-to-west along the Beaufort Sea coast at this time.

To avoid and minimize impacts on subsistence whaling, AGDC has met with and received com-

ments from the NSB Planning Department (Barrow), the NSB Department of Wildlife Management

(Barrow), the Alaska Eskimo Whaling Commission, and the Kuukpik Corporation (Nuiqsuit). The

AGDC has also attended scoping meetings in North Slope villages to take public comments as part

of the National Environmental Policy Act (NEPA) process for an ongoing Supplemental Environ-

mental Impact Statement. AGDC will continue to meet with Barrow and Nuiqsut whalers, other

stakeholders, the NSB, and regulatory agencies to implement appropriate mitigation measures,

avoid and minimize impacts on whale movements, and avoid conflicts with whalers.

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3. DREDGING

ASAP proposes to dredge to 9ft (-9ft below mean lower low water (MLLW)) throughout the navi-

gational channel (Figure 2) to accommodate the maximum barge draft of 7.6ft (Table 4) and allow

an additional 1.4ft of clearance space. Ovedredging will mitigate against trench infilling during

spring break-up and will eliminate any need for summer dredging. Screeding of the navigational

channel to level the seabed to a precise depth will be necessary in early summer prior to barge

arrival.

The dredging of the navigational channel leading in to West Dock - DH3 was permitted previously

to BPXA. Under a 2008 permit modification (Attachment 2), BPXA may dredge up to an estimated

153,600 cubic yards of material leading up to DH3; this volume formed the basis for ASAP’s ear-

liest dredging estimates; however, recent bathymetry has shown that dredging the channel to -9ft

will remove approximately 250,000 cubic yards of native material.

3.1 WINTER DREDGING

Winter dredging was selected over summer dredging for the following reasons:

Migrating whales are not in the area during winter, reducing the potential for conflicts with

whaling activities.

Fish are not migrating through the area during the winter, thereby reducing the impact on

fish migration.

Ice mitigates the potential of an excavation turbidity plume.

Excavation accuracy is increased when using a more stable surface, reducing the chance of

unintentional over-dredging.

Ice eliminates wave action.

Longer winter season aids in completing the excavation.

Work fronts can be increased simultaneously by adding excavators and extra dump trucks.

Minimal channel maintenance is required during the winter because ice helps keep channel

side slopes from sloughing

Shorter time between dredging and the sealift reduces sediment redispositioning

Conventional winter excavation, using extended reach excavators, is the preferred method of dredg-

ing and has been used during the construction of several North Slope pipelines. Three tracked ex-

cavators will be used over one winter construction season to provide enough time for ice cutting,

winter storms, dredge disposal at the approved location, and other unforeseen delays.

Ice will be thickened to support excavators by drilling though the ice and pumping seawater onto

the icesurface. This technique will then allow a safe platform for excavation and hauling equipment

as well as efficient dredge operation. Next, a Ditch Witch will be used to cut the ice in the excava-

tion area and remove it with tracked excavators. The excavators will then excavate the 500ft-wide

channel to approximately -9ft (Figures 2 and 3) and place the dredged material into dump trucks.

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Concurrent with the excavation, dump trucks will transport the dredge spoils to the designated

construction site (Section 4).

3.2 SEDIMENT SAMPLING AND TESTING PRIOR TO DREDGING

Chemical analysis of potential dredge sediment is required (CWA 404[b][1] guidelines, Code of

Federal Regulations [CFR], Title 40, Part 230.60) prior to dredging and discharging dredge spoils.

ASAP proposes that the USACE issue a permit with a condition of physical and chemical testing

of sediment prior to dredging with sampling and testing protocols matching those in existence under

the existing BPXA permit modification (Attachment 2). The best available data suggest that

sediments around West Dock are not contaminated. Sediment composition has been characterized

following recent core sampling on the east side of West Dock, with sediment cores ranging from 8

to 11ft in length (URS, 2012; Attachment 5). An extrapolation of the data allows for a reasonable

estimate as to the make-up of sediments within the navigational channel. Furthermore, in May

2002, OASIS Environmental, Inc. completed geotechnical and environmental testing activities

along the east side of the West Dock causeway, including at DH3, as part of a dredge permitting

process (Tables 4 and 5, below) (Oasis Environmental, Inc., 2002). This work determined the

suitability of dredged materials for reuse in other natural environments (40 CFR 230.60). Sediments

were sampled from the top 4 inches of sediment, the area most likely to be impacted by

contamination, using continuously sampled boreholes. Results are shown, below, in Table 4.

Table 4. West Dock Sediment Environmental Organic Compound Results

BORING ID GRO BENZENE TOLUENE ETHYLBENZENE TOTAL

XYLENES DRO RRO

WD 1 <1.71 <0.00854 <0.0342 <0.0342 <0.0342 <21.1 21.2

WD 2 <3.12 <0.0156 <0.0624 <0.0624 <0.0624 <30.8 60.9

WD 3 <3.06 <0.0153 <0.0612 <0.0612 <0.0612 <34.3 92.2

G 1 <1.52 <0.0076 <0.0304 <0.0304 <0.0304 <215 <21.5

G 2 <2.04 <0.0102 <0.0407 <0.0407 <0.0407 <23.2 72.4

G 3 <1.76 <0.00878 <0.0351 <0.0351 <0.0351 <23.0 30.2

Alaska Cleanup Standards Arctic

Zone Direct Contact* 1,400 200 11,000 13,700 27,400 12,500 2,200

Alaska Cleanup Standards Migration

to Groundwater* Evaluation N/A 0.025 6.5 6.9 63 N/A N/A

Framework Screening Levels for

Dredge Materials** N/A N/A N/A N/A N/A N/A N/A

Notes: Units are mg/kg; Data from Oasis Environmental, Inc. 2002, West Dock Causeway testing report for BPXA; Depth = 0.0 to 0.3 ft below sea bed floor; OASIS samples were not compared with Alaska soil standards for their research. All standards are listed for reference. ADEC = Alaska Department of Environmental Conservation BPXA = BP Exploration (Alaska) Inc. GRO = gasoline range organics DRO = diesel-range organics N/A = not applicable RRO = residual-range organics USACE = U.S. Army Corps of Engineers * Source: ADEC (2012) ** Source: USACE (1998) *** Value was missing from table in 18 ACC 75

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West Dock Dredge and Disposal Plan

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Table 5. West Dock Sediment Environmental Inorganic Compound Results

Boring ID TOC

Metals

Arsenic Barium Cadmium Copper Lead Nickel Zinc Silver Mercury Total

Solids (%)

WD 1 4,121 2.54 21.5 0.227 3.43 2.16 6.17 14.7 0.237 <0.0414 92.2

WD 2 16,790 5.9 63.9 <0.254 13.8 6.79 18.9 46.8 0.48 <0.0617 64.3

WD 3 22,790 7.95 90.3 <0.295 19.1 10.8 25.4 64.6 0.553 <0.0696 57.3

G 1 1,357 2.41 38.8 <0.195 2.57 2.13 6.2 11.7 0.265 <0.0439 90

G 2 10,730 8.36 66.9 <0.229 9.25 4.93 13.3 29.8 0.311 <0.0454 85.7

G 3 10,850 4.93 50.8 <0.193 5.43 3.31 7.86 16.6 0.239 <0.0467 85.6

Average TOC and Total Metals 11,106 5 55 NC 9 5 13 31 0.35 NC 79

Cleanup Stand-ards Arctic Zone Direct Contact*

N/A 6.1 27,40

0 110 5,500 400 2,700 41,100 680 41 N/A

Cleanup Stand-ards Migration to Groundwater*

N/A 3.9 1,100 5 460 *** 86 4,100 11.2 1.4 N/A

Screening Levels for Dredge

Materials**

N/A 57 N/A 5 390 450 140 410 6.1 0.41 N/A

Notes: Units are mg/kg; Depth = 0.0 to 0.3 ft below sea bed floor; OASIS samples were not compared to Alaska soil stand-ards for their research. All standards are listed for reference. AAC = Alaska Administrative Code ADEC = Alaska Department of Environmental Conservation N/A = not applicable NC = not calculated TOC = total organic carbon USACE = U.S. Army Corps of Engineers

* Source ADEC (2012) ** Source: USACE (1998). *** Value was missing from table in 18 AAC 75.

No samples exceeded cleanup or screening levels of organic or inorganic particulates (Tables 4 and

5), except for arsenic (Table 5), which is a naturally occurring metal, and the quantities found in

the West Dock area (2.5 to 8.0 milligram per kilogram [mg/kg]) fall on the low end of the spectrum

for arsenic in sediment samples (2 to 2,500 mg/kg).

Although residual-range organics (RRO) levels are well-below Alaskan Cleanup Standards (Ta-

ble 4), they are significantly higher than other petroleum hydrocarbon levels found at the sampling

area, and there are indications that this is naturally occurring material, not contamination. Further-

more, a review of the oil and hazardous substance spill reporting made to ADEC

(http://dec.alaska.gov/applications/spar/SpillsDBQuery/search.asp) indicated minimal spills in the

West Dock area have escaped recovery or containment in the past 15 years (less than 15 gallons

lost).

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3.3 SCREEDING

Before offloading materials at DH3, the seabed at the offloading dock will need to be sufficiently

leveled to allow the barges to be ballasted to the seafloor. Screeding barges will be used to level

the seafloor, transferring high spots to low ones. These barges will be positioned in the offloading

area and moved by shallow draft assist tugs. This method requires no material to breach the surface.

Screeding will be conducted at each barge berth at DH3.

Depending on the nature of the seabed at the barge bridge, some minor screeding may also be

required to keep the barge decks level with the dock abutments. Prior to offloading the first module,

the seafloor will be examined at both locations.

Migratory marine mammals, including whales and Pacific walrus (Odobenus rosmarus), are pre-

sent in the Beaufort Sea during the ice-free season. All screeding and offload activities will take

place in accordance with the regulatory authorities and in consultation with the NSB Department

of Wildlife Management.

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West Dock Dredge and Disposal Plan

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4. DREDGE DISPOSAL

4.1 DREDGE DISPOSAL BACKGROUND

The following factors were considered in determining the best location and most appropriate meth-

ods for dredge disposal:

Physical and chemical composition of dredged material

Matching of dredged material to disposal area sediments

Timing of disposal

Technical feasibility

Environmental acceptability

Cost-benefit

Careful consideration and planning are necessary to determine the best disposal location

and eliminate harm to human health, safety, or the environment.

4.2 PHYSICAL COMPOSITION OF SEDIMENTS WITHIN PRUDHOE BAY

The sediment composition of Prudhoe Bay, while not necessarily uniform throughout, is generally

silty with a thin layer of sand and clayey sand (Niedoroda et al. 1980). Within the proposed dredg-

ing area, ADNR data indicate the sediment is soft, silty sand mixed with a thin layer of gravel and

organics. Beneficial reuse options for soft, silty sand are limited but include building temporary

berms on nearby islands or on an uninhabited shoreline. Nearshore sediment, which has been used

for West Dock causeway maintenance, comprises silty sand underlain with gravel.

4.3 TIMING OF DISPOSAL

Winter disposal will coincide with winter dredging activity. Winter activities will eliminate poten-

tial impacts to or conflicts with migratory animals (birds and marine mammals), subsistence activ-

ities, and migratory fish routes. AGDC will seek and adhere to appropriate mitigation measures for

polar bear and ice seals and will acquire needed permits and authorizations directed by the juris-

dictional agencies.

4.4 DISPOSAL LOCATION

The preferred disposal location for dredge material from the West Dock navigational channel will

be landward of the Territorial Sea boundary in the nearshore environment over bottomfast ice

within Prudhoe Bay (Figure 6). Dredge material will be positioned in 1 to 2ft piles over a 100-acre

area (1,000ft by 4,356ft for a rectangular plot). The nearshore environment is likely to be regularly

disturbed by seasonal bottomfast ice movements that scour the seabed, as well as by intermittent

storms in the ice-free season. These nearshore areas adjacent to West Dock generally will be too

perturbed an environment to allow significant aquatic marine plant or algae communities to thrive.

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The continual formation and retreat of ice throughout the season will move sediments away from

the nearshore environment over time.

Figure 6. Approximate Disposal Location within Prudhoe Bay

In accordance with the timing of dredging, the native sediment excavated from the navigation chan-

nel will be trucked over thickened ice roads to a preapproved location in Prudhoe Bay. Bottomfast

ice is jagged and not typically level, meaning that the ice road and the dredge disposal location will

need to be leveled and prepared to facilitate vehicle access and an efficient disposal.

Extensive hydrological research from the West Dock/Prudhoe Bay area shows prevailing winds in

the area are typically alongshore and easterly, causing an eddy to form on the western side of West

Dock (Fechhelm et al., 1999 and 2001). Most nearshore sediment transport along the Arctic coast-

line will be via a longshore, wind-driven current. Westerly winds have been seen in atypical sum-

mer seasons (Fechhelm et al., 1994), creating a west-to-east longshore current that will redeposit

the sediment towards the eastern shore of Prudhoe Bay and away from the navigation channel. The

Prudhoe Bay shoreline is relatively stable because it is protected by adjacent landforms; this pro-

tection dampens the current flow within the bay, which is evident from the small accumulation of

sediment at the West Dock-shore junction. The low-energy environment within Prudhoe Bay will

be beneficial for this disposal site. Less transfer will be expected than for other offshore sites. Ad-

ditionally, the location of the proposed disposal location is far enough away from the West Dock

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breach (about 5 miles) that it is extremely unlikely that sediments would get deposited back into

the channel, even during strong storm events. Fish movements are not expected to impede dredge

disposal because the silt and sediment will be pushed east.

There is little concern over dredged spoils covering benthic biota at the proposed location because

of the constantly changing seabed and the preexisting occurrence of ice gouging. Ice gouging is

caused when wind and current force sea ice to pile up into ice ridges. These ridges have keels that

extend into the water column. In shallow water, the keel can scour and cut gouges into the seabed.

Most ice gouges are 3.5ft deep (Ishita, 2013). Ice is continually moving and scraping the bottom of

the seafloor in shallow waters, perturbing it and limiting aquatic marine plant or algal communities;

gouged areas are generally a less biologically productive environment than areas of deeper water

(Ross, 1988). Using the shallow nearshore environment for disposal of dredged material will alle-

viate navigational hazards from sediment mounds because little to no vessel traffic will be in the

shallower waters at this location.

Spoils will be frozen in winter, and frozen or wet in spring. Wind impacts would be for a very short

time period and are likely to be negligible. Sediments can be monitored on the ice and watered

down if wind impacts appear at all likely to spread sediments beyond the 100 acres of bottomfast

ice before melt and submergence.

The nearshore disposal site was chosen to avoid interference with subsistence use areas or subsist-

ence activities (as per the NSB Department of Wildlife Management). Additional consideration

was also given to biologically important areas, such as polar bear and ice seal dens, the boulder

patch (a unique area of boulders that provides habitat for multiple species in an otherwise habitat-

poor environment), migratory fish routes, and benthic communities (e.g., clam habitat). Addition-

ally, the nearshore disposal site will not interfere with industry-related activities. This option does

not offer beneficial reuse of dredge material; however, when weighed against the other alternatives,

a nearshore disposal is the preferred option based on the following reasons:

Area is adequate distance from West Dock, so there would be no sediment refilling in the

navigation channel or the West Dock breach.

Area is accessible from both land and water.

Dredged sediment is presumed clean, and composition similar to disposal site

Area has poor benthic habitat because of ice gouging on the seafloor.

Area has naturally high turbidity, therefore, sediment plumes should not alter the water

quality to an unacceptable level.

There is no navigation interference.

A one-time nearshore dispersal of dredge material onto bottomfast ice is not likely to have adverse

effects on the surrounding environment (e.g., habitat, migratory routes, or navigational routes).

Identifying a suitable dredge disposal site will require approval by the USACE. An in-depth coop-

erating agency discussion has been and will continue to be conducted as part of the USACE Section

404 permit process for the ASAP Project. AGDC is aware that previous scientific research has been

conducted in the area (Niedoroda et al. 1980; Fechhelm et al. 2001; Sanzone et al. 2010).

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5. DOCK AND CAUSEWAY UPGRADES

All methods and specifications of dock upgrades and causeway widening at West Dock were de-

signed by Arctic Solutions. The West Dock causeway will require widening and infrastructure

modifications (Figure 7). Before offloading the barges at DH3 and constructing the temporary

barge bridge, activities will occur up to 1 year in advance of the sealift to prepare DH3 and the

West Dock causeway, including road maintenance and widening to allow for module movement,

as well as pile-driving and infrastructure improvements, described below. Gravel fill will also be

used to level the seafloor beneath the proposed temporary barge bridge.

Figure 7. Overview of Planned Upgrades and Modifications to West Dock Causeway

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Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 23 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

5.1 CAUSEWAY WIDENING AND UPGRADES

Sections of the causeway road bed will need to be widened to accommodate module movement

along the causeway between DH3 and DH2. Gravel will be used to fill in the affected areas and

widen the causeway road (Figure 7). In the summer, just prior to module delivery the newly placed

gravel, including approach and abutment fill gravel, will be brought to finish grade and compacted

to accommodate the module haul loads.

5.2 PILE-DRIVING

In the winter prior to the sealift, new approaches will be built at the north and south sides of the

existing causeway breach using open cell sheet pile (OCSP). These new approaches will be east of

the existing causeway and will have integral abutments where they terminate at the causeway

breach. Mooring dolphins will be installed to secure the two barges that will create a temporary

bridge for the modules to travel over. All the new construction, including gravel fill at the new

approaches, will occur the winter prior to module sealift.

Figure 8. Bulkhead Infrastructure Placement Leading to Temporary Bridge

The four mooring dolphins (Figure 9) will protect the current bridge from the barges and hold the

ballasted barges in place. The mooring dolphins are 4ft-diameter piles that will be driven a mini-

mum of 65ft into the seabed. When not left in place, large-diameter piles such as these are cut off

below the surface. The upper portion will be removed from the area, and the remaining shaft will

either be filled in or left to allow moving sediments to self-fill over time. Vibrating out piles is not

recommended, because doing so is a much more hazardous operation than the installation process

due to loads placed on the crane.

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Figure 9. Mooring Dolphin Infrastructure Placement

5.3 DOCKHEAD 3 CONSTRUCTION IMPROVEMENTS

In the summer prior to module delivery, improvements will be made to DH3 to accommodate the

sealift. These consist of removing existing damaged timber mats and replacing with new barge

mats, removing and replacing existing damaged upper and lower fenders, and installing a 5ft ramp.

The current DH3 structure will allow for barges with a 20ft sideshell depth to be level with the

dock when completely ballasted to the seafloor. A 5ft ramp will be installed at one of the barge

berths, using rig mats and gravel, to accommodate 25ft sideshell barges. Gravel for the ramp will

be placed in lifts wrapped in geotextile fabric and folded over at the sides to minimize encroaching

on the adjacent berth space. The 5ft ramp will be temporary and removed after offloading the mod-

ules.

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5.4 REGULATORY CONSIDERATIONS FOR DOCKHEAD 3 AND CAUSEWAY

UPGRADES

Installing the temporary barge bridge is likely to require a Bridge Permit from the U.S. Coast Guard

Bridge Administration. This work will occur in summer, while all other dock and causeway up-

grades will occur in winter.

Pile-driving is known to produce strong pulses of sound through water (Richardson et al. 1995;

Blackwell 2005) that can also travel through ice and air. To mitigate against potential noise impacts

to fish and marine mammals, vibratory pile-driving technology will be used in the installation of

sheet piling and mooring dolphins rather than impact pile driving (Blackwell et al., 2004; Black-

well 2005). AGDC will further adhere to guidance from the services on permits, authorizations and

mitigation for all winter activities including pile driving, dredging and transport of heavy equip-

ment or dredge spoils over sea ice.

Winter and summer fieldwork will be compliant with all regulatory requirements (e.g., ESA,

MMPA, MBTA). As stated earlier, dock and causeway upgrades will not take place during bird

nesting season and will not impact ESA bird species, such as Steller’s eider (Somateria fischeri) or

spectacled eider (Polysticta stelleri). Fish are not expected to be impacted by construction phase

activities (Attachment 3); however, AGDC will consult with regulatory agencies to determine

whether additional mitigation will be required. The ASAP Environmental Evaluation Document

contains information on wildlife, fish, and threatened and endangered species, as well as a Biolog-

ical Assessment and an Essential Fish Habitat Report (AGDC 2016.) These work products charac-

terize environmental resources and potential project-related impacts to them with regard to work at

West Dock.

The use and improvement of West Dock will require coordination with BP and ADNR to modify

or amend the existing leases. AGDC is currently coordinating with BP and ADNR and we antici-

pate an increase in this coordination as the project moves closer to permitting.

5.5 STAKEHOLDER ENGAGEMENT

AGDC has engaged stakeholders since 2014 in regard to West Dock activities. Representatives for

the ASAP Project have held public meetings or have reached out to stakeholders to provide infor-

mation through:

o Attendance of Bi-annual BP West Dock Users Meetings (since spring 2014, ongoing)

o SEIS Scoping Meeting in Nuiqsut (USACE presented ASAP Project Plans and received pub-

lic comment; ASAP dialogued w/ Nuiqsut residents & Cross Island whalers in attendance)

o SEIS Scoping Meeting in Barrow (USACE presented ASAP Project Plans and received pub-

lic comment; ASAP dialogued w/ Barrow residents, whalers, & NSB representatives in at-

tendance)

o Presentation to members of NSB Planning Dept. Staff in Barrow

o Meeting w/ Director of NSB Fire Dept. in Barrow; Visit NSB Search & Rescue Facilities

o Meeting and Tour w/ Barrow Gas Utility Service Staff in Barrow

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o Preliminary Meeting w/ NMFS staff

o Presentations to USACE and Cooperating Agencies

o Meetings and Presentation to NSB Wildlife Dept. staff

o Presentations to NSB Wildlife and Chair of AEWC

o Invited Presentation to Alaska Eskimo Whaling Commission (AEWC) whalers in Barrow

o Presentation to NSB Planning Dept. Director and Management Team in Anchorage

o Presentation to Kuukpik Corporation President and Staff in Anchorage

o Attend Recurring AEWC Meetings in Barrow and Anchorage (ongoing)

o Meeting with BPXA West Dock Operations Manager

o Phone Attendance of NSB Planning Commission Meetings

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 27 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

6. REFERENCES

Alaska Department of Environmental Conservation (ADEC). 2012.

Alaska Administrative Code, Title18, Chapter 85, Oil and Other Hazardous Substances

Pollution Control. April.

Alaska Gasline Development Corporation (AGDC). 2016. Alaska Stand Alone Pipline / ASAP

Project Environmental Evaluation Document. 001-C-22-GRD-W-0055. July 15.

Blackwell, S.B. 2005. Underwater Measurements of Pile-Driving Sounds During the Port Mac-

Kenzie Dock Modifications, 13-16 August 2004. Rep. from Greeneridge Sciences, Inc.,

Goleta, CA, and LGL Alaska Research Associates, Inc., Anchorage, AK, in association

with HDR Alaska, Inc., Anchorage, AK, for Knik Arm Bridge and Toll Authority, Anchor-

age, AK, Department of Transportation and Public Facilities, Anchorage, AK, and Federal

Highway Administration, Juneau, AK. 33 p.

Blackwell, S.B., Lawson, J.W., Williams, M.T. 2004. “Tolerance by ringed seals (Phoca hispida)

to impact pipe-driving and construction sounds at an oil production island.” J. Acoust. Soc.

Am. 115, 2346.

Craig P.C. and W.B. Griffiths. 1981. “Passage of Large Fish Around a Causeway in Prudhoe Bay,

Alaska.” Arctic 34(4):314-317.

Fechhelm, R.G., J.D. Bryan, W.B. Griffiths, W.J. Wilson, and B.J. Gallaway. 1994. “Effects of

Coastal Winds on the Summer Dispersal of Young Least Cisco (Coregonus sardinella)

from the Colville River to Prudhoe Bay, Alaska: A Simulation Model.” Can J Fish Aquat

Sci 51: 890-899.

Fechhelm, R.G., L.R. Martin, B.J. Gallaway, W.J. Wilson, and W.B. Griffiths. 1999. “Prudhoe Bay

Causeways and the Summer Coastal Movements of Arctic and Least Cisco.” Arctic

52(2):139-151.

Fechhelm, R.G., L.R. Martin, B.J. Gallaway, W.J. Wilson, and W.B. Griffiths. 2001. “Estimating

the Hydrograpic Effects of Prudhoe bay Causeway Breaches Using the Before-After Con-

trol-Impact (BACI) Analysis.” Arctic 54(2): 162-173.

Ishita, S. 2013. “First Successful Subsea Pipeline in the Arctic: Northstar.” Prototype Journal of

Undergraduate Engineering Research and Scholarship. Memorial University of New-

foundland, St. John’s, Newfoundland, Canada. 7 pp.

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 28 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

Niedoroda, A., H. Chin, and P. Mangarella. 1980. Addendum to Environmental Studies Associated

with the Prudhoe Bay Dock- Physical Oceanography and Benthic Ecology. The 1978 Stud-

ies. Prepared by Woodward-Clyde Consultants, Anchorage, Alaska for ARCO Alaska, Inc.

(Oceanography, marine benthos).

Oasis Environmental, Inc.. 2002. West Dock Causeway Testing – West Dock and Seawater Treat-

ment Plant Groin Area. Report to BP Exploration Alaska, Inc. July 10, 2002

Richardson J.W., C.R. Greene, C.I. Malme, and D.H. Thomson. 1995. Marine Mammals and Noise.

Academic Press, San Diego, California, 579 pp.

Ross, B.D. 1988. Causeways in the Alaskan Beaufort Sea. EPA 910/9-88-218. Prepared for United

States Environmental Protection Agency, Region 10, Alaska Operations Office, Anchor-

age, Alaska.

Sanzone, D., Streever, B., Burgess, B., and Lukin, J. (editors). 2010. Long-Term Ecological Mon-

itoring in BP’s North Slope Oil Fields: 2009 Annual Report. BP Exploration (Alaska) Inc.,

Anchorage, Alaska.

URS Corporation. (Alaska), 2012. Drilling Procedures, Sample Descriptions, Boring Logs, Bore-

hole Locations, and Archive Inventory for 32 Near-Shore Marine Sediment Vibracore Sam-

ples, West Dock Causeway, Prudhoe Bay, Alaska. Alaska Geologic Materials Data Report

No. 407.

U.S. Army Corps of Engineers (USACE). 1998. Dredged Material Evaluation Framework: Lower

Columbia River Management Area. November.

Wilhelmsson, D., Langhamer, O., and Tchou, J. 2010. “Brief on Tidal and Current Power.” In:

Greening Blue Energy: Identifying and managing the biodiversity risks and opportunities

of offshore renewable energy. D. Wilhelmsson, et al. (eds.). Pp.5-7. Gland, Switzerland:

IUCN.

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West Dock Dredge and Disposal Plan

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Attachment 1 - Screening for Port and Dock Site Selection, Dredge Material Disposal, and Offload Methodology

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West Dock Dredge and Disposal Plan

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Attachment 2 - BP Exploration (Alaska), Inc. West Dock Permit Modification

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 1 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

Attachment 3 – Review of West Dock and Beaufort Sea Fisheries

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West Dock Dredge and Disposal Plan

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Attachment 4 – Authorities Applicable to The Proposed Action

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AUTHORITIES APPLICABLE TO THE PROPOSE ACTION

LEGAL AUTHORITY AUTHORIZATIONS REGULATORY INTENT

Federal

Federal Laws Common To Multiple Federal Agencies

National Environmental Policy Act (NEPA) 42 United States Code (USC) 4321

The NEPA of 1969 requires all federal agencies to prepare a detailed statement of the environmental effects of proposed fed-eral actions that may significantly affect the quality of the human environment.

Protect the environment through proce-dures that ensure environmental infor-mation is available to public officials and citizens before decisions are made and before actions are taken.

National Historic Preservation Act (NHPA) of 1966 16 USC 470 et seq.

Federal agencies are responsible for ensur-ing protection of historical, cultural, and ar-chaeological sites and resources in areas where federal actions are taking place.

Ensure consideration of the values of historic properties in carrying out federal actions. Make efforts to identify and miti-gate impacts on significant historic prop-erties.

U.S. Army Corps of Engineers (USACE)

Clean Water Act (CWA) of 1972 33 USC 1344

The USACE issues a Section 404 permit for discharge of dredged and fill material into American waters, including wetlands.

The U.S. Environmental Protection Act (EPA) reviews and comments on permit ap-plications for compliance with Section 404(b)(1) guidelines.

Minimize impacts to waters of the United States, including wetlands, by regulating the discharge of dredged and/or fill material.

Rivers and Harbors Act (RHA) of 1899 33 USC 403

The USACE issues Section 9 and Section 10 permits for structures or work in, or af-fecting, navigable waters of the United States.

Prevent unauthorized obstruction or al-teration (dam, dike, or other structure) of any navigable waters of the United States.

U.S. Environmental Protection Agency (EPA)

CWA of 1972, Amended 1977 33 USC 1251 et seq.

The National Pollutant Discharge Elimina-tion System (NPDES) Permit program is ad-ministered under Section 402, CWA of 1972, as amended for discharges of pollu-tants from a point source into waters of the United States. Through program delegation, the EPA oversees the Alaska Department of Environmental Conservation’s (ADEC’s) ad-ministration of the Alaska Pollutant Dis-charge Elimination System (APDES) program that regulates the discharge of pol-lutants from a point source into waters of the United States for facilities, and construc-tion.

The purpose of the CWA is to restore and maintain the chemical, physical, and biological integrity of the nation’s waters. It prohibits the “discharge of toxic pollutants in toxic amounts” to nav-igable waters of the United States.

Section 402 establishes guidelines for effluent discharges from point-sources to the waters of the United States and for the NPDES permitting program.

U.S. Coast Guard (USCG)

RHA of 1899 33 USC 403

The USCG approves construction of a bridge across navigable waters to ensure safe navigability of waterways.

Prevent unauthorized obstruction or al-teration (dam, dike, or other structure) of any navigable waters of the United States.

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LEGAL AUTHORITY AUTHORIZATIONS REGULATORY INTENT

U.S. Fish and Wildlife Service (USFWS)

Fish and Wildlife Coordination Act (FWCA) 16 USC 661 et seq.

FWCA of 1980 16 USC 2901

The USFWS provides consultation on ef-fects to fish and wildlife resources.

The USFWS consults with the state agency responsible for fish and wildlife resources to conserve or improve wildlife resources.

Ensure that fish and wildlife resources receive equal consideration to other ASAP Project features.

Conserve and promote conservation of non-game fish and wildlife species and their habitats.

Bald and Golden Eagle Protection Act 16 USC 668

The USFWS permits the relocation of bald and golden eagle nests that interfere with resource development or recovery opera-tions.

Protect bald eagle populations.

Marine Mammal Protection Act (MMPA) 16 USC 1361-1407

The USFWS issues a Letter of Authorization for incidental takes of marine mammals in-cluding polar bear and walrus.

Ensure that marine mammal popula-tions are maintained at, or in some cases restored to, healthy population levels.

Migratory Bird Treaty Act (MBTA) 16 USC 703

The USFWS implements provisions of the MBTA.

Protect birds that have common migra-tion patterns between the United States and Canada, Mexico, Japan, and Rus-sia.

Endangered Species Act of 1973 (ESA) 16 USC 1531

The USFWS provides consultation on ef-fects to threatened or endangered species, and to designated critical habitat, and is-sues incidental take authorizations.

Protect wildlife, fish, and plant species in danger of becoming extinct, and con-serve the ecosystems on which endan-gered and threatened species depend.

National Oceanic and Atmospheric Administration - National Marine Fisheries Service (NOAA Fisheries)

FWCA 16 USC 661 et seq.

The NOAA Fisheries provides consultation regarding effects on marine fish and wildlife resources.

Ensure that fish and wildlife resources receive equal consideration to other ASAP Project features.

Magnuson-Stevens Fishery Manage-ment and Conservation Act 16 USC 1801-1883

The NOAA Fisheries provides consultation on the effects on Essential Fish Habitat (EFH). EFH includes habitats necessary to a species for spawning, breeding, feeding, or growth to maturity.

Protect fish habitats and populations.

MMPA 16 USC 1361-1407

The NOAA Fisheries provides consultation regarding effects on marine mammals.

The NOAA Fisheries issues Incidental Har-assment Authorization under the MMPA for incidental takes of certain protected marine mammals (ringed seals, bowhead whales, etc.).

Ensure that marine mammal popula-tions are maintained at, or in some cases restored to, healthy population levels.

The ESA of 1973 16 USC 1531

The NOAA Fisheries provides consultation on effects to threatened or endangered spe-cies, and to designated critical habitat, and issues incidental take authorizations.

Protect certain species of marine mam-mals and fish in danger of becoming ex-tinct, and conservation of the ecosystems on which endangered and threatened species depend.

State

Alaska Department of Environmental Conservation (ADEC)

CWA of 1972, Amended 1977 33 USC 1251 et seq.

Section 401 requires the ADEC to certify that federal permits meet standards set by the Water Quality Standards program. The ADEC reviews and approves Stormwater Pollution Prevention Plans.

Establish guidelines for effluent dis-charges from non-point sources to the waters of the United States and the NPDES permitting program.

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LEGAL AUTHORITY AUTHORIZATIONS REGULATORY INTENT

CWA of 1972, Amended 1977 33 USC 1251

APDES 18 Alaska Administrative Code (AAC) 83

Water Quality Standards 18 AAC 70

The ADEC is fully authorized to administer the EPA’s NPDES program through the APDES. Existing regulations at 18 AAC 15 and 18 AAC 72 were amended to comply with the Clean Water Act.

The ADEC provides approval for treatment and disposal plans for industrial wastewaters.

Regulate discharges to protect water quality.

Clean Air Act of 1967 (CAA), Amended 1977 42 USC 7401 et seq.

Air Quality Control 18 AAC 50 et seq.

The ADEC issues Air Quality Control per-mits to construct and to operate.

The ADEC issues Title V Operating permits and prevention of significant deterioration permits for air pollutant emissions under the CAA Amendments (Title V).

Provide air quality information as part of the ASAP Project NEPA review.

Prevent, abate, and control air pollution in a manner that meets the purposes of Alaska Statute (AS) 46.03, AS 46.14, and 42 USC 7401 – 7671q (CAA).

Alaska Department of Fish and Game (ADF&G)

The FWCA of 1980 16 USC 2901

The FWCA of 1980 16 USC 661 et seq.

The ADF&G consults with the USFWS about fish and wildlife resources to con-serve or improve wildlife resources.

The ADF&G provides comments and rec-ommendations to federal agencies pursuant to the FWCA.

Conserve and promote conservation of non-game fish and wildlife species and their habitats.

Ensure that fish and wildlife resources receive equal consideration to other ASAP Project features.

Anadromous Fish Act

AS 16.05.871

Fishway Act

AS 16.05.841

An individual or governmental agency noti-fies and obtains authorization from the ADF&G for activities that could use, divert, obstruct, pollute, or change natural flow of specified anadromous fish streams.

Protect the integrity of the various rivers, lakes, and streams or parts of them that are important for the spawning, rearing, or migration of anadromous fish.

Alaska Department of Natural Resources (ADNR)

Alaska Historic Preservation Act AS 41.35.010 to .240

NHPA of 1966 16 USC 470 et seq. 36 Code of Federal Regulations 800 Sections 106 and 110

The Archeological Resources Protec-tion Act of 1979 16 USC 470

Section 106 of the NHPA requires federal agency consultation with the Historic and Archaeological Office within the Alaska State Historic Preservation Office of History and Archaeology Office (OHA) and, when there are effects on cultural resources listed on or eligible for inclusion in the National Register of Historic Places.

OHA may issue a Cultural Resources Con-currence for developments that may affect historic or archaeological sites.

Protect cultural and archaeological re-sources to ensure consideration of the values of historic properties in carrying out federal activities and to make efforts to identify and mitigate impacts to signif-icant historic properties.

The Archeological Resources Protection Act secures the protection of archaeo-logical resources and sites on public and Native American lands and encour-ages the exchange of information be-tween involved individuals and entities.

Public Land Act

Material Sales AS 38.05.110

Permits AS 38.05.850

Mining Sites Reclamation Plan Ap-provals AS 27.19

The ADNR issues a Material Sales Contract for mining and purchase of gravel from state lands.

The ADNR issues Land Use permits for use of state land, ice road construction on state land, and state waters.

The ADNR approves mining reclamation plans on state, federal, municipal, and pri-vate land and water.

Manage use of Alaska’s land and water resources.

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LEGAL AUTHORITY AUTHORIZATIONS REGULATORY INTENT

Local

North Slope Borough (NSB)

NSB Land Management Regulations (NSB Municipal Code §§ 19.10.010 through 19.70.060)

The NSB requires compliance with its zon-ing and permitting ordinances and issues permits for development, uses, and activities on land within the NSB.

The NSB regulates land uses and activi-ties within the borough to provide for the protection of the health, safety, and wel-fare of NSB residents and to ensure compliance with environmental policies of local concern.

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West Dock Dredge and Disposal Plan

Document No: ASAP-22-PLN-WWW-DOC-00004 Date: July 12, 2016 Page 1 NOTICE – THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED OR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING. THIS DOCUMENT IS UNCONTROLLED WHEN PRINTED. THIS COPY VALID ONLY AT THE TIME OF PRINTING

ATTACHMENT 5 – WEST DOCK BORING LOGS