vvEPA
DOI
United States
Environmental Protection
Agency
Region 10
1200 Sixth Avenue
Seattle WA 98101
EPA 9lO/9-84-122a
September, 1984
Water Division
EPA-10-AK-Wulik-NPDES-84
United States
Department of
Interior
Post Office Box
100120
Anchorage AK 99510
Environmental
Impact Statement
Red Dog Mine Project
Northwest Alaska
Final
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TO: All Interested Government Agencies, Public Officials, Public and
Private Groups and Citizens
Pusuant to Section 102(2)(c) of the National Environmental Policy Act of
1969 and implementing Federal Regulations, the U.S. Environmental
Protection Agency (EPA) and U.S. Department of the Interior (DOI) have
prepared this Final Environmental Impact Statement (FEIS) on the proposed
Red Dog Mine Project. The Red Dog mineral prospect (lead, zinc, silver,
and barite) is located in the De Long mountains of Northwest Alaska on
lands owned by the NANA Regional Corporation. Through an agreement with
NANA, Cominco Alaska proposes to develop an open-pit mine with adjacent
ore milling facilities, and to construct a transportation route and
saltwater port on the Chukchi Sea for shipping ore concentrates to foreign
and domestic markets. As proposed, the transportation route would cross
the northwest corner of Cape Krusenstern National Monument.
This FEIS provides information to aid Federal permitting decisions for the
mine and mill facilities and for the transportation system. Cominco
Alaska has applied to EPA for a National Pollutant Discharge Elimination
System (NPDES) permit to discharge pollutants from the mine site to
navigable waters pursuant to the provisions of the Clean Water Act (Public
Law 95-217). The proposed mine and mill facility has been determined to
be a new source under Section 306 of the Clean Water Act and, according to
Section 511(c)(l) of the Clean Water Act, is subject to the provisions of
the National Environmental Policy Act. The new source NPDES permit which
EPA has under consideration for the mine and mill operation is included in
Appendix 4.
As a cooperating agency for the EIS, the Alaska District Corps of
Engineers (Corps), under the authority of Section 10 of the River and
Harbor Act of 1899 and Section 404 of the Clean Water Act, will evaluate
Cominco Alaska's proposed activities in certain waters of the United
States in the vicinity of the mine site. Appendix 5 of the EIS contains a
complete description of the proposed activities requiring Department of
the Army (DA) authorization.
Cominco Alaska has also filed a consolidated Alaska National Interest
Lands Conservation Act (ANILCA) Title XI application with the DOI, EPA,
and the Corps for Federal permits required for the development of the
proposed transportation system. The following permits are covered by the
consolidated Title XI application and this FEIS:
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- 2 -
- A DOI National Park Service (NFS) Right-of-Way Permit to
construct a transportaton route through Cape Krusenstern
National Monument.
- An EPA NPDES permit for a sanitary waste discharge from the
port facility. A draft copy of this permit is included in
Appendix 4 for your review.
- DA permits for proposed activities in certain waters of the
United States that would be affected by the transportation
system.
These three permits are necessary to authorize construction of the
system. Furthermore, EPA and the Corps have the authority to issue
their respective permits, while NFS does not. In this case, the
recommendation by NFS to approve or disapprove the Right-of-Way
permit would have to be forwarded to the President and Congress for
their action.
This Final EIS will be circulated for a 30 day pubic review period,
ending on November 18, 1984. EPA's Project Officer is:
William M. R1ley
EIS Project Officer, M/S 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
RED DOG MINE PROJECT
Prepared by
U.S. ENVIRONMENTAL PROTECTION AGENCY (Region 10)
and
U.S. DEPARTMENT OF THE INTERIOR
0 National Park Service
0 Bureau of Land Management
0 Fish and Wildlife Service
Cooperating Agency
U.S. Department of the Army
Corps of Engineers
With Technical Assistance From
Ott Water Engineers, Inc.
RESPONSIBLE OFFICIALS:
\
Ernesta B. Barnes
Regional Administrator
Environmental Protection Agency
Region 10
Date: SEP 6 1984
Paul D. Gates
Regional Environmental Officer
Department of the Interior
SEP 61984
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ERRATA
As a result of geotechnical investigations conducted this summer, Cominco
Alaska has recently requested a modification to the proposed southern
transportation route (Alternative 1). The proposed realignment (see
overleaf) would pass closer to Mud Lake within Cape Krusenstern National
Monument. Mud Lake is a sedge-grass marsh that provides high quality
habitat for waterfowl.
Cominco has also identified a new borrow site location one-half mile south
of Mud Lake. Borrow sites 3 and 5 have been relocated and borrow site 6
has been enlarged. The new locations are shown in the August 27, 1984,
letter from Cominco to NPS included as part of the Title XI application
(Appendix 6). The new locations for sites 3 and 5 are along the present
road alignment. Site 5, however, would lie within 91m (300 feet) of a
stream, contrary to the information in Table 11-3 (page 11-25).
Although the new alignment would disturb less acreage, it does encroach on
a more sensitive environment, Mud Lake (see page V-42). Depending on the
depth of excavation of the adjacent borrow site and local hydrologic
conditions, the possiblity of partially draining Mud Lake exists. Proper
design and reclamation of the borrow site, however, would prevent this
from occurring.
The proposed new alignment and borrow site locations would not change the
overall ranking of the alternatives and road options.
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OIV1IK RIVER
b
KRUSENSTERN
PARK BOUNDARY
TO RED DOO
MINE
RED DOB ROAD
MUD LAKE
ROAD ALTERNATIVES
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COVER SHEET
FINAL ENVIRONMENTAL IMPACT STATEMENT (FEIS)
RED DOG MINE PROJECT
NORTHWESTERN ALASKA
Co-Lead Agency:
Responsible Official:
Co-Lead Agency:
Responsible Official:
Cooperating Agency:
U.S. Environmental Protection Agency
Ernesta B. Barnes
Regional Administrator
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
U.S. Department of the Interior
0 National Park Service
0 Bureau of Land Management
0 Fish & Wildlife Service
Paul D. Gates
Regional Environmental Officer
Department of the Interior
Box 100120
Anchorage, AK 99510
U.S. Army Corps of Engineers
Abstract of FEIS
The actions to be considered are the approvals of permits for the proposed
Red Dog Mine Project in northwestern Alaska. The mine area facilities would
be located on private land owned by the NANA Regional Corporation. A
transportation corridor would be constructed from the mine to a port site on
the Chukchi Sea. Three action alternatives and a No Action Alternative are
discussed. Rationale is given why various options were eliminated from
consideration. The preferred alternative would traverse Cape Krusenstern
National Monument. Impacts of the proposed project are described as they
relate to vegetation and wetlands, wildlife, water quality, fishery resources,
physical and chemical oceanography, air quality, visual resources, cultural
resources, subsistence, socioeconomics, recreation, technical complexity, cost
and Cape Krusenstern National Monument.
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Public FEIS Review and Comment Process
This FEIS is offered for review and comment to members of the public,
special interest groups and agencies. Public meetings/hearings were held
in April and May 1984 in Washington D.C., Anchorage and Kotzebue to dis-
cuss the DEIS. Announcements of these meetings/hearings were made by
local newspapers and other appropriate media. No further public hearings
were scheduled. Comments received on the FEIS will be addressed in the
record of decision.
Location of Technical and Reference Reports and Appendices
Copies of the major reports relating to the Red Dog EIS will be available at
the following locations:
EPA Region 10 Headquarters Ott Water Engineers, Inc.
1200 Sixth Avenue 4790 Business Park Blvd.
Seattle, WA 98101 Building D, Suite 1
Anchorage, AK 99503
EPA Maniilaq Association Offices
3200 Hospital Drive Shore Street
Suite 101 Kotzebue, AK 99752
Juneau, AK 99801
Department of the Interior Noel Wien Public Library
1689 'C' Street 1215 Cowles
Anchorage, AK 99501 Fairbanks, AK 99701
Z. J. Loussac Library
524 West 6th Avenue
Anchorage, AK 99501
Deadlines for Comments: November 18, 1984
Address all Comments to: William M. Riley
EIS Project Officer
Environmental Evaluation Branch (M/S 443)
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Telephone: (206) 442-1760
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Summary
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SUMMARY
INTRODUCTION
Cominco Alaska, Inc. proposes to develop the Red Dog mineral prospect
131 km (82 mi) north of Kotzebue in northwestern Alaska. The proposed
mine site is located on Red Dog Creek, just west of Deadlock Mountain in the
De Long Mountains of the western Brooks Range. The project would consist
of an open pit lead/zinc mine and concentrator located 75 km (47 mi) inland,
with interconnecting transportation facilities and shipping facilities located at
the coast. The mine, mill, tailings pond, housing and water supply facilities
would all be located on private lands owned by the NANA Regional Corpora-
tion as part of a 8,975 ha (22,176 ac) parcel in the Red Dog Valley.
The NANA Regional Corporation obtained selection rights to the Red Dog
mineral prospect with passage of the Alaska National Interest Lands Con-
servation Act (ANILCA) in 1980. After the establishment of its right to the
Red Dog deposit, NANA selected Cominco Alaska, Inc. as a partner to aid in
the development of the project.
The agreement between NANA and Cominco for development of the Red Dog
mine represents a melding of environmental, social, cultural and economic
interests. The intent of the agreement is to allow development in a manner
that provides for: a long-term economic base for the NANA region; jobs for
NANA shareholders and other Alaskans; a source of lead/zinc concentrates
and an economic return for Cominco; and minimal impacts on the region's
social, historical, cultural and subsistence lifestyles.
The EIS process began in January 1983 with the U.S. Environmental Protec-
tion Agency (EPA) as lead federal agency. A unique feature of the Red Dog
project is that the preferred alternative would involve a transportation cor-
ridor through Cape Krusenstern National Monument. This would require
consideration of the specific requirements mandated by Title XI of ANILCA
for acquiring a right-of-way across the Monument. On November 7, 1983
Cominco made a formal Title XI application to the National Park Service
(NPS). Cominco's application was the first ever filed. At that point, the
U.S. Department of the Interior (DOI) became co-lead agency with EPA for
the EIS process. Title XI applications were also filed with EPA and the
U.S. Army Corps of Engineers (Corps).
In June 1983 NANA began separate discussions with the NPS for a land
exchange. This exchange, if successfully negotiated and implemented, would
alter the northwest boundary of the Monument to exclude lands surrounding
the preferred transportation corridor, thereby making a Title XI permit
in
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unnecessary. If the preferred alternative were developed with a land ex-
change, the environmental impacts would be similar.
PROJECT DESCRIPTION
It is important that the reader understand the relationship among the terms
"component", "option" and "alternative". The project has several compo-
n_ents_, each one a necessary part of an entire viable mining project (e.g.,
the mine, mill site, tailings pond, transportation system, port site, etc.).
For each component there may be one or more options (e.g., a northern
and a southern transportation corridor option). An alternative is a combin-
ation of options (one for each component) that constitutes an entire function-
ing project.
Development of the Red Dog mine project would involve an open pit lead/
zinc mine. While the deposit has not yet been fully defined by geologists,
at least 77 million Mg (85 million tons) of ore exist. The ore is estimated to
contain approximately 5.0 percent lead, 17.1 percent zinc, 75 g/Mg (2.4
oz/ton) silver and measurable levels of barite. The project has a potential
life of at least 40 years under expected production rates, with the possibility
of extension if additional ore is found.
The ore would be crushed, and metallic sulfides would be concentrated using
a selective flotation process in a mill near the mine site. No reduction of
sulfides to base metals would take place at the project site. The upgraded
concentrates would be sent outside Alaska for processing to refined metals.
Initially, about 434,450 Mg/yr (479,000 tons/yr) of combined concentrates
would be transported to the coast for shipment to world markets. After five
years, expanded production of about 683,878 Mg/yr (754,000 tons/yr) of
combined concentrates would be shipped.
A 237 ha (585 ac) tailings pond would be created on the South Fork of Red
Dog Creek. The tailings pond dam would be in the form of an impervious
earth-filled structure with a spillway designed to maintain structural integ-
rity in the event of an overflow. The pond would contain thickened tailings
slurry from the mill process, in addition to surface and subsurface waters
with known toxic concentrations of metals. Chemical treatment and metals
removal of tailings pond water would occur prior to discharge to Red Dog
Creek. A seepage contingency dam would be constructed downstream of the
main tailings pond dam to collect any seepage and return it to the tailings
pond.
An approximately 25 ha (63 ac) water storage reservoir would be located on
Bons Creek at the south end of Red Dog Valley. This reservoir would serve
as the water supply for all aspects of the milling process, as well as for
domestic use.
A gravel road to the coast would be 9 m (30 ft) wide and composed of gran-
ular fill averaging 2.0 m (6.5 ft) in thickness and designed to prevent de-
gradation of permafrost. The proposed northern transportation corridor
would be about 117.0 km (73.1 mi) long and would require the construction
IV
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of six major bridges, seven minor bridges and about 300 culverts. The pro-
posed southern corridor would be about 89.9 km (56.2 mi) long and would
require one major bridge, four minor bridges and about 182 culverts.
Though operations at the mine and mill would continue year-round, activity
at the port site would be limited to the receipt of supplies and fuel during
the summer sealift, and the shipment of concentrates from late June until
early October. Climatic constraints on shipping activities thus require that
adequate storage facilities for concentrates, fuel and other supplies exist at
the port site. Only emergency and temporary ship loading crews would be
housed there.
Two methods to transfer concentrates from the port site storage facility to
ocean going vessels are included in the alternatives: a short causeway/
lightering transfer system and a short causeway/offshore island transfer
system. Both systems would use a 122 m (400 ft) causeway/dock structure
as an interface between the shore and the concentrate loading vessels or
offshore island. The lightering system would use two 4,535 Mg (5,000 ton)
lighters and two support tugs to transfer concentrates from the dock
directly to the side of a moored ocean-going ship. The offshore island
system would use an approximately 226,750 Mg (250,000 ton) surplus oil
tanker which would be ballasted to the bottom about 1,097 m (3,600 ft) from
shore. This approximately 305 m (1,000 ft) tanker "island" would serve as
an offshore dock for loading/unloading smaller, ocean going ships.
Cominco's most probable development schedule shows the winter of 1985-86 as
the beginning of construction. The construction period would last a minimum
of 24 months with mining beginning in 1988. The actual beginning of con-
struction would depend on world economic conditions, ability to complete de-
tailed engineering design, and the progress of the environmental permitting
process.
EXISTING ENVIRONMENT
The Red Dog project area encompassing the mine, mill, housing and tailings
pond sites, and the transportation corridor and port site options, fall within
the northwestern corner of the NANA Regional Corporation's boundaries.
Nearly all of the study area is undeveloped and is within the so-called
unorganized borough. That is, it is outside any incorporated city or bor-
ough governmental jurisdiction. Only the mine area facilities in Red Dog
Valley and a thin strip immediately to the south would fall within the North
Slope Borough.
The project area is characterized by moderately sloping hills, broad stream
valleys and coastal lowland lagoon systems. The entire area is underlain by
permafrost. Gentle, poorly defined surface undulations are caused by pat-
terned ground, old drainage channels, thaw lakes, and other depositional,
erosional or permafrost related features. The seasonal thaw or active layer
varies throughout the area. It generally ranges from 50 to 100 cm (20 to 39
in) deep in vegetated areas and may range up to 3 m (10 ft) deep on
exposed, rocky hillsides.
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Vegetation types at the mine site, along the transportation corridors and at
the alternate port sites range from xerophytic (dry-adapted), upland mat
and cushion tundra to wet, lowland sedge-grass marsh. Vegetation consists
primarily of cotton-grass tussock tundra, low shrublands and herbaceous
meadows, in order of relative abundance.
Waterfowl and shorebird use of the project area is centered along the coast
during the spring and fall migrations, although coastal and inland breeding
occurs. Portions of the project area provide good habitat for cliff nesting
raptors including the endangered peregrine falcon, golden eagle, gyrfalcon
and the rough-legged hawk.
Five large terrestrial mammal species are found in the project area: caribou,
muskoxen, moose, Dall sheep and brown bear. The Arctic caribou herd,
numbering approximately 190,000 animals and the largest herd in North
America, encompasses the project area within its range. Caribou use the
Asikpak, Kivalina, Wulik and Omikviorok River drainages, and probably the
Singoalik River drainage, for winter range. A small herd of muskoxen
appears to be established on winter range in the Rabbit Creek Valley south
of the Mulgrave Hills. A larger herd is established to the northwest in the
Cape Thompson area. Moose are found in the region closely associated with
riparian tall shrub communities along major rivers and streams, particularly
during the winter. Dall sheep habitat in the project vicinity is limited to
the Wulik Peaks and the mountains bordering the headwaters of the Wulik
River and Ikalukrok Creek. Brown bears are found throughout the project
area. Other important terrestrial mammals include the wolf, wolverine and
red fox.
Water quality in the major rivers of the project area, the Kivalina, Wulik and
Omikviorok, is typical of unpolluted fresh water in the Arctic. These rivers
are clear water streams with low levels of color, suspended solids, turbidity
and nutrients. Ikalukrok Creek has similar water quality characteristics,
except below its confluence with the lower quality waters of Red Dog Creek.
The waters of Red Dog Creek are atypical of most undeveloped Arctic
streams because of the toxic concentrations of cadmium, lead, zinc and iron
that enter the main stem of the creek as it flows through the highly min-
eralized Red Dog ore body. Waters not affected by the ore body in the
upper portion of the main stem, the North Fork, and most of the South Fork
exhibit high water quality.
Important fishery resources in the Kivalina, Wulik and Omikviorok River
drainage systems include Arctic char, Arctic grayling and various salmon
species.
Important marine fish found in the area include starry flounder, Arctic
flounder and saffron cod. Marine mammals present include ringed, spotted
and bearded seals, harbor porpoise, belukha, and the endangered Gray and
bowhead whales.
Wind and wave conditions along the coast have a significant effect on sedi-
ment transport. Long-term net transport is generally in a southeasterly
direction. The Chukchi Sea typically has relatively warm, low salinity water
VI
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present near shore. Sea ice generally begins to form on the coast in early
October, but periodic high winds and waves may delay formation of a solid
cover until January. The ice cover usually disappears by early July.
The earliest known prehistoric cultural remains in the vicinity of the Red
Dog project area are located on a series of beach ridges at Cape Krusen-
stern, and form the core of the Cape Krusenstern National Monument. A
major portion of the project area is within the Cape Krusenstern Archeolog-
ical District. The known major archeological sites for which the Monument
was created are located on beach ridges. Inland, archeological sites are
more scattered and indicate a less intensive settlement pattern involving
limited use. Beach ridge sites would not be subject to impact. Known
inland sites within the Monument or within the Cape Krusenstern Archeolog-
ical District would be avoided by project design. The easily visible concen-
tration of houses and occupied beach ridge sites in the Monument are often
used as a diachronic model of human life in northwestern Alaska. Sites
within the Red Dog project area are typical of the region and consist of
surface scatters, or shallowly buried deposits of lithic materials that were
used in making stone artifacts.
Subsistence is vital to the economic well being and nutrition of most of the
region's residents. Approximately 55 percent of all households obtain half or
more of their food supply by subsistence hunting, fishing and gathering.
In a region where imported foodstuffs are costly and cash income depressed,
the economic importance of the subsistence food supply is evident.
SCOPING
The EIS scoping process identified the following 12 issues of concern for the
project:
0 Maintaining the quality and quantity of water
0 Maintaining the quality and quantity of fishery habitat, and mini-
mizing disruption of fish movements
0 Maintaining the quality and quantity of wildlife habitat, and mini-
mizing impacts on wildlife
0 Minimizing impacts on coastal geologic processes
0 Minimizing impacts on marine life
0 Protecting subsistence resources and their use
0 Protecting cultural resources
0 Minimizing the social, cultural and economic impacts on residents of
the region
0 Designing project components from a regional use perspective
0 Impacts on Cape Krusenstern National Monument
0 Technical feasibility
0 Economic feasibility
VII
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OPTIONS SCREENING PROCESS
To address those 12 issues, the scoping process also identified a total of 30
options and seven suboptions for the 11 project components (see first column
of Table 1 for list of components). To determine reasonable options, a two-
step options screening process was conducted. In the first step all options
were reviewed to eliminate from further consideration those which were
clearly unreasonable or infeasible primarily for environmental or technical
reasons. This resulted in 11 options and one suboption being eliminated.
In the second step, the remaining options were individually evaluated in de-
tail from the perspective of each resource or technical discipline (e.g.,
water quality, wildlife, subsistence, technical feasibility). For each disci-
pline, a specific set of "options screening criteria" was used to identify
potential impacts for each option. Then, each option was compared to all
other options for each of the 11 components to identify the best option (i.e.,
the one with the least potential impacts) for each component.
Following the options screening process, the best options for eight of the 11
components were relatively easy to identify. However, three components
(transportation corridor location, port site location and marine transfer facil-
ity) had two options each which adequately addressed one or more of the
12 issues. These options were therefore retained and, with the other eight
options, were used to form the alternatives (Table 1).
IDENTIFICATION OF ALTERNATIVES
The identification of alternatives process was relatively straightforward as
there were only three combinations (and hence alternatives) necessary to
address the issues raised by the three components with more than one option
remaining. The three action alternatives and the no action alternative for
the Red Dog project are described below.
Alternative 1
This alternative would site the tailings pond in the South Fork of Red Dog
Creek with the mill in close proximity to the west. A worker camp would
be located close to the mill. Power would be supplied by diesel generators
also sited near the mill. Water would come from an impoundment on Bons
Creek to the south of the tailings pond and airstrip. All these facilities, as
well as the mine, would be located on private land owned by NANA.
Transportation would be by year-round road along the southern corridor to
a port site at VABM 28 on private NANA land within the boundaries of Cape
Krusenstern National Monument. The transfer facility would be the short
causeway/offshore island.
Alternative 2
This alternative is the same as Alternative 1 for all components except the
transportation corridor and port site location. It includes the northern
transportation corridor to a port site at Tugak Lagoon.
VIII
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Table 1
OPTIONS USED TO FORM ALTERNATIVES
Component
Option(s)
Mine Location
Tailings Pond Location
Mill Site Location
Worker Housing
Type
Location
Water Supply
Power Generation
Transportation
Corridor Location
System
Port Site
Location
Transfer Facility
Fixed
South Fork Red Dog Creek
South Fork Red Dog Creek
Campsite
South Fork Red Dog Creek
Bons Creek
Diesel
Northern
Southern
Road
Tugak Lagoon
VABM 28
Short Causeway/Lightering
Short Causeway/Offshore
Island
Suboption
Asikpak Route
Kruz Route
Year-round
Alternative 3
This alternative is the same as Alternative 1 except that the transfer facility
would be the short causeway/lightering option instead of the short causeway/
offshore island option.
No Action Alternative
The No Action Alternative is defined as meaning no development of the Red
Dog project would occur. The No Action Alternative would result from
denial of at least one, or perhaps more, of the federal or state permits
necessary for project development. Or, it could mean that the project
sponsor chose not to undertake the project.
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COMPARISON OF ALTERNATIVES
The impacts of each of the three action alternatives were compared by an
evaluation against the 12 issue criteria identified during the scoping process
(Chapter III). The quantified impacts of each alternative (Table 2) were
then compared for identification of the preferred alternative.
IDENTIFICATION OF PREFERRED ALTERNATIVE
Alternative 1, comprised of the southern corridor, VABM 28 port site and
the offshore island facility, has been identified by the co-lead agencies as
the preferred alternative. The Corps has not identified a preferred alterna-
tive and will not until the Record of Decision.
The preferred alternative would require a road through Cape Krusenstern
National Monument, and, therefore, an ANILCA Title XI permit would be
needed. This would require that the transportation system be evaluated
against the standards set forth in Section 1105 of ANILCA. The Title XI
application was filed by Cominco with the NPS, Corps and EPA, each of
which has land management and/or permitting responsibility for the project.
This application is undergoing review by the NPS, Corps and EPA. A copy
of the Title XI application and agency review comments are included in this
document as Appendix 6.
ENVIRONMENTAL CONSEQUENCES OF THE PREFERRED ALTERNATIVE
The mine area facilities (mine, tailings pond, mill site, worker housing,
water supply, airstrip and all associated access roads) would directly disturb
a total of about 541 ha (1,336 ac) of vegetation in Red Dog Valley. Devel-
opment and operation of these facilities might have an indirect impact upon
caribou by displacing some animals from marginal winter range. This impact
would not be significant on more than a local basis and no other wildlife
species would be significantly impacted.
Ninety-five percent of the metal loads in the main stem of Red Dog Creek
above the South Fork come from an area bounded by the exposed ore zone.
Since this area would be developed, with runoff diverted to the tailings pond
where water treatment would occur prior to discharge, water quality in the
naturally contaminated main stem of Red Dog Creek could improve. There
would be no significant impacts on fishery resources from mine area facili-
ties.
Four archeological sites are located in the immediate area of the mine site.
Two of these could not be avoided during ore removal, and therefore they
would be evaluated for eligibility to the National Register of Historic Places.
If eligible, mitigation actions would be included in the Advisory Council on
Historic Preservation (ACHP) commenting procedures developed in consulta-
tion with the State Historic Preservation Officer (SHPO) and the federal
agencies permitting the project. Wherever feasible, road alignments and
other facilities would be designed to
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Table 2
EVALUATION CRITERIA MATRIX SHOWING RELATIVE TOTAL IMPACT
VALUES ASSIGNED TO THE THREE ACTION ALTERNATIVES
Evaluation Criteria
ALTERNATIVE 1
Southern Corridor
VABM 28 Port Site
Offshore Island Fac.
ALTERNATIVE 2
Northern Corridor
Tugak Lagoon P. S.
Offshore Island Fac.
ALTERNATIVE 3
Southern Corridor
VABM 28 Port Site
Lightering Facility
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
Minimize Risk of Water
Quality Degradation
Minimize Impacts to Fish
and Fish Habitat
Minimize Impacts to Wildlife
and Wildlife Habitat
Minimize Impacts to Coastal
Geologic Processes
Minimize Impacts to Marine
Life and Marine Habitat
Minimize Impacts to
Traditional Subsistence
Harvest Activities
Minimize Impacts to
Cultural Resources
Minimize Social, Cultural and
Economic Impacts upon
Residents of the Region
Maximize the Potential for
Other Regional Uses
Minimize Impacts on Cape
Krusenstern National
Monument
Minimize Technical Complexity
Minimize Costs
Low Risk
Low Impact
Low Impact
Low Impact
Low Impact
Low Impact
Low Impact
These impacts would
High Potential
High Impact
Moderate Complexity
Low Cost
High Risk
High Impact
High Impact
Low Impact
Low Impact
High Impact
Low Impact
be similar for all three
High Potential
Low Impact
High Complexity
High Cost
Moderate Risk
Moderate Impact
Low Impact
Low Impact
Moderate Impact
Moderate Impact
Low Impact
alternatives.
Moderate Potential
Moderate Impact
Moderate Complexity
Moderate Cost
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avoid direct impact to these sites. If sites could not be reasonably avoided,
recovery operations would be conducted to preserve the site data. The mine
site vicinity possesses little value for subsistence or recreational fishing and
hunting, and no significant impacts would be anticipated.
Construction of the southern transportation corridor from the mine area
through Cape Krusenstern National Monument to the coast at VABM 28 would
directly disturb a total of about 197 ha (487 ac) of vegetation. Several nest
sites of birds of prey, including three of the endangered peregrine falcon,
have been reported along the southern corridor. The peregrine nests would
not be significantly impacted because the road alignment has been altered to
provide a buffer of at least 3.2 km (2 mi) around the nests. The corridor
passes through presently used caribou winter range. Indirect habitat loss
for caribou would likely be significant only on a local basis, but could, as
other developments occurred in the region, be significant on a greater than
local basis if changes to historical caribou migrations occurred.
Impacts on hydrology and water quality would be insignificant as proper
methods of road construction and drainage control would be followed. The
road would cross 11 streams which are known to contain fish, but no sig-
nificant impacts to fish movements or spawning and/or rearing habitat would
be expected.
Construction of the southern corridor could impact 12 archeological sites, six
within Cape Krusenstern National Monument. All reasonable measures would
be taken to avoid these sites by realigning the road. Recovery operations
would be conducted under terms of the Memorandum of Agreement to pre-
serve the site data and material that could not be preserved in place.
Construction of the port site would directly disturb about 20 ha (50 ac) of
vegetation. No terrestrial wildlife species would be significantly impacted on
greater than a local basis. Port Lagoon would be breached to shelter barges
during construction and operation, but impacts to fish and invertebrate
species would be insignificant. Construction of the transfer facility would
also have minimal impact on anadromous and marine fish, as well as on
marine birds and mammals.
Impacts from the alteration of sediment transport patterns by the port site
causeway would be insignificant on more than a local basis. Port site con-
struction could increase sediment loading for a short period, but long-term
impacts on marine water quality would be insignificant. Potential impacts
from spills of fuel, concentrates or mill reagents would be expected to be
insignificant on greater than a local basis.
The remains of the historical reindeer herding facility at the VABM 28 port
site could be directly or indirectly impacted by the port facilities. Recovery
and recording operations would be developed if the site could not be avoided
by redesigning the facility.
Marine mammal hunting is generally confined to the winter and spring months
when the port would be ice-bound, so ship traffic from the port should not
significantly disrupt subsistence harvest activities. Port construction and
noise from year-round activities aboard the offshore transfer facility would
likely displace some marine mammals from the immediate area.
xii
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Although the majority of the area is on private and state land, the unde-
veloped nature of the project area would be permanently altered with the
loss of wilderness characteristics such as solitude and the opportunity for
primitive types of recreational experiences.
XIII
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TABLE OF CONTENTS
COVER (Photo: The WuIik River flowing from the De Long
Mountains to the Chukchi Sea.)
Page
COVER SHEET i
SUMMARY i i i
INTRODUCTION 1
I. PURPOSE OF AND NEED FOR ACTION
INTRODUCTION 1-1
DESCRIPTION OF PROPOSED ADMINISTRATIVE ACTIONS .... 1-1
PROJECT LOCATION, HISTORY AND STATUS 1-2
COMINCO AND NANA OBJECTIVES 1-7
SCOPING ISSUES 1-7
FEDERAL, STATE AND MUNICIPAL PERMITTING REQUIREMENTS . . 1-9
COOPERATING AGENCY 1-11
I I . THE PROPOSED PROJECT
INTRODUCTION I I-1
PROJECT COMPONENTS AND OPTIONS I I-1
Mine M-2
Tailings Pond 11-6
Mill M-6
Wastewater Treatment Plant 11-12
Worker Housing I 1-12
xi v
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TABLE OF CONTENTS
(Continued)
I I . THE PROPOSED PROJECT (Continued) Page
Water Supply ................... I 1-12
Power Generation ................. I 1-13
Transportation Corridor .............. I 1-13
Road Transportation System ............ 11-16
Port Site .................... II -18
Transfer Faci I i ty ................ I 1-30
Fuel Storage ................... I 1-32
DEVELOPMENT SCHEDULE
III. ALTERNATIVES INCLUDING THE PROPOSED ACTION
INTRODUCTION I I I-1
OPTIONS INITIALLY CONSIDERED I I I-1
Tailings Pond I I I-3
Worker Housing Type I I 1-3
Water Supply II f-3
Power Generation I I I-3
Transportation Corridor Location I I I-3
Transportation System I I I-7
Port Site Locations I I 1-8
Transfer Facility I I I-8
OPTIONS SCREENING PROCESS I I I-8
Initial Options Evaluation IM-8
Remaining Options Evaluation I I 1-9
Transportation Corridor Identification 111-35
IDENTIFICATION AND DESCRIPTION OF ALTERNATIVES 111-39
Alternative 1 111-40
Alternative 2 111-40
xv
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TABLE OF CONTENTS
(Cont inued)
III. ALTERNATIVES INCLUDING THE PROPOSED ACTION (Cont.) Page
Alternative 3 I I I-*tO
No Action Alternative II 1-^0
COMPARISON OF ALTERNATIVES 111-^2
IDENTIFICATION OF PREFERRED ALTERNATIVE 111-50
IV. AFFECTED ENVIRONMENT
INTRODUCTION IV-1
HISTORY IV-1
LAND STATUS IV-2
AFFECTED ENVIRONMENT IV-if
Geology, Physiography and Soils IV-*t
Geology \\J-k
Seismology IV-5
Physiography IV-5
Floodplains IV-7
Soi Is IV-8
Permafrost IV-8
Mineral Resources IV-8
Vegetation and Wetlands IV-8
Vegetation Type Descriptions IV-9
Wetlands IV-10
Threatened or Endangered Species IV-11
Terrestrial Wildlife IV-11
Birds IV-11
Mammals IV-12
Threatened or Endangered Species IV-17
Groundwater Resources IV-19
XV!
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TABLE OF CONTENTS
(Conti nued)
IV. AFFECTED ENVIRONMENT (Continued) Page
Freshwater Resources IV-19
Hydrology IV-19
Water Quality IV-22
Biology IV-30
Marine Biology IV-37
Marine Invertebrates IV-38
Marine Fish IV-ifO
Marine Birds and Mammals \\l-k2
Threatened or Endangered Species \\l-kj>
Physical and Chemical Oceanography \M-kk
Currents/Circulation IV-*t^
Wind and Wave Climate \V-kk
Coastal Geologic Processes IV-46
Marine Water Qua Iity IV-^6
Ice Conditions IV-47
Meteorology and Air Quality IV-47
Meteorology IV-^7
Air Quality IV-49
Visual Resources IV-50
Sound IV-51
Cultural Resources IV-51
Subsistence IV-54
Socioeconomics IV-62
Population IV-62
Economy IV-65
Community Facilities and Services IV-69
Local and Regional Governance IV-70
Recreation IV-70
Boating IV-71
Hunting/Fishing IV-71
Cape Krusenstern National Monument IV-72
XVI I
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TABLE OF CONTENTS
(Continued)
V. ENVIRONMENTAL CONSEQUENCES Page
INTRODUCTION V-l
COMPONENTS COMMON TO ALL ALTERNATIVES V-l
Vegetation and Wetlands V-2
Terrestrial Wildlife V-3
Groundwater Resources V-*+
Freshwater Resources V-5
Hydrology and Water Quality V-5
Biology V-13
Invertebrates V-13
Fish V-lif
Air Quality V-17
Visual Resources V-22
Sound V-23
Cultural Resources V-25
Subsistence V-25
Soci©economics V-27
Regional Employment and Income V-27
Population Growth and Migration V-32
Demand for Community Infrastructure V-3^
Social, Political and Cultural Stability
and Autonomy V-34
Recreation V-36
COMPONENTS SPECIFIC TO SOME ALTERNATIVES V-36
Vegetation and Wetlands V-36
Terrestrial Wildlife V-ifO
Groundwater Resources V-^5
Freshwater Resources V-^6
Hydrology and Water Quality V-*+6
Biology V-if9
Invertebrates V-49
XVI I I
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TABLE OF CONTENTS
(Conti nued)
V. ENVIRONMENTAL CONSEQUENCES (Continued) Page
Fish V-50
Marine Biology V-52
Marine Invertebrates and Fish V-52
Marine Birds and Mammals V-55
Physical and Chemical Oceanography V-57
Coastal Geologic Processes V-57
Marine Water Qua Iity V-59
Air Qua I i ty V-66
Visual Resources V-67
Sound V-68
Cultural Resources V-71
Subsistence V-72
Recreation V-7^
Regional Use V-75
Technical Feasibility V-76
Cost V-77
NO ACTION ALTERNATIVE V-77
MITIGATION V-78
MONITORING V-81
RECLAMATION PLAN V-83
OTHER PROJECT IMPACTS V-86
Regional Impacts V-86
Increased General Public Access V-89
Cape Krusenstern National Monument Impacts .... V-91
Cumulative Impacts V-9^
UNAVOIDABLE ADVERSE IMPACTS V-95
SHORT-TERM USES VERSUS LONG-TERM PRODUCTIVITY V-95
IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES V-96
SECTION 810, SUMMARY EVALUATION AND FINDINGS V-97
xix
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TABLE OF CONTENTS
(Continued)
VI. SUMMARY OF PERMIT AND REGULATORY PROGRAMS
INTRODUCTION
FEDERAL APPROVALS
STATE APPROVALS
LOCAL APPROVALS
Page
VI -1
Vl-l
VI-8
Vl-ll
VII. CONSULTATION AND COORDINATION
VI 1-1
VIM. LIST OF PREPARERS
VI I 1-1
IX. EIS DISTRIBUTION LIST
IX-1
X. PUBLIC RESPONSE TO DEIS
PUBLIC HEARING SUMMARY
DEIS COMMENT RESPONSES
X-l
X-l
X-6
XI. REFERENCES CITED
Xl-l
XI
GLOSSARY OF TECHNICAL TERMS, ACRONYMS AND
ABBREVIATIONS AND MEASUREMENT EQUIVALENTS
XI 1-1
XIII. INDEX
XI I I-1
XX
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TABLE OF CONTENTS
(Continued)
XIV.
LIST OF APPENDICES
APPENDIX 1.
APPENDIX 2.
APPENDIX 3.
APPENDIX k.
APPENDIX 5
APPENDIX 6,
APPENDIX 7.
APPENDIX 8.
RECLAMATION PLAN
SPILL PREVENTION, CONTROL AND
COUNTERMEASURE (SPCC) PLAN
ENDANGERED SPECIES BIOLOGICAL ASSESSMENT
PROPOSED NPDES PERMITS
DEPARTMENT OF ARMY PUBLIC NOTICE AND
SECTION *tO*t(b)(l) EVALUATION
ANILCA TITLE XI RIGHT-OF-WAY APPLICATION
CULTURAL RESOURCES PROTECTION
COASTAL ZONE MANAGEMENT CONSISTENCY
XX I
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LIST OF TABLES
Table Page
I 1-1 Concentrate Production Schedule 11-2
11-2 Red Dog Concentrator Reagents 11-10
11-3 Preliminary Borrow Site Specifications,
Southern Corridor I 1-25
11-4 Preliminary Borrow Site Specifications,
Northern Corridor I 1-26
11-5 Preliminary Borrow Site Specifications If All
Borrow Material Was Taken From Outside Cape
Krusenstern National Monument 11-27
I I 1-1 Component Options And Suboptions Identified
During The Scoping Process I I I-2
I I 1-2 Distances For Transportation Corridor Options
And Suboptions I I 1-6
I I 1-3 Major Reasons For Elimination Of Individual
Options And Suboptions During Initial Options
Review 111-10
111-4 Options And Suboptions Eliminated Or Retained
For Further Analysis During Initial Options
Review Ill-12
IM-5 Individual Discipline Options Screening
Criteria II1-13
I I 1-6 Summary Of Options Screening Criteria Analyses
Showing Relative Levels Of Potential Impact . 111-17
I I I-7 Grouped Relative Levels Of Potential Impact
For Individual Disciplines 111-31
I I 1-8 Overall Relative Levels Of Potential Impact . . 111-34
I I I -9 Options Used To Form At ternati ves 111-36
111-10 Evaluation Criteria Matrix Showing Relative
Total Impact Values Assigned To The Three
Action Alternatives II1-43
IV-1 Mean Annual Flow Data For Some Streams In The
Red Dog Mine Project Area IV-21
IV-2 Typical Mean Monthly Flow Proportions For Red
Dog Project Study Area Streams IV-22
IV-3 Ten- And 100-Year Recurrence Flood Flows For
Stream Locations In Red Dog Valley IV-23
XXI I
-------
LIST OF TABLES
(Conti nued)
Tab Ie Page
IV-*t Seasonal Flows And Concentrations And Loads Of
Zinc In Project Area Streams IV-27
IV-5 Seasonal Flows And Concentrations And Loads Of
Lead In Project Area Streams IV-28
IV-6 Seasonal Flows And Concentrations And Loads Of
Cadmium In Project Area Streams IV-29
IV-7 Results Of Aerial Survey Counts For
Overwintering Arctic Char In The WuIik And
Kivalina Rivers, 1968 to 1982 IV-33
IV-8 Summary Of Number Of Fish Counted In ADF&G
Arctic Char Spawning Surveys, 1981 to 1983 . . \V-~51*
IV-9 Numbers And Percent Occurrence Of Marine Fish
Species Collected During Summer 1982 By
Various Gear Types IV-^tl
IV-10 Percent Occurrence Of High Winds And Associated
Storm Waves (Not Including Swell) At The Port
Sites IV-*t5
IV-11 NANA Region Household Dependency On Subsistence
Harvest, Percent Distribution IV-55
IV-12 Subsistence Resources Harvested For Kivalina
And Noatak, 1972 IV-59
IV-13 Population Trends, 1960 To 1982, Study Area
Communities IV-63
IV-l^t Distribution of Population, By Age And Sex,
Kobuk Census Division, 1980 IV-G^t
IV-15 Baseline Population Forecast, For The NANA Region
And Point Hope, 1982 To 2010 IV-65
IV-16 Distribution Of Employment, Kobuk Census
Division, 1970 & 1980 IV-67
IV-17 Sources of Personal Income, By Sector, Kobuk
Census Division, 1970 & 1980 IV-68
IV-18 Personal Income, By Source, Kobuk Census
Division, 1970 & 1980 IV-69
V-l Tailings Pond Water Balance V-6
V-2 Treated Water Quality Projections V-7
V-3 Tailings Pond Water Quality Projections
(Assuming Complete Mixing) V-10
xx i i i
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LIST OF TABLES
(Continued)
Table Page
V-4 National Ambient Air Quality Standards (NAAQS),
Estimated Prevention Of Significant
Deterioration Increments,, And Worst Case
Projected Concentrations .......... V-18
V-5 EPA Significant Emissions Rates ........ V-19
V-6 Estimated Sources And Amounts Of Emissions From
Project Components .............. V-21
V-7 Estimated Sound Levels Generated By Mine Area
Equipment And Faci I i ties ........... V-2*+
V-8 Average Annual Employment By Occupational
Group .................... V-28
V-9 Estimated Total Resident Employment Impacts,
NANA Region ................. V-30
V-10 Projected Annual Personal Income ........ V-31
V-ll Projected Population Impact, NANA Region .... V-32
V-12 Estimated Population-Base Case And Impact Case,
NANA Region ................. V-33
V-13 Approximate Area Of Vegetation Types Intersected
By Roads In The Transportation Corridors . . . V-37
V-l^ Estimated Number And Type Of Stream Crossings
Required For Southern And Northern
Transportation Corridors .......... V-^8
V-15 Transfer And Shipping Frequency ........ V-6^
V-16 Estimated Road System And Port Facility Capital
And Annual Operating Costs ($000) For Each
Alternative ................. V-78
VI-1 Major Federal, State And Local Permits, Con-
tracts Or Other Approvals Required For
Project Development VI-2
VI1-1 Matrix Of Comments Received From Scoping
Meetings And Written Responses VI1-3
X-l Summary Of Concerns Raised At The Anchorage And
Kotzebue Public Hearings, May 2 and 3, 198** . X-3
XXIV
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LIST OF FIGURES
Figure Page
1-1 Northwestern Alaska 1-3
1-2 Mining Claims in Project Area 1-4
1-3 Red Dog Project Development Schedule 1-6
I I -1 Red Dog Va I I ey Map 11-3
11-2 Mine Pit Layout 11-5
11-3 South Fork Tailings Pond 11-7
11-4 Mill Site Facilities 11-9
11-5 Water Storage Reservoir 11-14
11-6 Red Dog Project Area 11-15
11-7 Typical Bridge & Culvert Crossings 11-17
11-8 Potential Borrow Sites Along Corridors 11-19
11-9 Location of Potential Borrow Sites 1, 2 & 3 . . 11-20
11-10 Location of Potential Borrow Sites 4, 5 & 6 . . 11-21
11-11 Location of Potential Borrow Sites 7 & 8 ... 11-22
11-12 Location of Potential Borrow Site 9 11-23
11-13 Location of Potential Borrow Sites 10, 11, 12,
13 & 14 I 1-24
11-14 Conceptual Diagram Of A Short Causeway/Lightering
Transfer Facility 11-28
11-15 Conceptual Diagram Of A Short Causeway/Offshore
Island Transfer Facility 11-29
11-16 Coastal Concentrate Storage Facility 11-31
11-17 Ballasted Tanker Transfer & Storage Facility . . 11-33
11-18 Conceptual Diagram of Construction Barge in
Coastal Lagoon I 1-35
I I I-1 Red Dog VaI Iey Map Showing TaiI ings Pond Options I I I-4
I I I-2 Red Dog Project Area Showing Transportation
Route Options I I 1-5
I I 1-3 Red Dog Project Alternatives 111-40
IV-1 Land Status In Project Area IV-3
IV-2 Poor Soils in Project Area IV-6
xxv
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LIST OF FIGURES
(Continued)
Figure Page
IV-3 Spring And Fall Waterfowl Staging Areas .... IV-13
\\f-k Raptor Nest Sites In Project Area IV-1*+
IV-5 Caribou Winter Range IV-16
IV-6 Dal I Sheep Range IV-18
IV-7 Ikalukrok Creek Drainage Area Showing Existing
Water Quality IV-2*t
IV-8 Benthic Invertebrate & Fish Sampling Stations
in Ikalukrok & Red Dog Drainages IV-31
IV-9 Fish Occurrence in Project Area IV-35
IV-10 Marine Benthic Infauna Sampling Stations .... IV-39
IV-11 Visual Quality Objective Zones In Project Area . IV-52
IV-12 Subsistence Use By Northwestern Alaska Native
Vi I lages IV-56
IV-13 Annual Subsistence Activity Cycles, Upper And
Lower Kobuk River Villages IV-57
IV-lif Annual Subsistence Activity Cycles, Noatak And
Kivalina Villages IV-58
IV-15 Subsistence Use Areas, Kivalina Village .... IV-60
IV-16 Subsistence Use Areas, Noatak Village IV-61
XXVI
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Introduction
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INTRODUCTION
This introduction explains the requirement for an Environmental Impact
Statement (EIS), the purpose of an EIS, and describes the process by which
it is developed. It also explains how the EIS document is organized and how
to effectively comment on the EIS.
WHY PREPARE AN EIS?
The National Environmental Policy Act (NEPA) of 1969 requires the prepara-
tion of an EIS whenever a proposed major federal action could significantly
affect the quality of the human environment. In the case of the Red Dog
project, the issuance of several major federal permits required before the
project could proceed constitutes a set of major federal actions. These
permits include the National Pollutant Discharge Elimination System (NPDES)
Permit from the Environmental Protection Agency (EPA), and the Department
of Army Permit from the U.S. Army Corps of Engineers (Corps). The
NPDES Permit would authorize a wastewater discharge from the mining and
milling operations. The Department of Army Permit would authorize dredging
and filling operations within waters of the United States.
Additionally, Cominco has applied to the Department of the Interior (DOI) for
permission to construct a mining access road through the northwest corner
of Cape Krusenstern National Monument. This road would provide a means
of transporting lead and zinc concentrates to a regional saltwater port on the
Chukchi Sea. The process for authorizing construction of this transporta-
tion system, which includes the port and the road, is governed by Title XI
of the Alaska National Interest Lands Conservation Act (ANILCA) of 1980.
The Title XI process requires compliance with NEPA, as well as approvals
from the President and Congress.
This EIS is therefore being written to fulfill the permitting requirements of
EPA and the Corps as well as the EIS requirements of Title XI. EPA and
DOI share the lead responsibility for preparing this document. The Corps is
a cooperating agency. The NEPA regulations which outline the purpose,
requirements and procedures for this EIS process may be found in the Code
of Federal Regulations at 40 CFR Parts 1500 to 1508.
While the federal permitting actions require the preparation of an EIS, NEPA
regulations also require that the EIS address, to the fullest extent possible,
state and local planning requirements. This EIS therefore provides an
information base which allows state and local agencies to begin addressing
state right-of-way permit conditions, tideland lease stipulations and a number
-------
of other necessary permits (including state certification of the EPA and
Corps permits). However, in several cases, the information necessary to
fully address certain state and local permits has not yet been developed.
These permits, which generally require detailed engineering information, will
be sought after the location, size, etc., of the major project components
have been determined by the EIS process.
HOW DOES THE EIS PROCESS WORK?
The primary purpose of the EIS process is to ensure that environmental
information is available to public officials and citizens before permit decisions
are made and before actions are taken. The process must encourage and
facilitate public involvement in the decisions affecting the quality of the
human environment. "Scoping" is the first step of the EIS process.
The purpose of the scoping process is to provide the opportunity for mem-
bers of the public, interest groups and agencies to assist in defining the
significant environmental issues related to the proposed project. For the
Red Dog project, examples of these issues include water quality, fisheries,
subsistence and impacts on Cape Krusenstern National Monument. Once
these specific issues are identified, they are described in a document called
the Responsiveness Summary that is distributed to all interested agencies
and parties. These issues form the primary basis for determining the range
of alternatives considered in the EIS.
Following scoping, the lead agency or agencies must ensure that sufficient
environmental information is available to adequately address the significant
issues raised during the scoping process. Alternative means of achieving
the proposed project's objectives are developed and the environmental impacts
are studied and compared. Finally, the EIS document is prepared and dis-
tributed to the public in draft form (DEIS) for a minimum of 45 days for
formal review. During this period, public hearings or meetings are held to
discuss the DEIS and to receive comments. Written comments may also be
submitted, and they are encouraged.
Following public review of the DEIS, comments are evaluated and the DEIS
changed accordingly. All written comments received during the review
period are actually reproduced in the final EIS (FEIS), and the points raised
are individually addressed in that document. The FEIS is then distributed
for another public review period of at least 30 days before any decisions
about the project can be implemented. This is to allow for additional public
comments on the FEIS.
Once a permit decision has been made, a formal public record of decision is
prepared by each permitting federal agency. The Record of Decision (ROD)
states what major permit decision was made, identifies all alternatives con-
sidered including those considered environmentally preferable, and may dis-
cuss preferences among alternatives based on factors such as economic,
technical, national policy and agency mission considerations. The ROD also
states what mitigation, monitoring, and other means to avoid or minimize
environmental harm were adopted, and if not, why they were not.
- 2 -
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EIS DOCUMENT STRUCTURE
The format for an EIS is prescribed by the NEPA regulations. Each section
has a specific purpose and often is required to include certain kinds of
information. Following is a brief description of the major sections of an EIS.
0 Summary - An adequate and accurate summarization of the EIS
stressing major conclusions, areas of controversy, and the issues to
be resolved.
0 Purpose of and Need for Action - This chapter (I) specifies the
underlying purpose of the action for which the EIS is being written,
and why the action is needed.
0 The Proposed Project - This chapter (II) describes the individual
components of the project (e.g., mine, mill, power source, trans-
portation system) and the specific options being considered for each
component. It tells how the project will be developed.
0 Alternatives Including the Proposed Action - This chapter (III) is
the heart of the EIS. It describes all the initial options that were
considered for the project, why many of them were eliminated, and
how the final options and alternatives were selected. Then, based
on the information and analyses presented in the chapters that follow
on Affected Environment (IV) and Environmental Consequences (V),
this chapter presents the environmental impacts of the proposed
project alternatives in comparative form, thus sharply defining the
issues and providing a clear basis for choice by the decision-makers
and the public. It also identifies and describes the preferred alter-
native.
0 Affected Environment - This chapter (IV) succinctly describes the
existing environment of the area which would be affected by
development of the project. It explains what the environment is like
now, before project development begins.
0 Environmental Consequences - This chapter (V) forms the scientific
and analytic basis for the comparison of alternatives in Chapter III.
It details the potential environmental impacts which could be ex-
pected for each alternative considering the mitigation, monitoring and
reclamation procedures which would be used. In addition, it de-
scribes unavoidable impacts; discusses any irreversible or irretriev-
able commitments of resources; and describes the relationship be-
tween short-term and long-term productivity.
0 Summary of Permit and Regulatory Programs - This chapter (VI)
briefly describes the major federal, state and local permits, contracts
and other approvals required for project development, and discusses
how the EIS incorporates the relevant information to assist agencies
in their permitting decisions.
- 3 -
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0 Consultation and Coordination - This chapter (VII) describes the
process for soliciting input from agencies and the public, and how
the process was coordinated with the agencies' permitting processes.
0 Public Response to the DEIS - This chapter (X) includes a response
to comments received during the DEIS review, both at public hear-
ings and as written comments. Responses indicate how the final
document was changed or why no changes were made.
0 Appendices - This section incorporates important supplementary
material prepared in connection with the EIS which is more appro-
priately presented separately from the body of the document.
Note that several words in the text are followed by an "*". These are
technical terms which are defined in the Glossary (Chapter XII). The
Glossary also contains acronyms, abbreviations and measurement equivalents.
- 4 -
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Chapter I
Purpose of and Need for
Action
-------
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I. PURPOSE OF AND NEED FOR ACTION
INTRODUCTION
Under the terms of the National Environmental Policy Act of 1969 (NEPA), all
federal agencies must build into their decision-making processes ways both to
consider the environmental effects of proposed actions and to minimize the
adverse impacts of those actions. The Environmental Impact Statement (EIS)
required by Section 102(2)(c) of NEPA is the action-forcing mechanism to
accomplish those tasks.
DESCRIPTION OF PROPOSED ADMINISTRATIVE ACTIONS
The U.S. Environmental Protection Agency (EPA) has been considering the
issuance of a New Source National Pollutant Discharge Elimination System
(NPDES) Permit for wastewater discharge from the proposed Red Dog mine
project in northwest Alaska. Also, the U.S. National Park Service (NPS)
has been considering the issuance of a right-of-way permit for a road cor-
ridor across Cape Krusenstern National Monument for the same project. The
issuance of either of these permits would be a type of federal action which is
subject to NE:PA. Pursuant to NEPA, and implementing regulations issued by
the Council Cm Environmental Quality (CEQ), EPA, the U.S. Department of
the Army and the U.S. Department of the Interior (DOI), this EIS has been
prepared to evaluate the potential impacts of the proposed actions on the
environment.
EPA's NPDES regulations [40 CFR 122.29(c)(2)] require that the EIS include
a recommendation on whether the NPDES Permit should be issued, denied or
issued with conditions, and further, require that such action shall occur
only after a complete evaluation of the projected impacts and recommendations
contained in the Final EIS (FEIS).
Pursuant to Title XI* of the Alaska National Interest Lands Conservation Act
of 1980 (ANILCA), in cases where transportation and utility systems would
cross conservation system units, a consolidated application must be filed with
appropriate federal agencies. Because the NPS does not have existing
authority to grant rights-of-way for industrial public use transportation
systems, a consolidated Title XI application to cross Cape Krusenstern
National Monument must be submitted to Congress and the President for
approval. The NPS is required to evaluate the proposed transportation
system across the Monument to determine whether it is compatible with the
* Defined in Glossary.
I - 1
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purposes for which the Monument was established, and whether there is any
economically feasible and prudent alternative route for the system.
In addition, the U.S. Department of the Army Corps of Engineers (Corps),
Alaska District, has jurisdiction over this action under Section 10 of the
River and Harbor Act of 1899 which provides for control over structures
or work in or affecting navigable waters of the U.S.; and under Section 404
of the Clean Water Act which provides for regulation of the discharge of
dredged or fill material into U.S. waters, including wetlands. Action by the
Corps could result in denial of the permit, issuance of the permit, or issu-
ance of the permit with stipulations. The Corps intends to adopt this docu-
ment to fulfill its NEPA obligations if its concerns are satisfied in the FEIS.
The 30-day review and comment period for this FEIS begins when the Notice
appears in the Federal Register announcing the availability of this FEIS.
PROJECT LOCATION, HISTORY AND STATUS
Cominco Alaska, Inc. proposes to develop the Red Dog mineral prospect on
Red Dog Creek, just west of Deadlock Mountain in the De Long Mountains of
the Western Brooks Range (Fig. 1-1). The site is located approximately
131 km (82 mi) north of Kotzebue, 55 km (34 mi) north of Noatak, 89 km (55
mi) east-northeast of the Chukchi Sea at Kivalina, and 161 km (100 mi)
southeast of Cape Lisburne. It is 168 km (105 mi) north of the Arctic
Circle.
The project would consist of an open pit lead/zinc mine, mill, diesel power
generators, tailings pond*, housing and water supply facilities. All of these
facilities would be located on private lands owned by the NANA Regional
Corporation which are part of a selection of at least 8,975 ha (22,176 ac) in
the Red Dog Valley. The mine area facilities would be connected by a road
corridor to a port and shipping facilities located at the coast. The proposed
mine contains approximately 77 million Mg (85 million tons) of ore and the
expected mine life is at least 40 years.
Passage of the Alaska Native Claims Settlement Act (ANCSA) in 1971 called
for the evaluation of the resource potential of lands considered for possible
inclusion in various national conservation systems. One of the areas of
study was the De Long Mountains. In September 1975 the U.S. Bureau of
Mines issued a press release outlining the findings of its work in that area.
This press release spurred considerable interest from the mining industry.
In the years to follow, two major exploration efforts, one by Cominco and
the other by GCO Minerals Company, resulted in the staking of some 18,000
claims in the area to the west and southwest of the Red Dog prospect (Fig.
I-2). The NANA Regional Corporation obtained selection rights to the Red
Dog area with the passage of ANILCA in 1980.
After the establishment of its right to the Red Dog deposit, NANA sought a
partner to aid in development of the project. After discussing the project
* Defined in Glossary.
I - 2
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CAPE LISBURNE
BROOKS RANGE
MOUNTAINS
NOATAK NATIONAL PRESERVE
N^ALASKA MARITIME
CAPE A S\ NATIONAL
NV ' WILDLIFE REFUGE
RED DOG/
/
DEADLOCK MT
EL 2995'
, ^-CAPE KRUSENSTERN
U-^ ARCHEOLOGICAL DISTRICT
CAPE KRUSENSTERN
NATIONAL \
MONUMENT
CAPE I
KRUSENSTER
so kilometers
FIGURE 1-1 NORTHWESTERN ALASKA
-------
SOUTHERN BOUNDARY NORTH SLOPE BOROUGH
CAPE KRUSENSTERN
NATIONAL MONUMENT
CAPE
KRUSENSTERN
CLAIMS
GCO CLAIMS
KOTZEBUE SOUND
NANA LAND
RED DOG CORE SELECTION
CONSERVATION UNIT BOUNDARY
FIGURE 1-2 MINING CLAIMS IN
PROJECT AREA J
-------
with a number of mining companies, NANA selected Cominco as its partner.
In the spring of 1982, a letter of agreement was signed which outlined the
relationship between Cominco and NANA. That agreement called for Cominco
to lease the property from NANA and to act as operator of the project.
Cominco would be responsible for permit acquisition, design, construction,
financing and operation of the mine. NANA would receive 50 percent of the
net profits of the project over time.
In August 1982 GCO Minerals made application to the U.S. Bureau of Land
Management (BLM) and the Alaska Department of Natural Resources (DNR)
for a transportation right-of-way from their Lik mineral prospect (only 19 km
[12 mi] northwest of Red Dog Valley) to the Chukchi Sea. In January 1983,
Cominco formally made application to EPA for an NPDES Permit. EPA then
made a determination under NEPA that its issuance of that permit would
constitute a significant action affecting the human environment. This
determination formally began the EIS process, with EPA as the lead federal
agency. Ott Water Engineers, Inc. of Anchorage was then selected by EPA,
in consultation with Cominco, as the third party contractor to prepare the
EIS for EPA. Faced with two similar right-of-way applications, federal and
state agencies decided that only one transportation corridor would be
approved, and that only one EIS would be written for both applications to
select that route. After further discussions among the applicants and
agencies, GCO Minerals requested that its application be held in abeyance.
During February and March of 1983 an EIS scoping process identified the
major issues associated with the Red Dog project. In late spring Cominco's
baseline data collection program, which was initiated in the spring of 1981,
was extended through the summer of 1983.
As the EIS process progressed, the possibility emerged that a transportation
corridor through Cape Krusenstern National Monument might be selected as
the preferred alternative. Cominco then began to explore with NPS the
ANILCA Title XI process for securing a right-of-way across the Monument.
On November 7, 1983 Cominco made a formal Title XI application to the NPS.
Cominco's application is the first ever filed. At that point, DOI became co-
lead agency with EPA for the EIS process in accordance with the Memorandum
of Agreement among EPA and the cooperating agencies. Title XI applications
were also filed with EPA and the Corps.
In June 1983 NANA began separate discussions with the NPS for a land
exchange. This exchange, if successfully negotiated and implemented, would
alter the northwest boundary of the Monument to exclude lands surrounding
the preferred transportation corridor, thereby making a Title XI permit un-
necessary. The NPS would receive NANA lands for inclusion within the
Monument, as well as other lands and interests outside the Monument. Land
exchange discussions are expected to continue throughout the EIS and Title
XI processes. If the preferred alternative were developed with a land
exchange, the environmental impacts would be similar.
Cominco's most probable schedule (Fig. I-3) shows the winter of 1985-86 as
the beginning of construction. The construction period would last a minimum
of 24 months with mining beginning in 1988. The actual beginning of con-
struction would depend on world economic conditions, ability to complete de-
I - 5
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FIGURE 1-3 RED DOG PROJECT
DEVELOPMENT SCHEDULE
-------
tailed engineering design, and the progress of the environmental permit pro-
cess. In the event that any delays in the schedule occurred, the necessity
to meet annual sealift* windows would require modification in the construction
period by one year increments.
COMINCO AND NANA OBJECTIVES
The agreement between NANA and Cominco for development of the Red Dog
mine represents a melding of social, cultural, environmental and economic
interests. The intent of the agreement is to allow development in a manner
that provides for: a long-term economic base for the NANA region; jobs for
NANA shareholders and other Alaskans; a source of lead/zinc concentrates
and an economic return for Cominco; and minimal impacts on the region's
social, historical, cultural and subsistence lifestyles. Important features of
the agreement include:
0 A rate of production jointly determined to maximize life of the mine
and economic return.
0 Development of "temporary" facilities to house workers on a rota-
tional basis to eliminate the long-term disruptive influence of a new
townsite on the existing village lifestyle of the region.
0 A commitment to develop and operate the project with careful consid-
eration for the existing subsistence lifestyle of the region. NANA
has the authority to suspend operations if the project were to have
too negative an effect upon subsistence (e.g., during caribou, fish
or marine mammal migrations).
0 Complete reclamation of the area, to the extent feasible, following
completion of the project.
SCOPING ISSUES
During the scoping process, which involved the full participation of Cominco,
members of the public, special interest groups, and agencies involved in the
EIS process, the following 12 issues were identified as being of major con-
cern if the project were developed:
Issue 1: Maintaining the Quality and Quantity of Water
The project has the potential for both enhancement and degradation of
freshwater resources in the project area. Potential problems associated with
the project include:
0 Increased sediment loads in watercourses from disturbed areas.
0 Alteration of streamflow which could affect fish movements and
habitat.
* Defined in Glossary.
I - 7
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0 Degradation of surface and/or groundwater through mine drainage,
heavy metal and trace element leachates, and the addition of reagent
chemicals.
Issue 2: Maintaining the Quality and Quantity of Fishery Habitat, and
Minimizing Disruption of Fish Movements
Construction of an overland transportation system and a port site has the
potential to disturb fish movements, spawning, and rearing habitats. Failure
to meet water quality criteria at the mine could also adversely affect fishery
resources.
Issue 3: Maintaining the Quality and Quantity of Wildlife Habitat, and
Minimizing Impacts on Wildlife
Development of several project components, particularly the overland trans-
portation system and the port site, has the potential to impact wildlife and
wildlife habitats. Specific concerns include:
0 Direct habitat loss due to physical change.
0 Indirect habitat loss due to increased activity and human disturbance.
0 Alteration of traditional movement patterns (e.g., caribou).
Issue 4: Minimizing Impacts on Coastal Geologic Processes
Development of a port site and concentrate shipping facilities has the poten-
tial to disturb natural sediment processes (e.g., longshore gravel transport).
Such disturbance might affect the integrity of coastal lagoons and could con-
ceivably affect the archeologically significant beach ridges at Cape
Krusenstern.
Issue 5: Minimizing Impacts on Marine Life
Construction and operation of a port site with fuel and concentrate loading
facilities and shipping activity could directly impact or cause the relocation
of marine species.
Issue 6: Protecting Subsistence Resources and Their Use
Construction and operation of the project could impact subsistence resources
and their use by residents of the nearby communities of Kivalina and
Noatak. Of particular concern are caribou, Arctic char, waterfowl and
marine mammals.
Issue 7: Protecting Cultural Resources
The project would be constructed and operated in an area of important arch-
eological resources as evidenced by the creation of Cape Krusenstern
National Monument around the significant archeological values of the Cape
Krusenstern beach ridges.
I - 8
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Issue 8: Minimizing the Social, Cultural and Economic Impacts on Residents
of the Region
Development of a large mining project in an otherwise rural area of north-
western Alaska would have impacts upon the social, cultural and economic
lifestyles of the region's residents.
Issue 9: Designing Project Components from a Regional Use Perspective
The design of several project components, particularly the port site and
transportation corridor, would significantly influence the future development
of the western De Long Mountains region of northwest Alaska. DNR has
indicated that they will permit only one, multi-use transportation corridor
through the region, so the siting and design of these components should be
made from a regional use perspective.
Issue 10: Impacts on Cape Krusenstern National Monument
Since some feasible transportation corridor options pass through Cape
Krusenstern National Monument, impacts on the Monument would have to be
evaluated. This issue could have national significance. While Title XI of
ANILCA establishes a process for gaining access through the Monument, the
act requires that there be no economically feasible and prudent alternative
route for the system. In addition, the act requires that a proposed trans-
portation corridor be compatible with the purposes for which the unit was
established.
Issue 11: Technical Feasibility
If project components or mitigation and reclamation measures became too com-
plex, an increased risk of failure could result, and technical feasibility
would then become an issue.
Issue 12: Economic Feasibility
If costs of project components or mitigation and reclamation requirements
exceeded reasonable or practical limits, economic feasibility would become an
issue.
FEDERAL, STATE AND MUNICIPAL PERMITTING REQUIREMENTS
Before construction and operation of the Red Dog project could begin,
Cominco must obtain several federal and state approvals. These are dis-
cussed in more detail in Chapter VI as they relate to the EIS process. Some
of the major permits, contracts or other approvals include:
Federal Government
U.S. Environmental Protection Agency (EPA):
0 National Pollutant Discharge Elimination System Permit (NPDES)
I - 9
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0 Review of U.S. Army Corps of Engineers Section 404 Permit
0 Review of ANILCA Title XI Permit Application
U.S. Army Corps of Engineers (Corps):
0 Department of the Army (DA) Permit under authority of Section 404
of the Clean Water Act (discharge of dredged or fill material into
U.S. waters, including wetlands)
0 DA Permit under authority of Section 10 of the River and Harbor Act
of 1899 (any structure or activity affecting navigable waters of the
U.S.)
0 Review of transportation system under ANILCA Title XI
U.S. National Park Service (NPS):
0 Right-of-way for transportation system under ANILCA Title XI (if
Cape Krusenstern National Monument route were selected)
0 ANILCA Section 810 Subsistence Compliance Findings
U.S. Fish and Wildlife Service (FWS):
0 , Possible Section 7 Consultation (for the endangered peregrine falcon)
National Marine Fisheries Service (NMFS):
0 Possible Section 7 Consultation (for endangered marine mammals)
Advisory Council on Historic Preservation (ACHP)
0 Consultation on Cultural Sites
State of Alaska
Department of Environmental Conservation (DEC):
0 Air Quality Permit to Operate (including Prevention of Significant
Deterioration [PSD] Permit approval)
0 Certificate of Reasonable Assurance (Water Quality)
0 Wastewater Disposal Permit
0 Solid Waste Disposal Permit
Department of Fish & Game (ADF&G):
0 Title 16 Anadromous* Fish Protection Permit
0 Title 16 Fishways for Obstructions to Fish Passage Permit
* Defined in Glossary.
I - 10
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Department of Natural Resources (DNR):
0 Right-of-Way Permit
0 Water Rights Permit
0 Dam Safety Permit
0 Tidelands Use Permit
0 Tidelands Lease
0 Materials Sale Contract
0 Land Use Permit
State Historic Preservation Office (SHPO):
0 Cultural Resources Clearance on State Lands
0 Consultation on Cultural Sites, Federal Lands
Governor's Office of Management and Budget, Division of Governmental
Coordination:
0 Coastal Zone Management Consistency Determination Concurrence
Local Government
North Slope Borough (NSB):
0 Land Use Permit
COOPERATING AGENCY
In addition to the EPA and DOI as co-lead agencies, the Corps is a coop-
erating agency for the Red Dog EIS.
I - 11
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Chapter II
The Proposed Project
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II. THE PROPOSED PROJECT
INTRODUCTION
Development of the Red Dog mining project would involve an open pit lead/
zinc mine located 131 km (82 mi) north of Kotzebue. The ore would be
crushed and the metallic sulfides concentrated in a mill near the mine site,
with the concentrates transported to the coast for shipment to market. While
the deposit has not yet been fully defined by geologists, at least 77 million
Mg (85 million tons) of ore exist. The ore contains approximately 5.0 per-
cent lead, 17.1 percent zinc, 75 g/Mg (2.4 oz/ton) silver and measurable
levels of barite. The project has a potential life of at least 40 years under
expected production rates, with the possibility of extension if additional ore
is found. The mine would be developed in two phases. The "initial" phase
of production would extend five years and produce approximately 434,450
Mg/yr (479,000 tons/yr) of concentrates (Table 11-1). The "expanded"
phase of production would extend from the sixth year of development
through the life of the project. Approximately 683,878 Mg/yr (754,000
tons/yr) of concentrates would be produced during this phase (Table 11-1).
Anticipated markets for the Red Dog ore concentrates include Canada, Europe
and Japan.
The mine, tailings pond, mill, power plant, worker housing and water
reservoir would all be located within a 8,975 ha (22,176 ac) parcel of private
land owned by NANA in Red Dog Valley. The port site would also be on
private NANA land if located at VABM 28, and probably on NANA land if
located at Tugak Lagoon. The transportation corridor would be almost
totally on public land.
PROJECT COMPONENTS AND OPTIONS
In reviewing this document, it is important that the reader understand the
relationship among the terms "component", "option" and "alternative". The
project has several components, each one a necessary part of an entire
viable mining project (e.g., the mine, mill site, tailings pond, transportation
system, port site, etc.)- For each component there may be one or more
options (e.g., a northern or a southern transportation corridor option). An
alternative is a combination of options (one for each component) that consti-
tutes an entire functioning project.
The EIS scoping process initially identified at least two, and often several,
options for each component. The process by which this large number of
options was screened to reduce the number to a manageable level, and the
II - 1
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Table 11-1
CONCENTRATE PRODUCTION SCHEDULE
Daily Production
(Average
Amount/Day)
Ore
Lead Concentrate
Zinc Concentrate
Barite Concentrate
Tailings*
Annual Production
Ore
Lead Concentrate
Zinc Concentrate
Barite Concentrate
Tailings
Initial Production Rate
Mg1
2,721
204
907
127
1,678
958,700
71,650
317,450
45,350
524,250
Tons
3,000
225
1,000
140
1,850
1,057,000
79,000
350,000
50,000
578,000
Expanded Production Rate
Mg1
5,079
308
1,515
127
2,766
1,779,534
107,933
530,595
45,350
1,095,656
Tons
5,600
340
1,670
140
3,050
1,962,000
119,000
585,000
50,000
1,208,000
1 1 Mg (megagram) = 1.102 tons
1 ton = 0.907 Mg
Source: Cominco Alaska, Inc.
ultimate project alternatives were selected, is described in detail in Chapter
III. The following description of each project component, therefore, ad-
dresses only those component options which were ultimately retained and
are specifically addressed in at least one of the three action alternatives.
Mine
The Red Dog deposit is located on a side hill on the main fork of Red Dog
Creek. The immediate topography generally consists of rolling hills with
wide valleys. The zone of mining influence would impact the main stem of
Red Dog Creek (Fig. 11-1).
* Defined in Glossary.
II - 2
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APPROX PT
OF WATER
TREATMENT
DISCHARGE
,—TV VOLCAN
S ^
\ fet-. 2127
SOUTH PORK
TAILINGS POND
SITE a
FIGURE II -1 RED DOG VALLEY MAP
-------
The outcropping ore body and its geological configuration dictate that a con-
ventional underground mine would not be feasible. Open pit mining would
require overburden (waste rock) removal from the surface of the ore body,
followed by drilling and blasting of the ore in benches within an open pit.
Overburden material not suitable for mill processing would be stockpiled near
the tailings pond.
The mine pit would be developed in two stages: preproduction followed by
production mining. During preproduction, overburden would be removed
from the pit, and access roads, pit ramps and the initial benches would be
established. Unmineralized overburden would be used for road and tailings
dam construction. Mineralized overburden would be stockpiled in a catch-
ment area above the tailings pond. During preproduction, it is estimated
that a total of 1,242,000 Mg (1,365,000 tons) of material would be removed.
Ore production rates are an important economic factor and are normally
based on the extent of services and the estimated quantities of concentrates
that would be accepted in the markets. Initial production mining would in-
volve the annual extraction of 958,700 Mg (1,057,000 tons) of ore. On an
initial operating basis, an average of 2,721 Mg (3,000 tons) of ore would be
sent each day to the concentrator (mill) for upgrading (Table 11-1). Drilled
and blasted ore would be loaded into mine type trucks using front-end
loaders. The mine trucks would transport the ore to a crushing facility
adjacent to the mill. The same loaders and trucks would be used to trans-
port low grade ore and waste materials to stockpiles at the tailings pond.
Ammonium nitrate would be used as a blasting agent to recover the ore.
This compound would be shipped and stored in sacks, and is not reactive
until mixed with fuel oil and detonated.
The open pit would be designed to optimize ore recovery with due considera-
tion given to protection of the Red Dog Creek watershed adjacent to the pit
area (Fig. II-2). Pit slopes would be designed at 35 degrees and would be
confirmed by rock mechanics design. Benches would be 7.6 m (25 ft) high
and access ramps 18.3 m (60 ft) wide at an eight percent grade. The initial
pit would be approximately 244 m (800 ft) in diameter and could contain
seven benches down to the 297 m (975 ft) elevation. The final pit could be
853 m x 305 m (2,800 ft x 1,000 ft) in area and contain up to 28 benches to
the 152 m (500 ft) elevation.
A diversion ditch would be constructed between Red Dog Creek and the open
pit to collect runoff from the mine area. The ditch would initially intercept
runoff from an approximate area of 0.65 km2 (0.25 mi2). The depth of the
ditch would be sufficient to ensure that it would collect most of the ore zone
runoff from the south side of the creek. If significant subsurface inflow
from the creek occurred, a seepage cutoff wall would be added where neces-
sary to block this inflow.
The drainage ditch would also collect surface erosion sediment originating
from the open pit and the associated ore haul road to the mill. A pump
station would route runoff from the open pit to the tailings pond. The
ditch, collection sump and pump to the tailings pond would be sized for a
10-year recurrence 24-hour storm event. Adequate capacity would be
allowed for winter icings and snow accumulation. The ditch would be
cleaned of ice and erosion debris, if necessary, in late winter or spring to
retain capacity for spring breakup and summer storm runoff.
II - 4
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EXCSKDCIT
LATITUDE
1300
125O -
>
UJ
_J
Ul
ORIGINAL GROUND
, Jfijr«M PmU-JL, f
'• A..V .... ..) i..
^
1 EXPANDED
I \
250 FT.
PROPOSED DIVERSION
DITCH/BERM
FIGURE II -2 MINE PIT LAYOUT
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Tailings Pond
The location of the South Fork tailings pond in Red Dog Valley is shown on
Figure 11-1. A detailed diagram of the approximately 237 ha (585 ac) tail-
ings pond facility is shown on Figure 11-3. The tailings pond dam would be
in the form of an impervious earth-filled structure with a spillway designed
to maintain structural integrity in the event of an overflow. The earth-filled
dam would be constructed in stages. Prior to full production, the dam
would be constructed to contain five years of production tailings. The dam
would then be raised to its final elevation in stages during the next five
years. The top of the dam would be used as a road to haul ore from the pit
to the mill complex. The dam is designated to handle tailings from produc-
tion of the known ore body which is presently identified as 77 million Mg (85
million tons) of ore.
Thickened tailings slurry from the mill concentrating process would contain
about 60 percent solids by weight, with the liquid portion consisting of ex-
cess process water, dissolved minerals and perhaps some residual reagents.
The slurry would flow by gravity from the mill into the tailings pond. An
internal process using a thickener would be used to return water directly to
the mill process circuit as a step in minimizing process water loss. It is
estimated that approximately 85 percent of mill process water could be recir-
culated directly in the mill in this way. Additional mill process water would
be recycled from the tailings pond (25 percent) or from the freshwater
source (11 percent). These recycle estimates are based upon water balance
flowsheet data (Cominco Engineering Services, Ltd., 1983b). Tailings in the
form of a thickened pulp would be deposited behind the dam.
Red Dog Creek tributaries with known metal content of toxic concentrations
would continue to drain into the tailings pond for treatment, as would pre-
cipitation-related runoff. Diversion structures and ditches would be built to
control or prevent excess surface drainage of uncontaminated water into the
tailings pond. The surface water would be routed into the Bons Creek
drainage, thus reducing the amount of water accumulating in the tailings
pond. Chemical treatment and metals removal of tailings pond water would
take place in a treatment plant prior to discharge to the presently minerals-
contaminated Red Dog Creek. Discharges would occur only between May and
October. A seepage contingency dam would be constructed downstream of
the main tailings pond dam to collect any seepage and return it to the
tailings pond.
Mill
Proximity to the mine and tailings pond were determining factors in mill loca-
tion. The proposed mill site would be on a small hill of bedrock outcrop
located opposite the ore body on the northwest side of the South Fork tail-
ings pond (Fig. 11-1). This site would be located within the pond catchment
area so that tailings slurry could flow by gravity from the concentrator com-
plex to the tailings pond. In addition, worker housing facilities would be
located within a reasonable distance of the mill site so that waste heat pro-
duced in the power generation process could be used to heat the accommoda-
tions.
II - 6
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WORKER HOUSING
EEPAGE
CONTINGENCY
DAM
VERBURDE
STOCKPILE
AREA
NATURAL RUNOFF
DIVERSION DITCH
HAUL ROAD
YEAR 5
-EL 950
SEEPAGE CONTINGENCY
DAM
-EL 870
HAUL ROAD
EL 800
TAILINGS DAM SECTION
FIGURE II -3 SOUTH FORK TAILINGS POND
-------
The proposed mill complex is shown on Figure 11-4. The approximately 14
ha (35 ac) complex would include a water treatment plant, a diesel-based
power plant, fuel storage and distribution facilities, and a vehicle mainten-
ance/warehouse structure in addition to facilities integral to the milling
process.
The project would use a selective flotation milling process to concentrate
valuable minerals. The flotation process would consist of three major steps:
size reduction, selective mineral concentration and moisture reduction of the
concentrates. During the milling process, lead, zinc and barite minerals
would be separated and concentrated, while the residual tailings slurry con-
taining waste rock would be directed to the tailings pond. Silver forms
complexes with the lead and zinc concentrates in the milling process, and
would be separated out later during smelting.
After grinding, the ore would be suspended in a water slurry and trans-
ported to flotation cells (tanks) where the valuable minerals would be sepa-
rated from waste materials in a froth flotation process. In this process,
valuable minerals adhere to air bubbles that rise to the surface of the tanks
and are removed. To make the process work efficiently, it is necessary to
add air and various reagents. The reagents either aid flotation of valuable
components or suppress flotation of waste material. This allows the bubbling
and frothing action to float different ore minerals selectively so that metal
concentrates can be produced. The ore minerals would be separated as
sulfide concentrates of lead and zinc, with barite recovered in the last stage
of the process as barium sulfate. Waste would include silicate minerals and
small concentrations of sulfides.
Following separation of the ore minerals from waste rock, dewatering of the
concentrates would take place using lead and zinc thickeners, followed by
filtration and thermal drying. Wherever possible, waste heat from the diesel-
based power generation would be used for drying the concentrates.
No reduction of sulfides to base metals or other changes in the chemical
composition of ore minerals would take place in the concentrator or at the
project site. The upgraded lead and zinc concentrates (which would also
contain silver) would be shipped to smelters outside of Alaska for processing
to refined metals. Barite concentrate would be dried and bagged locally for
possible use in formulating oil well drilling mud.
The mill would be a major consumer of water and, as such, recirculation of
process water would be used to the fullest extent possible. In addition to
concentrate thickeners, a tailings thickener would be used to recycle water,
thus decreasing the volume of tailings slurry produced. This would de-
crease the amount of water that would have to be treated, and would reduce
annual water demand by approximately 3,400 million £ (900 million gal).
Reagents are an integral part of mill operation and sufficient quantities for a
year's operation would be stored at the mill site. Reagents to be used for
the Red Dog project are shown in Table 11-2. These materials would be
supplied in annual shipments and stored in a secure area at the port site.
II - 8
-------
FIGURE 11-4 MILL SITE FACILITIES
-------
Table 11-2
RED DOG CONCENTRATOR REAGENTS
Initial Production
Zinc sulfate (ZnSO4)
Copper sulfate (CuSO4)
Sodium cyanide (NaCn)
Methylisobutyl carbinol (MIBC)
Sodium isopropyl xanthate
Sodium cetylsulfonate (EC-111)
Sulfuric acid (H2SO4)
Hydrated lime [Ca(OH)2]*
Polyacrylamide flocculant*
(Percol 730)
Mg/yr
480
480
96
48
480
72
959
2,396
5
tons/yr
529
529
106
53
529
79
1,057
2,642
6
Expanded Production
Mg/yr tons/yr
891
891
179
89
891
72
1,780
5,845
5
982
982
197
98
982
79
1,962
6,443
6
* Note: Part of the lime and all of the flocculant supply would be used in
the wastewater treatment process.
The zinc (ZnSO4) and copper (CuS04) sulfates used as conditioners in flota-
tion would be handled in polylined and sealed palletized cartons of approxi-
mately 0.9 Mg (1 ton) capacity. These materials could be compatibly stored
together and their toxic environmental hazards are well known.
Sodium cyanide (NaCn) is a toxic reagent and must, at all times, be stored
and handled in isolation from other chemicals, particularly those which are
acidic in nature, including the sulfate salts. This material would be shipped
in 102 kg (225 Ib) sealed drums on pallets. The reagent is essential to the
metallurgical process as a depressant of iron minerals.
II - 10
-------
Methylisobutyl carbinol (MIBC) is an aliphatic liquid alcohol which has only a
moderate solubility in water. It is moderately toxic to aquatic life and com-
parable in this respect to most intermediate molecular weight liquid alcohols.
This chemical would be shipped in 181 kg (400 Ib) steel drums and could be
safely stored with the other chemicals.
Sodium isopropyl xanthate is an essential sulfide mineral collector in the
flotation process, and is very toxic in the environment. It would be shipped
in approximately 0.9 Mg (1 ton) sealed, palletized containers which prefer-
ably would be stored apart from acidic materials. A potential problem with
xanthate is that it may deteriorate from prolonged contact with moisture and
then would require disposal as it would be unusable as a reagent.
Sodium cetylsulfonate (EC-Ill) is a paste-like surface active agent used for
barite flotation that has only a moderate solubility in water. It is essen-
tially non-toxic and has been approved for use in food applications. This
material would be shipped in 181 kg (400 Ib) steel drums on pallets and
would be compatible with all other reagents.
Sulfuric acid (H2SO4) is a hazard to aquatic life by virtue of pH reduction
effects. Because of its liquid nature, spills would be difficult to contain and
the chemical could have long lasting impacts on vegetation recovery unless
lime were applied as a neutralizing agent. Sulfuric acid would be stored at
the port in an isolated, berm-protected bulk tank and hauled to the mine in
acid standard tank trailers of 24,227 $, (6,400 gal) capacity.
Lime would be used as a pH modifier in the mill flotation process and in the
wastewater treatment plant. It is only toxic in concentrations which result
in high alkalinity and would be relatively safe to manage in the hydrated
form. It would be shipped and stored in heavy-wall plastic bags of about
1.8 IVIg (2 tons) capacity. There would be no constraints on its storage with
other reagents.
Polyacrylamide flocculant (Percol 730) is a slowly water soluble, high molec-
ular weight, acrylamide-based polymer that would be used as a solids set-
tling aid in the wastewater treatment plant. This material is relatively non-
toxic. It would be shipped in 23 kg (50 Ib) sacks on pallets and must be
protected from temperature extremes in storage or its effectiveness might
deteriorate.
The mill would produce lead, zinc and barite concentrates. Lead and zinc
concentrates would be shipped to the port site in covered gondola-type
trailers while barite would be moved in sealed containers on flat bed units.
The mill would operate on a continuous, round-the-clock basis for an esti-
mated 350 days per year. Initial and final mill production rates are shown
in Table 11-1. Concentrates would be transported from the mill site to the
main storage terminal at the port site in truck/trailer units. Approximately
nine to 12 daily truck trips to the seaport would be required to handle the
estimated daily production rate. Six weeks' production of concentrates could
be stored at the mill to allow for transportation delays during periods of bad
weather, when the roads were unsafe for travel, or if transportation activ-
II - 11
-------
ities were temporarily suspended to protect subsistence activities or animal
migrations.
Wastewater Treatment Plant
Excess water from the mill process and site runoff would accumulate in the
tailings pond. By federal law only water from precipitation in excess of
evaporation can be discharged, and it must meet federal water quality
criteria for metals and suspended solids. All discharged water would be
drawn from the tailings pond and passed through a chemical treatment
process to reduce metals and suspended solids concentrations. Normal
discharge of treated water into the main stem of Red Dog Creek 19 m (62 ft)
below its confluence with the South Fork (Fig. 11-1) would occur during ice
free months from May to October.
The proposed treatment plant would be based on a High Density Sludge
(HDS) process that would use lime to neutralize acidity and precipitate
soluble metals as hydroxides, followed by flocculant-induced clarification to
remove solids. Treatment plant process reliability would depend on a sub-
stantial degree of internal sludge recycle to produce a final sludge with
about 10 times the density that could be achieved without recycle. This
feature is designed to enhance clarification and reduce the volume of waste
sludge by an order of magnitude. Approximately 9 Mg (10 tons) of sludge
solids as a 25 percent pulp density slurry would be produced each operating
day.
Worker Housing
A campsite or hotel-style facility would be constructed a reasonable distance
from the mill site complex. The actual location of the accommodations would
be more specifically defined during the detailed design stage of the project
in accordance with Mining Safety and Health Administration (MSHA) regula-
tions that mandate specific criteria for worker safety and comfort.
Approximately 225 to 250 full-time employees would comprise the project site
workforce at any given time. Workers would be scheduled on a rotation of
approximately two weeks on and two weeks off so the total project workforce
would be twice that figure. The projected mine/mill workforce breakdown
would be as follows:
Miners/Mill Operators 50 percent
Mechanics/Electricians 15 percent
Support 15 percent
Supervisory/Management 20 percent
Water Supply
The mill would be a major consumer of water so a guaranteed year-round
water source would be essential to the project. Wells would not be feasible
since the permanently frozen ground prohibits free-flowing water aquifers.
II - 12
-------
An approximately 25 ha (63 ac) water storage reservoir located on Bons
Creek at the south end of Red Dog Valley would serve as the water supply
(Fig. 11-5). A rock-filled dam would be constructed on bedrock foundation
near the existing airstrip, and a pipeline would follow the existing road
system to the mill site. The reservoir would also serve as a domestic water
supply. It would have a capacity of 1,462 dam3 (1,185 ac-ft) of water to
meet an expected total daily consumption rate of 1,136 £/min (300 gal/min)
for all the mine area facilities.
Power Generation
For the concentration of minerals to take place, a large amount of power
would be expended in grinding to achieve a fineness which allows adequate
liberation of lead sulfide, zinc sulfide and barite particles from waste par-
ticles. On an average basis, electric power at a rate of 19.3 kWh/Mg (17.5
kWh/ton) of mill feed would be required for the grinding process. In order
to meet this and other support facility demands, a dedicated power plant
would be necessary. The Red Dog project would consume approximately 10.2
MW, and an 18 MW diesel-based power plant would be installed to allow for
down time of some generators.
It was desirable to minimize both the loss of waste heat and air pollutant
discharge by designing a system whereby waste heat would be used for
concentrate drying, with the dryer exhaust treated in a scrubber or other
type of pollutant control device. Diesel fuel storage and distribution facil-
ities would be provided at the mill site. Fuel storage units (capacity of
4,800 bbls) would periodically be replenished from the main fuel depot at the
coast by tanker trucks or by ore trucks specially fitted with tanker units.
Transportation Corridor
A transportation corridor would link the Red Dog Valley mine facilities with
the Chukchi Sea coast. Two corridor options are included in the alterna-
tives: a northern and a southern corridor (Fig. 11-6). For the first
11.8 km (7.4 mi) the two corridors follow a common alignment. At a point
near Dudd Creek, the northern corridor swings westward across the Wulik,
Kivalina and Asikpak River drainages to a port site near Tugak Lagoon
24 km (15 mi) northwest of Kivalina. At Dudd Creek the southern corridor
continues southwest along the flanks of the Mulgrave Hills to a port site
near VABM 28, approximately 25.6 km (16 mi) southeast of Kivalina. The
topography of both corridors would be gentle enough to handle railroad
grades. Both corridors have therefore been laid out to accommodate a rail-
road at some future time.
Northern Corridor
The northern transportation corridor would be approximately 117.0 km
(73.1 mi) long and would require the construction of six major (greater than
30.5 m [100 ft]) multiple-span bridges, seven minor bridges and approxi-
mately 300 culverts. The route would traverse the main stems of Ikalukrok
Creek, and the Kivalina, Wulik and Asikpak Rivers (Fig. II-6). It would
cross approximately 12 streams which contain fish, including major char
II - 13
-------
FIGURE II -5 WATER STORAGE RESERVOIR
-------
FIGURE 11-6
RED DOG PROJECT AREA
-------
spawning and overwintering areas along Ikalukrok Creek, the Wulik River,
Grayling Creek and the Kivalina River. The route would provide access to
these fisheries streams.
Southern Corridor
The southern transportation corridor would be 89.9 km (56.2 mi) long and
would require the construction of one major bridge, four minor bridges and
approximately 182 culverts. The corridor would cross tributaries of the
Wulik, Noatak and Omikviorok Rivers near their headwaters, and would
generally stay at a higher elevation than the northern corridor until its
terminus at the VABM 28 port site (Fig. 11-6). It would cross approximately
11 streams which contain fish. None of the streams is considered a major
fishery stream; the route would not provide access to major fisheries
streams.
Road Transportation System
The road haulage system would comprise a gravel surfaced road and double
truck/trailer haulage units similar to normal highway vehicles, but over-
sized. A truck and a trailer would weigh approximately 103 Mg (114 ton)
and 90 Mg (108 ton), respectively, or 201 Mg (222 tons) for one combined
truck and trailer unit. Nine to 12 daily truck/trailer round trips to carry
concentrates to the port site would be required for the first five years at
initial production rates. Following proposed expansion of production after
five years, daily concentrate transport trips would average between 16 and
20. Additional daily tanker and supply truck trips and one or two trips per
day by light utility vehicles would also occur. Inbound freight would likely
be containerized, though some specialized trailers such as tanker units (to
haul fuel oil to the mill site) would be required. Continuous maintenance of
the roadway would be necessary, thus requiring a full complement of road
maintenance and repair equipment.
Road Construction
Gravel or competent soils are the desirable materials for construction of the
road either as a base or as topping material. The roadbed or subbase would
be composed of granular fill averaging 2.0 m (6.5 ft) in thickness. The
road would be designed to meet Arctic engineering specifications for the
prevention of thermal degradation. The top surface of the road would be
9 m (30 ft) in width while the corridor boundary would average 20 m (65 ft)
in width over flat terrain. This width would vary depending on the cut and
fill requirements of the slope (Fig. II-7). Turnouts and passing places
would be provided along the route. Curvature and grade would generally be
limited to 10 degrees and three percent, respectively, to permit eventual
construction of a railroad. Bridge structures and culverts would be de-
signed to accommodate year-round concentrate haulage by combined truck/
trailer units.
Borrow Sites*
Because few gravel sources have been identified along the corridors, the
majority of fill needed for road construction and maintenance would come
* Defined in Glossary.
II - 16
-------
30'
?
0
U
C_
1
1
• ' '
1
f. i
4
p
1— l_l 1— 1— 1
8 GIRDER:
1
1
8 at 4'-0
J
1
4
CLj
I«
1-
- - - p 2
«
.1
P.C. SLAB
•^
STEEL GIRDERS
28'
TYPICAL BRIDGE CROSSING
TYPICAL SIDE SLOPE
2
GRADED ROCK
PROTECTION AROUND
CULVERT AS REQUIRED
CORRIDOR
BOUNDARY
NATURAL STREAM SLOPE
CORRUGATED STEEL CULVERT
TYPICAL CULVERT CROSSING
15
FIGURE 11-7 TYPICAL BRIDGE
& CULVERT CROSSINGS
-------
from rock quarry borrow sites. Proposed borrow site locations were deter-
mined by reference to U.S. Geological survey maps, aerial photographs
(1:12,000 scale), and terrain unit mapping reports based on field reconnais-
sance studies conducted by Cominco. An overview of potential borrow sites
along the transportation corridors is shown on Figure 11-8. Locations of
borrow sites along the southern corridor are shown in more detail on Figures
II-9 through 11-13. In addition, specific information about each potential
borrow site along the southern corridor, including surface area and volume
of material to be extracted, is shown in Table II-3. This is preliminary
information that could change as better field data are collected for the de-
tailed design and permitting phases of the project. Preliminary borrow site
information is not as well developed for the northern corridor. Information
on the amount of fill that could be extracted from northern borrow sites is
shown in Table II-4.
In the event that a right-of-way were granted across Cape Krusenstern
National Monument, but borrow extraction were not permitted within the
boundaries of the Monument, all borrow material would be extracted from
Sites 7 to 14 (Fig. 11-8). Anticipated changes in borrow site specifications
(area, volume, etc.) are shown in Table 11-5. Sites 7 and 8 would be
expanded in surface area and excavation depth to compensate for the change
in the total number of sites, and to provide the necessary volume of borrow
material. In addition, the main concentrate storage building would be
located at the port site rather than 4.0 km (2.5 mi) inland at Borrow Site 1.
Port Site
Though operations at the mine would continue year-round, activity at the
deep-draft port site would be limited to the receipt of supplies and fuel
during the summer sealift, and the shipment of concentrates from late June
until early October. Climatic constraints on shipping activities thus require
that adequate storage facilities for concentrates, fuel and other supplies
exist at the port site. Using an all-weather road, it is estimated that eight
and a half months of concentrate storage capacity would be required at the
port site.
Schematics of the approximately 20 ha (50 ac) proposed port site facilities
are shown on Figures 11-14 and 11-15. Depending upon the type of transfer
facility (described below), fuel would be stored either onboard an "offshore
island" or in tanks on land at the port site. In either case, a year's supply
would be kept there to serve as the main fuel depot for the project. Fuel
would be periodically hauled to the mine site as required. A short cause-
way/dock structure would be required to receive incoming freight and sup-
plies, and for transfer of the concentrates for shipment.
Only emergency and temporary ship loading crews would be housed at the
port site. A small accommodation complex would be provided to support
activities during the summer shipping season. Domestic sewage would be
collected and treated using a package treatment facility before discharge into
the sea. An NPDES permit (separate from the major permit) is required for
discharge at the port facility. A small diesel-based 1.5 MW power plant
would be required to operate conveyor equipment and life support facilities.
II - 18
-------
FIGURE 11-8
POTENTIAL BORROW
SITES ALONG CORRIDORS
-------
VABM 28 PORT SITE
CHUCKCHI SEA
\ mile
.ORAVEL PIT
EXPLORATION AREA
FIGURE 11-9
LOCATION OF POTENTIAL
BORROW SITES 1, 2 & 3
-------
I FIGURE II-
I LOCATION
VBORROW
-------
CAPE KRUSENSTERN
NATIONAL MONUMENT
FIGURE V11
LOCATION OF POTENTIAL
BORROW SITES 74 8
-------
FIGURE 11-12
LOCATION OF POTENTIAL
BORROW SITE 9
-------
FIGURE 11-13 LOCATION
OF POTENTIAL BORROW
-------
Table 11-3
PRELIMINARY BORROW SITE SPECIFICATIONS,
SOUTHERN CORRIDOR
ro
en
Borrow
Site
Number
1*
2
3
4
5
6
7
8
9
10
11
12
13
14
Exploration
Area
ha
85.5
49.2
57.0
98.4
77.7
163.2
67.3
59.6
88.1
20.7
20.7
16.8
36.3
15.5
ac
211.2
121.6
140.8
243.2
192.0
403.2
166.4
147.2
217.6
51.2
51.2
41.6
89.6
38.4
Disturbed
Pit Area
ha
19.4
9.5
--
5.2
13.9
—
2.4
5.0
5.6
6.3
3.0
3.0
6.5
4.6
ac
48.0
23.4
--
12.8
34.4
--
6.0
12.4
13.8
15.5
7.3
7.3
16.1
11.5
Approximate
Volume Needed
m3
305,853
289,144
--
190,189
590,100
--
149,447
307,096
422,903
246,600
54,008
54,008
174,850
171,703
yd3
400,043
378,188
--
248,760
771,826
--
195,471
401,669
553,140
322,543
70,640
70,640
228,697
224,580
Average
Excavation
Depth
m
2.1
3.0
--
4.9
4.3
--
6.1
6.1
7.6
4.0
1.8
1.8
2.7
3.6
ft
7.0
10.0
--
16.0
14.0
--
20.0
20.0
25.0
13.0
6.0
6.0
9.0
12.0
Access
Road
Length
km
0.19
0.39
--
1.29
1.08
--
0.48
1.06
3.96
0.24
0.16
0.16
0.16
0.08
mi
0.12
0.24
--
0.80
0.67
--
0.30
0.66
2.46
0.15
0.10
0.10
0.10
0.05
Within 91 m
(300 ft)
of Stream
No
No
No
No
No
Yes
No
Yes
No
Yes
No
No
No
No
* Would also serve as the coastal concentrate storage facility site after borrow excavation.
-------
Table 11-4
PRELIMINARY BORROW SITE SPECIFICATIONS,
NORTHERN CORRIDOR
Approximate Volume Needed
Borrow Site Numbers ma ~ yd3 ~~
1, 2, 3, 4, 5 857,716 1,121,858
6, 7, 8, 9, 10, 11, 12 1,286,516 1,682,710
13, 14, 15 798,786 1,044,780
16, 17, 18, 19 1,466,201 1,917,731
II - 26
-------
Table 11-5
PO
-vj
PRELIMINARY BORROW SITE SPECIFICATIONS
IF ALL BORROW MATERIAL WAS TAKEN FROM
OUTSIDE CAPE KRUSENSTERN NATIONAL MONUMENT
Borrow
Site
Number
7
8
9
10
11
12
13
14
Exploration
Area
ha
80.8
71.5
88.1
20.7
20.7
16.8
36.3
15.5
ac
199.6
176.6
217.6
51.2
51.2
41.6
89.6
38.4
Disturbed
Pit Area
ha
9.9
10.2
5.6
6.3
3.0
3.0
6.5
4.6
ac
24.5
25.3
13.8
15.5
7.3
7.3
16.1
11.5
Approximate
Volume Needed
m3
760,569
974,211
422,903
246,600
54,008
54,008
174,850
171,703
yd3
994,793
1,274,228
553,140
322,543
70,640
70,640
228,697
224,580
Average
Excavation
Depth
m
7.6
9.1
7.6
4.0
1.8
1.8
2.7
3.6
ft
25.0
30.0
25.0
13.0
6.0
6.0
9.0
12.0
Access
Road
Length
km
0.48
1.06
3.96
0.24
0.16
0.16
0.16
0.08
mi
0.30
0.66
2.46
0.15
0.10
0.10
0.10
0.05
Within 91 m
(300 ft)
of Stream
No
Yes
No
Yes
No
No
No
No
-------
ooc
ooc
FIGURE 11-14
CONCEPTUAL DIAGRAM OF A
SHORT CAUSEWAY/LIGHTERING
TRANSFER FACILITY M
-------
FIGURE 11-15
CONCEPTUAL DIAGRAM
OF A SHORT CAUSEWAY/OFFSHORE
ISLAND TRANSFER FACILITY j
-------
In addition to the facilities located immediately at the coast, the main con-
centrate storage building would be located approximately 4.0 km (2.5 mi)
inland, adjacent to the transportation corridor at about the 76 m (250 ft)
elevation (Fig. 11-16). This structure would be constructed at excavated
Borrow Site 1 to minimize habitat destruction, and to take advantage of
foundation materials and protection from the wind. The structure would
completely enclose the concentrates to provide protection from the elements,
and to prevent accidental loss of materials or possible surface water contami-
nation. In addition, settling ponds would be constructed to collect runoff
from around the facility.
Transfer Facility
Two methods to transfer concentrates from the port site storage facility to
ocean going vessels are included in the alternatives: a short causeway/
lightering* transfer system and a short causeway/offshore island transfer
system. Both systems would use a 122 m (400 ft) causeway/dock structure
as an interface between the shore and the concentrate loading vessels or
offshore island. The causeway/dock structure would extend to the 4.6 m
(15 ft) water depth. Concentrates would be transferred by conveyor belt
from a storage building, along the causeway, to a barge loader structure
mounted on the dock face.
The causeway structure would be constructed of sheet pilings with solid
earth fill (Fig. 11-14). It would be suitably capped and faced to allow
lighter* barges to tie up at its seaward face. Depending on the transfer
facility option selected, lighter barges ranging from 907 to 4,535 Mg (1,000
to 5,000 tons) would be used.
Short Causeway/Lightering System
This transfer method would use two 4,535 Mg (5,000 ton) lighters and two
support tugs to transfer concentrates from the dock directly to the side of a
moored ocean going bulk-handling ship (Fig. 11-14). The ocean going vessel
would load concentrates with clam shell cranes, though rough sea conditions
might make this transfer method unreliable. Winter shelter for the two
large-capacity lighters and their tugs would be provided in a coastal lagoon
located adjacent to the port facilities. The barrier beach between the lagoon
and the sea would be breached by bulldozing each fall and spring for winter
harboring. Lighters would also be sheltered in the lagoon during severe
storms. No dredging would take place within the lagoon.
Short Causeway/Offshore Island
This transfer method would use an approximately 226,750 Mg (250,000 ton)
Very Large Crude Carrier (VLCC) surplus oil tanker as an "offshore island"
dock for the smaller, ocean going bulk carriers (Fig. 11-15). Prior to being
ballasted perpendicular to shore at a prepared bottom location, the outer hull
* Defined in Glossary.
II - 30
-------
CONCENTRATE STORAGE FACILITY
PORT LAGOON
VABM 28 PORT SITE
LOCATION DETAIL
PLAN VIEW
TRACKED LOADER
75 TON TRUCK
75 TON TRAILER
BUILDING CROSS SECTION
FIGURE 11-16
COASTAL CONCENTRATE STORAGE FACILITY
-------
of this approximately 305 nn (1,000 ft) long, 92 m (300 ft) wide tanker would
be ice strengthened by the addition of about 544 Mg (600 tons) of new,
corrosion-protected steel plate. In addition, about 181 Mg (200 tons) of
steel would be provided for additional bulkheads in the ship's internal tanks.
Approximately 72,628 m3 (95,000 yd3) of gravel ballast would be used to
stabilize the vessel on the sea floor (Fig. 11-17).
Sea floor preparation for tanker placement would require dredging of material
in the specific placement area so that the exterior edges of the tanker would
rest on berms, while the central axis of the ship would settle in a slight
depression. This would place the hull bottom in tension. Gaps under the
hull would then be filled with additional dredged material, thus creating a
stable "bed" in which the bottom of the tanker would be firmly seated.
The landward end of the tanker would be in approximately 9.1 to 10.7 m (30
to 35 ft) of water and the seaward end in 10.7 to 12.2 m (35 to 40 ft) of
water. The tanker would have a molded sidewall height of 24 to 27 m (80 to
90 ft) depending on the type of VLCC selected, which would provide a free-
board of approximately 12 to 18 m (40 to 60 ft). Depending upon the port
site selected, the landward end of the tanker would be approximately 1,067
to 1,219 m (3,500 to 4,000 ft) from shore. The tanker would be large
enough to accommodate storage of concentrates, fuel and supplies in center
compartments protected from the sea by two layers of steel (Fig. 11-17).
Onboard concentrate storage capacity would be sufficient to load three to
five ocean going bulk carriers.
The bow of the ship would be modified to accommodate a 907 Mg (1,000 ton),
self-unloading lighter which would discharge directly by conveyor belt into
the ship (Fig. 11-17). Only one self-propelled lighter would be needed to
transport concentrates because of the storage capacity onboard the tanker.
Shelter for the single, smaller lighter could be provided in the lee of the
tanker if necessary during bad weather. Winter shelter and protection from
severe storms would be provided in a coastal lagoon adjacent to the port
site. The lagoon would be breached each fall and spring for winter harbor-
ing, but no dredging would take place within the lagoon. If ice conditions
were suitable, winter transfer of concentrates to the tanker island might be
accomplished by trucks driven directly over the ice.
Transfer of concentrates from the ballasted tanker to bulk carriers would be
accomplished using moveable conveyors between ships which would be loaded
from storage by a clam shell bucket. Similar to the shore-based system,
conveyors would be covered, and the end of the loader would be fitted with
a telescoping spout or "elephant's trunk", to direct the concentrate into the
receiving ship's hold below deck level. Conveyor return belts would be
brushed in an enclosure to prevent losses to the sea. Sealed barite con-
tainers would be loaded by crane.
Fuel Storage
Location of the major fuel storage depot for the project would depend upon
the transfer facility selected. For the short causeway/lightering option a
full year's supply of fuel for the project, as well as fuel to meet the annual
needs of the region's villages, would be stored in tanks on land at the port
II - 32
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FIGURE 11-17
BALLASTED TANKER
& STORAGE FACILITY
-------
site (Fig. 11-14). The fuel would be lightered to the dock from ships
moored offshore and then transferred by pipe to onshore storage tanks.
These tanks would be constructed either on well drained gravel pads or on
pilings to preclude heaving or jacking problems that could result in tank
failure. Spillage containment dikes and synthetic liners would be installed
around the tank structures. Storage capacity of the onshore fuel tanks
would total approximately 214,000 bbls with about 56 percent of that (120,000
bbls) being for the project. Fuel would be hauled to the mine area facilities
by tanker truck as needed during the year. It would be distributed to the
villages from the port site using the same smaller barges as presently used
by local barge services to navigate the rivers.
For the offshore island option, the same amount of fuel would be transferred
directly into the ballasted tanker from fuel transport ships and stored in
tanks aboard the ship (Fig. 11-17). It would be moved to shore year-round
through a 10 cm (4 in) diameter steel pipe (schedule 40) surrounded by a
15 cm (6 in) diameter steel guard pipe. The pipeline would be buried in the
sea bed below ice gouge depth. Flow detectors would be used to monitor
fuel transfer operations to give immediate indication of pipeline leakage or
unusual transfer conditions. As an extra precaution, a fuel leak detection
system would be installed to detect leakage from the 10 cm (4 in) transfer
pipe into the space between the two pipes. Fuel would be stored at the port
site to a capacity of approximately 2,000 bbls (Fig. 11-15). It would then be
transported to the mine area facilities by tanker truck as needed. Regional
village fuel would be distributed by barges directly from the tankers.
DEVELOPMENT SCHEDULE
As is the case with any endeavor in the Arctic, the critical factor affecting
the development schedule is the limited shipping season (generally July
through September). Within these confines and assuming a project start-up
date of January 1985, key periods in the development schedule are discussed
below.
Construction equipment for road building activities would be landed at the
port site during the summer of 1985. This equipment would be idled until
freeze-up occurred prior to moving inland to the first borrow site. From
January to July of 1986, a road would be built inland from the first borrow
site, as well as back to the port site.
The first major construction sealift of equipment and materials would be made
in the 1986 shipping season. The equipment for constructing the main road,
as well as the mining equipment, would be brought in at that time. A small
20-person "fly-in" construction camp would be set up at the Red Dog mine
site. A self-contained barge-mounted camp would be located in a lagoon at
the port site to support construction activity during the same sealift (Fig.
11-18). The barrier beach between the lagoon and the sea would be
breached by a bulldozer during the first season to position the barge in the
lagoon. The 100-person barge camp would remain in the lagoon for the two
to three seasons required for construction of the port site facilities. The
lagoon would be rebreached to remove the barge after the port facilities were
established. The barge would then be converted to the self-propelled con-
centrate transport lighter.
II - 34
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^
L 168' I
T
2
-------
In January of 1987 the main road would be completed from the port site to
Red Dog Valley. Construction equipment to prepare the mill site, as well as
mining equipment to begin development work, would then be moved to the
site. Additional camp facilities (for 50 people) would also be moved over the
road to the Red Dog site at that time. Mine development would continue
through 1987 to the time of production mining start-up in early 1988. Suit-
able mine overburden would be used to construct the tailings pond dam
during this period. To the extent that schedule constraints would allow,
initial mine work would be carried out by permanent crews so that fully
trained personnel would be available by the commencement of full operation.
A permanent dockface (in 4.6 m [15 ft] of water) and short causeway would
be constructed prior to the 1987 sealift. This facility would be used to off-
load ore concentrator and worker housing modules, as well as other mine
equipment. During the 1987 sealift the worker housing modules would be the
first to be moved to the mine site. These living quarters would be estab-
lished as quickly as possible for use by construction crews, and later by
operating personnel during the project start-up period. In this manner, the
additional expense of a larger construction camp would be avoided.
During the summer and early fall of 1987, the concentrate storage building
and other port site facilities would be constructed. If the offshore island
transfer facility were selected, the modified tanker would be towed to the
site and ballasted to the bottom during the 1987 shipping season.
From September to December 1987, the concentrator complex modules at the
mine site would be joined and services installed. The facilities would be
ready for commissioning (start-up) in December. Once commissioned, opera-
tions would commence in February 1988. Construction activities would be
completed prior to the 1988 sealift. Construction surplus and equipment
would be snipped out at that time.
The first movements of concentrates to market would probably be during the
1988 shipping season, though this would depend on project financing and the
status of world lead and zinc markets.
II - 36
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Chapter III
Alternatives
-------
III. ALTERNATIVES INCLUDING THE PROPOSED ACTION
INTRODUCTION
The EIS scoping process, described in Chapter VII, established two impor-
tant cornerstones for the EIS. First, it identified 12 issues of major concern
to be addressed during the EIS process. These issues are described in
Chapter I and were the bases for ultimately determining the makeup of the
project alternatives. Second, to address these 12 issues, the scoping pro-
cess identified a full range of options for the project components (Table
111-1). Thus, a large number of options were initially considered to address
the major technical, environmental and economic issues associated with the
project.
Even before the scoping process began, however, certain transportation
corridor and port site options in the lowlands of the Wulik and Kivalina
drainages were eliminated because of the obvious and significant technical,
environmental, and social impacts they would cause. As shown in Figure
IV-2, that area is dominated by organic soils (poor foundation conditions),
floodplains (annual flooding and unstable banks), patterned ground (severe
permafrost conditions), aufeis zones (blockage of drainage structures and
transportation systems) and occasional steep slopes (landslides, solifluction*
and steep grades).
Environmentally these lowland areas contain important wetlands, waterfowl
and shorebird breeding areas, caribou winter range, and fish migration,
spawning, rearing and overwintering habitats. From a social standpoint they
are the prime subsistence areas for the residents of Kivalina. Also, the
location of a transportation corridor and port site in close proximity to the
village would have a much greater disruptive effect upon existing lifestyles,
an impact the project is striving to avoid.
OPTIONS INITIALLY CONSIDERED
Thirty options and seven suboptions were identified for the 11 project
components (Table II1-1). Three components (mine, mill site and housing
locations) had only one option for each. The ore body, and therefore the
mine, was fixed in location. For technical, environmental and economic
reasons (e.g., shorter tailings slurry line; natural drainage into the tailings
pond; good foundation material; use of waste heat to dry concentrates and
heat worker housing), locating the mill, power generation source and worker
* Defined in Glossary.
-------
Table 111-1
COMPONENT OPTIONS AND SUBOPTIONS IDENTIFIED
DURING THE SCOPING PROCESS
Component
Option
Suboption
Mine Location
Fixed
Tailings Pond Location
North Fork Red Dog Creek
Volcano Creek
South Fork Red Dog Creek
Mill Site Location
Dependent upon Tailings Pond Location
Worker Housing
0 Location
Dependent upon Mill Site Location
Type
Townsite
Campsite
Water Supply
Buddy Creek
Bons Creek
Power Generation
Coal
Gas
Hydropower
Diesel
Transportation
0 Corridor Location
Northern
Southern
Noatak
GCO Route
Asikpak Route
Western Route
Omikviorok Route
Kruz Route
System
Slurry Pipeline
Hovercraft
Railroad
Road
Winter Only
Year-round
Port Site
0 Location
Singoalik Lagoon
Tugak Lagoon
VABM 17
VABM 28
Hotham Inlet/Kotzebue Sound
0 Transfer Facility
Short Causeway/Lightering
Medium Causeway
Long Causeway
Short Causeway/Offshore Island
III - 2
-------
housing together near the tailings pond was necessary for logistical pur-
poses. Since no objections to locating them there were identified, no other
options were investigated.
Tailings Pond
Three options were identified (North and South Forks of Red Dog Creek,
and Volcano Creek), all within 7 km (4.4 mi) of the ore body (Fig. 111-1).
Characteristics important for locating these options include capacity, amount
of surrounding surface drainage area, structural soundness of dam founda-
tions, minimal impact upon fish, and the ability of adjacent slopes to hold
the mill and worker housing facilities as well as stockpiled overburden
materials.
Worker Housing Type
Two options were identified, a campsite and a townsite. The campsite would
house only workers and support staff, with rotations on a periodic basis to
allow employees to return to their homes elsewhere in the region. A town-
site would be considerably larger, including families and all the infrastruc-
ture necessary to support a larger population.
Water Supply
The inability of wells to supply water, because of permafrost, required use
of surface impoundments. Two options, Buddy and Bons Creeks, were iden-
tified just south of the headwaters of the South Fork of Red Dog Creek in
the Dudd Creek drainage (Fig. II-5). Characteristics important in selecting
a water supply include water quality (particularly the ambient concentrations
of zinc), impoundment capacity, structural soundness of foundations, stabil-
ity, minimal fish impact and minimal pumping distance.
Power Generation
Four options were identified; coal, natural gas, hydropower and diesel. The
primary factors affecting selection of the power source were energy effi-
ciency and the primary resource availability.
Transportation Corridor Location
Three options were identified (northern, southern and Noatak) between Red
Dog Valley and the coast (Fig. III-2). Characteristics important in selecting
a corridor include distance; ability to maintain grades suitable for both a
railroad and road; suitability of soil conditions; avoidance to the extent
possible of major stream crossings; subsistence use areas and cultural sites;
impact on Cape Krusenstern National Monument; and impacts on other
regional uses.
Northern Corridor
The northern corridor has two suboptions (Fig. III-2). The first would be
the GCO route originally suggested by GCO Minerals (drawing No. 1763-0-
002). This route would connect GCO's Lik mineral prospect 19 km (12 mi)
III - 3
-------
OVOLCAN.
MOUNTAI
EL. 2127
FIGURE 111-1 RED DOG VALLEY MAP
SHOWING TAILINGS POND OPTIONSj
-------
-------
northwest of Red Dog Valley to the Chukchi Sea port site at Singoalik
Lagoon, 43 km (27 mi) northwest of Kivalina. The route, as modified to
reach the Red Dog Valley, would traverse the Wulik and Kivalina Rivers and
then cross into and down the Singoalik River drainage to the coast. It
would be 133.6 km (83.5 mi) long (Table III-2) and have eight major multi-
span bridge crossings (greater than 30.5 m [100 ft]). This route would be
similar to the route considered in the Western and Arctic Alaska Transpor-
tation Study (WAATS) (Louis Berger & Assoc., 1981) as a route from the
Noatak mining district to the coast.
The second northern corridor suboption would be the Asikpak route (Fig.
III-2). This route would share a common alignment with the GCO route for
the first 46.6 km (29.1 mi) from Red Dog Valley. From the point of diver-
gence at the west fork of the Wulik River, the Asikpak route would proceed
westerly similar to the GCO route, but south of it, reaching the coast via
the Asikpak River at Tugak Lagoon, 24 km (15 mi) northwest of Kivalina.
The route would be 120 km (75 mi) long (Table III-2) and have six major
multi-span bridge crossings.
Table III-2
DISTANCES FOR TRANSPORTATION CORRIDOR OPTIONS AND SUBOPTIONS
Total Distance
Transportation Corridor
Option
Northern
Southern
Noatak
Suboption
GCO
Asikpak
Western (VABM 17)
Western (VABM 28)
Omikviorok (VABM 17)
Omikviorok (VABM 28)
KRUZ (VABM 28)
To Noatak Village
To Fish Hatchery
Mine to
km
133.6
117.0
95.8
104.8
88.6
97.6
89.9
81.6
110.4
Port Site
mi
83.5
73.1
59.9
65.5
55.4
61.0
56.2
51.0
69.0
Within
km
NA
NA
15.7
27.2
34.6
46.1
38.4
NA
NA
Monument
mi
9.8
17.0
21.6
28.8
24.0
III - 6
-------
Southern Corridor
The southern corridor has three suboptions, all following the same alignment
for approximately the first 48.3 km (30.2 mi) south from Red Dog Valley
(Fig. 111-2). At that point, just north of the northern boundary of Cape
Krusenstern National Monument, the western route suboption would diverge
west to within approximately 3.2 km (2 mi) of the Wulik River. It would
then turn south into Native-selected, but not yet conveyed, lands still with-
in the Monument, paralleling the Omikviorok River to the VABM 17 port site,
or crossing the river and proceeding south to the VABM 28 port site. This
route to VABM 17 would be a total of 95.8 km (59.9 mi) long (15.7 km
[9.8 mi] within the Monument), and to VABM 28 would be 104.8 km (65.5 mi)
long (27.2 km [17.0 mi] within the Monument) (Table III-2). The leg to
VABM 17 would cross no major streams. The leg to VABM 28 would have
one major multi-span bridge crossing.
The Omikviorok route suboption would also diverge west from the common
alignment. Beginning just south of the northern boundary of the Monument,
the route would parallel the Omikviorok River to VABM 17, or cross the
Omikviorok River and proceed south to VABM 28. This route to VABM 17
would be a total of 88.6 km (55.4 mi) long (34.6 km [21.6 mi] within the
Monument), and to VABM 28 would be 97.6 km (61.0 mi) long (46.1 km
[28.8 mi] within the Monument) (Table III-2). The leg to VABM 17 would
cross no major streams. The leg to VABM 28 would have one major multi-
span bridge crossing.
The Kruz route suboption would continue to VABM 28 from the points of
divergence from the other suboptions. It would be 89.9 km (56.2 mi) long
with 38.4 km (24.0 mi) within the Monument (Table III-2). It would cross
the Omikviorok River considerably further upstream than the other two
suboptions, and would have one major multi-span bridge crossing.
Noatak Corridor
The Noatak corridor option (Fig. III-2), unlike the others, has not been
specifically located by any study. It would proceed south from Red Dog
Valley on the same alignment as the southern corridor for approximately
20.8 km (13 mi) and then southeast down Evaingiknuk Creek into the Noatak
Valley. It would then proceed south on the west side of the Noatak River,
paralleling the river at least as far as the village of Noatak 81.6 km (51 mi).
It would probably continue on to the vicinity of the fish hatchery approxi-
mately 28.8 km (18 mi) downriver from Noatak (total corridor length of
110.4 km [69 mi]) to reach deeper water for barge transport.
Transportation System
Four options were identified (slurry pipeline, hovercraft, railroad and road).
The road had two suboptions: a winter only road and a year-round road.
Characteristics important in selecting a transportation system include avail-
ability of technology and reliability.
I - 7
-------
Port Site Locations
Five options were identified (Singoalik Lagoon, Tugak Lagoon, VABM 17,
VABM 28, and an unspecified location in Hotham Inlet/Kotzebue Sound) (Fig.
III-2). Each site was specifically associated with one transportation corridor
suboption except for VABM 17, which could be the terminus of either the
Western or Omikviorok southern route suboptions, and VABM 28, which could
be the terminus of all three southern route suboptions. The Hotham Inlet/
Kotzebue Sound site would serve as the loading point for barges moving
down the Noatak River.
Characteristics important for locating a port site include suitability of soils
for construction, distance to deep water, suitability for expansion, and
suitability for other regional uses. Selection of a port site was, obviously,
closely associated with the selection of a transportation corridor.
Transfer Facility
Four options were identified (short causeway/lightering, medium causeway,
long causeway and short causeway/offshore island). The short causeway/
lightering option would involve a 122 m (400 ft) earth-filled dock structure
with stone protection facing. Concentrates would be transferred to bulk
carriers anchored offshore using two large barge lighters moved by tugs.
The medium and long causeways would be earth-filled structures approxi-
mately 1,219 m (4,000 ft) and 2,438 to 4,267 m (8,000 to 14,000 *t), respec-
tively, that would allow loading of concentrates directly to ships in deeper
water. The short causeway/offshore island option would involve the same
122 m (400 ft) filled dock structure and lightering as in the short causeway/
lightering option, but the concentrates would be transferred by one smaller,
self-powered lighter to a large ballasted ship resting on the sea bottom at
sufficient depth to directly load the bulk carriers. The ballasted ship would
serve as a docking platform and concentrate storage facility.
Characteristics important for selecting these options include distance to deep
water, longshore sediment transport, fish and marine mammal movements,
reliability and seasonal shipping constraints.
OPTIONS SCREENING PROCESS
The options screening process was conducted in two steps. First, all of the
30 options and seven suboptions identified during the scoping process (as
described previously) were initially reviewed to eliminate from further con-
sideration those options which were clearly unreasonable or infeasible pri-
marily for environmental or technical reasons. In the second step, all re-
maining options and suboptions not eliminated in step one were individually
evaluated in detail from the perspective of each resource or technical disci-
pline (e.g., water quality, subsistence, technical feasibility, etc.). These
two steps are described below.
Initial Options Evaluation
Each component option and suboption identified during the scoping process
was individually reviewed from environmental and technical perspectives. If
III - 8
-------
an option (or suboption) was environmentally and technically reasonable and
feasible, it was retained for further detailed analysis. If, however, the op-
tion was determined to be unreasonable or infeasible on environmental or
technical grounds, and if other options retained for that component ade-
quately addressed the 12 issues, it was eliminated. Table III-3 identifies the
11 options and one suboption eliminated during this initial options review,
and outlines the major reasons why each was eliminated. Table III-4 sum-
marizes the results of the initial options review process and shows those
options and suboptions retained and eliminated.
Note that as a result of this initial options review two additional components,
i.e., type of worker housing and power generation, had options eliminated
such that only one option remained for each. Thus, a total of five compon-
ents at this stage of the option screening process had only one option left
while the six other components still had two or more options each.
Remaining Options Evaluation
Each of the remaining 14 options and six suboptions (for the six components
having two or more options) was then individually evaluated in detail from
the perspective of each resource or technical discipline (e.g., water quality,
subsistence, technical feasibility, etc.). For each discipline, a specific set
of "options screening criteria" was developed against which each option (and
suboption) was screened to identify potential impacts upon that discipline.
Table III-5 lists these individual discipline screening criteria.
For example, when evaluating the two remaining tailings pond location op-
tions from the water quality perspective (Table III-5) five screening criteria
were used: stream diversion requirements, spill hazard, downstream impacts,
capacity and reclamation difficulty.
For each discipline, once each option for a specific component had been
evaluated against all screening criteria, each option was then compared to
all other options for that component and a "relative level of potential impact"
was assigned. It is important to understand that potential impacts were
assigned relative to the other options for each project component. The rela-
tive levels of potential impact were low, moderate and high. For example,
using the water quality discipline and the tailings pond location component,
both remaining tailings pond options (North Fork and South Fork of Red Dog
Creek) were first evaluated individually against the option screening criteria
to determine what the stream diversion requirements would be, what was the
spill hazard, etc. When this was completed for both the North Fork and
South Fork options separately, the two were compared on the basis of the
screening criteria and a relative level of potential impact was assigned to
each option. In this case (i.e., for water quality), the relative level of
potential impact for North Fork was "high" while that for South Fork was
"low". Thus, from a water quality perspective, the South Fork of Red Dog
Creek had the relatively lower level of potential impact for location of a tail-
ings pond.
Ill - 9
-------
Table 111-3
MAJOR REASONS FOR ELIMINATION OF INDIVIDUAL OPTIONS
AND SUBOPTIONS DURING INITIAL OPTIONS REVIEW
Component
Tailings Pond
Option or
Suboption
Volcano Creek
Worker Housing
Townsite
Power Generation
Coal
Natural Gas
Hydropower
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
Major Reasons for Elimination
Two dam structures required
Higher risk of embankment failure
Limited storage capacity
Major pumping required
Difficult mitigation/reclamation
Insufficient overburden storage area
Least dilution/mixing of runoff,
seepage & spills
Short distance to fish populations in
Ikalukrok Creek if spill occurred
Substantially greater infrastructure
required (water, sewer, housing,
etc.)
Adverse to local autonomy
Less adaptable to traditional regional
lifestyles
Fewer local hire opportunities
Competition with subsistence activities
Greater land area impact
Increased site runoff problems
Greater impacts on fish and wildlife
(increased hunting & fishing; human/
wildlife contacts; etc.)
No nearby, operating source of supply
Low energy efficiency
Scrubber and cooling wastewater
disposal impacts
Air pollutant emissions
No nearby, operating source of supply
Low temperature pipeline technology re-
quired (if liquified gas was considered)
Major additional impacts if pipeline
constructed
No nearby, operating source of supply
No year-round sites identified in area
Construction of dam & impoundment
would create additional major environ-
mental impacts
III - 10
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Table 111-3
(Continued)
MAJOR REASONS FOR ELIMINATION OF INDIVIDUAL OPTIONS
AND SUBOPTIONS DURING INITIAL OPTIONS REVIEW
Component
Transportation
Corridor and
Port Site
Option or
Suboption
Noatak Corridor
& Hotham Inlet
Transportation
System
Slurry Pipeline
Hovercraft
Winter Road
Transfer Facility Medium Causeway
Long Causeway
Major Reasons for Elimination
Limited barging season would require
significant dredging of Noatak River
Substantial weather and low water
problems
Barge to bulk carrier transfer point
would still have to be constructed in
Hotham Inlet/Kotzebue Sound
Corridor would cross many lowlands
with substantial permafrost and
wetlands problems
Many stream crossings with associated
impacts on water quality and fish
Cold weather slurry lines not yet
feasible
High spill hazard
Slurry water disposal problems
Waste heat from power generation
couldn't be used to dry concentrates
Units large enough to efficiently haul
concentrates not yet available
Excessive fuel consumption
Noise levels reach 105 db
Substantial disturbance to wildlife
Unpredictability of snow availability
Annual construction of ice/snow
bridges at river crossings pose ero-
sion problems
Greater spill hazards at river crossings
Increased disturbance to wintering
caribou
Less flexibility for other regional uses
Possible significant impacts on sedi-
ment transport causing erosion &
lagoon breaching
Impacts on fish and marine mammal
movements
Winter and breakup ice problems
Greater disruption of marine benthos
Substantial armor rock needed - no
local source available
Same problems as for medium cause-
way - but of greater magnitude
III - 11
-------
Table IM-4
OPTIONS AND SUBOPTIONS ELIMINATED OR RETAINED
FOR FURTHER ANALYSIS DURING INITIAL OPTIONS REVIEW
Component
Mine Location
Tailings Pond Location
Mill Site Location
Worker Housing
0 Location
0 Type
Water Supply
Power Generation
Transportation
0 Corridor Location
0 System
Port Site
• Location
Retained Eliminated
Option Suboption Option Suboption
Fixed1
North Fork R.D. Creek Volcano Creek
South Fork R.D. Creek
Dependent upon Tailings Pond Location
Dependent upon Mill Site Location
Campsite1 Townsite
Buddy Creek
Bons Creek
Diesel1 Coal
Natural Gas
Hydropower
Northern GCO Route Noatak
Asikpak Route
Southern Western Route
Omikviorok Route
Kruz Route
Railroad Slurry Pipeline
Road Year-round Hovercraft
Road Winter Only
Singoalik Lagoon Hotham Inlet/
Tugak Lagoon Kotzebue Sound
VABM 17
VABM 28
Transfer Facility
Short Causeway/
Lightering
Short Causeway/
Offshore Island
Medium Causeway
Long Causeway
1 Sole option remaining for that component.
Ill - 12
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Table 111-5
INDIVIDUAL DISCIPLINE OPTIONS SCREENING CRITERIA
DISCIPLINE
OPTIONS SCREENING CRITERIA
Water Quality
Air Quality
Coastal Geologic Processes
Vegetation
Tailings Pond Location:
Stream diversion requirements
Spill hazard
Downstream impacts
Capacity
Reclamation difficulty
Transportation Corridor Location:
Spill hazard
Reclamation difficulty
Sediment production from road surface, cuts,
fills, sideslopes and road crossings
Transportation System:
Spill hazard
Sediment production and control
Port Site and Transfer Facility:
Impact on seawater quality
Impact on lagoons
Spill hazard
Air pollutant emission rates
Power plant plume impact areas
Transportation system dust generation
Net sediment transport
Erosion of port facilities
Breaching of adjacent lagoons
Direct vegetation loss
Indirect loss from dust, foot or vehicular traffic
Relative functions of wetlands
Freshwater Biology
Quality and quantity of habitat affected
Quality/quantity of trophic* resources
* Defined in Glossary.
Ill - 13
-------
Table 111-5
(continued)
INDIVIDUAL DISCIPLINE OPTIONS SCREENING CRITERIA
DISCIPLINE
OPTIONS SCREENING CRITERIA
Fish
Wildlife
Fish present or absent
Resource value in terms of spawning, rearing,
overwintering and migration
Recreation and access
Number of major stream crossings
Direct habitat loss
Indirect habitat loss due to noise, other
disturbance or human contacts
Affect on animal movements
Marine Biology
Quality and quantity of benthic habitat affected
Disruption of sedimentation patterns
Disruption of organism movements
Spill hazard
Socioeconomics
Subsistence
Impact on community population growth and
infrastructure needs
Impact on autonomy of social and governing
institutions
Ratio of nonresident/resident hire
Resident employment and income gains
Project compatibility with continuance of
subsistence culture and traditional lifestyle
Interference with subsistence harvest activities
Compatibility of project employment with sub-
sistence harvest cycles
Increased nonresident harvest of subsistence
resources
Effects of mine employment on subsistence
efficiency and success.
Ill - 14
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Table 111-5
(continued)
INDIVIDUAL DISCIPLINE OPTIONS SCREENING CRITERIA
DISCIPLINE
OPTIONS SCREENING CRITERIA
Cultural Resources
Recreation
Direct impact
Indirect impact from erosion, foot or vehicular
traffic, accessibility, unauthorized artifact
collection, etc.
Significance based on National Register of His-
toric Places Criteria for Evaluation
(36 CFR Part 60.4)
Impacts on existing recreation
Access
Regional Use
Krusenstern Impact
Technical Feasibility
Economic Feasibility
Flexibility for other regional uses
Size and location of component site
Preclusion of other users or uses
Beach erosion at Cape Krusenstern
Archeological site protection
Aesthetic degradation (visual, sound, wilderness
character)
Access
Availability of adequate construction technology
Relative difficulty of design, construction and
operation
Cost of construction
Operation costs
Reclamation costs
III - 15
-------
In addition to the water quality discipline, the options screening criteria for
every other discipline were applied in a similar manner and a relative level
of potential impact was assigned to each option for every remaining compon-
ent. The results of this process, including the assigned relative levels of
potential impact, are summarized in Table 111-6 for each discipline where a
reasonable difference existed between options.
Where screening analyses comments shown in Table 111-6 were based upon
published material or documentation (letters, etc.) developed for the Red
Dog project, a lower case citation letter in parenthesis (e.g., "(c)") is
shown that corresponds to the proper citation listed on a separate page that
follows the table. Where no citation letter is shown, the comment represents
best professional judgement based upon past experience, discussion with
others, visits to the project area or calculations developed specifically for
this options screening process.
It should be noted in Table III-6C and III-6D that the suboptions for the
northern and southern transportation corridors, respectively, were compared
only against the other suboption(s) for each of those corridors (i.e., the
GCO route and the Asikpak route were compared only against each other for
the northern corridor, and the Western, Omikviorok and Kruz routes were
compared only among themselves for the southern corridor). This was done
to specifically address the Title XI requirement that alternate routes around
the Monument be fully evaluated in the EIS process. By comparing each
corridor's routes only among themselves, the best route for each corridor
was identified, thus guaranteeing that each corridor would be considered
during the evaluation of alternatives process and be included in the alterna-
tives for formal public review.
In the next step of the process, the levels of potential impact for all disci-
plines (as shown in Table 111-6) were grouped for each option. This pro-
vided a combined picture of the individual levels of potential impact (Table
111-7).
A perusal of Table 111-7 shows that for most options the distribution of the
relative levels of potential impact made determination of an overall relative
level of potential impact for a specific option fairly straightforward. These
overall relative levels of potential impact are shown in Table 111-8.
The final step of the option screening process was to select the best option
for each of the remaining six components. This was done by using Table
111-8 to determine the option for each component which showed the lowest
level of potential impact (the lower the potential level of impact, the better
the option). That option was then selected unless one of the other options
for that component addressed one or more of the 12 issues in a significantly
more favorable manner.
For three of the six remaining components, selection of the best option was
relatively straightforward. For the tailings pond component the South Fork
of Red Dog Creek (Table III-8) was clearly the best location, as was Sons
Creek for the water supply. For the southern transportation corridor and
port site the Kruz route to VABM 28 was selected.
Ill - 16
-------
Table III-6A
Discipline1
Water Quality
SUMMARY OF
Low
Larger capacity.
OPTIONS SCREENING
NORTH FORK RED
Moderate
(1) Larger drainage
area.
CRITERIA ANALYSES
TAILINGS POND
DOG CREEK
High
Higher risk of
diversion system
failure.
SHOWING RELATIVE LEVELS
LOCATION
Total
High
Low
Smaller drainage
area.
OF POTENTIAL IMPACT
SOUTH FORK RED DOG CREEK
Moderate High
Smaller capacity. (1)
Total
Low
Ikalukrok Creak.
diversion system
failure.
Spill further from
Ikalukrok Creek.
Vegetation
Direct loss of
4M ha (1,157 ac).
Greater wetlands
(•pact.
High
Direct toss of
237 ha (585 ac).
Lesser wetlands
impact.
Moderate
_ Freshwater Biology
Best quality habi-
tat tost.
Greater quantity
habitat tost.
Greater trophic
tost.
High Poor quality habi-
tat lost.
Lesser quantity
habitat tost.
Fewer trophic
resources tost.
Low
Fish
ing ft
habitat tost.(d)
Pish present.(d)
High No migration,
spawning * rearing
habitat tost.(d)
Fish absent, (d)
Low
Wildlife
Greater direct
habitat toss.(c)
Greater Indirect
habitat toss.
Greater effect on
animal movements.
High Lesser direct hab-
itat loss.(c)
Lesser Indirect
habitat loss.
Lesser effect on
animal movements.
Low
Technical Feasibility
Greater thaw bulb
It stability prob-
lems with larger
pond.(n)
Larger dam to
build, (c)
High Smaller thaw bulb
& stability prob-
lems with smaller
pond.(n)
Smaller dam to
build, (c)
Low
Economic Feasibility
greater cost. (I) High
25% lower cost. (I)
Low
1 Includes only disciplines having a reasonable difference in Impacts between options.
(a) etc. See reference list following Table III-6H.
-------
Table Ill-SB
SUMMARY OF OPTIONS SCREENING CRITERIA ANALYSES SHOWING RELATIVE LEVELS OF POTENTIAL IMPACT
WATER SUPPLY
00
Discipline1 Low
Vegetation Direct loss of
>40 ha (>100 ac).
Technical Feasibility
BUDDY CREEK
Moderate High
Greater dam
height, (c)
Lower capacity. (c)
Longer access
road.(c)
BONS CREEK
Total Low Moderate
Low Direct loss of
31 ha (76 ac).
Moderate Lower dam height, (c)
Higher capacity. (c)
Shorter access
road.(c)
High Total
Low
Low
Economic Feasibility
Construction cost
approximately
$9.3M.(I)
High Construction cost
approximately
Low
1 Includes only disciplines having a reasonable difference tn impacts between options.
(a) etc. See reference list following Table III-6H.
-------
Table III-6C
SUMMARY OF OPTIONS SCREENING CRITERIA ANALYSES SHOWING RELATIVE LEVELS OF POTENTIAL IMPACT
NORTHERN TRANSPORTATION CORRIDOR
Discipline1
Low
Vegetation
GCO ROUTE
ASIKPAK ROUTE
Moderate
Direct loss of
293 ha (723 ac)
(not including
borrow sites).(I)
High
Total
Moderate
Low
Moderate
Direct loss of
257 ha (634 ac)
(not including
borrow sites).(I)
High
Total
Moderate
Fish
i
-a
UD
Impacts on spawn-
ing, rearing, over-
wintering and
migration from
crossings of import-
ant streams,
particularly the
upper Kivalina
River and tributar-
ies, (d, i, j, p)
Impacts from access
to important spawn-
ing areas.
High
Impacts on spawn-
ing, rearing, over-
wintering and
migration from
crossings of import-
ant streams,
particularly Grayling
Creek and Kivalina
River.(d, i, j, p)
Impacts from access
to important spawn-
ing areas.
Wildlife
Direct habitat loss
of 293 ha (723 ac)
(not including
borrow sites).(I)
Moderate
Direct habitat loss
of 257 ha (634 ac)
(not including
borrow sites).(I)
Moderate
Subsistence
Lesser conflict
with subsistence
use areas.(a)
Lesser nonresident
harvest of subsis-
tence resources.(a)
Moderate
Greater conflict
with subsistence
use areas.(a)
Greater nonresi-
dent harvest of
subsistence
resources.(a)
High
Cultural Resources2
Potential Indirect
impacts on 12
sites, (f)
High
No sites along
route.(d, e)
Low
1 Includes only disciplines having a reasonable difference in impacts between options.
1 Does not address common alignment segment In eastern portion of northern corridor.
(a) ttc. See reference list following Table III-6H.
-------
Table III-6C
(Continued)
SUMMARY OF OPTIONS SCREENING CRITERIA ANALYSES SHOWING RELATIVE LEVELS OF POTENTIAL IMPACT
NORTHERN TRANSPORTATION CORRIDOR
GCO ROUTE ASIKPAK ROUTE
Discipline1
Regional Use
Low Moderate High Total Low Moderate
More difficult to Moderate Easier to access
access from from Kivalina.
Kivalina.
High Total
Low
ro
o
Technical Feasibility
65% of route High
moderately diffi-
cult or difficult
to construct, (c)
Two more major
bridge crossings.(m)
41% of route
moderately diffi-
cult or difficult
to construct, (c)
Two fewer major
bridge crossings.(m)
Moderate
Economic Feasibility
Construction cost
approximately
$128M.(c)
High
Construction cost
approximately
$126M.(c)
High
1 Includes only disciplines having a reasonable difference in impacts between options.
(a) etc. See reference list following Table III-6H.
-------
Table III-6D
I
ro
SUMMARY OF
OPTIONS SCREENING CRITERIA
SOUTHERN
WESTERN ROUTE
Discipline1
Water Quality
Vegetation
Freshwater Biology
Fish
Wildlife
Low Moderate
Close to Wuhk and
crosses Omikvio-
rok spill hazard,
sedimentation
problems
Close to Wuhk and
crosses Omikvio-
rok risk of dis-
ruption to habitat
and trophic re-
sources.
High Total
Moderate
Direct loss of High
330 ha (568 ac) (I)
Most impact to
productive wet-
lands.
Moderate
Close to Wuhk and High
crosses Omikvio-
rok: spill and sed-
imentation risks.
Increased access
to fish populations.
Most direct habi- Htgh
tat loss (1)
Most indirect
habitat loss.
ANALYSES SHOWING RELATIVE LEVELS OF POTENTIAL IMPACT
TRANSPORTATION CORRIDOR2
OMIK1VOROK ROUTE
Low Moderate High Total
Parallels and Moderate
crosses the Omik-
viorok: spill haz-
ard; sedimentation
problems.
Direct loss of Moderate
Z14 ha (529 ac) (I)
Moderate impact to
productive wet-
lands.
Adjacent to and High
crosses Omikvio-
rok: greatest risk
of disruption to
habitat and trophic
resources .
Adjacent to and High
crosses Omikvio-
rok: spill and sed-
imentation risks.
Increased access
to fish populations.
Moderate direct Moderate
habitat loss (1)
Moderate indirect
habitat loss.
KRUZ ROUTE
Low Moderate High
Minor crossings
of upper Omikvio-
rok: less spill haz-
ard; less sedimen-
tation
Direct loss of
197 ha (487 ac).(l)
Least impact to
productive '"etlands
One major bridge
crossing of upper
reaches of Omikvio-
rok: least risk of
disruption to habi-
tat and trophic
resources .
One major bridge
crossing of upper
reaches of Omikvio-
rok: fewer spill
and sedimentation
risks. (d,i,|)
Less access to fish
populations
Least direct habi-
tat loss. (1)
Least indirect hab-
itat loss.
Total
Low
Low
Low
Moderate
Low
-------
Table III-6D
PO
t\J
Discipline Low
Subsistence
Cultural Resources3
access and traffic
in Monument. (c)
Two of the four
archeological sites
in the Monument.
(f,g)
Technical Feasibility
Economic Feasibility
SUMMARY OF OPTIONS SCREENING CRITERIA
SOUTHERN
WESTERN ROUTE
Moderate High Total
Some interference Moderate
with harvest
activities.
Some increase in
nonresident harvest
Potential indirect Moderate
impacts on four
sites. (f,g)
23% of route mod- Moderate
erately difficult or
difficult to con-
struct. (1)
One major multi-
span bridge
crossing. (c)
Construction cost High
approximately
$98M (1)
(Continued)
ANALYSES SHOWING RELATIVE LEVELS OF POTENTIAL IMPACT
TRANSPORTATION CORRIDOR
OMIKVtOROK ROUTE KRUZ ROUTE
Low Moderate High Total Low Moderate High Total
Some interference Moderate Least interference Low
with harvest with harvest
activities . activities .
Some Increase in Least increase in
nonresident harvest. nonresident harvest
Potential indirect Moderate Potential indirect High
impacts on three impacts on svx
sites. (f,g) sites. (f,g)
access and traffic m access and traffic
Monument. (c) in Monument. (c)
All three archeo- All six archeo-
logical sites in logical sites in
the Monument Monument. (f,g)
(f,g)
25% of route mod- Moderate 19% of route mod- Low
erately difficult or erately difficult or
difficult to con- difficult to con^
struct. (1) struct. (1)
One major multi- One major multi-
span bridge span bridge
crossing, (c) crossing. (1)
Construction cost Moderate Construction cost Low
approximately approximately
$83M.(I) $75M (1)
1 Includes only disciplines having a reasonable difference in impacts between options.
2 The Western, Omtkviorok and Kruz routes are compared using the alignments to the environmentally and technically superior VABM 28 port site option.
3 Does not address common alignment segment in northern portion of southern corridor.
(a) etc. See reference list following Table III-6H.
-------
Table III-6E
Discipline1
Water Quality
Air Quality
Vegetation
Freshwater Biology
Fish
Wildlife
SUMMARY OF OPTIONS SCREENING CRITERIA ANALYSES SHOWING RELATIVE LEVELS OF
TRANSPORTATION SYSTEM
RAILROAD
Low Moderate High Total Low
Greater spill Moderate Lower spill hazard.
hazard.
Lower sedimenta-
tion hazard.
Lower dust Moderate
generation.
Lesser loss from Moderate
dust.
Fewer impacts
from poorer access.
Fewer impacts at Moderate
stream crossings.
Lower sedimenta- Moderate Lower spill hazard.
tlon hazard.
Greater spill
hazard.
Poorer access.
Lower Indirect Moderate
habitat lose.
POTENTIAL IMPACT
YEAR-ROUND ROAD
Moderate High
Higher sedimenta-
hazard.
Higher dust
generation .
Greater loss from
dust.
Greater loss from
better access.
Greater impacts at
stream crossings.
Higher sedimenta-
tion hazard.
Better access.
Higher Indirect
habitat loss.
Total
High
High
High
High
High
High
Fewer effects on
animal movements.
Greater effects on
animal movements.
-------
Table III-6E
(Continued)
SUMMARY OF OPTIONS SCREENING CRITERIA ANALYSES SHOWING RELATIVE LEVELS OF POTENTIAL IMPACT
TRANSPORTATION SYSTEM
Discipline
Low
RAILROAD
Moderate
YEAR-ROUND ROAD
High
Total
Low
Moderate
High
Total
Subsistence
Lower nonresident
harvest of subsis-
tence resources.
Low
Higher nonresident
harvest of subsis-
tence resources.
High
Cultural Resources
Fewer indirect
impacts due to
poorer access.
Moderate
Greater indirect
impacts due to
better access.
High
— Recreation
I
ro
Regional Use
Less adaptability
to other uses.
Poorer access. High Better access.
Moderate Most adaptability
to other uses.
Low
Low
Krusenstern Impact
Poorer access to
Monument.
Moderate
Better access to
Monument.
High
Technical Feasibility
Cannot transport
large mine area
facilities modules.(c)
High Can transport
large mine area
facilities modules.(c)
Low
Economic Feasibility
High capital costs
($20M to $50M
greater than
road2).(c)
High
Lower capital costs
($20M to 50M less
than R.R.z).(c)
Moderate
1 Includes only disciplines having a reasonable difference In Impacts between options.
1 For Kruz route suboptlon.
(•) etc. See reference list following Table III-6H.
-------
Table III-6F
SUMMARY OF OPTIONS SCREENING CRITERIA ANALYSES SHOWING RELATIVE LEVELS OF POTENTIAL IMPACT
PORT SITE LOCATION (NORTHERN CORRIDOR)
Discipline1
Coastal Geologic
Processes
Low
Low net sediment
transport, (o)
SINGOALIK LAGOON
Moderate High
Total
Low
Low
Low net sediment
transport, (o)
TUGAK LAGOON
Moderate High
Total
Low
Fish
Herring present
offshore, (d)
Anadromous* fish High
present in lagoon.
Anadromous fish
absent from
lagoon. (d,i)
Herring present
offshore, (d)
Low
ro
Cn
Wildlife
Marine Biology
Lesser inter-
ference with
coastal animal
movements.
Low
Marine biota in
lagoon.
High
Greater inter-
ference with
coastal animal
movements.
Few marine biota
in lagoon.
Moderate
Low
Subsistence
Some interference
with subsistence
harvest areas.(a)
Low
Greater inter-
ference with
marine mammal and
waterfowl harvest
areas.(a)
High
Cultural Resources
Facility design
should prevent
Impact to sod
house, (f)
Low Facility design
should prevent
impact to eroding
cabin site.(f)
Low
Regional Use
Potential private
GCO mill site
claims.
Moderate
Potential NANA
private lands.
Moderate
1 Includes only disciplines having a reasonable difference In Impacts between options.
(a) etc. See reference list following Table III-6H.
* Defined In Glossary.
-------
Table III-6G
SUMMARY OF OPTIONS SCREENING CRITERIA ANALYSES SHOWING RELATIVE LEVELS OF POTENTIAL IMPACT
PORT SITE LOCATION (SOUTHERN CORRIDOR)
VABM 17
Discipline1
Water Quality
Low
Moderate
High
High lagoon
sedimentation
risk from
construction.
Total
High
Low
VABM 28
Moderate
Moderate lagoon
sedimentation
risk from
construction.
High
Total
Moderate
Coastal Geologic
Processes
I
PO
Possible erosion
of port facilities.
Moderate net
sediment
transport.
(h,k,o)
Severe storm(s)
could breach
Imikruk or Ipiavik
Lagoons.
High Possible erosion
of port facilities.
Moderate net
sediment
transport.
(h,k,o)
Severe storm(s)
could breach Port
Lagoon.
Moderate
Fish
Anadromous fish High
present in lagoon.
(d, i)
Anadromous fish
absent from lagoon.
(d, I)
Low
Wildlife
Greater Indirect
waterfowl habitat
loss.
High Lesser indirect
waterfowl habitat
loss.
Low
Marine Biology
Marine biota in
both lagoons.
High Few marine biota
in lagoon.
Low
Subsistence
Some interference
with subsistence
harvest areas.(a)
Low
Greater Interference
with marine mammal
harvest area.(a)
Moderate
Cultural Resources
Facility design
should prevent
impact to one
cabin and two
grave sites.(f)
Low Facility design
should prevent
Impact to
reindeer herding
slte.(d,e,g)
Low
-------
Table III-6G
(Continued)
SUMMARY OF OPTIONS SCREENING CRITERIA ANALYSES SHOWING RELATIVE LEVELS OF POTENTIAL IMPACT
PORT SITE LOCATION (SOUTHERN CORRIDOR)
Discipline
Regional Use
VABM 17
Low Moderate High
NANA private Small size.
land.
Poor expansion
potential, (c)
VABM 28
Total Low Moderate High
High Adequate size. NANA private
land.
Good expansion
potential, (c)
Total
Low
Krusenstern Impacts
Some impact on
littoral sediment
drift, but proba-
bility of impact
on beach ridges
not significant, (o)
Lower aesthetic
impact of site
adjacent to
Monument.
Less access to
Monument, (c)
Moderate
Some impact on
littoral sediment
drift, but proba-
bility of impact
on beach ridges
not significant.(o)
Higher aesthetic
impacts of site
surrounded by
Monument.
Greater access
to Monument, (c)
High
Technical Feasibility
Bedrock not
present to
18.9 m (62 ft).(I)
Greater Ice con-
tent In soils.(I)
Moderate
Bedrock present
about 16.8 m
(55 ft).(I)
Lower ice content
In soils.(I)
Low
1 Includes only disciplines having a reasonable difference In Impacts between options.
(a) etc. See reference list following Table III-6H.
-------
I able 111-bH
SUMMARY OF OPTIONS SCREENING CRITERIA ANALYSES SHOWING RELATIVE LEVELS OF POTENTIAL IMPACT
TRANSFER FACILITY
SHORT CAUSEWAY/LIGHTERING
SHORT CAUSEWAY/OFFSHORE ISLAND
Discipline1
Low
Moderate
High
Total
Low
Moderate
High
Total
Water Quality
Less seabed
disturbance.
Greater spill risk
from many in-sea
fuel/concentrate
transfers between
unstable transfer
platforms.
Greater spill risk
from fuel lightered
to shore.(I)
Greater risk of
weather impact-
Ing lightering or
transfers. (I)
High Minor risk of
weather impacting
lightering or
transfers. (I)
More seabed
disturbance.
Significantly fewer
in-sea concentrate
transfers between
unstable transfer
platforms.
Lower spill risk
from fuel trans-
ported to shore
via pipeline.(I)
Moderate
PO
00
Coastal Geologic
Processes
Some sediment
transport restric-
tion.(h,k,o)
Possible erosion of
port facilities and
lagoon breaching.
Low Some sediment
transport restric-
tion. (h,k,o)
Possible erosion of
port facilities and
lagoon breaching.
Low
Fish
Some movement
Interference, (d)
Greater spill risk
from many in-sea
fuel/concentrate
transfers between
unstable transfer
platforms.(b, m)
Greater spill risk
from fuel lightered
to shore.(m)
High Some movement
Interference, (d)
Small loss/con-
version of habi-
tat under ship.(d)
Significantly fewer
in-sea concentrate
transfers between
unstable transfer
platforms.(b, m)
Lower spill risk
from fuel trans-
ported to ship
via pipeline.(m)
Moderate
Wildlife
Little direct habitat
loss.(I)
Little Indirect habitat
loss.
Few effects on animal
movements.
Low
Greater direct habitat
loss.(I)
Greater Indirect habitat
loss.
Greater effects on
animal movements.
Moderate
-------
Table III-6H
(Continued)
SUMMARY OF OPTIONS SCREENING CRITERIA ANALYSES SHOWING RELATIVE LEVELS OF POTENTIAL IMPACT
TRANSFER FACILITY
I
ro
SHORT CAUSEWAY/LIGHTERING
Discipline
Marine Biology
Regional Use
Krusenstern Impacts
Technical Feasibility
Low
Low bottom dis-
turbance.
Some movement
interference.
Some impact on
littoral sediment
drift, but proba-
bility of impact on
beach ridges is
not significant, (o)
Some aesthetic
impact to coast-
line.
No ship or
pipeline ice/
scour problems.
Moderate High Total
Moderate lagoon Moderate
disturbance.
Greater spill risk
from in-sea con-
centrate transfers
and lightering of
fuel
Less flexibility Moderate
for other users.
Low
Two concentrate Two large tug/ High
transfers. (1) barge lighters. (1)
SHORT CAUSEWAY/OFFSHORE ISLAND
Low
Some movement
interference.
Lesser spill risk
from fewer in-
sea concentrate
transfers and use
of fuel pipeline.
Greater flexibility
for other users.
Some impact on
littoral sediment
drift, but proba-
bility of impact
on beach ridges
is not significant.
Moderate
Greater bottom
disturbance.
Moderate lagoon
disturbance.
Greater aesthetic
impact on coast-
line from large
ballasted tanker.
(0)
Fuel piped to
shore. (1)
High Total
Low
Low
Moderate
One self-propelled/ High
unloading barge. (1)
Economic Feasibility
More transfers
between unstable
platforms. (I)
Fuel lightered to
shore. (I)
Construction costs
approximately $74M.
(I)
Annual operating
costs $1.4M greater.
0)
Fewer transfers
between unstable
platforms. (I)
Ballasted ship and
pipeline ice/scour
problems.
Three concentrate
transfers.(I)
High Construction costs
approximately $55M.
(I)
Annual operating
costs $1.4M less.
(I)
Low
1 Includes only disciplines having a reasonable difference In Impacts between options.
(•) etc. See reference list fallowing this table.
-------
Table 111-6 References1
(a) Braund & Associates, 1983
(b) Cominco Alaska, Inc., 1983a
(c) Cominco Alaska, Inc., 1983c
(d) Dames & Moore, 1983a
(e) Hall, 1982a
(f) Hall, 1983a
(g) Hall, Pers. Comm., 1983b
(h) Hopkins, 1977
(i) Houghton, Pers. Comm., 1983
(j) LGL Ecological Research Associates, 1980
(k) Moore, 1966
(I) Noah, Pers. Comm., 1983
(m) Rae, Pers. Comm., 1983
(n) Tsytovich, 1977
(o) Woodward-Clyde Consultants, 1983
(p) Alt, Pers. Comm., 1983
Full references found in Chapter XI (References Cited).
Ill - 30
-------
Table 111-7
GROUPED RELATIVE LEVELS OF POTENTIAL IMPACT FOR INDIVIDUAL DISCIPLINES1
Component
Option
Suboption
Relative Level of Potential Impact2
Low
Tailings Pond Location
North Fork Red Dog Creek
Moderate
High
Water Quality
Vegetation
Freshwater Biology
Fish
Wildlife
Technical Feasibility
Economic Feasibility
South Fork Red Dog Creek
Water Quality
Freshwater Biology
Fish
Wildlife
Technical Feasibility
Economic Feasibility
Vegetation
Water Supply
Buddy Creek
Vegetation
Technical Feasibility Economic Feasibility
Bons Creek
Southern Corridor3
Western Route
Vegetation
Technical Feasibility
Economic Feasibility
Transportation Corridor8
Northern Corridor
GCO Route
Aslkpak Route Cultural Resources
Regional Use
Subsistence Cultural Resources
Regional Use Technical Feasibility
Technical Feasibility Subsistence
Krusenstern Impact
Water Quality
Freshwater Biology
Subsistence
Cultural Resources
Technical Feasibility
Vegetation
Fish
Wildlife
Economic Feasibility
Omikviorok Route
Water Quality
Vegetation
Wildlife
Subsistence
Cultural Resources
Krusenstern Impact
Technical Feasibility
Economic Feasibility
Freshwater Biology
Fish
III - 31
-------
Table IU-7
(Continued)
GROUPED RELATIVE LEVELS OF POTENTIAL IMPACT FOR INDIVIDUAL DISCIPLINES1
Component
Option
Suboptlon
Kruz Route
Low
Relative Level of Potential Impact2
Water Quality
Vegetation
Freshwater Biology
Wildlife
Subsistence
Technical Feasibility
Economic Feasibility
Moderate
Fish
High
Cultural Resources
Krusenstern Impact
Transportation System
Railroad
Subsistence
Water Quality
Air Quality
Vegetation
Freshwater Biology
Fish
Wildlife
Cultural Resources
Regional Use
Krusenstern Impact
Recreation
Technical Feasibility
Economic Feasibility
Road
Recreation
Regional Use
Technical Feasibility
Economic Feasibility
Water Quality
Air Quality
Vegetation
Freshwater Biology
Fish
Wildlife
Subsistence
Cultural Resources
Krusenstern Impact
Port Site Location4
Singoalik Lagoon
Wildlife
Subsistence
Fish
Marine Biology
Tugak Lagoon
Fish
Marine Biology
Wildlife
Subsistence
VABM 17
Subsistence
Krusenstern Impact
Technical Feasibility
Water Quality
Coastal Processes
Fish
Wildlife
Marine Biology
Regional Use
VABM 28
Fish
Wildlife
Marine Biology
Regional Use
Technical Feasibility
Water Quality
Coastal Processes
Subsistence
Krusenstern Impact
III - 32
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Table 111-7
(Continued)
GROUPED RELATIVE LEVELS OF POTENTIAL IMPACT FOR INDIVIDUAL DISCIPLINES1
Component
Option
Suboption
Transfer Facility
Short Causeway/Lightering
Short Causeway/Offshore Island
Relative
Low
Wildlife
Krusenstern Impact
Marine Biology
Regional Use
Economic Feasibility
Level of Potential Impact2
Moderate
Marine Biology
Regional Use
Water Quality
Fish
Wildlife
Krusenstern Impact
High
Water Quality
Fish
Technical Feasibility
Economic Feasibility
Technical Feasibility
Excludes components for which only one option remained.
Disciplines having the same level of potential Impact for all options of a component are not shown.
Suboptions compared only with the other(s) for same corridor (I.e., GCO and Aslkpak routes for north-
ern corridor; western, Omikviorok and Kruz routes for southern corridor).
Options compared only with other one for same corridor (I.e., Singoalik and Tugak Lagoon for northern
corridor; VABM 17 and VABM 28 for southern corridor).
Ill - 33
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Table 111-8
OVERALL RELATIVE LEVELS OF POTENTIAL IMPACT1
Component
- Option
Tailings Pond
Location
Overall Relative Level of Potential Impact
Low
Moderate
South Fork Red
Dog Creek
High
North Fork Red
Dog Creek
Water Supply
Bons Creek
Buddy Creek
Transportation
0 Corridor Location
- Northern
- Southern
0 System
Kruz Route
Asikpak Route GCO Route
Omikviorok Route Western Route
Railroad
Year-round Road
Port Site
0 Location
- Northern Corridor
- Southern Corridor VABM 28
0 Transfer Facility
Tugak Lagoon
Singoalik Lagoon
VABM 17
Short Causeway/
Lightering
Short Causeway/
Offshore Island
1 Excludes components for which only one option remained.
Ill - 34
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Selection of the best northern corridor route and port site was not as clear
cut. Because the northern corridor routes went to separate port sites (Fig.
111-2), each route and its port site had to be considered in combination for
comparison with the other. As shown in Table 111-8, both the Singoalik
Lagoon and Tugak Lagoon port sites were considered to have moderate levels
of potential impact.
Comparison of the GCO and Asikpak routes (Table 111-8) showed an overall
high level of potential impact for the GCO route and an overall moderate
level of potential impact for the Asikpak route. For those disciplines in
which a reasonable difference existed between the two routes (Table 111-7),
the Asikpak route had lower relative levels of potential impact for technical
feasibility, cultural resources and regional use, while the GCO route had a
lower relative level of potential impact for subsistence.
Thus, while comparison of the Asikpak route/Tugak Lagoon combination with
the GCO route/Singoalik Lagoon combination did not show great differences
between them, on balance the Asikpak route/Tugak Lagoon combination had
an overall lower potential for impacts, and it was selected as the best com-
bination for the northern corridor.
For the two remaining components selection of the best option was not as
simple. For the transportation system, the railroad initially appeared to
have a lower overall level of potential impact. However, analysis showed
that several of the individual discipline differences were either not signifi-
cantly different, or could be mitigated or eliminated by construction or
operational procedures. The road was finally selected on the bases of
greater regional use flexibility, substantially less capital cost, and the fact
that the transportation corridors would be initially laid out to meet the more
restrictive railroad grade constraints, thus keeping open the option for
construction of a railroad within the same right-of-way at a later time.
For the marine transfer facility both the short causeway/lightering and short
causeway/offshore island options appeared to have about the same overall
level of potential impact. An analysis of the 12 issues showed that where
one option addressed some of the issues more favorably, the second
addressed other issues more favorably. Thus, both options were retained
for this component.
At the completion of the options screening process, therefore, the options
that were retained and used to form the alternatives were those shown in
Table III-9.
Transportation Corridor Identification
This section describes in more specific detail the process by which the two
transportation corridor options (Asikpak route for the northern corridor and
Kruz route for the southern corridor) were identified for inclusion in the
alternatives. This description is included because of the importance of the
location of the southern corridor which passes through Cape Krusenstern
National Monument, and because of a previous attempt to identify a trans-
portation corridor which would avoid the Monument.
Ill - 35
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Table 111-9
OPTIONS USED TO FORM ALTERNATIVES
Component
Mine Location
Tailings Pond Location
Mill Site Location
Worker Housing
Type
Location
Water Supply
Power Generation
Transportation
Corridor Location
System
Port Site
Location
Transfer Facility
Option(s)
Fixed
South Fork Red Dog Creek
South Fork Red Dog Creek
Campsite
South Fork Red Dog Creek
Bons Creek
Diesel
Northern
Southern
Road
Tugak Lagoon
VABM 28
Short Causeway/Lightering
Short Causeway/Offshore
Island
Suboption
Asikpak Route
Kruz Route
Year-round
During its ANILCA deliberations, Congress decided to exclude from National
Interest Lands status certain lands within a north/south corridor in the
Noatak Valley, located between the Noatak Preserve on the east and Cape
Krusenstern National Monument on the west. This corridor was proposed for
transportation purposes for the Red Dog prospect as well as for other
potential resource developments in the Western Brooks Range and the
National Petroleum Reserve. Thus, the possibility that the Red Dog project
southern transportation corridor would now traverse the Monument has raised
concern.
Ill - 36
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Noatak Corridor and Port Site
The scoping process initially identified three corridors, the northern, the
southern and the Noatak (Table 111-1). The Noatak route would follow the
ANILCA north/south corridor to the village of Noatak. It then would pro-
ceed downriver approximately 28.8 km (18 mi) to reach deeper water for
barge transport, or continue to an unidentified port somewhere on Hotham
Inlet or Kotzebue Sound (Fig. MI-2). Total corridor length would be about
110.4 km (69 mi). This corridor and port option was eliminated during the
initial options review because of significant potential problems with both the
route and the port (Table III-3).
The corridor would cross extensive lowland areas where the presence of
permafrost and wetlands present substantial geotechnical problems for road
or railroad construction. In addition, the many stream crossings required
would pose a significant threat to water quality and fisheries resources in
the Noatak River system. The Noatak is considered a major anadromous
stream (Selkregg, 1974) that supports important runs of Arctic char and
chum salmon, as well as numerous other migratory and non-migratory fish
species. In addition, the Noatak Valley provides important habitat to a wide
variety of raptors (including the endangered peregrine falcon and the
rough-legged hawk), waterfowl (including the whistling swan), small mammals
(including beaver, lynx and mink) and large mammals (including caribou,
moose and grizzly bear). Construction and operation of a transportation
system through this valley would significantly impact these biological
resources as well as disrupt critical subsistence activities.
In addition to major geotechnical problems and impacts to biological resources
and subsistence, another problem with the Noatak corridor involves the need
to barge concentrates down the river to a transshipment site in Hotham Inlet
or Kotzebue Sound. Travel time from a barge loading and unloading facility
on the Noatak River to a bulk carrier anchored in 10.7 m (35 ft) of water
would average about 20 hours. The barging season available for the 181 Mg
(200 ton) barges needed for concentrate transfer lasts from June to Septem-
ber, but low water on the Noatak or bad weather in Kotzebue Sound could
limit the barging season significantly. Because of this limited shipping
season, during the initial production phase of the mine approximately 30
barges and tugs would have to be in continuous operation to ensure the
transshipment of concentrates to the bulk carrier. The operating cost of
these 30 barges on the Noatak would increase the cost of the metal in excess
of 50 cents per pound. Even if the corridor were extended directly to some
point on Hotham Inlet or Kotzebue Sound (thereby eliminating the need for
barging on the Noatak River), a transfer facility and numerous barges would
still be needed to reach the transshipment point in deeper water, and
weather factors could still present a problem.
Of the remaining two transportation corridor options, the southern corridor
would cross the Monument while the northern corridor would completely avoid
the Monument. Because of the Title XI requirement that alternate routes not
crossing the Monument be fully considered in the EIS, a decision was made
that a northern corridor route would be retained and incorporated in an
alternative. This was done to ensure that full consideration and opportunity
for formal public review would be given to a non-Monument corridor by
lit - 37
-------
inclusion in the EIS. Thus, during the analysis of the suboptions for both
corridors, each corridor's routes were compared only among themselves
(i.e., the GCO route and the Asikpak route were compared only against each
other for the northern corridor, and the Western, Omikviorok and Kruz
routes were compared only among themselves for the southern corridor).
This guaranteed that a non-Monument corridor would be included in an
alternative, and that the environmentally and technically best routes for each
of the northern and southern corridors would be considered in the compari-
son of alternatives process.
Northern Corridor and Port Site
The results of the remaining options evaluation process for the northern
corridor routes, when the individual discipline screening criteria were
applied to both the GCO and Asikpak routes, are shown in Table III-6C, and
are summarized in Table 111-7. For those disciplines in which reasonable
difference existed between the two routes, the Asikpak route had lower
relative levels of potential impact for technical feasibility, cultural resources
and regional use, while the GCO route had a lower relative level of potential
impact for subsistence.
For those disciplines in which a reasonable difference existed between the
two northern corridor port sites, the remaining options evaluation process
(Tables III-6F and 111-7) showed that Tugak Lagoon had lower relative levels
of potential impact for fish and marine biology, while Singoalik Lagoon had
lower relative levels of potential impact for wildlife and subsistence.
Because the northern corridor routes went to separate port sites (Fig.
111-2), each route and its port site had to be considered in combination for
comparison with the other. Such a comparison of the Asikpak route/Tugak
Lagoon combination with the GCO route/Singoalik Lagoon combination did not
show great differences between them. However, on balance, the Asikpak
route/Tugak Lagoon combination had an overall lower potential for impacts,
and it was tentatively selected as the best combination for the northern
corridor.
The GCO route/Singoalik Lagoon combination was then reviewed against the
12 issues to see if it addressed one or more of the issues in a significantly
more favorable manner than did the Asikpak route/Tugak Lagoon combina-
tion. As it did not, the Asikpak route/Tugak Lagoon combination was
selected as the best one for the northern transportation corridor.
Southern Corridor and Port Site
The results of the remaining options evaluation process for the three
southern corridor routes are shown in Tables III-6D and III-7, with the
overall relative levels of potential impact shown in Table III-8. These tables
show the specific discipline by discipline analysis of impacts which resulted
in overall relative levels of potential impact of high for the Western route,
moderate for the Omikviorok route, and low for the Kruz route. Although
Table III-7 shows that the grouped levels of potential impact did not differ
greatly between the Western and Omikviorok routes, the grouped levels of
potential impact for the Kruz route were clearly lower than the other two.
Ill - 38
-------
For the VABM 17 and VABM 28 port sites, the results of the remaining
options evaluation process are shown in Tables III-6G and III-7, with the
overall relative levels of potential impact shown in Table III-8. As Table
III-7 shows, the grouped levels of potential impact for the VABM 28 port site
were significantly lower than those for the VABM 17 port site.
Two of the southern corridor options, the Western and Omikviorok routes,
could have used either VABM 17 or VABM 28 as a port site, while the Kruz
route could only use VABM 28 (Fig. III-2). To reduce the number of com-
binations of routes and port sites to be compared, it was decided that since
the VABM 28 port site clearly had the lowest overall relative level of poten-
tial impact (Table III-8), and since it was also common to all three routes, it
would be considered as the port site for comparison of all three southern
corridor routes.
With VABM 28 as the common port site, selection of the best southern cor-
ridor route was straightforward (Tables III-7 and III-8). As discussed
above, the Kruz route clearly had the lowest overall relative level of poten-
tial impact, and it was thus tentatively selected as the best southern corri-
dor route.
The Western and Omikviorok routes to VABM 28 were then reviewed against
the 12 issues to see if either addressed one or more of the 12 issues in a
significantly more favorable manner than did the Kruz route. This review
showed that both the Western and Omikviorok routes would have less impact
upon the Monument by being closer to its northwest boundary than the Kruz
route, with the Western route having the least impact. Even that route,
however, would traverse 27.2 km (17 mi) of the Monument.
While the lesser potential for impacts to the Monument from either the
Western or the Omikviorok routes was important, it was not considered to be
significantly so (as would a route along the northern corridor which would
completely avoid the Monument). Therefore, when the advantages of the
smaller potential for impacts to the Monument from either the Western or
Omikviorok routes were weighed against the significantly lower overall rela-
tive level of potential impact for the Kruz route (Tables III-7 and III-8), the
Kruz route to VABM 28 was selected as the best route for the southern cor-
ridor.
As a result of the analyses described above, two transportation options re-
mained; the Asikpak route to Tugak Lagoon for the northern corridor, and
the Kruz route to VABM 28 for the southern corridor. These two options
were then incorporated into the alternatives as described in the next section
(Identification and Description of Alternatives). Once incorporated into the
alternatives, selection of the final transportation corridor became part of the
overall process for selecting the preferred alternative. This was decided by
comparison of alternatives as described later in this chapter.
IDENTIFICATION AND DESCRIPTION OF ALTERNATIVES
The options screening process left only three components with more than one
option remaining. These were the transportation corridor and port site loca-
III - 39
-------
tions, which were dependent upon one another, and the transfer facility.
The identification of alternatives process was therefore relatively straight-
forward as there were only three combinations (and hence alternatives)
necessary to address the issues raised by those three components with more
than one option remaining (Fig. 111-3).
Alternative 1
This alternative would site the tailings pond in the South Fork of Red Dog
Creek with the mill in close proximity to the west (Fig. 11-3). A worker
camp would be located close to the mill. Power would be supplied by diesel
generators also sited near the mill. Water would come from a reservoir
on Bons Creek to the south of the tailings pond and airstrip. All these
facilities, as well as the mine, would be located on private land owned by
NANA.
Transportation would be by year-round road along the southern corridor to
a port site at VABM 28 (Fig. 11-6). The transfer facility would be the short
causeway/offshore island (Fig. 11-8).
Alternative 2
This alternative is the same as Alternative 1 for all components except the
transportation corridor and port site locations (Fig. III-3). It includes the
northern corridor to Tugak Lagoon (Fig. 11-6). A northern corridor and
port site were included in an alternative to specifically address Issue Number
10 - Impacts on Cape Krusenstern National Monument. Since Alternative 1
identified a southern corridor that crossed the Monument, the question of
gaining legal access through the Monument arose. The process for acquiring
such access was established by Title XI of ANILCA, and requires that
alternative routes be considered that would not cross the Monument. Thus,
although the northern corridor and Tugak Lagoon options might otherwise
have been eliminated earlier in the option screening process, both were
specifically retained and included in a separate alternative to ensure this
Title XI issue would be addressed during the formal draft EIS review.
Alternative 3
This alternative is the same as Alternative 1 except that the transfer facility
is the short causeway/lightering option instead of the short causeway/
offshore island option (Fig. 11-7).
No Action Alternative
The No Action Alternative is defined as meaning no development of the Red
Dog project would occur. This alternative may be used as a baseline to
which the other alternatives can be compared.
The No Action Alternative would result from denial of at least one, or
perhaps more, of the federal or state permits necessary for project develop-
ment. Or, it could mean that the project sponsor chose not to undertake
the project. However, under both federal and state law, a landowner or
lessee generally has a right to reasonable access across public lands to his
III - 40
-------
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land, and a right to develop that land in a manner consistent with applicable
law. The specific purpose of Section 1418 of ANILCA was to permit NANA to
select a known, valuable mineral prospect with the intention of developing it
for the benefit of its shareholders and other residents of northwest Alaska.
Therefore, it is understood that implementation of the No Action Alternative
might be in conflict with existing federal and state law. However, federal
regulations governing the content of EIS's require an analysis of the No
Action Alternative.
COMPARISON OF ALTERNATIVES
To compare the three action alternatives it was necessary to develop evalua-
tion criteria. Development of these criteria was based upon the twelve
issues identified during the scoping process (Chapter VII) and described in
Chapter I. Each of the twelve issues was considered appropriate as a cri-
terion for evaluation of the three action alternatives, however each was not
considered to be equally important. Throughout the alternatives evaluation
process, the most important criteria were water quality, fish and wildlife
populations and habitats, subsistence activities and the protection of Cape
Krusenstern National Monument values. The twelve evaluation criteria are
shown in the first column of Table 111-10.
To evaluate the alternatives, the evaluation criteria were applied separately
to each of the three alternatives to determine a relative value for the total
potential impacts for each alternative. It is important to note that the "rela-
tive total impact value" assigned to a given alternative was derived only by
evaluation of that alternative relative to the other two alternatives for each
criterion. The relative values used were low, moderate and high. For
example, using the first evaluation criterion, "Minimizing the risk of water
quality degradation", each alternative was analyzed from the standpoint of
its total potential risk of impact to water quality, and a relative total impact
value (compared to the other two alternatives) was assigned. For this
example, as shown in Table 111-10, Alternative 1 had a relatively low value
for total potential water quality impacts compared to Alternatives 2 and 3,
which had relative values of high and moderate, respectively. Table 111-10
is important as it summarizes, for each evaluation criterion and alternative,
the relative total impact values for all the disciplines. Thus, the evaluation
criteria and relative total impact values are devices which provide for con-
sistent comparison of alternatives.
It must be emphasized again that while a particular alternative might be
assigned a high relative total impact value when compared with the other two
alternatives, that did not necessarily mean that alternative would have a
high absolute impact; only that it was relatively higher than the other two
alternatives. In addition, because certain evaluation criteria were considered
more important than others, the importance of each relative impact value was
further weighted. For example, Alternative 1 was assigned a high relative
total impact value for impacts upon Cape Krusenstern National Monument
simply because of the visual impact of the ballasted tanker. But, although
this meant Alternative 1 would have a higher relative impact than the other
two alternatives, the absolute impact of that visual effect was not considered
significant. In this chapter, therefore, alternatives were assigned total
III - 42
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Table 111-10
EVALUATION CRITERIA MATRIX SHOWING RELATIVE TOTAL IMPACT
VALUES ASSIGNED TO THE THREE ACTION ALTERNATIVES
Evaluation Criteria
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
Minimize Risk of Water
Quality Degradation
Minimize Impacts to Fish
and Fish Habitat
Minimize Impacts to Wildlife
and Wildlife Habitat
Minimize Impacts to Coastal
Geologic Processes
Minimize Impacts to Marine
Life and Marine Habitat
Minimize Impacts to
Traditional Subsistence
Harvest Activities
Minimize Impacts to
Cultural Resources
Minimize Social, Cultural and
Economic Impacts upon
Residents of the Region
Maximize the Potential for
Other Regional Uses
Minimize Impacts on Cape
Krusenstern National
Monument
Minimize Technical Complexity
Minimize Costs
ALTERNATIVE 1
Southern Corridor
VABM 28 Port Site
Offshore Island Fac.
Low Risk
Low Impact
Low Impact
Low Impact
Low Impact
Low Impact
Low Impact
These impacts would
High Potential
High Impact
Moderate Complexity
Low Cost
ALTERNATIVE 2
Northern Corridor
Tugak Lagoon P. S.
Offshore Island Fac.
High Risk
High Impact
High Impact
Low Impact
Low Impact
High Impact
Low Impact
be similar for all three
High Potential
Low Impact
High Complexity
High Cost
ALTERNATIVE 3
Southern Corridor
VABM 28 Port Site
Lightering Facility
Moderate Risk
Moderate Impact
Low Impact
Low Impact
Moderate Impact
Moderate Impact
Low Impact
alternatives.
Moderate Potential
Moderate Impact
Moderate Complexity
Moderate Cost
See text explanation on preceding page.
-------
impact values relative to one another, while the actual significance of the
alternatives' impacts were described under Environmental Consequences
(Chapter V).
Following is a discussion, on an individual evaluation criterion basis, which
describes the reasoning behind the assignment of relative total impact values
to the three action alternatives. In most cases the discussion focuses on the
three components which differ among the alternatives, that is: the road
corridor location (southern versus northern); the port site location (VABM
28 versus Tugak Lagoon); and the transfer facility (short causeway/
lightering versus short causeway/offshore island). If one of these compon-
ents is not mentioned for a particular evaluation criterion, it is because
there were no significant differences among the alternatives. This discus-
sion also considers the mitigation, monitoring and reclamation measures
described under Environmental Consequences (Chapter V).
Water Quality
Potential water quality impacts were evaluated primarily on the bases of the
number, size and difficulty of stream crossings as they would relate to sedi-
mentation and spill risks (for the northern and southern road corridors);
and on the number of concentrate and fuel transfers as they would relate to
spill risk (for the lightering and offshore island transfer facilities).
Because the northern road corridor in Alternative 2 would have six major
multi-span bridges compared to one on the southern corridor in Alternatives
1 and 3, there would be a much greater opportunity for increased sedimenta-
tion and spills. For the transfer facilities, the greater number of transfers
required in Alternative 3 between unstable (i.e. floating) platforms, and the
necessity for the lighters to work in more marginal weather to load moored
ships, were considered to have a higher risk for potential spillage than
would operations at the offshore island facility in Alternatives 1 and 2.
Of the two higher potential risks, i.e., the northern corridor stream cross-
ings and the lightering transfer facility, the environmental risks associated
with the many stream crossings were considered greater. A spill or serious
sedimentation problem in the ocean would much more likely be dispersed
quickly over a much larger area; such a serious problem on a major stream
could have impacts of far greater environmental magnitude, particularly if it
occurred during the low flow period in winter or during a major fish use
period.
Thus, Alternative 1 (with the southern corridor and the offshore island
transfer facility) was assigned a low relative total impact value for water
quality. Alternative 3, similar to Alternative 1 but with the lightering
transfer facility, was assigned a moderate relative total impact value.
Alternative 2, with the northern corridor, was assigned a high relative total
impact value.
Fish
Potential impacts to fish and fish habitat were evaluated primarily on the
bases of the number of stream crossings and possible borrow site locations at
III - 44
-------
or near important spawning, rearing, overwintering or fish migration areas
(for the road corridors), and on the number of concentrate and fuel trans-
fers as they would relate to spill risk (for the transfer facilities).
The northern road corridor in Alternative 2, with 12 crossings of streams
important to fish compared to 11 on the southern corridor in Alternatives 1
and 3, was considered to have significantly higher risks for potential sedi-
mentation impacts on spawning areas, blockage of fish movements, and con-
centrate, fuel and reagent spills. For the marine transfer facilities, the
greater number of transfers required between unstable platforms and the
necessity for the lighters to work in more marginal weather to load moored
ships in Alternative 3 were considered to have a higher risk for potential
spillage and subsequent effects upon fish than would offshore island opera-
tions.
Of the two major potential risks, i.e., the northern corridor crossings of
important fish streams and the lightering transfer facility, the risks to fish
and fish habitat associated with the many fish stream crossings were con-
sidered greater. A serious sedimentation problem or major spill in the ocean
would be more likely dispersed quickly over a much larger area, while such
a serious problem on a major fish stream could have impacts of far greater
magnitude on fish, particularly if it occurred during the low flow period in
winter when fish would be restricted to relatively few deep holes under the
ice.
Thus, Alternative 1 with the southern road corridor and the offshore island
transfer facility was assigned a low relative total impact value for fish.
Alternative 3, similar to Alternative 1 but with the lightering transfer facil-
ity, was assigned a moderate relative total impact value. And Alternative 2,
with the northern route corridor, was assigned a high relative total impact
value.
Wildlife
Potential impacts upon wildlife were evaluated primarily on the bases of in-
direct habitat loss due to noise, other disturbance or human contacts, and
effects on animal movements for the road corridors, port site locations and
the transfer facilities.
The northern road corridor in Alternative 2, which crosses directly through
the currently used primary caribou winter range in the Wulik and Kivalina
drainages, was considered to pose a higher risk of indirect habitat loss than
would the southern corridor road in Alternatives 1 and 3, which would be
within, but near the eastern edge of that currently used winter range.
Also, the northern corridor would be more likely to affect the major spring,
post-calving and fall caribou migrations than would the southern corridor.
For the port site, the Tugak Lagoon location in Alternative 2 would likely
affect movements of bears and muskoxen to a greater extent than would the
VABM 28 location in Alternatives 1 and 3 because it would be located in a
much narrower and more restricted area between the coast and the first
hills.
Ill - 45
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For the transfer facility, the offshore island in Alternatives 1 and 2 would
likely have marginally greater indirect habitat loss and migration effects
upon marine mammals than the lightering facility in Alternative 3.
Of the three higher potential risks, i.e., the northern corridor caribou
winter range and movement impacts, the Tugak Lagoon bear and muskoxen
movement impacts, and the offshore island effects upon marine mammals, the
first two are found in Alternative 2 while the third is common to Alternatives
1 and 2. The combined potential risks to wildlife associated with the north-
ern corridor and Tugak Lagoon port site locations were considered to be
significantly greater than those associated with the southern corridor and
offshore island. Thus, Alternatives 1 and 3 were assigned low relative total
impact values for wildlife while Alternative 2 was assigned a high relative
total impact value.
Coastal Geologic Processes
Potential coastal geologic processes impacts were evaluated on the bases of
net sediment transport, facility erosion and lagoon breaching for the port
site locations and the transfer facilities.
For both the VABM 28 port site in Alternatives 1 and 3 and the Tugak
Lagoon port site in Alternative 2, the potential effects on sediment transport
and erosion were considered similar. Lagoon breaching would take place at
either port site and the effects were considered similar.
For the transfer facility, it was considered that the presence of the ballasted
tanker in Alternatives 1 and 2, or its absence in Alternative 3, would be
insignificant to net sediment transport, erosion or lagoon breaching at either
of the port sites.
For the port site locations and the transfer facilities, therefore, no major
difference existed between the three alternatives. All were considered to
have a low relative total impact for coastal geologic processes.
Marine Biology
Potential marine biology impacts were evaluated primarily on the bases of the
quality and quantity of benthic habitat disturbed, disruption of sedimentation
and organism movement patterns, lagoon breaching and spill hazards for both
the port site location and transfer facility.
Differences among the three alternatives were considered to be negligible
with respect to disruption of sedimentation and organism movement patterns.
The VABM 28 port site location in Alternatives 1 and 3 was considered to
have a lesser density and diversity of benthic organisms than the Tugak
Lagoon port site. The offshore island transfer facility in Alternatives 1 and
2 was considered to have a greater net loss of benthic habitat (due to the
ballasted ship) than the lightering facility in Alternative 3. However, the
offshore island facility was considered to have a lower risk for concentrate
and fuel spills than the lightering facility.
Ill - 46
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The differences in potential impacts between port site locations were not
considered significant. For the transfer facility, the greater loss of benthic
habitat from the offshore island in Alternatives 1 and 2 was considered
insignificant compared to the greater risk of spills from the lightering
facility. Thus, both Alternatives 1 and 2, with the offshore island transfer
facility, were assigned a low relative total impact value for marine biology
while Alternative 3, with the lightering transfer facility, was assigned a
moderate relative total impact value.
Subsistence
Potential subsistence impacts were evaluated primarily on the bases of inter-
ference with traditional harvest activities and increased nonresident harvest
of fish and wildlife resources for the road corridors, port sites and transfer
facilities.
The southern road corridor in Alternatives 1 and 3 was considered to have a
much lower risk of interference with traditional harvest activities; it would
parallel the primary winter caribou range in the Kivalina and Wulik drainages
rather than cut across it as would the northern corridor in Alternative 2.
Also, the southern corridor would cross fewer fish streams important for
subsistence use than would the northern corridor. The southern corridor
would also provide less access to prime subsistence harvest areas for non-
residents who might compete with local residents for the same fish and wild-
life resources.
The VABM 28 port site in Alternatives 1 and 3 would likely have a mar-
ginally greater impact upon marine mammal hunting than the Tugak Lagoon
port site in Alternative 2.
The offshore island transfer facility in Alternatives 1 and 2 was considered
to have a lower risk of concentrate and fuel spills than the lightering facility
in Alternative 3, although the offshore island might cause some additional
sound or activity disturbance during the spring marine mammal subsistence
hunting period.
While the difference between the VABM 28 port site in Alternatives 1 and 3
and the Tugak Lagoon site in Alternative 2 was considered insignificant, the
risk of potential impacts to subsistence harvests by the northern road cor-
ridor in Alternative 2 compared to the southern road corridor in Alternatives
1 and 3 was considered significant. And, for the transfer facility, the
lightering facility in Alternative 3 was considered to have the greater risk of
potential impact because of the higher spill hazard compared to the offshore
island in Alternatives 1 and 2.
Thus, Alternative 1, with the southern corridor and offshore island facility,
was assigned a low relative total impact value for subsistence. Alternative
2, with the northern corridor and the offshore island transfer facility, was
assigned a high relative total impact value. Alternative 3, with the southern
corridor and lightering facility, was assigned a moderate value.
Ill - 47
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Cultural Resources
Potential cultural resources impacts were calculated primarily on the bases of
the number of sites which would likely be impacted and whether they are
within Cape Krusenstern National Monument or the Cape Krusenstern
Archeological District; whether primary impacts could be avoided by reason-
able corridor, port site or transfer facility relocation; and whether protec-
tive measures could be taken to avoid secondary impacts.
All sites would be avoided if reasonably possible during road and port facil-
ities design and construction; SHPO- and ACHP-approved recovery opera-
tions would be used to preserve site data and material that could not be
reasonably preserved in place; and approved measures would be used to
protect sites near the corridor and port facilities from secondary impacts.
The southern road corridor in Alternatives 1 and 3 includes 13 cultural
sites, seven of which are within the Cape Krusenstern Archeological District
(six of these being within the Cape Krusenstern National Monument). There
are 23 cultural sites within the northern road corridor identified by recon-
naissance survey. Sites along the northern corridor road have not been
evaluated against National Register of Historic Places Criteria for Evaluation
(36 CFR 60.4).
The VABM 28 port site in Alternatives 1 and 3 contains a historical site that
appears to meet National Register criteria, while the Tugak Lagoon port site
in Alternative 2 has only a small eroding sod cabin that might meet National
Register of Historic Places criteria for eligibility.
The offshore island and lightering transfer facilities for all three alternatives
would have no impacts on known cultural resources.
No significant difference in potential impacts was determined among the
three alternatives and they were each assigned a low relative total impact
value.
Social, Cultural and Economic Impacts
Potential social, cultural and economic impacts of the Red Dog project would
occur largely from development of the project as a whole and would not
depend on selection of any particular alternative. Such impacts would there-
fore not be significantly altered by selection of any one of the three action
alternatives and are not discussed further here. The social, cultural and
economic impacts of the project are discussed in Chapter V.
Regional Use
Potential impacts to regional use by development of the road corridors, port
sites and the transfer facilities were evaluated primarily on the bases of
their size and location, adaptability for other potential users, and whether
any other uses would be precluded. As described under Regional Use in
Chapter V, a guarantee of reasonable access and use by other industrial
resource users was considered assured for the following analysis.
Ill - 48
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The offshore island transfer facility in Alternatives 1 and 2 was considered
to be more flexible for other users than the lightering facility in Alternative
3. The size and location of the port site and transfer facilities in all three
alternatives were considered to be adequate for any needed expansion. No
preclusion of any other uses was identified for any of the alternatives.
Since this would be the first major development in this area of Alaska, it is
not possible to accurately assess the best route location from the standpoint
of other potential users. GCO's Lik prospect, which would likely be one of
the earlier users of any transportation system developed for the Red Dog
project, would be closer to the northern corridor. However, this route
would be correspondingly further from Red Dog which is now actively being
developed. The Lik prospect would be reasonably accessible from either
corridor location.
In assigning relative total impact values, Alternatives 1 and 2 with the off-
shore island facility were assigned high values for regional use potential,
while Alternative 3 with the lightering facility was assigned a moderate value
for regional use potential.
Cape Krusenstern National Monument
Potential impacts on Cape Krusenstern National Monument were evaluated
among the alternatives primarily on the bases of impacts on cultural re-
sources, littoral sediment transport effects upon the Cape Krusenstern beach
ridges, increased access to the Monument and the visual impact of the marine
transfer facility. Since Alternative 2 with the northern corridor and Tugak
Lagoon port site would not impact Cape Krusenstern National Monument, it
was not considered further in this analysis and was assigned a low relative
impact value for potential Monument impacts. Also, since potential impacts
from the southern corridor road and the VABM 28 port site location would be
identical for Alternatives 1 and 3, these impacts were not considered in
differentiating between these alternatives. Therefore, for Alternatives 1 and
3, only the type of transfer facility differed.
Neither the offshore island nor the lightering facility was considered to have
a significant potential for impact upon the Monument from the standpoint of
interference with littoral sediment transport, nor would either facility signif-
icantly affect access to the Monument more than the other. The offshore
island facility, however, with the large tanker ballasted on the seabed was
considered to have a higher visual impact compared to the lightering facility.
Thus, Alternative 1 with the offshore island facility was assigned a high
relative total impact value while Alternative 3 with the lightering facility was
assigned a moderate value.
Technical Complexity
Potential technical complexity impacts were evaluated primarily on the basis
of the relative complexity of the design, construction and operation of the
road, port site and transfer facilities.
The southern corridor road in Alternatives 1 and 3 would have one major
multi-span bridge over 30.5 m (100 ft) in length and four single-span
III - 49
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bridges under 30.5 m in length, and 19 percent of its alignment would
traverse soil, slope, permafrost and other conditions in which construction
would be considered moderately difficult or difficult. The northern corridor
road in Alternative 2 would have six major multi-span bridges and seven
single-span bridges, and 41 percent of its alignment would traverse condi-
tions in which construction would be considered moderately difficult or diffi-
cult. For these reasons, the southern corridor road was considered to have
significantly less technical complexity than the northern corridor road.
The VABM 28 and Tugak Lagoon port sites both had suitable soils and both
sites were considered to be of equivalent complexity.
The offshore island transfer facility in Alternatives 1 and 2, with a self-
propelled lighter, more conveyors, a buried fuel pipeline and possible winter
ice scour problems was considered to be of approximately equally high
technical complexity to the lightering facility in Alternative 3 with tug-
assisted barges, clam shovel concentrate transfers between two unstable
platforms, and fuel lightering to shore.
Alternative 2, therefore, with the technically more complex northern corridor
road and high complexity offshore island transfer facility was assigned a
high relative total impact value for technical complexity. Alternatives 1 and
3 with the less complex southern corridor road and high complexity offshore
island facility were assigned moderate relative total impact values.
Cost
The estimated capital cost for the southern road corridor in Alternatives 1
and 3 would be approximately $74.7 M (Table V-16), while the cost for the
northern road corridor in Alternative 2 would be approximately $125.7 M, or
a difference of $51 M. The estimated annual operating costs would be
approximately $2.6 M and $3.3 M, respectively, or a difference of $0.7 M.
The estimated capital cost for the offshore island marine transfer facility in
Alternatives 1 and 2 would be approximately $54.7 M, while the cost for the
lightering facility in Alternative 3 would be approximately $74.0 M, or a
difference of $19.3 M. The estimated annual operating costs would be
approximately $1.6 M and $3.0 M, respectively, or a difference of $1.4 M.
On the basis of these estimates, the lightering facility would be significantly
more costly than the offshore island facility both to construct and maintain.
Alternative 1, with the southern corridor and offshore island facility, would
be significantly less expensive than Alternative 2, with the northern corridor
and offshore island. Costs associated with Alternative 3, with the southern
corridor and lightering facility, would be intermediate between Alternatives 1
and 2.
IDENTIFICATION OF PREFERRED ALTERNATIVE
As described above, the alternative evaluation process assigned relative total
impact values to each of the three action alternatives as shown in Table
111-10. While the individual evaluation criteria were not considered equally
III - 50
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important, a broad review of Table 111-10 showed that, from the standpoint
of best addressing the 12 evaluation criteria, Alternative 1 rated equal to or
better than Alternatives 2 and 3 for nine of the 11 criteria for which com-
parison was possible. Alternative 2 rated equal to or better than Alterna-
tives 1 and 3 for five of the 11 criteria, and Alternative 3 rated equal to or
better than Alternatives 1 and 2 for three of the 11 criteria.
On a more specific basis, the alternatives were compared to each other.
Because they differed only for the marine transfer facility, Alternatives 1
and 3 were compared first. Alternative 1 showed a greater potential impact
for only one of the evaluation criteria, while Alternative 3 showed greater
potential impacts for six of the criteria. Alternative 1 showed greater
potential impacts to Cape Krusenstern National Monument based upon the
visual impact of the ballasted tanker at the VABM 28 port site.
Conversely, Alternative 3 showed greater potential for impacts on water
quality, fish, marine life, subsistence, regional use and cost. The first
four were based upon similar and important concerns for the increased risks
associated with the lightering facility. The lesser flexibility of the Alterna-
tive 3 lightering facility for regional use was not considered a significant
difference. For the sixth criterion, cost, Alternative 3 was significantly
greater.
In comparing Alternatives 1 and 3, therefore, the major differences were
that Alternative 1 would have a higher visual impact upon the Monument,
while Alternative 3 would have higher potential for impacts to water quality,
fish, marine life and subsistence from higher spill risks, and significantly
greater costs.
Alternative 1 was then compared to Alternative 2. Alternative 1 showed a
greater potential impact for only one of the evaluation criteria, while
Alternative 2 showed greater potential impacts for six of the criteria.
Alternative 1 showed a clear, and substantial, greater potential impact to
Cape Krusenstern National Monument since Alternative 2 would have virtually
no direct impact upon the Monument.
Conversely, Alternative 2 showed greater potential impacts for water quality,
fish, wildlife, subsistence, technical complexity and cost. While the tech-
nical complexity criterion could be considered as a relatively insignificant
difference between the two alternatives, the other five were considered
significant.
In comparing Alternatives 1 and 2, therefore, the major differences were
that Alternative 1 would have a substantially higher potential impact upon
the Monument, while Alternative 2 would have higher potential for impacts to
water quality, fish, wildlife, and subsistence, and significantly greater
costs.
Thus, in comparison among the alternatives, Alternative 1 showed sub-
stantially fewer potential impacts for the evaluation criteria. However,
Alternative 1 showed higher potential impacts to the Monument, substantially
so when compared to Alternative 2.
Ill - 51
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Alternative 1 has been identified by the co-lead agencies as the preferred
alternative. The Corps has not identified a preferred alternative and will
not until the Record of Decision.
Ill - 52
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Chapter IV
Affected Environment
-------
IV. AFFECTED ENVIRONMENT
INTRODUCTION
This chapter describes the existing environment without the project, empha-
sizing those environmental aspects of the Red Dog project area* that may be
affected by the construction and operation of the proposed mining facility.
Baseline environmental investigations were initiated in the early summer of
1981, and data collection has continued through the summer of 1983.
Environmental field studies, literature surveys and mapping have been docu-
mented. Much of this information is included as appendices to this docu-
ment, or is on file at those sites identified in the Summary Sheet.
HISTORY
Traditionally much of northwest Alaska is used extensively by residents for
their subsistence livelihoods. Following the purchase of Alaska from Russia
in 1867, the aboriginal land claims of Alaska Natives, including northwest
Natives, were formally recognized. As early as the federal Organic Act of
1884 it was stated (in Section 8) that:
...The Indians or other persons in said district shall not be dis-
turbed in the possession of any lands actually in their use or
occupation or now claimed by them but the terms under which such
persons may acquire title to such lands is reserved for future
legislation by Congress...
The current status of lands in northwest Alaska bears the imprint of three
major federal land laws: the Alaska Statehood Act of 1958, the Alaska
Native Claims Settlement Act of 1971 (ANCSA) and the Alaska National
Interest Lands Conservation Act of 1980 (ANILCA). As these laws are still
in the process of being implemented, land ownership and management status
are only partly settled; much remains to be resolved as implementation con-
tinues.
Pending resolution of the Native land claims question, virtually all land in
the region remained in the federal public domain, managed by the federal
Bureau of Land Management (BLM), until the Alaska Statehood Act author-
ized the State of Alaska to select federal lands as part of its statehood
entitlement. However, the land claims of Alaska Natives remained unresolved
until ANCSA's passage in 1971.
* Defined in Glossary.
IV - 1
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ANCSA set out terms for resolving Native land claims as part of the complex
package of land legislation that also addressed ownership and management of
state and federal lands in Alaska. In simplest terms, ANCSA appropriated
funds and land entitlements to compensate Alaska Natives in exchange for
extinguishment of their unresolved aboriginal land claims. These benefits
were distributed through and administered by a two-tiered structure of pri-
vate village and regional corporations established pursuant to ANCSA.
Based on population, traditional Native villages received a share of funds
and selection rights to the surface estate of lands at or near their traditional
settlement sites. Similarly, regional corporations received funds and full fee
land selection rights, plus subsurface estate rights to village land selections
within their regions.
The NANA Regional Corporation for northwest Alaska is one of 12 in-state
regional corporations established under ANCSA. Originally, there were also
11 village corporations set up in the region. Both the NANA Regional Cor-
poration and the village corporations of Kivalina and Noatak had land selec-
tion rights within the Red Dog project area. Subsequently, all of the NANA
region's village corporations except Kotzebue merged with the regional cor-
poration, pooling land assets and land management functions.
ANILCA amended some terms of ANCSA, including giving NANA the right to
select the Red Dog prospect. Also of significant importance to the project,
ANILCA established the Cape Krusenstern National Monument under manage-
ment of the National Park Service to, among other purposes, protect and
interpret the archeologic sites and other evidence of prehistoric and historic
Native cultures, and to protect the viability and use of subsistence resources.
LAND STATUS
The Red Dog project area (Figure III-2), encompassing the mine, mill, hous-
ing and tailings pond sites, and the transportation corridor and port site op-
tions, falls within the northwestern corner of the NANA Regional Corpora-
tion's boundaries. Overall, the project area includes only a small portion
(about 650,000 ha [1.6 million ac] or less than five percent) of the land and
waters encompassed by the NANA region. Nearly all of the project area is
within the so-called unorganized borough. That is, it is outside any incor-
porated city or borough governmental jurisdiction. Only the mine site and a
thin strip immediately to the south fall within the North Slope Borough.
Recognizing that land status within the project study area is fluid pending
exercise of outstanding selection rights and resolution of overlapping Native
and state selections, current land ownership and management status of the
project study area's 650,000 ha (1.6 million ac) can be summarized very
approximately as follows (Fig. IV-1): State of Alaska selected, tentatively
approved or patented lands, some of which are overlapped by and may be
superceded by Native selections, comprise about 50 percent; federal lands,
chiefly Cape Krusenstern National Monument (about 85,000 ha [210,000 ac])
and other federal (d-l) lands (about 89,000 ha [220,000 ac]), amount to
about 29 percent; Kivalina and Noatak village selections cover about 65,000
ha (160,000 ac) or 10 percent of the project area; most of the rest consists
of regional corporation selections and overselections, part of which may ulti-
mately revert to the federal or state governments.
IV - 2
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.fimimiHiimiiiuimi
FIGURE IV-1 LAND
STATUS IN PROJECT AREAV
-------
Although much of the Native land within the project area was selected by
the villages of Kivalina and Noatak following the merger of NANA Regional
Corporation with its villages, all land title issued has been in NANA's name.
Lands selected from within Cape Krusenstern National Monument and trans-
ferred to NANA, even though owned by NANA in fee title, would remain
within the boundaries of the Monument unless those boundaries were changed
by Congress. However, such lands would not be subject to the regulations
applicable solely to the public lands within the Monument.
The mine, tailings pond, mill, power plant, worker housing and water reser-
voir would all be located within a 8,975 ha (22,176 ac) parcel of private land
in Red Dog Valley. The port site would also be on private land if located at
VABM 28, and probably on private land if located at Tugak Lagoon since
NANA could still select that area. The transportation corridor would be
almost totally on public land.
AFFECTED ENVIRONMENT
Geology, Physiography and Soils
Geology
The Red Dog mine site is located approximately 89 km (55 mi) from the
Chukchi Sea, east-northeast of Kivalina and 132 km (82 mi) north of Kotze-
bue. Local topography consists of moderately sloping hills with elevations
ranging from 243 to 455 m (800 to 1500 ft). The ore deposit lies at the
western base of Deadlock Mountain (elevation 913 m [2,995 ft]), and is sur-
rounded to the north and east by the rugged ridges of the De Long Moun-
tains. To the west and southwest, the foothills of the De Long Mountains
drop off to gently sloping coastal uplands. The coastal region consists of a
series of closed and open coastal lagoons separated from the Chukchi Sea by
narrow barrier beaches or islands.
The De Long Mountains are generally underlain by folded and faulted thrust
sheets of sedimentary rocks which are intruded by mafic* and ultramafic
rocks (containing large percentages of dark-colored minerals). Bedrock in
these mountains consists principally of limestone, sandstone, shale, chert
and mafic igneous* rocks (Selkregg, 1974).
The geology of the eastern portion of the project area, including the mine
site, generally consists of bedrock deposits of Mississippian conglomerate
that contain shale and limestone with subordinate shale, chert and dolomite.
Bedrock igneous complexes of mafic volcanic and intrusive rocks are also
present.
Coastal upland regions further west in the project area generally consist of
unconsolidated deposits of glacial moraine*, as well as glaciofluvial or out-
wash deposits associated with glaciers or bordering older moraines. Glacial
moraines are fairly regular, low, linear hills which are formed at the edge of
* Defined in Glossary.
IV - 4
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glaciers. Moraines generally consist of a complex mixture of unsorted gra-
vel, sand, silt and clay.
In addition to unconsolidated deposits, the upland regions located between
the Kivalina and Wulik Rivers, and between the Singoalik and Kivalina
Rivers, also contain areas of bedrock outcroppings. These consist of ultra-
mafic intrusives; igneous complexes of mafic volcanic and intrusive rocks;
and Precambrian- to Devonian-aged rocks consisting of limestone, dolomite,
chert and phyllite (Selkregg, 1974).
The coastal region in the project area consists of unconsolidated deposits of
older, interlayered alluvium* and marine sediments. These formations were
laid down in shallow, nearshore shelf environments where frequent sea level
changes alternately exposed and submerged portions of the gently sloping
terrain. Deposits consist of alternating lenses and mixtures of gravel, sand,
silt and clay. More modern coastal beaches, spits, bars and deltas are also
present in the region.
Seismology
According to Corps classification, the project area falls within Seismic* Risk
Zone 2. This designation applies to areas that could be affected by earth-
quakes with maximum magnitudes of 4.5 to 6.0 on the Richter scale. The
only seismic activity reported in northwestern Alaska between 1955 and 1964
occurred in the Chukchi Sea. It is believed that seismic shocks occur in-
land, but equipment is not available in the area to record such events
(Selkregg, 1974).
Physiography
The project area is characterized by moderately sloping hills, broad stream
valleys and coastal lowland lagoon systems. The entire area is underlain by
permafrost. Gentle, poorly defined surface undulations are caused by pat-
terned ground, old drainage channels, thaw lakes, and other depositional,
erosional or permafrost related features (Fig. IV-2).
Polygonal or patterned ground is a conspicuous surface feature, especially
near the coast. Temperature-induced contraction cracks are formed in poly-
gonal patterns similar to those encountered on dry mud flats. These cracks
fill with water and freeze. Continued cracking, filling and freezing along
the same lines eventually form a network of ice wedges that sometimes be-
come several meters deep and are generally spaced tens of meters apart. In
time the ice wedges form troughs bounded by ice push ridges. Troughs,
ridges and undisturbed central areas are referred to as ice-wedge polygons
(Selkregg, 1974).
Thaw lakes are also important features in the area. These usually originate
from small, shallow ponds that generally begin in low-centered polygons or
at the intersection of ice wedges (Sellmann et al., 1975). Other nearby
ponds expand and coalesce to form larger ponds and lakes. During the
summer period, the underlying permafrost is thawed, which allows deepening
* Defined in Glossary.
IV - 5
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H-
DEADLOCK
MJN
LAGOON
PORT SITE
-o
Q TUGAK LAGOON
O
33
PORT SITE
KAVRORAK LAGOON
KIVALINA
LAGOON
LEGEND
VABM 17
PORT SITE
IPIAVIK
LAGOON
VABM 28
PORT SITE
I POSSIBLE CONNECTION
TO GCO'S LIK PROSPECT
MONUMENT BOUNDARY
TRANSPORTATION CORRIDOR
ORGANIC SOILS
FLOODPLAIN
PATTERNED GROUND
AUFEIS ZONE
KRUEENSTERN
-------
and enlarging of the small lake. As the lake expands, it joins with others
and becomes deep enough to maintain a thaw bulb*. Because thaw lakes are
largely unstable with active erosion at basin margins, lake basins often
coalesce and drain. The thaw lake cycle consists of repetitive stages of lake
formation and ultimate drainage, and is the primary geomorphic process that
modifies the land surface. Nested and overlapped drained basins contribute
most to characteristic topography formation, and drainage and wetland distri-
bution.
Among other important surface features in the area are pingos. These are
small, conical hills which have a central core of ice. Closed-system pingos
develop when tundra thaw lakes drain and permafrost encroaches from the
sides. As sediments near the center slowly freeze, massive segregation of
ice develops. Volume increases as freezing occurs and pushes the tundra
and ice upward, forming a large, ice-cored mound or pingo. As the pingo
expands upward a summit crack or fissure often opens, exposing the ice
core and allowing part of it to melt and a small lake to form in the crater.
Closed-system pingos are characteristic of the continuous permafrost zone
(Selkregg, 1974).
Floodplains
The floodplains of the Kivalina and Wulik Rivers consist of unconsolidated
deposits of alluvial material (Fig. IV-2). Alluvial deposits represent rock
materials that are picked up and carried along in streams and rivers. As
materials move downstream, they are gradually broken, abraded, rounded,
and eventually deposited as stream velocity decreases. Older alluvial
deposits that formed in coastal plains during the Pleistocene Epoch are often
interfingered with marine sediments that were deposited during that time.
Seasonal hydrologic variations, though not documented for the Wulik and
Kivalina Rivers, are likely to be similar to those of the Noatak River basin
as reported by Childers and Kernodle (1981). Both rivers begin to freeze
over in October and exhibit annual low flows from January through April.
Annual peak flows occur in May or June as a result of snowmelt during
spring breakup. Both rivers exhibit rapid response to precipitation events
as a result of shallow permafrost depths and correspondingly small ground-
water storage capacity.
Channel geometry surveys (Childers et al., 1979) were conducted near the
Wulik and Kivalina River mouths in order to determine the two-year and 50-
year flood discharges. This study computed the two-year and 50-year flood
flows to be 476 and 1,232 m3/s (17,000 and 44,000 ft3/s), respectively, for
the Wulik River, and 336 and 924 m3/s (12,000 and 33,000 ft3/s), respec-
tively, for the Kivalina River.
Areas of thick ice cover occur within the Wulik and Kivalina River drainages
as a result of aufeis* formation (Fig. IV-2). Aufeis occurs due to confine-
ment of surface and groundwater flows as ice and frost formations penetrate
deeper through winter. If confinement pressures become sufficient, the ice
cover is fractured and pressure ridges are formed as the escaping water is
frozen in thin surface sheets.
* Defined in Glossary.
IV - 7
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Soils
Soils vary considerably in the project area depending on location and vegeta-
tion cover. The seasonal thaw or active layer also varies throughout the
area. It generally ranges from 50 to 100 cm (20 to 39 in) deep in vegetated
areas and may range up to 3 m (10 ft) deep on exposed, rocky hillsides. In
general, the slopes of rolling hills have mineral, silty soils with some sphag-
num peat. River terraces are characterized by sandy, silty soil overlying
cobbles. Upland drainage channels have sphagnum peat and mineral soil
types, while moraine knolls have mineral, rocky soils. Lake basins are gen-
erally characterized by mineral, organic, silty soils (Fig. IV-2).
Permafrost
Permafrost is not a material; it is the temperature state of a material and is
usually defined as any area which remains below 0°C for a period of two or
more years. Rock or gravel can be permafrost, and its thawing will not
usually cause settlement. However, ice can be permafrost (such as an ice
lens in the ground or even a glacier) and its thawing would very much
affect the surrounding environment. The temperature of soil can be well
below 0°C and be officially classified as permafrost, but it may not be hard
frozen and may be structurally similar to unfrozen ground. This is caused
by saline pore water and is a common occurrence along the western and
northern coasts of Alaska. This soil may not be hard frozen until its tem-
perature is lowered several degrees below 0°C.
Although the entire Red Dog project area is underlain by permafrost, the
vertical extent of the permafrost and its properties at depth are not well de-
fined at this time. Permanent thaw bulbs are present under the beds of
major waterways such as the Wulik and Kivalina Rivers and Ikalukrok Creek.
Mineral Resources
Weathering sulfide minerals have been reported in a 259 km2 (100 mi2) area
in the northwestern Brooks Range. The most significant area of mineraliza-
tion within this region is the Red Dog prospect (Tailleur, 1970; Jansons and
Bottge, 1977). Outcroppings containing high concentrations of lead, zinc,
silver and barite are present at this mine site, and the subsurface ore body
is thought to contain 77 million Mg (85 million tons) of high grade ore (17.1
percent zinc, 5.6 percent lead, 75.0 g/Mg [2.4 oz/ton] silver). There are
indications that these minerals may extend at shallow depths throughout
much of the northwestern Brooks Range region (WGM, Inc., 1978). Other
minerals reported in the De Long Mountains region, but outside the project
area include: copper, chromium, nickel and chrysotile serpentine (asbestos).
Nonmetallic mineral resources in the project area consist of deposits of sand
and gravel along the Kivalina and Wulik Rivers and at the coast (Selkregg,
1974).
Vegetation and Wetlands
Using the classification system of Viereck et al. (1981), 13 vegetation types
were described for the project area (Dames & Moore, 1982a). Vegetation
IV - 8
-------
types at the mine site, along the transportation corridors and at the alter-
nate port sites range from xerophytic*, upland mat and cushion tundra to
wet, lowland sedge-grass marsh. Vegetation consists primarily of cotton-
grass tussock tundra, low shrublands and herbaceous meadows, in order of
relative abundance. Complexes of up to three vegetation types are also
common throughout the project area (Dames & Moore, I982a).
Vegetation Type Descriptions
Shrubland
Both closed and open tall shrub vegetation types (greater than 1.5 m [5 ft]
tall) occur in the study area. Closed (more than 75 percent foliar cover)
tall shrub communities occur in relatively few locations, primarily as riparian
or snowbank vegetation along streams. Grayleaf willow (Salix glauca) domin-
ates this vegetation type, which usually contains an understory of sweet
coltsfoot (Petasites frigidus) and moss. Open (25 to 75 percent foliar cover)
tall shrub communities are more abundant and more variable in species com-
position throughout the study area. Diamondleaf willow (Salix planifolia
pulchra), feltleaf willow (S. alexensis), or a mixture of both occur along
most stream terraces in the area, usually with an understory of bluejoint
(Calamagrostis canadensis).
Low shrub vegetation (20 cm [8 in] to 1.5 m [5 ft] tall) is very abundant in
the study area and includes tundra as well as closed and open low shrub
types. Low shrub tundra communities are dominated by such species as four-
angled cassiope (Cassiope tetragona), crowberry (Empetrum nigrum) and bog
blueberry (Vaccinium uliginosum). Other woody plants such as dwarf Arctic
birch (Betula nana) and willow species may be present as codominants in this
community. Low shrub tundra vegetation is quite common on the upland
rolling hills where it often forms a complex with cottongrass (Eriophorum
spp.) tussock tundra.
Closed low shrub communities occur sporadically along the two transportation
corridors, but are prevalent near the coast on slopes directly above the
beach. Dominant species in this community include dwarf Arctic birch,
diamondleaf willow, bog blueberry and narrow-leaf Labrador-tea (Ledum
decumbens).
Open low shrub communities are common on upland rolling hills and riparian
stream terraces located along the transportation corridors. This vegetation
type consists primarily of a codominance of willow and assorted heath
species. Dwarf Arctic birch, bog blueberry, moss and herbaceous species
may also codominate this vegetation type.
Dwarf shrub mat and cushion tundra communities are primarily associated
with upland ridges and bedrock outcroppings located above 244 m (800 ft)
elevation in the De Long Mountains. This vegetation type typically contains
white mountain-avens (Dryas octopetala) in association with a variety of
willow, heath and lichen forms, depending on the moisture content of the
soil. On more mesic* sites, dwarf Arctic birch and narrow-leaf Labrador-tea
may also describe a community.
* Defined in Glossary.
IV - 9
-------
Herbaceous
Herbaceous tall grass (greater than 1 m [3 ft] tall) communities occur along
the coastal dune regions of the study area. This vegetation type is domi-
nated by lyme grass (Elymus arenarius mollis) in association with beach pea
(Lathyrus maritimus pubescens).
Sedge-grass tundra communities typically occur in lake basins or infilled
backwater areas along streams where there is no surface water and water
inundation of the soil profile may occur for only part of the growing season.
This vegetation type is usually composed of various combinations of cotton-
grass (Eriophorum vaginatum, JE. angustifolium) and the sedge Carex
aquatilis aquatilis, although willow and moss species, may also occur.
Tussock tundra is by far the most prevalent vegetation type along the
transportation corridors, typically occurring on rolling upland slopes.
Cottongrass is the principal species of tussock tundra, but the community
usually contains codominant species of various other sedges (Carex bigelowii,
C_. microchaeta), bog blueberry, narrow-leaf Labrador-tea, dwarf Arctic
birch, and Sphagnum moss.
Sedge-grass marsh communities usually occur near lakes and in historic lake
beds which contain at least 15 cm (6 in) of surface water. This vegetation
type usually contains pendent grass (Arctophilia fulva) or sedge (Carex
aquatilis) in association with a codominant such as mare's tail (Hippuris
vulgaris).
Sedge-grass wet meadow communities are similar to sedge-grass marsh com-
munities but occur in historic, infilled lake basins and high- or low-centered
polygonal ground having less than 15 cm (6 in) of surface water. Carex
species dominate this vegetation type, although common associates include
cottongrass species, bog blueberry and mosses.
Sedge-grass bog meadow communities are similar to sedge-grass wet meadow
communities but occur only in poorly drained lake basins which have peat
soil at least 30 cm (12 in) deep. As with wet meadow communities, domin-
ant species of this vegetation type include Carex species, cottongrass, bog
blueberry, narrow-leaf Labrador-tea and Sphagnum species.
Wetland herbaceous communities occur in small ephemeral ponds located be-
tween sand dunes and along some coastal lagoons. Halophytic* (salt-
adapted) herb wet meadows are dominated by arrow grass (Triglochin
maritimum), though mare's tail may also be present. In more freshwater
habitats, this vegetation type is dominated by horsetail (Equisetum spp.).
Wetlands
Development in wetland areas is regulated by federal law to the extent that
any discharge of dredged or fill material may require a Department of the
Army (DA) permit. The Corps defines wetlands as "areas that are inundated
or saturated by surface or groundwater at a frequency and duration suffi-
* Defined in Glossary.
IV - 10
-------
cient to support ... a prevalence of vegetation typically adapted for life in
saturated soil conditions. Wetlands generally include swamps, marshes,
bogs, and similar areas" (Federal Register 47[141 ] :31811). Vegetation,
though, is only one indication of a wetland system. Other parameters in-
clude the hydrologic regime and soil characteristics. All three parameters
should be considered in determining wetlands. The identification of wetlands
in Arctic areas is complicated by the fact that permafrost can impede the
drainage of soils, and large areas not considered typical wetlands may be-
come water-saturated as thawing progresses through a growing season.
Wetlands were set aside for special consideration because they may provide
valuable habitat and perform important natural functions. Therefore, a wet-
lands evaluation must go beyond identification and take into consideration the
ecological contribution made by the defined communities. In addition to pro-
viding habitat, important functions of the wetland system of the project area
include flood control, particularly in the major wetland area near Kivalina;
nutrient and detrital movement, particularly in wetland areas adjacent to
lagoons and other aquatic systems; filtration; erosion control and runoff
retardation.
Several vegetation types identified in the project area satisfy the technical
wetland criteria (i.e., plant species are either facultative or obligate hydro-
phytes*, soil has hydric* characteristics, and the soil is saturated or inun-
dated during a portion of the growing season). These wetland vegetation
types include sedge-grass marsh, sedge-grass wet meadow, sedge-grass bog
meadow, wetland herbaceous, sedge-grass tundra, tussock tundra and open
low shrub communities.
In general, riparian tall and low shrub vegetation types are classified as
wetlands when they occur along low terraces and river bars that are flooded
during spring runoff and periods of intense rainfall and are vegetated by
willows or river beauty (Epilobium latifolium) (Dames & Moore, 1982a).
Threatened or Endangered Species
Three candidate threatened or endangered species have potential for occur-
rence in the project area (Murray, 1980). These are Kobuk locoweed
(Oxytropis kobukensis), the kokrines oxytrope (Oxytropis kokrinensis) and
fleabane (Erigeron grandiflorus muirii). However, none of these species
were found during extensive field surveys from 1981 to 1983 (Dames & Moore,
1982a, 1983a,b). Thus, it appears unlikely that candidate threatened or
endangered species occur in areas proposed for development.
Terrestrial Wildlife
Birds
Three groups of birds are of particular concern in the project area: water-
fowl, shorebirds and raptors.
* Defined in Glossary.
IV - 11
-------
Waterfowl and Shorebirds
Waterfowl and shorebird use of the project area is centered along the coast
during the spring and fall migrations, although coastal and inland breeding
occurs. The areas of primary importance to waterfowl and shorebirds are
the river delta habitats along the coast, especially those associated with
coastal lagoons. The total number of birds staging in these areas is not
high in comparison to other areas of the Kotzebue Sound region (Dames &
Moore, 1983a). Figure IV-3 shows the most important spring and fall migra-
tion staging areas.
During spring migration, the staging areas most heavily used by water-
orientated birds are the delta areas of the Singoalik River (Singoalik
Lagoon), Asikpak River (Asikpak Lagoon), Kivalina and Wulik Rivers
(Kivalina Lagoon), Imikruk Creek (Imikruk Lagoon), Omikviorok River
(Ipiavik Lagoon) and Tugak Lagoon. During the fall migration, major stag-
ing areas are the deltas of the Kivalina River (Kivalina Lagoon) and the
Omikviorok River (Ipiavik Lagoon).
Inland habitats for this species group are found in the extensive riparian
low shrub areas, and in the sedge-grass marsh areas associated with ponds
in the lowlands of the Kivalina, Wulik and Omikviorok River drainages. A
combination of emergent vegetation and open water make these ponds high
quality habitat for breeding and molting Canada geese (Branta canadensis).
Raptors
Portions of the project area provide good habitat for cliff nesting raptors
including the peregrine falcon (Falco peregrinus), golden eagle (Aquila
chrysaetos), gyrfalcon (Falco rusticolus) and the rough-legged hawk (Buteo
lagopus). The peregrine falcon is classified as a federally endangered
species under the Endangered Species Act, and golden eagle nest sites are
protected by the Bald Eagle Protection Act. Peregrine falcon and golden
eagle nest sites which have been reported in the vicinity of potential project
impact areas (Dames & Moore, 1983a) are shown on Figure IV-4. Additional
information on peregrine falcons is included in Appendix 3, Endangered
Species Biological Assessment.
In addition to waterfowl, shorebirds and raptors, ptarmigan are also impor-
tant species because of their utilization as a subsistence resource. Ptarmigan
occur throughout the project area, primarily in low shrub and tussock tundra
habitats.
Mammals
Five large terrestrial mammal species are found in the project area; caribou
( Rangifer tarandus), muskoxen (Ovibos moschatus), moose (Alces alces),
Dall sheep (Ovis dalli) and brown bear ( Ursus arctos). Other important
terrestrial mammal species in the project area include the wolf (Canis lupus),
wolverine ( Gulo gulp), red fox ( Vulpes vulpes) and Arctic fox (Alopex
lagopus).
IV - 12
-------
FIGURE IV-3
SPRING & FALL WATERFOWL
STAGING AREAS
-------
PUSIGFAK
LAOOOH
DEADLOCK
MTN
SINGOALIK
LAGOON
SINGOALIK
LAGOON
PORT SITE
TUSAK LAGOON
TUGAK LAGOON
PORT SITE
KAVRORAK LAGOON
KIVALINA
LAGOON
IMIKRUK
LAGOON
LEGEND
VABM 17
PORT SITE
IPIAVIK
LAGOON
VABM 28
PORT SITE
POSSIBLE CONNECTION
TO GCO'S LIK PROSPECT
MONUMENT BOUNDARY
TRANSPORTATION CORRIDOR
PEREGRINE FALCON NEST
GOLDEN EAGLE NEST
CAPElKRUSENSTERN
NATIONAL IV ONUMENT
-------
Caribou
The western Arctic caribou herd, numbering approximately 190,000 animals
and the largest herd in North America, encompasses the project area within
its range. A small portion of this herd uses the Singoalik, Asikpak,
Kivalina, Wulik and Omikviorok River drainages for winter range, while the
large majority of the herd moves further south and eastward to overwinter.
Winter distribution in the project area, both in numbers and location, is
highly variable and probably dependent on local weather conditions (e.g.,
snow depth). Winter numbers in these drainages may reach 10,000 individ-
uals in some years (Dames & Moore, I983a). Figure IV-5 shows the histor-
ical caribou winter range within the project area since 1966 (Coady, 1983),
as well as the more specific primary and secondary habitats used by caribou
from 1981 to 1983 (Dames & Moore, 1983a).
In the spring, caribou leave winter ranges in the project area and migrate
north through the De Long Mountains to their traditional calving grounds on
the Arctic Slope. In years of particularly heavy snowfall, this spring migra-
tion might be delayed somewhat. Subsistence hunters report that when the
migration is delayed, caribou have been known to drop their calves in the
Mulgrave Hills winter range. Calving within the project area is not a normal
event, however. Relatively few animals normally remain in the vicinity of
the project area during late spring and early summer, but in early July 1982
approximately 10,000 bulls were observed there (Coady, 1983). In early
July a large movement of caribou numbering in the tens-of-thousands nor-
mally enters the project area from the northwest, and passes through the
upper drainages of the Kivalina and Wulik Rivers in the traditional counter-
clockwise post-calving aggregation. These animals then return to the Arctic
Slope to spend the remainder of the summer. Caribou normally enter the
Wulik and Kivalina drainages again in late fall, primarily from the northwest.
In some years this movement may involve a large portion of the western
Arctic herd (e.g., in 1975 an estimated two-thirds of the entire herd passed
through the project area during the fall on their migration to wintering areas
to the south and east).
Muskoxen
Muskoxen appear to be slowly increasing in numbers in the region following
introductions at several locations during the past 13 years. A herd of at
least eight animals appears to be established on winter range in the Rabbit
Creek valley south of the Mulgrave Hills. A larger herd is established to
the northwest in the Cape Thompson area, and some individuals probably use
the Singoalik River Valley as part of their home range. During the late
spring, summer and fall, the animals appear to range widely along the coast,
and inland in the Singoalik, Asikpak, Kivalina and Wulik River drainages.
Moose
Moose are found in the region closely associated with riparian tall shrub
communities along major rivers and streams, particularly during the winter.
In late spring, moose disperse to shrub habitats at higher elevations, though
riparian tall shrub habitats probably still support most moose. This disper-
sal continues through the summer and autumn, until the approach of winter
when moose concentrate along the waterways again.
IV - 15
-------
DXDOG
E^
DEADLOCK
MTN
SINGOALIK
LAGOON
PORT SITE
TUGAK LAGOON
PORT SITE
KAVRORAK LAGOON
KIVALINA
LAGOON
IMIKRUK
LAGOON
LEGEND
VABM 17
PORT SITE
IPIAVIK
LAGOON
VABM 28
PORT SITE
POSSIBLE CONNECTION
TO GCO'S LIK PROSPECT
MONUMENT BOUNDARY
TRANSPORTATION CORRIDOR
HISTORICAL WINTER RANGE
SINCE 1966
PRIMARY RANGE 1981-83
(A\\\\V SECONDARY RANGE 1981-83
SOURCE:
OAMESa MOORE
-------
Population densities in the project area do not appear high. A 1980 survey
by ADF&G estimated a total population of about 150 moose in the drainages of
the Wulik and Kivalina Rivers. Another area of apparent significant winter
range use is the Rabbit Creek valley south of the Mulgrave Hills.- In June
of 1983, a moose was sighted by ADF&G biologists in the Bons Creek drain-
age, about 0.4 km (0.25 mi) northwest of the Red Dog airstrip.
Dall Sheep
Dall sheep in the region are near the western limit of their Brooks Range
distribution. Sheep habitat in the project vicinity is limited to the Wulik
Peaks and the mountains bordering the headwaters of the Wulik River and
Ikalukrok Creek (Fig. IV-6). Sheep are generally found in low to moderate
numbers in these areas.
Brown (Grizzly) Bears
Brown bears are found throughout the project area. They occupy several
different habitats depending on the season and availability of food. In
spring the upper mountainous areas appear to be favored, while the lowland/
coastal areas are favored in the summer and fall. The bears tend to move
toward spawning streams when fish are present, and bears have been ob-
served along the Wulik River, Ikalukrok Creek and the Asikpak River.
Denning probably occurs throughout the region at higher elevations, and the
Siaktak Hills area on the Asikpak River is known to support several dens.
Wolf
Wolves occur throughout the project area in moderate numbers and are an
important ungulate* predator in the region. They are eagerly hunted and
trapped by local residents for their pelts. Single animals and packs of up
to 12 wolves have been reported by Red Dog Camp personnel (Dames &
Moore, 1983a).
Wolverine
The wolverine is a wide-ranging species that presently occurs throughout
the project area in moderate numbers. They are also important to hunters
and trappers in the region for their pelts.
Fox
Red fox and Arctic fox are found throughout the region and occur in a
variety of habitats. Their abundance fluctuates and the populations within
the project area appear to be low to moderate at present. They are also
important species for local trappers.
Threatened or Endangered Species
The only threatened or endangered terrestrial animal species within the pro-
ject area is the endangered peregrine falcon. Dames & Moore (1983a)
reported seven nest sites (Fig. IV-4) and several other observations of
* Defined in Glossary.
IV - 17
-------
SINGOALIK
LAGOON
PORT SITE
TUGAK LAGOON
TUGAK LAGOON
PORT SITE
KAVRORAK LAGOON
KIVAL1NA
LAGOON
IMIKRUK
LAGOON
LEGEND
VABM 17
PORT SITE
i POSSIBLE CONNECTION
TO GCO'S LIK PROSPECT
MONUMENT BOUNDARY
TRANSPORTATION CORRIDOR
RANGE
VABM 28
PORT SITE
CAPEJKRUSENSTERN
NATIONAL
-------
birds not associated with nests. During 1983, a survey of the previously
identified peregrine nest sites did not find any active peregrine nests
(Dames & Moore, I983b). Additional information may be found in Appendix 3
(Endangered Species Biological Assessment).
Groundwater Resources
The volume and distribution of groundwater is dependent upon the geology
and soils of an area and is controlled by seasonal permafrost depths.
Groundwater may occur above (suprapermafrost water), within (intraperma-
frost water) or below (subpermafrost water) the permafrost layer (Muller,
1947). At this time, permafrost depths in the project area have not been
ascertained. Sources of groundwater include surface recharge by percolation
through unfrozen bedrock fractures, and infiltration of surface runoff
through thawed surficial soils.
Relatively small quantities of groundwater exist within the bedrock and soil
deposits in the Red Dog Creek valley. It is estimated that groundwater
wells would produce less than 83 £/min (10 gal/min) (Balding, 1976; Fuelner
et al., 1971). Groundwater flows through unfrozen bedrock fractures gen-
erally follow topographic slopes. Groundwater movements through unfrozen,
suprapermafrost soils are closely associated with surface water flows, and
eventually discharge into Red Dog Creek.
Most of the groundwater encountered in the project area is ephemeral and
occurs only during warmer months when the active soil layer is thawed.
The availability of year-round groundwater is likely to depend on the thick-
ness of the alluvial layer beneath streams in relation to the depth of winter
freezing and the top of the permafrost layer. Small quantities of ground-
water may exist throughout the year as evidenced by icings and pressure
ridges observed on the ice-covered creeks (Dames & Moore, 1983a).
Groundwater samples have been collected from two small seeps located along
Red Dog Creek. In general, these seep samples had substantially lower pH
and temperature, and higher levels of conductivity than Red Dog Creek.
Water samples from the seeps were worse than EPA aquatic life water quality
standards for cadmium, copper, iron, lead, nickel, phosphorous and zinc.
The high metals content of these seeps indicates that their source is from
within the ore zone. The mechanism of groundwater movement and residence
time within the ore zone is not known.
Freshwater Resources
Hydrology
The project area is located primarily within the drainage basins of three
major rivers: the Kivalina, Wulik and Omikviorok (Fig. III-2). A small
portion of the area is also located in the upper reaches of the Noatak River
drainage basin. The Kivalina River, in the western portion of the project
area, originates in the Wulik Peaks at the western end of the De Long
Mountains and flows southwest to enter the Chukchi Sea approximately 10 km
(6 mi) northwest of the Native community of Kivalina. River crossings of
the Kivalina would be required at three locations along the northern trans-
portation corridor. The northern corridor also crosses the Asikpak River,
IV - 19
-------
which is a much smaller drainage entering the Chukchi Sea northwest of
Kivalina Lagoon.
Most of the project area is located within the Wulik River basin. The Wulik
River drains the western De Long Mountains and flows approximately 128 km
(80 mi) southwest before entering the Chukchi Sea at Kivalina.
The proposed mine and mill facilities are located in the drainage basin of Red
Dog Creek. This creek is a tributary of Ikalukrok Creek which is a major
tributary of the Wulik River (Fig. IV-2). The northern transportation cor-
ridor crosses both Ikalukrok Creek and the Wulik River. The eastern end
of the southern transportation corridor crosses small tributaries of Ikalukrok
Creek, and small portions of the upper Wulik and Noatak River watersheds.
The western end of the southern transportation corridor traverses the
Omikvidrok River basin, and may require a major bridge across this river
depending on the final routing. The Omikviorok River is considerably
smaller than the Wulik River. It drains the coastal uplands on the north
side of the Mulgrave Hills before flowing west to enter the Chukchi Sea at
Ipiavik Lagoon.
Limited flow data are available for these rivers and their tributaries. The
USGS has published data for two streams which provide representative sea-
sonal flow characteristics in the De Long Mountains region. These are the
Noatak River, whose much larger river basin is east of the Wulik River, and
Ogotoruk Creek, which is located approximately 65 km (40 mi) northwest of
Kivalina. Table IV-1 summarizes the estimated annual flow characteristics
for streams in the project area based upon these records and other sources
of information on precipitation.
Mean annual runoff for streams in the project area varies from 0.01 to 0.02
m3/sec/km2 (1.1 to 1.9 ft3/sec/mi2). This corresponds to basin runoff of 30
to 64 cm/yr (12 to 25 in/yr) and mean basin precipitation of 38 to 76 cm/yr
(15 to 30 in/yr). The lowest annual runoff is in coastal lowland locations
and the highest in the De Long Mountains.
Seasonal flow changes in Arctic streams are much greater than those typical
of temperate climates. Virtually all streamflow occurs between breakup and
freezeup, a period of approximately five months from the middle of May
through the middle of October. Streams generally exhibit two periods of
high flow: at spring breakup and during summer and fall storm events.
Typical proportions of mean monthly runoff for rivers in the study area are
shown in Table IV-2.
Smaller tributaries freeze to the bottom in winter. Some springs continue to
flow during the winter months, but generally form icings a short distance
away. Major rivers continue to flow through the winter, but accurate flow
measurements are difficult to determine because of the imprecision associated
with determining under-ice flow.
The presence of shallow permafrost and saturated soils results in a rapid
response between snowmelt or rainfall and the resulting stream discharge.
Over 80 percent of annual peak floods occur during the breakup period in
May and June. All other floods result from intense summer rain events.
IV - 20
-------
Table IV-1
PO
MEAN ANNUAL FLOW DATA FOR SOME STREAMS
IN THE RED DOG MINE PROJECT AREA
Drainage Area
Location
Kivalina River at Chukchi Sea
Wulik River at Chukchi Sea
Omikviorok River at Chukchi Sea
Ikalukrok Creek at Wulik River
Ikalukrok Creek above Red Dog Creek
Red Dog Creek at Ikalukrok Creek
North Fork Red Dog Creek at Main Fork
Main Fork Red Dog Creek above South Fork
South Fork Red Dog Creek at Main Fork
Main Fork Red Dog Creek above North Fork
Bons Creek at Water Supply Dam Site
kmz
1,740
2,339
469
492
153
65
36
13
8
23
10
mi2
672
903
181
190
59
25
14
5
3
9
4
cm
41
46
38
48
61
48
48
51
48
48
48
in
16
18
15
19
24
19
19
20
19
19
19
Mean Annual Runoff
ma/s
22.6
34.0
5.7
7.6
3.1
1.0
0.6
0.2
0.1
0.4
0.2
ft3/s
800
1,200
200
270
110
35
20
7
4
13
6
m3/s/kmz
0.013
0.014
0.012
0.015
0.020
0.015
0.017
0.015
0.012
0.017
0.020
ftVs/mi*
1.2
1.3
1.1
1.4
1.9
1.4
1.4
1.4
1.3
1.4
1.5
-------
Table IV-2
TYPICAL MEAN MONTHLY FLOW PROPORTIONS FOR
RED DOG PROJECT STUDY AREA STREAMS
Month
October
November
December
January
February
March
April
May
June
July
August
September
Mean Monthly
Flow Proportion
3.0%
1.0%
0.5%
0.5%
0.5%
0.5%
1.0%
7.0%
32.0%
22.0%
17.0%
15.0%
The 100-year recurrence flood is 0.547 to 1.641 m3/s/km2 (50 to 150 ft3/s/
mi2) for drainage areas of 2,589 to 259 km2 (1000 to 100 mi2) (Childers et
al., 1979). Smaller tributaries in the De Long Mountains have larger peak
runoff rates per square mile than major streams. Ten-year and 100-year
recurrence flood peaks for locations in Red Dog Valley are shown in Table
IV-3.
Water Quality
Water quality in the Kivalina and Wulik Rivers is typical of unpolluted fresh
water in the Arctic. Both of these rivers are clear water streams with low
levels of color, suspended solids, turbidity and nutrients. The water is
highly oxygenated, moderately hard to hard, and classified as a calcium
bicarbonate type. The pH level of these rivers is essentially neutral (7.0 to
8.2), and levels of most trace elements fall within ranges acceptable for
freshwater aquatic life. Ikalukrok Creek has similar water quality character-
IV - 22
-------
Table IV-3
TEN- AND 100-YEAR RECURRENCE FLOOD FLOWS
FOR STREAM LOCATIONS IN RED DOG VALLEY
Flood Event
10-year
Location
North Fork Red Dog Creek
at Main Fork
South Fork Red Dog Creek
at Main Fork
Main Fork Red Dog Creek
above South Fork
Bons Creek at Water
Supply Dam Site
m3/s
25.5
7.1
11.3
8.5
ft3/s
900
250
400
300
100-year
m3/s
62.3
21.2
28.3
24.1
fta/s
2,700
750
1,000
850
istics to the Kivalina and Wulik Rivers, except below its confluence with the
lower quality waters of the Red Dog Creek (Fig. IV-7).
The waters of Red Dog Creek are atypical of most undeveloped Arctic
streams because of the toxic concentrations of dissolved elements that enter
the main stem of the creek as it flows through the highly mineralized ore
body. Waters in the upper portion of the main stem, the North Fork, and
most of the South Fork exhibit high water quality. However, the middle
portion of the main stem has high concentrations of cadmium, lead, zinc and
iron. This water also has decreased levels of dissolved oxygen and alkalin-
ity, and increased levels of turbidity, suspended solids and sulfate. The
pH turns slightly acidic, and water type changes from calcium bicarbonate to
a mixture of calcium-magnesium bicarbonate and magnesium-sodium sulfate
water. Dilution from North and South Fork waters improves the water qual-
ity of the main stem further downstream, but Red Dog Creek adversely
affects the water quality of Ikalukrok Creek below their confluence.
IV - 23
-------
z
LEGEND
CONCENTRATION
(MG/L)
DESIGNATION ELEMENT
ZINC
LEAD
CADMIUM
0.02 - 0.05
0.0004 - 0.01
0.001 - 0.004
CLEAN
WATER:
OOOO
ZINC
LEAD
CADMIUM
0.2 -I.I
0.01 - 0.05
0.005 - 0.02
SOMEWHAT
DEGRADED:
4 6 A
ZINC
LEAD
CADMIUM
HIGHLY .
DEGRADED
O D D D
FIGURE IV-7 IKALUKROK
CREEK DRAINAGE AREA SHOWING
EXISTING WATER QUALITY A
-------
Kivalina River
Water in the Kivalina River is of the calcium bicarbonate type with high
alkalinity. Both major forks of the river are highly oxygenated, clear, and
have neutral pH. Zinc concentrations occur in moderate levels, but boron
and cadmium concentrations in both forks exceed EPA water quality stan-
dards for aquatic life.
Wulik River
The Wulik River is a clear water system typified by high dissolved oxygen
and low levels of color, suspended solids, turbidity and nutrients. The
water is moderately hard, and of the calcium bicarbonate type, with pH
ranging from 7.0 to 8.1. Winter water quality values are similar to those
measured during open water periods with minor exceptions. Concentrations
of barium, cadmium and silver are slightly higher in the winter than in the
summer, while iron, sodium and zinc levels are lower in the winter.
Ikalukrok Creek
Except for a short period during breakup, Ikalukrok Creek is a highly oxy-
genated, clear water stream that exhibits low levels of color, suspended
solids, turbidity, ammonia and orthophosphate throughout the year. The
water is moderately hard to hard except during breakup when it is soft, and
of the calcium bicarbonate type with pH near neutral.
Ikalukrok Creek water quality is significantly affected by Red Dog Creek
waters for a considerable distance below their confluence. Water quality
parameters such as pH, carbon dioxide, cadmium, lead and zinc show high
concentrations at the confluence of the two streams, but gradually decrease
to typical low levels downstream of the confluence as a result of tributary
and groundwater dilution. Seasonal flows and concentrations of total zinc,
lead and cadmium are shown in Tables IV-4, IV-5 and IV-6. Figure IV-7
shows the extent of degraded water quality due to high concentrations of
zinc, lead and cadmium.
Dudd, Buddy and Bons Creeks
Water quality in these creeks is generally very good during breakup, sum-
mer and early winter. Water is of the calcium bicarbonate type, low in tur-
bidity and settleable solids and highly oxygenated. With the exception of
cadmium levels in Bons Creek during breakup, concentrations of aluminum,
copper, lead, silver and zinc are better than EPA water quality standards
for aquatic life in all three creeks throughout the year.
North Fork Red Dog Creek
This creek is a high quality, clear water stream with high dissolved oxygen
levels during summer and breakup, and low levels of suspended solids, tur-
bidity and settleable solids throughout the year. Water is of the calcium-
magnesium bicarbonate type with elevated levels of sulfate, and normal
ranges of pH, alkalinity and conductivity. Concentrations of cadmium, lead
and silver are slightly above recommended EPA water quality criteria for
aquatic life, but much lower than concentrations observed in the South and
IV - 25
-------
Main Forks of Red Dog Creek. Typical concentrations of total zinc, lead and
cadmium are shown in Tables IV-4, IV-5 and IV-6. Figure IV-7 shows that
the North Fork is a clean, uncontaminated stream similar to Ikalukrok Creek
upstream of Red Dog Creek.
South Fork Red Dog Creek
The water of this fork is generally a mixture of calcium-magnesium bicar-
bonate type with sodium sulfate type water. Concentrations of cadmium,
lead and zinc reach highly toxic levels, while concentrations of mercury,
chromium and silver slightly exceed EPA water quality criteria for aquatic
life. Alkalinity and pH are generally depressed in this creek, and total dis-
solved solids are elevated compared to other streams outside of Red Dog
Valley. Seasonal flows and concentrations of total zinc, lead and cadmium
are shown in Tables IV-4, IV-5 and IV-6. Figure IV-7 shows that the South
Fork is moderately degraded and does not support fish life.
Main Stem Red Dog Creek
Water in the main stem is of the calcium-magnesium-sodium sulfate type with
very high concentrations of dissolved toxic metals. Concentrations of the
metals cadmium, lead, silver and zinc greatly exceed EPA water quality cri-
teria for aquatic life. Concentrations of aluminum, chromium, copper, iron,
manganese, mercury and nickel also exceed those criteria. Metal concentra-
tions in late winter are particularly high, sometimes an order of magnitude
greater than during the open water period. Water in this creek has un-
usually low pH, low alkalinity and high acidity. Seasonal flows and concen-
trations of total zinc, lead and cadmium are shown in Tables IV-4, IV-5 and
IV-6. Figure IV-7 shows that all of the main stem is highly degraded down-
stream of the ore body and supports no significant aquatic life.
The upper section of the creek, which lies above the ore body, is relatively
uncontaminated with dissolved metals. However, a zone of water quality
degradation begins at the upper end of the ore body and extends down-
stream to the confluence of the main stem with the South Fork. Water
quality improves somewhat below this confluence, but downstream levels of
metals, turbidity, suspended solids and sulfate continue to remain higher
than those found in adjacent streams.
One cause of water quality degradation of the main stem is that the creek
flows directly over heavily mineralized rocks. The creek also receives
surface and groundwater draining from the ore body area which contains
high metals and sulfide concentrations. All parts of the ore body will pro-
duce soluble metals by simple dissolution of previously oxidized mineralized
zones without significant acid production. These effects are stronger in the
main stem of Red Dog Creek compared to the South Fork due to the relative
exposure of the ore body to surface runoff. Tables IV-4, IV-5 and IV-6
indicate that 82 to 93 percent of the metal loads in Ikalukrok Creek below
the confluence with Red Dog Creek originate from the ore body zone.
Red Dog Creek at Mouth
By the time it enters Ikalukrok Creek, the water quality of Red Dog Creek
represents a mixture of the three upstream forks, with the greater flow of
IV - 26
-------
Table IV-4
SEASONAL FLOWS AND CONCENTRATIONS AND LOADS OF ZINC1 IN PROJECT AREA STREAMS
SUMMER LOW FLOWS
STORM EVENTS
WINTER FLOWS
SPRING FLOWS
Flow Cone. Load
Flow Cone. Load
Flow Cone. Load
Flow Cone. Load
DRAINAGE BASIN ma/s ft3/s mg/1 kg/day Ib/day ma/s fta/s mg/l kg/day Ib/day m3/s ft3/s ing/l kg/day Ib/day ma/s ftVs mg/l kg/day IbTday
Middle Fork Red Dog
Creek Above
South Fork 0.2 7 19.0 326 718 0.9 30 12.0 882 1,944 0.01 0.5 50.0 61 135 0.7 25 6.0 368 810
South Fork Red Dog
Creek 0.1 4 0.9 8.6 19 0.6 20 1.1 54
119 0.01 0.5 1.0 1.4 3 0.4 15 0.2 7.3 16
North Fork Red Dog
1 Creek and Lower
Basin
ro
0.7 24 0.02 1.4 3 2.1 75 0.04 7.3 16 0.08 3.0 0.02 0.5 1 2.2 77 0.05 9.5 21
Red Dog Creek
1.0 35 4.0 343 756 3.5 125 3.0 919 2,025 0.11 4.0 7.0 68 151 3.5 125 1.3 398 878
'kalukrok Creek
Above Red Dog
Creek
3.1 110 0.02 5.4 12 11.6 410 0.025 25 55 0.3 11.0 0.05 1.4 3 8.5 300 0.025 18 41
Ikalukrok Creek
Below Red Dog
Creek
4.1 145 1.0 355 783 15.2 535 0.7 918 2,022 0.4 15.0 1.7 63 138 12.0 425 0.4 416 918
Ore Zone Load In
Ikalukrok Creek
93 percent
93 percent
89 percent
88 percent
Source: Dames & Moore, 1983a
1 EPA Water Quality Criteria for Aquatic Life: 0.047 mg/t
-------
Table IV-5
SEASONAL FLOWS AND CONCENTRATIONS AND LOADS OF LEAD1 IN PROJECT AREA STREAMS
SUMMER LOW FLOWS
STORM EVENTS
WINTER FLOWS
SPRING FLOWS
Flow Cone. Load Flow Cone. Load Flow Cone. Load Flow Cone. Load
DRAINAGE BASIN mj/s ft3/s mg/Jt kg/day Ib/day m3/s ft3/s mg/t kg/day Ib/day ma/s ft3/s mg/JE kg/day Ib/day m3/s ft3/s mg/l kg/day Ib/day
Middle Fork Red Dog
Creek Above
South Fork 0.2 7 0.1 1.7 3.8 0.9 30 0.3 22 49 0.01 0.5 0.05 0.05 0.1 0.7 25 0.5 31 68
South Fork Red Dog
Creek
0.1 4 0.02 0.2 0.4 0.6 20 0.04 2.0 4.3 0.01 0.5 0.01 0.01 0.03 0.4 15 0.05 1.9 4.1
i North Fork Red Dog
Creek and Lower
Basin
ro
CO
0.7 24 0.001 0.05 0.1 2.1 75 0.0005 0.09 0.2 0.08 3.0 0.001 0.01 0.02 2.2 77 0.0005 0.09 0.2
Red Dog Creek
1.0 35 0.007 0.6 1.3 3.5 125 0.04 12 27 0.11 4.0 0.004 0.05 0.1 3.5 125 0.03 9.2 20
Ikalukrok Creek
Above Red Dog
Creek
3.1 110 0.0004 0.09 0.2 11.6 410 0.001 1.0 2.2 0.3 11.0 0.0005 0.01 0.03 8.5 300 0.001 0.7 1.6
Ikalukrok Creek
Below Red Dog
Creek
4.1 145 0.002 0.7 1.6 15.2 535 0.01 13 29 0.4 15.0 0.001 0.05 0.1 12.0 425 0.01 10 23
Ore Zone Load In
Ikalukrok Creek
88 percent
92 percent
90 percent
88 percent
Source: Dames & Moore, 1983a
1 EPA Water Quality Criteria (or Aquatic Life: 0.00075 mg/4
-------
Table IV-6
SEASONAL FLOWS AND CONCENTRATIONS AND LOADS OF CADMIUM1 IN PROJECT AREA STREAMS
SUMMER LOW FLOWS STORM EVENTS WINTER FLOWS SPRING FLOWS
Flow Cone. Load Flow Cone. Load Flow Cone. Load Flow Cone. Load
DRAINAGE BASIN m3/s fta/s mg/t kg/day Ib/day m3/s ft3/s mg/i kg/day Ib/day m3/s fta/s mg/A kg/day Ib/day m3/s fta/s mg/Jt kg/day Ib/day
Middle Fork Red Dog
Creek Above
South Fork 0.2 7 0.14 2.4 5.3 0.9 30 0.1 7.4 16 0.01 0.5 0.5 0.6 1.4 0.7 25 0.05 3.1 6.8
South Fork Red Dog
Creek 0.1 4 0.008 0.09 0.2 0.6 20 0.005 0.2 0.5 0.01 0.5 0.007 0.05 0.1 0.4 15 0.01 0.4 0.8
"^ North Fork Red Dog
i Creek and Lower
pj Basin 0.7 24 0.003 0.2 0.4 2.1 75 0.002 0.4 0.8 0.08 3.0 0.004 0.05 0.1 2.2 77 0.002 0.4 0.8
CD
Red Dog Creek 1.0 35 0.03 2.6 5.7 3.5 125 0.025 7.7 17 0.11 4.0 0.08 0.8 1.7 3.5 125 0.01 3.1 6.8
Ikalukrok Creek
Above Red Dog
Creek 3.1 110 0.001 0.3 0.6 11.6 410 0.001 1.0 2.2 0.3 11.0 0.002 0.05 0.1 8.5 300 0.001 0.7 1.6
Ikalukrok Creek
Below Red Dog
Creek 4.1 145 0.008 2.9 6.3 15.2 535 0.007 9.2 20 0.4 15.0 0.02 0.7 1.6 12.0 425 0.0035 3.6 8.0
Ore Zone Load in
Ikalukrok Creek 84 percent 85 percent 82 percent 81 percent
Source: Dames & Moore, 1983a
1 EPA Water Quality Criteria for Aquatic Life: 0.000012 mg/l
-------
the relatively clean North Fork diluting the poorer water quality of the other
two forks. The water is a calcium-magnesium bicarbonate type with elevated
levels of sulfate, normal pH and alkalinity, and elevated total dissolved
solids. Very toxic concentrations of cadmium, lead, silver and zinc are
present, and concentrations of aluminum, chromium, mercury and nickel also
exceed EPA criteria for aquatic life. Levels of total suspended solids,
settleable solids and turbidity are generally low except during breakup and
storm events. Alkalinity, carbon dioxide, hardness and conductivity levels
are lowest at breakup, and gradually increase throughout the year to reach
maximum levels in late winter.
Biology
Invertebrates
Benthic invertebrate fauna in the project area was studied by E.V.S. Con-
sultants in 1982 (E.V.S. Consultants Ltd., 1983). They found that aquatic
invertebrate communities typical of cold fast streams occurred on sections of
Ikalukrok Creek (sites corresponding to Dames & Moore Stations 8 and 9;
Fig. IV-8), on the North and South Forks of Red Dog Creek (Dames & Moore
Stations 12 and 22), and in the headwaters of Red Dog Creek above the main
ore body (Dames & Moore Station 43). These stations generally had high
abundances of organisms, and contributed 70 percent of the total number of
individuals sampled at all stations (Fig. IV-8). Midgefly larvae (Chirono-
midae; subfamilies Diamesinae and Orthocladiinae) were most abundant in
these communities. Other abundant taxa included stonefly nymphs
(Plecoptera), segmented worms (Oligochaeta*), mayfly nymphs (Ephemer-
optera), caddisfly larvae (Trichoptera), blackflies (Simuliidae), dancefly
larvae (Empididae), biting midges (Ceratopogonidae), water mites (Hydra-
carina), seed shrimp (Ostracoda) and roundworms (Nematoda).
The lowest number of individuals was collected along the main stem of Red
Dog Creek below the ore body (sites corresponding to Dames & Moore Sta-
tions 47, 40, 30, 20 and 10; Fig. IV-8). Although numbers were reduced at
these stations, taxa collected were generally similar to those found at sta-
tions with greater abundance, and included stoneflies, mayflies, oligochaetes,
midgeflies and water mites. Taxa absent at those sites in Red Dog Creek
with reduced abundance included roundworms, seed shrimp, mayflies (Family
Heptageniidae) and oligochaetes (Family Tubificidae).
The distribution of sites with reduced numerical abundance along Red Dog
Creek coincided with areas of elevated heavy metal concentrations near the
ore body. The most severely stressed area in terms of reduced numbers of
benthic invertebrate individuals and taxa extended from the ore body (Dames
& Moore Station 47) downstream nearly to the confluence of Red Dog and
Ikalukrok Creeks (Dames & Moore Station 10). The site with the least
numerical abundance of invertebrates occurred at Dames & Moore Station 30
near the confluence of the main stem and South Fork of Red Dog Creek
(Fig. IV-8).
Toxic metal effects on aquatic invertebrate populations may be a result of
direct physiological toxicity, or an indirect result of the elimination of food
* Defined in Glossary.
IV - 30
-------
O
10
CO
O).
UJ —
$
UJQ.
QCO
FIGURE IV-8
BENTHIC INVERTEBRATE & FISH SAMPLING
STATIONS IN IKALUKROK & RED DOG DRAINAGES
-------
sources (algae, bacteria, zooplankton) or microhabitat (algal mats, mosses).
Specht (1973) found a significant inverse correlation between the concentra-
tion of toxic metals and numbers of taxa and individuals in a receiving
stream. Data from Red Dog Creek show a similar trend of decreased numeri-
cal abundance as metals concentrations increase in the stream.
Further evidence of the deleterious effect of Red Dog Creek water on ben-
thic invertebrate populations was observed at the confluence of Red Dog and
Ikalukrok Creeks. Transects running perpendicular to streamflow were
sampled just above the confluence of the two creeks, and at five locations
downstream of their confluence (Dames & Moore, 1983a). Numerical abun-
dance in July 1982 was an order of magnitude greater in Ikalukrok Creek
just above the confluence as compared to Red Dog Creek. Downstream of
the confluence, transects consistently showed lower invertebrate abundance
on the southeast side of Ikalukrok Creek. This side visually and chemically
shows evidence of Red Dog Creek water for approximately 500 m (547 yd)
downstream of the confluence.
Fish
All of the major rivers in the Red Dog project area (Asikpak, Kivalina, Wulik
and Omikviorok Rivers) provide habitat for fish (Dames & Moore, 1983a, b).
However, the Kivalina and Wulik Rivers are by far the most important
streams in the area and have been designated as "major anadromous fish
streams" (Selkregg, 1974). The Red Dog ore body is located on a tributary
of the Wulik River.
The most important fish species in the area is Arctic char (Salvelinus
alpinus). It is the primary subsistence fish for the area as well as a prized
sport fish. Other major fish species present in the project area include, in
probable order of abundance: Arctic grayling (Thymallus arcticus), pink
salmon (Oncorhynchus gorbuscha), chum salmon (O. ketaJ7 coho salmon (O.
kisutch), king salmon (O. tshawytscha) and sockeye salmon (O. nerka) (Alt,
1978, 1983a; Dames & Moore, 1983a,b; De Cicco, in press).
Initial studies of the Wulik and Kivalina Rivers indicated that the Wulik River
was more important for char overwintering, whereas the Kivalina was viewed
as more important for char spawning (Alt, 1978; Bendock and Alt, 1981;
Winslow, 1968). More recent information obtained as a result of a multi-year
study begun in 1980 by ADF&G has confirmed the greater importance of the
Wulik River for char overwintering (Table IV-7). This study has also indi-
cated that the Wulik River may be the more important spawning stream as
well (Table IV-8) (Alt, 1983b; De Cicco, 1982, in press). Identified Arctic
char overwintering and spawning areas within the Red Dog project area are
shown on Fig. IV-9.
The general life history of Arctic char in the Wulik and Kivalina River
drainages is that spawning occurs from late July to late August (summer
spawners) and during September (fall spawners). Char juveniles are known
to remain in their natal* streams for two to four years before entering the
sea. Once these fish have gone to sea they return to freshwater streams
each year to overwinter.
* Defined in Glossary.
IV - 32
-------
De Cicco (in press) has found that char exhibit homing tendencies to natal
streams for spawning but that they may overwinter in other than natal
streams. In particular, char from the Noatak River have been found to
overwinter in the Wulik River, further emphasizing the value of the Wulik
River to the maintenance of the very important char resource.
Table IV-7
RESULTS OF AERIAL SURVEY COUNTS FOR
OVERWINTERING ARCTIC CHAR IN THE WULIK AND KIVALINA
RIVERS, 1968 TO 1982
Year
1968
1969
1976
1979
1980
1981
1982
Wulik River
90,236
297,257
68,300
55,030
113,553
101,826
65,581
Kivalina River
27,640
--
12,600
15,744
39,692
45,355
10,932
Source: De Cicco, in press.
The major char spawning areas in the Wulik drainage are the West Fork,
Main Fork, and main stem of the Wulik down to the confluence of Tutak
Creek, Ikalukrok Creek and Tutak Creek (Figure IV-9). The major char
spawning areas in the Kivalina drainage are the Main Fork and Grayling,
Baqhalik and Fivefingered Creeks (Fig. IV-9), even though lower Grayling
Creek can be dry during the summer months (Dames & Moore, 1983b).
Juvenile Arctic char have been captured in Rabbit and Fivefingered Creeks
by E.V.S. Consultants (1983).
In addition to Arctic char occurrence throughout the Wulik River, salmon
species spawn in the lower portions of the Wulik. Pink salmon spawn in the
lower 8 to 9.6 km (5 to 6 mi) of the river; sockeye salmon spawn below
Wulik Forks; and chum salmon spawn in the lower 19 to 22.4 km (12 to 14
mi) of the river, and for approximately 32 km (20 mi) up Ikalukrok Creek
(Dames & Moore, 1983a). Coho and king salmon have also been reported in
the river (Alt, 1978, 1983a). Other species present in the Wulik include
IV - 33
-------
Table IV-8
SUMMARY OF NUMBER OF FISH COUNTED IN ADF&G ARCTIC CHAR
SPAWNING SURVEYS, 1981 to 1983
Survey Date
Wulik River System 8/20/81 8/6-8/82 9/30/82 8/24/83
Main Fork above Sheep Creek -- -- -- 12
Sheep Creek 44 28 59 123
Main Fork, Sheep Creek to Lik Camp -- -- -- 158
Main Fork, Lik Camp to Forks -- -- -- 53
Main Fork -- 73 2
West Fork, Falls to Forks -- 133 30 196
Main Stem, Forks to Ikalukrok Mouth -- -- -- 386
Main Stem 129 184 20
Wulik below Ikalukrok Creek -- -- -- 8
Ikalukrok Creek 89 60 -- 185*
Dudd Creek -- -- -- 16
Tutak Creek -- -- -- 43
Total 262 478 111 1,180
Kivalina River System
Kivalina River -- 299 40
Main Fork 331 -- -- 412
West Fork -- 7 0 10
Grayling Creek 106 146 -- 183
Main Stem below Forks 40 -- -- 90
Baqhalik Creek 51** -- -•- --
Total 528 452 40 695
Omikviorok River 114*** __ _- 133
-- Not distinguished or not counted.
* 26 of these were above Red Dog Creek; 19 were between Dudd and Red
Dog Creeks.
** 245 char were observed in Baqhalik Creek on 9/25/81
*** Surveyed 7/26/81
Sources: Alt, 1983b; De Cicco, 1982, in press.
IV - 34
-------
h- QC
UJm Z O *
-I™ LJ 0. <
Cft
Z
_ < 5
00 O K <
0-t- 5 t-
FIGURE IV-9 FISH
OCCURRENCE IN PROJECT AREA
OURCE.
OAMESa MOORE
IieCICCO, 1982,
-------
slimy sculpin (Cottus cognatus), round whitefish (Prosopium cylindraceum),
humpback whitefish (Coregonus pidschian), least cisco (X. sardinella),
Bering Cisco (C_. laurettae) and Alaska blackfish (Pallia pectoralis).
In addition to char occurrence throughout the Kivalina, a few chum salmon
(Dames & Moore, 1983b) and about 26,000 pink salmon (De Cicco, "m press)
have been observed spawning downstream of the forks in the Kivalina River.
Other species commonly reported in the Kivalina drainage system include
Arctic grayling, round and humpback whitefish, least and Bering Cisco,
Alaska blackfish and ninespine stickleback (Pungitius pungitius).
Studies by Dames & Moore (1983a, 1983b), E.V.S. Consultants (1983) and
Alt (1983b) indicate that Red Dog Creek and its tributaries are largely de-
void of fish except for small numbers of Arctic char and Arctic grayling that
ascend to the North Fork during high spring flows to spawn. The general
absence of fish species in the Red Dog Creek system is probably due to low
pH and the high concentrations of dissolved metals that enter the main stem
as it flows past the main ore body in Red Dog Valley. The North Fork of
the creek is unaffected by the ore body and is, therefore, able to support
small populations of spawning char and grayling.
It is not known what percentage of juvenile and adult fish survive the
downstream migration from the North Fork of Red Dog Creek, through the
main stem/ to the relatively uncontaminated water of Ikalukrok Creek.
Dying juvenile grayling were observed in Red Dog Creek subsequent to the
high spring flow period (Dames & Moore, 1983a). The North Fork is known
to be frozen to its bed in some areas during the winter, although some
Arctic grayling have been captured there which appear to be in their second
year of life.
Baseline water quality characteristics and caged-fish studies (E.V.S.
Consultants, 1983) at the mouth of Red Dog Creek show that these waters
are toxic to fish during the summer. Analysis for dissolved metals indicated
that, of the metals examined, only zinc was in the range expected to be
acutely lethal without the interaction of other toxicants (Gregory, 1974).
However, dissolved cadmium values were above those found to cause sub-
lethal effects to brook trout (Salvelinus fontinalis) (Benoit et al., 1976).
Water quality analyses of Ikalukrok Creek just downstream of the mouths of
Red Dog and Dudd Creeks indicate that, for these sites, existing levels of
dissolved zinc would be expected to be acutely lethal to fish or cause sub-
lethal effects, and levels of dissolved cadmium could cause sublethal effects.
Ikalukrok Creek is used by Arctic char, Arctic grayling and salmon species
for spawning, rearing and migration. Char use the stream in its lower
reaches up to the vicinity of its confluence with Red Dog Creek, with a few
spawners passing further upstream (Table IV-8, Fig. IV-9). Grayling have
been found in good numbers throughout the stream. Chum salmon are
known to spawn as far upstream as Dudd Creek, but have not been found
above this point. Benthic organisms in Ikalukrok Creek downstream of Red
Dog Creek have shown both a reduction in diversity and numbers resulting
from the influence of Red Dog Creek.
It is not known whether Red Dog Creek actually causes a partial chemical
barrier to char moving up Ikalukrok Creek. However, the fact that other
IV - 36
-------
biological responses have been detected (benthic invertebrates), and that
char are uncommon near Red Dog Creek while grayling are present, may
indicate a greater sensitivity by char and possible avoidance of the area
influenced by the creek. The possible differential avoidance of the affected
area by these two fish species may in part be due to migration timing (i.e.,
grayling migrate during spring high water flow when lower metal concentra-
tions are found; char migrate during summer low flow when higher metal
concentrations exist). Zinc is known to cause avoidance by salmonid fish at
concentrations of 0.054 ring/2 (Salmo salar) (Sprague et al., 1965) and 0.0056
mg/S. (S. gairdneri) (Clarke, 1974). Avoidance reactions to other metals are
not well known.
Dudd Creek is a tributary to Ikalukrok Creek and supports both Arctic char
and Arctic grayling in its lower reaches (Dames & Moore, 1983a). This
stream provides spawning habitat for char which were enumerated in 1983 by
ADF&G (Table IV-8). The 16 adult char counted made up about one to two
percent of the known spawning population in the Wulik drainage.
Tutak Creek enters the Wulik River approximately 5 km (3 mi) downstream of
the mouth of Ikalukrok Creek. This stream supports populations of slimy
sculpin, Arctic grayling and juvenile Arctic char (E.V.S. Consultants,
1983). Char spawning was observed by De Cicco (in press) to occur in
locations indicated on Figure IV-9.
Metals in fish tissues from the entire project area were investigated. It was
found that cadmium, zinc and copper were elevated in fish captured in the
Wulik River drainage. The extent of elevation was related to proximity to
Red Dog Creek and probable duration of exposure to that creek over the
summer. Other metals examined did not demonstrate elevated levels in fish
tissues, and fish from other drainages did not exhibit elevated metals levels.
Guidelines for human consumption have not been established for any of the
three metals which showed accumulation in fish flesh.
Accumulation of metals in fish tissues is a direct result of metals being
absorbed more rapidly than they can be excreted. The rate of accumulation
is dependent on the ambient level of biologically available metals. These
levels vary with proximity to the source of metals, other water quality char-
acteristics, season and the particular metals and fish species under consid-
eration. Metals found to be elevated in Wulik River fish (cadmium, zinc and
copper) do not accumulate in fish through the food web, but instead enter
fish in a free ionic state, primarily by passing directly across gill mem-
branes. Apparently, conditions required for the accumulation of metals
other than cadmium, zinc and copper do not occur because the excretion
rates of fish species involved do not allow accumulation, the metals are not
biologically available, or a combination of these two reasons.
Marine Biology
Much of the coastline from Mapsorak Lagoon in the north to Kotlik Lagoon in
the south is characterized by a series of open or closed lagoons fronted by
barrier beaches. These lagoons tend to be larger in areas where the land
slopes gently to the Chukchi Sea (such as at Kivalina and Imikruk Lagoons),
and smaller in areas of steep slope (such as at Kavrorak and Tugak Lagoons
at the base of the Siaktak Hills). Four rivers (the Singoalik, Kivalina,
IV - 37
-------
Wulik and Omikviorok Rivers) enter the Chukchi Sea through lagoons in the
study area.
The 15 m (50 ft) depth contour extends approximately 8 km (5 mi) offshore
at the southern end of the study area, and approximately 6.4 km (4 mi) off-
shore in the north near Asikpak Lagoon. The sea floor in the project area
is predominantly muds and sands with a mixture of gravel and angular
rocks. In general, sands predominate in shallow areas less than 5 m (16 ft)
deep, while gravel, angular rock and boulders overlain by finer sands and
mud are found in deeper 15 m (50 ft) areas. Attached macroscopic algae are
scarce in the area.
Marine Invertebrates
During the open water period in 1982, infaunal* communities were sampled
along five transects in the study area (Fig. IV-10) (Dames & Moore, l983a).
In late July and late August, the infaunal community was numerically domin-
ated by polychaetes (segmented worms), followed by crustaceans (amphipods
and cumaceans), nematodes (roundworms), tunicates (sea squirts), bivalves
(clams) and ophiuroides (brittle stars). The distribution and numerical
densities of taxa varied over the study area, but certain patterns were
apparent. In general, polychaete species tended to dominate both shallow
(5 m [16 ft]) and deeper water (15 m [50 ft]) areas. Cumaceans, nematodes
and tunicates occurred primarily in shallow water depths, while ophiuroids
and bivalves tended to occur in deeper water. Amphipods were collected at
both shallow and deeper depths.
Numerical densities throughout the study area ranged from 267 organisms/m2
(11 ft2) to over 24,000 organisms/m2 (11 ft2). In general, the number of
species and organisms per square meter increased with increasing depth
throughout the area. This pattern was probably due to differences in sea
floor disturbance and sediment type between shallow and deep water sta-
tions.
Epibenthic* invertebrates in the study area were also sampled by Dames &
Moore (1983a). Dominant organisms captured in epibenthic sled tows were
gammarid amphipod crustaceans. Mysids (opposum shrimp) and crangonid
shrimp also comprised a large portion of the catch. Gammarid amphipods
were abundant at all depths sampled, while mysids were most abundant be-
tween 0 and 5 m (16 ft). Crangonid and pandalid shrimp were collected in
large numbers between 10 and 15 m (33 and 50 ft.) depth. Brittle stars
were locally abundant at deeper stations where mud and silt sediments pre-
dominated.
Species diversity of epibenthic sled catches was generally high throughout
the study area and tended to increase with increasing depth. The number
of species as well as numerical abundance also increased with increasing
depth. The lowest diversity occurred at Transect 8 where the gammarid
amphipod Monoculodes sp. made up over 89 percent of the organisms col-
lected (Fig. IV-10).
Otter trawl catches were dominated by seastars, particularly the species
Asterias amurensis. Other common seastar species were Lethasterias nani-
* Defined in Glossary.
IV - 38
-------
.
UJ
o
UJ
(9
FIGURE IV-10 MARINE BENTHIC INFAUNA
SAMPLING STATIONS
-------
mensis, Leptasterias sp. and Crossaster papposus. Crangonid shrimp were
also commonly collected in otter trawls (Crangon spp., Sclerocrangon
boreas), as was one species of pandalid shrimp (Pandalus goniurus). A
helmet crab (Telmessus cheiragonus) was the only species of crab taken by
otter trawl.
Results of diver transects indicated that densities of benthic invertebrates
were considerably higher than those estimated by trawls. Seastar and crab
species predominated, and increased in number with increasing depth.
Sessile species of anthozoans (sea anemones) and sponges were particularly
abundant at 15 m (50 ft), especially offshore at Ipiavik Lagoon (Transect 4)
and Pusaluk Lagoon (Transect 7). Species compositions between transects
were generally similar (though densities varied), except at the 15 m (50 ft)
depth at Transect 7 (Fig. IV-10), where the bottom consisted of rock rather
than fine sediments and species diversity was greater.
Marine Fish
Concurrent with the benthic invertebrate sampling program, marine fish were
sampled in the study area using beach seines, fyke net sets and otter trawls
in the open water period of 1982 (Dames & Moore, 1983a). A total of 626
individuals representing 20 species was captured by all the sampling efforts.
Otter trawls captured the greatest number of fish (74 percent of the total).
Starry flounder (Platichthys stellatus), Arctic flounder (Liopsetta glacialis),
rainbow smelt (Osmerus mordax dentex) and saffron cod (Eleginus gracilis)
were captured by all of the sampling methods. Arctic cod (Boreogadus
saida), which is probably common in the area, was not captured by any
method used (Table IV-9).
Beach seine catches were dominated by saffron cod, followed in decreasing
order by starry flounder, Pacific herring (Clupea harengus pallasi), Arctic
flounder, rainbow smelt and surf smelt (Hypomesus pretiosus).
The most abundant species captured in fyke net catches was saffron cod (65
percent of total). Other species captured included Atka mackerel (Pleuro-
grammus monopterygius), Pacific herring, starry flounder and rainbow smelt.
Otter trawl catches were dominated by saffron cod, yellowfin sole (Limanda
aspera) and Alaska plaice (Pleuronectes quadrituberculatus). Other species,
in order of decreasing abundance, included Arctic shanny (Stichaeus punc-
tatus , slender eelblenny (Lumpenus fabricii), Arctic flounder, longhead dab
(Limanda proboscidea), starry flounder and rainbow smelt. Numbers of
species and individuals captured in otter trawls increased with increasing
depth. The otter trawl catches did not present any unexpected findings.
Data using comparable sampling methods is not available for this area.
Although overall abundances were low (110 individuals), a total of six anad-
romous fish species was collected in beach seine hauls throughout the samp-
ling period. Pink salmon and Bering cisco (Coregonus laurettae) were by
far the most numerous species collected. Other species taken infrequently
were humpback whitefish, chum salmon, Arctic char and Arctic grayling.
IV - 40
-------
Table IV-9
NUMBERS AND PERCENT OCCURRENCE OF MARINE FISH SPECIES COLLECTED
DURING SUMMER 1982 BY VARIOUS GEAR TYPES
Species
Starry flounder - Platichthys stellatus
Arctic flounder - Liopsetta glacialis
Yellowfin sole - Limanda aspera
Longhead dab - Limanda proboscidea
Alaska plaice - Pleuronectes quadrituberculatus
Pacific sand lance - Ammodytes hexapterus
Rainbow smelt - Osmerus mordax dentex
Pacific herring - Clupea harengus pallasi
Saffron cod - Eleginus gracilis
Tubenose poacher - Pallasina barbata aix
Sturgeon poacher - Agonus acipenserinus
Atka mackerel - Pleurogjammus monopterygius
Fourhorn sculpin - Myoxocephalus quadricornis
Slender eelblenny - Lumpenus fabricii
Arctic shanny - Stichaeus punctatus
Bering poacher - Occella dodecaedron
Surf smelt - Hypomesus pretiosus
Larval smelt - Family Osmeridae
Ringtail snailfish - Liparis rutteri
Nine-spine stickleback - Pungitius pungitius
Beach
No. %
7
2
2
5
24
2
4
46
Seine
of Total
15.2
4.4
4.4
10.8
52.2
4.4
8.7
100.0%
Gear
Fyke
No. %
7
1
1
4
8
77
19
1
118
Type
Net
of Total
5.9
0.8
0.8
3.4
6.8
65.3
16.1
0.8
100.0%
Otter
No. %
14
17
94
16
87
3
10
143
11
9
9
6
20
21
1
1
462
Trawl
of Total
3.0
3.7
20.4
3.5
18.8
0.7
2.2
30.9
2.4
1.9
1.9
1.4
4.3
4.5
0.2
0.2
100.0%
Source: Dames & Moore, 1983a
-------
Beach seines were used to sample several lagoons in the study area (Dames
& Moore, 1983a). At the time of sampling, Ipiavik Lagoon was the only
water body open to the sea. This lagoon contained three marine species
(Arctic flounder, starry flounder and Pacific herring) and the fry of two
anadromous species (humpback whitefish and pink salmon). Kavrorak Lagoon
was also sampled by beach seine and contained landlocked Arctic char. Both
lagoons also contained ninespine stickleback, a typical estuarine species.
Marine Birds and Mammals
Marine birds in the vicinity of the project area would generally be associated
with the colonies at Cape Thompson. In the early 1960's these cliffs sup-
ported over 400,000 seabirds (Swartz, 1966), although numbers have steadily
declined since then (Springer and Roseneau, 1977, 1982). Marine birds
generally forage well offshore to the south of Cape Thompson and would not
normally be found in significant numbers nearshore in the project area.
Marine mammals of the Chukchi Sea have received considerable attention be-
cause of their importance to Native subsistence lifestyles as well as their
ecological significance (Johnson et al., 1966; Burns and Harbo, 1972; Burns
and Eley, 1978). Depending upon the time of year and ice conditions, the
eastern Chukchi Sea/Kotzebue Sound region supports four species of seals:
the ringed seal (Phoca hispida), spotted seal (P. largha), bearded seal
(Erignathus barbatus) and ribbon seal (P. fasciata). Of these, only the
ringed, spotted and bearded seals may be considered common.
The ringed seal is a winter inhabitant of Kotzebue Sound, being most common
in the eastern sound where fast ice predominates. It is less common along
the coast near Kivalina which is dominated by a persistent polynya*.
Pupping occurs primarily in the limited fast ice along the shore during late
March/early April (Burns, personal communication).
The ringed seal is replaced by the spotted seal during the ice-free summer
period. Bearded seals may be found during the periods of ice formation and
breakup. The northern fur seal (Callorhinus ursinus) has occasionally been
reported in the region.
Four species of cetaceans (whales and porpoises) are found in the region.
These are the belukha or white whale (Delphinapterus leucas), Gray whale
(Eschrichtius robustus), bowhead whale (Balaena mysticetus) and the harbor
porpoise (Phocoena phocoena). Only the belukha and Gray whales can be
considered common. Gray and bowhead whales are classified as endangered
species under the federal Endangered Species Act. Harbor porpoise are
common, but occur in low numbers.
A large group of belukhas numbering over 10,000 winters in the Bering Sea.
While a majority of these animals moves north in the spring through the
Bering Straits, past Point Hope and into the Beaufort Sea, a group number-
ing between 500 and 1,800 enters eastern Kotzebue Sound about mid to late
June. Most of these individuals stay in the area between Kotzebue and
Eschscholtz Bay, but others may be found throughout the sound. Some
* Defined in Glossary.
IV - 42
-------
calving occurs. In early to mid July many of the belukhas apparently move
out of the sound, possibly to and past Point Hope (Frost, personal commun-
ication).
From their wintering grounds in the western and central Bering Sea, the
western Arctic population ,of bowhead whales usually begins its northward
(spring) migration in early April. After passing through the Bering Strait
and into the Chukchi Sea, generally west of Big Diomede Island, the whales
follow ice leads seaward of landfast ice. These leads usually bring them
across outer Kotzebue Sound in a northeasterly direction to the vicinity of
Cape Thompson (McVey, personal communication). Some whales move
through the polynya that forms west of the project area between Kivalina
and Point Hope (Braham and Krogman, 1977; Braham et al., 1980). During
the past three years, National Marine Fisheries Service (NMFS) data show
very few bowheads east of approximately 167° W longitude, well away from
the project area (Johnson, personal communication). From Cape Thompson
open leads are again followed past Cape Lisburne to Point Barrow (Braham et
al., 1980; Rugh and Cubbage, 1980) and northeastward toward Banks Island
in the Canadian Beaufort Sea where the majority of the whales arrive by
mid-June to spend the summer. The fall migration toward the Bering Strait,
after passing Point Barrow, is believed to occur in the western Chukchi Sea
well to the west of the project area (Braham and Krogman, 1977; Cowles,
1981).
Gray whales migrating north from their wintering grounds enter the Bering
Sea in April or May with many moving through the Bering Strait into the
Chukchi Sea by June. During the summer most of the population concen-
trates in shallow waters around St. Lawrence Island north to the Chukchi
Sea (McVey, personal communication). Sightings suggest that they occur in
low densities in nearshore areas in Kotzebue Sound and north of 69°N lati-
tude (Marquette and Braham, 1982). Southward migrations appear to be
through the western Chukchi Sea.
Walrus (Qdobenus rosemarus) are also found in the area during the ice-free
season, but they are uncommon or only occasional visitors to the area.
Polar bears (Ursus maritimus) occur along the coast of the project area dur-
ing the winter. Their numbers vary greatly between years depending upon
the timing and direction of ice movements. In most years very few bears
are normally found between Kivalina and Point Hope, but when northwest
winds drive the ice southeast along this coast, polar bear numbers can in-
crease significantly.
Threatened or Endangered Species
Two species of marine mammals are listed as endangered: the bowhead and
Gray whales. These species are primarily migrants through the project area
during their northern movements in the spring, normally staying well to the
west in the Chukchi Sea during their southward migrations in the fall.
Additional information may be found in the preceding section on marine birds
and mammals, and in Appendix 3 (Endangered Species Biological Assessment).
IV - 43
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Physical and Chemical Oceanography
The coastline in the study area between latitudes 67°39'N and 68°00'N, has a
relatively straight northwest to southeast orientation with a land surface
consisting of a gently sloping plain. This plain continues underwater so
that the 15 m (50 ft) depth contour lies nearly 8 km (5 mi) offshore in most
locations. The area is also characterized by a series of open or closed
lagoons fronted by barrier beaches or islands.
Currents/Circulation
Oceanographic conditions in the southeastern Chukchi Sea were shown by
Barnes and Thompson (1938) to be primarily influenced by the northward
flow of water through the Bering Strait. Studies conducted by Fleming and
Heggarty (1966) showed that currents along the coastline are strongest near
shore, generally to the north or northwest, and roughly equal in velocity at
5 and 20 m (16 and 66 ft) depths. Current speeds range from approximately
0.5 to 1.0 m/s (1 to 2 knots) through summer. Wind and winter ice cover
movement can retard or reverse surface currents. Fleming and Heggarty
(1966) found that water residence time in the Chukchi Sea is short. An
average of 15 days is required for water to move from the Bering Strait to
Point Hope.
Diurnal tides occur in the Chukchi Sea, but the estimated tidal range of 0.3
to 0.8 m (1.0 to 2.6 ft) is quite small. Published tidal data for Kiwalik
(southern Kotzebue Sound) shows a mean tidal range of 0.6 m (2.0 ft).
Wind and Wave Climate
Wind and wave conditions have a significant effect on sediment movements
along the coast. Due to a lack of consistent long-term data for the study
area, it is difficult to determine typical wind velocity and wave height values
and therefore make predictions about the longshore transport of sediments.
Generalized data indicate that prevailing summer (June to October) winds are
from the northwest to west and range from 4 to 5 m/s (8 to 10 knots).
These winds occur about 50 percent of the time. The next most prevalent
wind direction is from the south to southeast and occurs about 25 percent of
the time. Major storms with winds up to 35 m/s (70 knots) generally come
from this direction.
Wave height is directly related to wind fetch and wind duration. A 2.6 m
(8.5 ft) wave could be generated in one hour by a 35 m/s (70 knot) wind
blowing over a fetch of 320 km (200 mi), while 3.3 m (11 ft) waves could be
expected from a 25 m/s (50 knot) wind blowing for 4 hours. Breaker height
is dependent on wave height, wave periodicity and the slope of the beach.
For example, a 3.3 m (11 ft) wave could run up a 0.028 slope beach (as
found at the port site) to a height of 3.6 m (12 ft). Storm surges may
raise the sea level by as much as 3 m (10 ft). Waves under these conditions
could cause significant erosion and breaching of coastal barrier beaches
found in the project area.
IV - 44
-------
Wind and wave statistics were estimated for the port sites using Kotzebue
records of wind speeds and directions. These statistics were developed for
the approximately 100 shipping days from the end of June until early
October (Table IV-10).
Table IV-10
PERCENT OCCURRENCE OF HIGH WINDS AND ASSOCIATED STORM WAVES
(NOT INCLUDING SWELL) AT THE PORT SITES
Percent
Event Occurrence
Wind Speed
6.5 to 8.5 m/s (13 to 17 knots) 16.0
9.0 to 11.0 m/s (18 to 22 knots) 9.5
11.5 to 13.5 m/s (23 to 27 knots) 2.5
14.0 to 16.0 m/s (28 to 32 knots) 0.5
Storm Wave Height
>1.2 m (4 ft) and <1.5 m (5 ft) 7.2
>1.5 m (5 ft) and <1.8 m (6 ft) 4.4
>1.8 m (6 ft) and <2.1 m (7 ft) 2.0
>2.1 m (7 ft) 3.0
Source: National Climatic Center Records, 1973 to 1982
Wave statistics developed for the Northern Pacific have shown that the mag-
nitude and frequency of swell waves (generated by distant storm winds) are
approximately the same as local storm waves. The significant storm wave
percent occurrence (Table IV-10) should, therefore, be doubled to account
for swell waves generated by storms offshore in the Chukchi Sea. Thus,
lightering operations and loading operations on unstable platforms would be
difficult or dangerous at wind speeds over 11 m/s (22 knots) (three percent
of the time), and during waves over 1.5 m (5 ft) (18.8 percent of the time).
These combined adverse conditions would occur approximately 20 to 22 per-
cent of the time at the port sites.
IV - 45
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Coastal Geologic Processes
Studies by Moore (1966) and Hopkins (1977) indicate that long-term net sedi-
ment transport is in a southeasterly direction, though average annual sedi-
ment movement takes place perpendicularly to the shoreline. Huge quantities
of beach sand (on the order of millions of cubic meters) can be washed out
in a single storm and deposited as a bar near the wave break point. For
example, on August 9, 1960, Ogotoruk Beach, located 66 km (41 mi) north-
west of Kivalina, was lowered 1.0 m (3.3 ft) by waves 15 m (50 ft) long and
1.4 m (4.6 ft) high (Moore, 1966). Sediments subsequently are restored to
beaches by more normal sea conditions.
In addition to the huge movement of beach sediment perpendicular to shore,
a small component of net sediment movement is directed southeasterly be-
tween Point Hope and Cape Krusenstern. Sediment movement can thus be
pictured as a zig-zag pattern with a small but important quantity displaced
southward in an average year. Over a long period, Moore (1966) estimated
that about 22,000 m3 (28,780 yd3) of sediment are annually transported along
the shore to Sheshalik Spit, 43 km (27 mi) east-southeast of Cape Krusen-
stern. Quantities of sediment moved vary considerably each year.
Woodward-Clyde Consultants (1983) calculated that 82,580 m3 (108,000 yd3)
of sediment were transported southeast along the coast each year. In some
years a reverse movement of sediment may also occur.
Hopkins (1977) calculated that beach erosion between Kivalina and Cape
Krusenstern is of the same order of magnitude as the quantity of material
deposited in the Cape Krusenstern beach ridge complex. Apparently rivers
and streams (such as the Singoalik and Wulik Rivers and Agagrak, Rabbit
and Kilikmak Creeks) as well as submerged sand bars serve as sediment
sources. Most sediment transport probably occurs in the summer months
when winds are predominantly from the west and northwest. Sediment dis-
placed in the winter by ice action is probably insignificant compared to wind-
driven sediment transport (Moore, 1966).
Marine Water Quality
The Chukchi Sea typically has relatively warm, low salinity water present
near shore. Following ice breakup in late June, freshwater influence near
shore is high due to melting ice and high stream runoff. Incoming fresh
water dilutes nearshore surface waters in summer so that salinities range
from 22 to 29 parts per thousand (ppt). Colder, deeper water and water
farther offshore typically has salinities ranging from 31 to 33 ppt. There is
a trend for salinity to increase in surface waters from late June through late
August. Seawater temperatures along the coast are generally quite warm
(11° to 14°C [52° to 57°F]). No significant cooling or warming trend occurs
over the summer, nor are seawater temperatures significantly warmer
(greater than 0.5°C difference) nearshore compared to offshore.
Temperature and salinity measurements were taken in the study area during
the open water period of 1982 (Dames & Moore, 1983a). In general, tempera-
ture and salinity profiles showed decreasing temperature and increasing sa-
linity values with depth. At deeper stations, the surface water layer was
IV - 46
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well mixed to a depth of 6 to 8 m (20 to 26 ft), and a sharp thermocline*
was present between 8 and 10 m (26 to 33 ft). A thermocline occurs where
there is a rapid decrease in water temperature with depth, in this case a
2.1°C (3.8°F) difference in 2 m (6.6 ft). At shallower, more nearshore
stations, a less distinct thermocline (1.1°C [2.0°F] temperature change in 2
m [6.6 ft]) occurred between 4 and 8 m (13 and 26 ft) of depth. Salinity
varied from 25 ppt at the surface to 31 ppt at a depth of 12 m (40 ft).
Lagoons in the study area are highly variable in physical and chemical
parameters. Closed lagoons tend to be mostly freshwater with a slight
brackish nature near their ocean shorelines. Open lagoons are normally
more saline near the opening and fresher near the creek and river mouths.
Ice Conditions
Sea ice generally begins to form on the coast in early October, but periodic
high winds and waves may delay formation of solid cover until January. Sea
ice normally reaches a thickness of 2 to 3 m (6.6 to 9.8 ft) during the
course of the winter, but can reach greater depths when it is piled up due
to storm driven currents. Melt pools and cracks begin to form in May and
June, and the ice cover usually disappears by early July. The edge of
landfast ice is usually 3 to 8 km (2 to 5 mi) offshore in an average winter.
The edge of landfast ice usually approximates the 9.2 m (30 ft) depth con-
tour where it can contact the bottom when it is piled into ridges. Landfast
ice, though stable through winter, is subject to movement during break-up.
Pack ice generally retreats north of Point Hope in August, September and
October. During late winter and spring, pack ice and landfast ice are
usually separated by a shear zone approximately 64 to 80 km (40 to 50 mi)
wide with open leads present.
Shore ice pile-up has been observed on the Chukchi and Beaufort Sea coasts
to heights of over 9.2 m (30 ft) up to 9.2 m (30 ft) onto the beach. The
same pile-up heights could occur on offshore structures. Ice run-up has
been observed also when relatively thin sheets of ice (0.6 to 1.5 m [2 to 5
ft] thick) run up beaches as far as 92 m (300 ft) from the water's edge.
Ice run-up reached heights of 9.2 m (30 ft) above the beach water line.
Meteorology and Air Quality
Meteorology
When the Chukchi Sea is generally ice-free (late June through early Octo-
ber), the coast of the project area is dominated by a polar maritime climate,
with cooler air temperatures, more frequent fog and clouds, and stronger
westerly winds compared to the inland transportation corridors and the De
Long Mountains. The summer inland climate is more continental with greater
sunshine, greater daily temperature swings and variable winds. In winter
months, climate is generally similar on the seacoast and inland, with some
differences in wind, precipitation and temperature depending on proximity to
* Defined in Glossary.
IV - 47
-------
the De Long Mountains. Mountain locations would have more variable winds,
greater precipitation and warmer temperatures compared to coastal locations.
Meteorological data applicable to the Red Dog project area were available for
Kotzebue, Point Hope and Cape Lisburne from the National Climatic Center.
Comprehensive meteorological records were also available for a two-year
period from Ogotoruk Valley (Project Chariot) at Cape Thompson, 65 km
(40 mi) northwest of Kivalina. A compilation of climatological data for the
coastal regions was available in Brower et al. (1977).
o
Near the seacoast, typical summer temperatures range from 4° to 13°C (39
to 55°F) and winter temperatures range from -26° to -15°C (-15° to 5°F).
Seacoast temperature extremes are -47°C (-53°F) in winter and 29°C (84°F)
in summer. In the De Long Mountain foothills, summer temperatures typi-
cally fluctuate between 2° and 18°C (36° and 64°F), with extreme high tem-
peratures near 32°C (90°F). The winter inversion layer usually lies below
the higher hills and ridges of the De Long Mountains, so extreme winter low
temperatures occur less frequently in the mountains.
Mean monthly cloudiness over the seacoast ranges from 50 to 80 percent,
with most clear days occurring in winter. Fog occurs about 10 percent of
the time on the coast. The sun is continuously above the horizon for
approximately seven weeks centered around June 22 (the summer solstice).
Due to orographic* shading by the De Long Mountains, the sun sets for a
few hours in Red Dog Valley, even in June. The sun is continuously below
the horizon for approximately four weeks centered around December 22 (the
winter solstice). A minimum of 4 to 5 hours of twilight adequate for outdoor
activities occurs during this time.
Mean annual precipitation on the seacoast and coastal lowland is approxi-
mately 25 cm (10 in). Orographic effects cause precipitation to increase to
38 cm (15 in) on the coastal upland, and precipitation ranges from 51 to 76
cm (20 to 30 in) in the De Long Mountains. Nearly half of the mean annual
precipitation occurs as rain during the three months of July through
September. August is the wettest month of the year, receiving one-quarter
of the annual precipitation. Mean annual evaporation from lakes and wet-
lands in Arctic conditions found in the foothills of the De Long Mountains
varies from 15 to 23 cm (6 to 9 in). Most of this evaporation occurs from
May through August.
Snowfall has been recorded every month of the year, but consistent snow
cover generally occurs only from the middle of October to the middle of May.
Maximum snow depths have reached 1.2 m (4 ft), but typical late winter
depths are 0.6 m (2 ft). Considerable blowing and drifting of snow occurs
in coastal locations and on exposed peaks and ridges. In these windy areas,
strong east to northeast winds create bare ground over 30 to 40 percent of
the area. Snowdrifts 1.8 to 3.0 m (6 to 10 ft) deep accumulate in depres-
sions and in the lee of banks.
* Defined in Glossary.
IV - 48
-------
There are marked seasonal differences in wind regime, particularly on the
seacoast. In winter the Arctic Front and associated storm tracks are nor-
mally far to the south. The Polar Cold High generates strong north to east
winds with the direction depending on local topography. Predominate winds
on the seacoast and the coastal upland are easterly, down the Wulik River
valley and parallel to the southern edge of the Brooks Range. During win-
ter this direction predominates over 60 percent of the time, with mean annual
wind speeds for all directions of 5 to 6 m/s (10 to 12 knots). When low
pressure centers are present in the Chukchi Sea, strong southeast winds
blow parallel to the coast.
Summer winds in the coastal areas are much more variable than during win-
ter, and speeds decrease to a mean of 4 to 5 m/s (8 to 10 knots). West to
northwest winds occur approximately 50 percent of the time, while east to
northeast winds occur 35 percent of the time. Most of the west and east
winds result from a sea breeze circulation that develops in late spring after
break-up. The strongest summer winds (south to southeast) are associated
with low pressure centers in the Chukchi Sea and may have maximum wind
speeds of 35 m/s (70 knots).
In the vicinity of the De Long Mountain foothills and in Red Dog Valley,
local topography strongly influences wind direction and velocity. Predomin-
ate winter winds (north to northeast) are channeled by the valleys of the
Wulik River, Ikalukrok Creek, and the North and South Forks of Red Dog
Creek. Mean annual wind speeds average 2.5 to 3 m/s (5 to 6 knots) in
Red Dog Valley. Near calm conditions can be expected 20 percent of the
time on the valley floor due to local cold air pooling.
Summer winds in the De Long Mountain foothills are controlled by local valley
circulation patterns. Up-slope winds occur during the day, and light down-
slope or down-valley winds typically occur at night. Occasional strong
southerly winds may occur in association with storm systems approaching
from the west.
Air Quality
There are no significant air pollutant sources in northwestern Alaska.
Therefore, background levels in the Red Dog project area are assumed to be
negligible. From measurements taken in similar remote areas, air pollutant
concentrations are probably less than follows: particulates 30 |jg/m / nitro-
gen dioxides 10 |jg/m3, sulfur dioxide 3 pg/m3, ozone 60 |jg/m3 and carbon
monoxide 500 |jg/m3.
Natural particulate levels are probably high during strong winds due to lack
of soil-protecting vegetation on hilltops and ridge crests. Observations at
Cape Thompson showed that strong winter winds created large bare areas
which generated surface dust deposits on snow cover downwind. High con-
centrations of smoke particulates may also occur as a result of rare summer
tundra fires.
IV - 49
-------
Visual Resources
Basic methods used to determine the value of visual resources have been
developed by the U.S. Forest Service in its Visual Resources Management
(VRM) Program for the National Forest System. It is used here only as a
classification device without regard to specific land ownership and with no
management implications for lands administered by the NFS.
The visual characteristics of a landscape include visual variety, the number
and interest of viewers, and the land's ability to visually change without
losing its inherent character. Visual variety has been shown to be a good
predictor of viewer preference. The number, interest and location of
viewers are also factors used to identify visually important areas.
For any particular area, visual variety classes are determined based on the
relative value of the surrounding area. For example, lands with visual
variety typical of the region are classified as "common" or Class B lands.
Areas with special patterns of vegetation, water or landforms are considered
"distinctive" or Class A lands. Areas with very little variety or interest are
considered "minimal" or Class C lands.
The Red Dog project area, including the De Long Mountains, the Mulgrave
Hills, and the Kivalina and Wulik River basins, is highly scenic relative to
the lower 48 states. A majority of the project area is rated variety Class A.
Highly rated areas include the shoreline, the larger rivers and adjacent
lakes, notable hills, and the more mountainous areas to the north and east.
The remainder of the landscape is considered Class B. None of the land-
scape is considered variety Class C.
The VRM system combines data on the number and interest of viewers to
determine a sensitivity rating for any particular area. Because of its
remoteness and the limited number of use areas (those being the village of
Kivalina and Cape Krusenstern National Monument), the general visual
sensitivity of the project area is considered to be low. Cape Krusenstern
National Monument is considered an area of high sensitivity based on
projections of future use.
The VRM program combines data on visual variety classes with sensitivity
ratings to determine Visual Quality Objective (VQO) zones. Five general
VQO zones are defined as follows:
0 Preservation - No visual changes permitted.
0 Retention - Visual changes must blend with the form, line, color and
texture of the existing landscape.
0 Partial Retention - Visual changes must be subordinate to and bor-
row visual elements from the natural landscape.
0 Modification - Major visual changes are allowed, but changes must
borrow from existing visual elements of the landscape.
0 Maximum Modification - Major visual changes allowed. Conformity
with the natural landscape is not required.
IV - 50
-------
VQO zones defined in the study area are shown on Figure IV-11. The Wulik
and Kivalina River basins, and the Mulgrave Hills in Cape Krusenstern
National Monument are classified as retention level quality. The remainder of
the project area is generally classified as partial retention quality. In gen-
eral, the project area is high in visual variety but low in visual sensitivity.
Red Dog project components occur in landscapes with varying visual char-
acteristics. The northern transportation corridor passes through areas of
both high and moderate visual variety. The southern transportation corridor
is located predominantly in an area of moderate visual variety, but is close
to viewers in Cape Krusenstern National Monument. The northern transpor-
tation corridor passes through retention quality areas, while the southern
corridor lies within partial retention areas. The port sites are located in
areas of high visual variety and partial retention quality.
Sound
The Red Dog project area is located in a remote region of northwestern
Alaska. The closest communities are the small Native villages at Kivalina
(located on the coast 32 km [20 mi] northwest of the proposed southern port
site), and at Noatak (located 42 km [26 mi] south of Red Dog Valley). Data
from similar remote locations indicate that typical natural noise levels usually
range from 15 to 45 dB(A), which is considered quiet (see Table V-7 for
comparison values). Natural noise levels up to 65 dB(A) may be associated
with storms and wildlife. Areas along the coast would have the highest
noise level due to strong winds, breaking waves, ice movements, marine
mammal cries and bird calls. Maximum natural noise levels along the pro-
posed transportation corridors and in the De Long Mountains would be
caused by wind, rain, wildlife and rare thunder.
Noise associated with the Native communities would not be discernable in
most of the project area, except that resulting from subsistence hunting
activities (use of snowmobiles, outboard motors and float planes). These
types of activities typically generate noise levels up to 85 dB(A) at 15 m (50
ft). Noise is presently being generated by temporary mining exploration
activities concentrated in the De Long Mountains. Infrequent helicopter and
light plane overflights at low altitudes may also occur in the project area.
These flights would generate ground level noise up to 90 dB(A).
Cultural Resources
It is generally accepted that the first Asian immigrants to the North Ameri-
can continent crossed the Bering Strait (Beringia), arriving in what is now
Alaska in the area of the Seward and Lisburne peninsulas. They then
moved eastward, probably north of the Brooks Range, into the Canadian
interior and southward east of the Rocky Mountain chain. This movement is
generally thought to have occurred toward the close of the Wisconsin glacial
advance, perhaps 10,000 to 15,000 years ago, although many scholars have
postulated the initial date of immigration at 80,000 to 100,000 years.
The Alaskan link between Asia and the early human sites in the interior,
while widely accepted in theory, is not well-documented in fact. Tangible
IV - 51
-------
FIGURE IV-11
VISUAL QUALITY
OBJECTIVE ZONES IN PROJECT AREA
-------
evidence may have been inundated as ocean levels rose with the melting of
the continental ice sheets. If so, those data are likely lost to bottom scour-
ing or strong ocean floor currents in the Bering Strait area. Site evidence
may also have been destroyed or disseminated by glacial action or natural
forces associated with land elevation changes resulting from glacial retreat.
It may also be that evidence of this earliest occupation has not been dis-
covered, or perhaps simply not recognized. It is fair to conclude that if
evidence of these first immigrants is to be found, it will likely be discovered
in the region where earliest contact was possible. This would include the
Red Dog project area.
The earliest prehistorical remains in the vicinity of the Red Dog project area
are located on a series of beach ridges at Cape Krusenstern, and form the
core of the Cape Krusenstern National Monument and the Cape Krusenstern
Archeological District (Fig. 1-1). The latter classification requires manage-
ment consideration for any archeological resource in the District (there is a
presumed eligibility to the National Register of sites for all recorded and
unrecorded sites within the Archeological District). The Cape Krusenstern
Archeological District encompasses approximately 809,000 ha (2,000,000 ac)
and includes most of the proposed transportation corridors.
While the National Monument constitutes only approximately 25 percent of the
District, its existence is predicated on the archeological remains in the area
that depict every known cultural period in Arctic Alaska. It is the purpose
of the Monument to preserve and interpret evidence of prehistorical and
historical Native cultures. The easily visible concentration of house and
occupied sites in the Monument are often used as a diachronic* model of
human life in northwestern Alaska (Giddings 1967; Giddings and Anderson,
in press).
Archeological sites located within the Red Dog project area are typical of
interior northwestern Alaska. These sites consist of surface scatters, or
shallowly buried deposits of lithic materials that were used in making stone
artifacts (Hall, 1982a). The localities served as prehistoric flaking stations
associated with upland game procurement, though some may have been
ephemeral camps. More permanent settlements are known closer to the coast,
although the majority of coastal sites within the project area relate to recent
periods (Hall, 1982a,b; 1983a).
Four archeological sites are located in the immediate area of the mine. At
least a dozen more archeological localities are within a 3 km (1.9 mi) radius
of the mine, mill, tailings pond and water storage facilities complex.
There are 13 archeological sites along the southern transportation corridor
(Hall 1982a,b; 1983a). Seven of these sites are within the Cape Krusenstern
Archeological District, with six of those sites being within Cape Krusenstern
National Monument. The other sites are on state selected or tentatively
approved lands. There are 23 archeological sites along the northern trans-
portation corridor (Hall I982a,b; 1983a). None of these sites are within
Cape Krusenstern National Monument or the Cape Krusenstern Archeological
District. All 23 sites are on state selected or tentatively approved lands.
* Defined in Glossary.
IV - 53
-------
Sites related to coastal activities are located at each port site. There is a
small eroding cabin at Tugak Lagoon of which little remains (Hall, 1983a). A
reindeer herding facility is present on private land at the VABM 28 port site
which may provide physical documentation for the historical reindeer herding
activity in this area.
The upland hunting sites of the Red Dog project area may reflect seasonal
use of the interior during months of resource unavailability at the coast.
Similar sites which reflect inland travel from Cape Krusenstern have been
noted for the De Long Mountains (Smith, 1982; Hall, 1982a,b; 1983a).
Subsistence
Subsistence is vital to the economic well being and nutrition of most of the
region's residents. The extent of its importance is indicated by the findings
of a 1978 survey of about one-third of the region's households. Approxi-
mately 55 percent of all households estimated they obtained half or more of
their food supply by subsistence hunting, fishing and gathering (Table
IV-11). This survey found that subsistence dependence was widespread
throughout the region, but much more pronounced in the outlying villages,
including Kivalina and Noatak, than in Kotzebue. In a region where im-
ported foodstuffs are costly and cash income depressed, the economic impor-
tance of the subsistence food supply is evident. Within this general reliance
on subsistence, there is a great deal of variation from settlement to settle-
ment, season to season, and year to year in subsistence harvest patterns
(Social Research Institute, 1982).
The region encompasses a great diversity of terrestrial, freshwater, marine
and wetland habitat types which support many valuable subsistence species.
Virtually the entire region and most of its nearshore marine waters fall with-
in the subsistence use area of one or more villages (Fig. IV-12).
Among the most important subsistence food resources are land mammals
(caribou, moose, Arctic fox and hares), fish (Arctic char, chum salmon,
sheefish, whitefish, tomcod, smelt), sea mammals (bearded, ringed and
spotted seals; belukha and bowhead whales) , ptarmigan and waterfowl.
However, nearly all edible animal species are used to add variety to the
customary diet or in times of scarcity. Berries and other wild plant foods
are extensively gathered for consumption , and driftwood is gathered for
heating and cooking.
Most of these subsistence resources (e.g., caribou, Arctic char, salmon,
marine mammals, plant foods) are either migratory or highly seasonal; the
period of their peak availability is often very brief and localized. Thus, the
yearly cycle of subsistence harvest activites for each settlement reflects
closely the timing and specific mix of locally available resources. Figures
IV-13 and IV-14 show typical annual subsistence activity cycles for Kivalina,
Noatak, and other selected community groups in the region. However, it
should be stressed that the "typical year" rarely occurs because the pattern
of resource availability is so unstable and because the harvest success for
individual families and villages is so variable. Adaptation to these uncertain
circumstances has produced a highly complex, diverse, and flexible pattern
of subsistence activity that continually adapts to harvest opportunities. Ex-
tensive sharing and trade of subsistence harvests among families and between
villages further complicates the picture of subsistence consumption patterns.
IV - 54
-------
Table IV-11
NANA REGION
HOUSEHOLD DEPENDENCY ON SUBSISTENCE HARVEST1
PERCENT DISTRIBUTION
All
Most
Half
Some
None
TOTAL
NANA
Region
7.5
24.8
23.2
36.1
8.5
100.0
Kivalina
5.6
16.7
38.9
38.9
--
100.0
Noatak
--
57.1
28.6
14.3
--
100.0
Kotzebue
5.6
14.9
16.1
49.1
14.3
100.0
Other
Villages2
12.4
30.1
27.5
27.5
2.6
100.0
1 Reply to question: How much of your own food would you say you and
your family gathered, hunted or fished for this year?
2 Other villages include Ambler, Buckland, Deering, Kiana, Kobuk, Noor-
vik, Selawik and Shungnak.
Source: NANA Regional Strategy, Community Survey, 1978
In addition to its economic importance, subsistence is essential in structuring
and sustaining the region's cultural values and social organization. It sus-
tains the important cultural practices of cooperative food-gathering and food-
sharing. Subsistence remains a strong, positive thematic value that binds
families, communities and northwest Inupiat people together as distinctive
social groups.
The current subsistence use areas of Kivalina and Noatak residents that
overlap the project area were recently described and mapped by Braund &
Associates (1983). The two communities make common use of some subsist-
ence resource areas. However, a 1972 survey (Mauneluk Association, 1974)
of overall harvest patterns found distinctive differences in the subsistence
orientations of coastal Kivalina and inland Noatak residents (Table IV-12).
In general, Kivalina was most heavily dependent on sea mammal and fisheries
IV - 55
-------
B RO OK S RANGE
MOUNTAINS
ALASKA MARIT.IME
NATIONAL
x WILDLIFE REFUGE
OfiPE KRUSENSTE*N
RCHEOLOGICALDISTRICT
CAPE KRUSENSTERN
NATIONAL \
VONUMENT
LEGEND
LOWER KOBUKVALLEY VILLAGES (NORVIK,
KIANA)
SUBSISTENCE STUDY BOUNDARY
SELAWIK
VILLAGE LAND SELECTIONS
Source-. Mauneluk Association, 1979
FIGURE IV-12 SUBSISTENCE USE BY
NORTHWESTERN ALASKA NATIVE VILLAGES^/
-------
•n
5
3)
m
0)
c>
m<
3JH
>o
ANNUAL SUBSISTENCE ACTIVITY CYCLE OF THE KUUVANMIIT OF
THE UPPER KOBUK RIVER VILLAGES (KOBUK, AMBLER AND
SHUNGNAK)'
CARIBOU HUNTING
MOOSE HUNTING
BEAR HUNTING
FUR-ANIMAL
HUNTING AND
TRAPPING
WATERFOWL
HUNTING
HARE SNARING
AND HUNTING
PTARMIGAN
SNARING AND
HUNTING
GILL-NETTING
SEINING
FISH HOOKING
BERRY PICKING
EDIBLE PLANT
GATHERING
WOOD CUTTING
WAGE LABOR AND
COMMERCIAL
FISHING
O
SOURCE: MAUNELUK ASSOCIATION, 1979
ANNUAL SUBSISTENCE ACTIVITY CYCLE OFTHE KUUVANMIIT OF
THE LOWER KOBUK RIVER VILLAGES (KIANA AND NORVIK)
WAGE LABOR AND
COMMERCIAL
FISHING
-------
ANNUAL SUBSISTENCE ACTIVITY CYCLE OF NOATAK
ANNUAL SUBSISTENCE ACTIVITY CYCLE OF KIVALINA
23
O
c
JJ
m
OZ
>z
HC
7s 00
-------
Table IV-12
SUBSISTENCE RESOURCES HARVESTED FOR KIVALINA AND NOATAK, 1972
Land Mammals
Sea Mammals
Fish
kg
23,496
55,519
50,326
Kivalina
Ib
51,800
122,400
110,950
Percent
of Total
17.9
42.3
38.3
kg
61,620
7,666
60,653
Noatak
Ib
135,850
16,900
133,718
Percent
of Total
46.3
5.8
45.6
Other (water-
fowl, berries,
greens)
Total
1,988
131,329
4,382
289,532
1.5
100.0
3,057
132,996
6,740
293,208
1.3
100.0
Source: Braund & Associates, 1983 from Mauneluk Association, 1974
harvests, with land mammals seasonally important. Noatak residents were
mostly dependent on land mammals and fisheries; sea mammals were of rela-
tively minor importance.
As shown on Figures IV-15 and IV-16, the proposed mine site is located on
the fringe of the subsistence areas used by Kivalina and Noatak residents.
In addition, the various overland transportation corridors and the port sites
cross or fall within subsistence use lands. Numerous coastal areas, the
Wulik and Kivalina River drainages, and the Mulgrave Hills are used inten-
sively by caribou hunters from both communities. The region is part of the
western Arctic caribou herd's range, but changes in the herd's migration
routes and winter range conditions greatly influence hunting success.
Subsistence fishing is important to both Kivalina and Noatak residents
throughout the year. The fall run of Arctic char is especially important to
both communities, while the Noatak River chum salmon and char runs are
locally important. Kivalina marine mammal hunters intensively search the
nearshore areas off Kivalina and other spots north and south of Kivalina in
season. Both Kivalina and Noatak residents harvest waterfowl in coastal
lagoons and wetlands.
IV - 59
-------
PUNUPKAHROAK
MOUNTAIN
TUGAK LAGOON^ .rv^-
KIVALINA
SUBSISTENCE USE AREAS, 1977-1982
SHEEP
SEA MAMMALS (SEAL,UGRUK,WALRUS a BELUGA)
INTENSIVE SEA MAMMAL HUNTING AREAS
TRAPPING (FOX,WOLVERINE,WOLF)
HUNTING, FISHING 8 TRAPPING CABINS
SPORT HUNTING 8 FISHING LODGE
BOWHEAD WHALING
INTENSIVE BOWHEAD WHALE HUNTING AREA
INTENSIVE CARIBOU HUNTING AREAS
OCCASIONAL CARIBOU HUNTING AREAS
WATERFOWL
WATERFOWL, GREENS 8 BERRIES
— — — — GREENS a BERRIES
. . . . . MOOSE
MAXIMUM USE AREA
SOURCE. BRAUND a ASSOCIATES, 1983
FIGURE IV-15 SUBSISTENCE USE AREAS,
KIVALINA VILLAGE
-------
PUNUPKAHROAK
MOUNTAIN
PARTIAL1 NOATAK
SUBSISTENCE USE AREAS, 1977-1982
LEGEND
D
O
-_-_ SEA MAMMALS (SEAL,UGRUK,WALRUS 8 BELUGA)
TRAPPING (FOX,WOLVERINE,WOLF)
HUNTING, FISHING 8 TRAPPING CABINS
SPORT HUNTING 8 FISHING LODGE
I II III! I I I I I I CHAR FISHING
SHEEP
INTENSIVE CARIBOU HUNTING AREAS
OCCASIONAL CARIBOU HUNTING AREAS
WATERFOWL
MAXIMUM USE
1 THIS RESEARCH ONLY ADDRESSED USE AREAS POTENTIALLY
AFFECTED BY RED DOG PROJECT DEVELOPMENT 8 NOT ALL
NOATAK RESOURCE USE AREAS.
^SOURCE- BRAUND 8 ASSOCIATES, 1983
FIGURE IV-16
SUBSISTENCE USE AREAS,
NOATAK VILLAGE
-------
Socioeconomics
The NANA region encompasses approximately 93,000 km2 (36,000 mi2) and 11
settlements with a population of 4,830 residents according to the 1980 cen-
sus. Overall, the region is sparsely populated, relatively undeveloped, and
lacking a unifying regional government. Nevertheless, the villages comprise
a true region which is linked by strong economic, ethnic and cultural ties;
common transportation and communications systems; and governmental and
other important institutional bonds. The coastal community of Kotzebue is
the largest settlement in the region. It is the natural hub of the region's
transportation and distributive system, and the administrative and service
headquarters for most of the public agencies and other institutions serving
the region.
Population
Approximately half of the population of the NANA region lives in Kotzebue,
with the rest spread among 10 smaller villages (Table IV-13). Alaska
Natives, mainly Inupiat Eskimos, comprise about 84 percent of the region's
population. Most non-Native people in the region live in Kotzebue.
The region's population is relatively young, with a median age of 21.6 years.
The distribution by age group has become fairly even (Table IV-14), indi-
cating that the period of very high birth rates and rapid natural increase
has subsided. Males (53.7 percent) outnumber females (46.3 percent), espe-
cially through the post-school age groups, which suggests a pattern of
selective outmigration by young adult females. Average household size is
relatively large (4.2 persons per household).
The region's population growth rate from 1970 to 1980 was moderate, aver-
aging about 1.8 percent annually. Apparently, natural increase contributed
most to the region's growth. All of the region's communities except Noatak
grew in size. Intraregional migration is common. Population mobility within
the region is high, especially between Kotzebue and the hinterland villages.
Movement into Kotzebue is probably in response to employment and educa-
tional opportunities, and to Kotzebue's superior public services.
A base case (i.e., without the Red Dog project) population forecast for the
region as a whole and for the individual communities of Kotzebue, Kivalina,
Noatak and Point Hope was prepared to serve as a benchmark for impact
assessment (Kevin Waring Associates, 1983). Based on a review of demo-
graphic and economic trends affecting the region, an average annual growth
rate of 1.5 percent was chosen for purposes of forecasting a future bench-
mark population. Assuming this general rate of growth and using the 1982
population base, the region's population was forecast to increase to 6,019 by
1990, 6,985 by 2000 and 8,110 by 2010 (Table IV-15). Kotzebue is expected
to retain its role as the region's main settlement.
IV - 62
-------
Table IV-13
POPULATION TRENDS, 1960 TO 1982
STUDY AREA COMMUNITIES
Ambler
Buckland
Deering
Kiana
Kivalina
Kobuk
Kotzebue
Noatak
Noorvik
Selawik
Shungnak
1960
70
87
95
253
142
54
1,290
275
384
348
135
1970
169
104
85
278
188
-
1,696
293
462
429
165
1980
192
177
150
345
241
62
2,054
273
492
535
202
1982
202
217
158
364
253
64
2,470
-
518
602
214
Kobuk Census
Division 3,560 4,048 4,831
Point Hope
324
386
461
544
Sources: U.S. Census of Population; Alaska Department of Labor, 1983
IV - 63
-------
Table IV-14
DISTRIBUTION OF POPULATION, BY AGE AND SEX
KOBUK CENSUS DIVJSION, 1980
Male
Age
Less
Total
Group
than 5 years
5
10
15
20
25
30
35
45
55
65
Median
- 9
- 14
- 19
- 24
- 29
- 34
- 44
- 54
- 64
plus
Age
No.
293
293
287
332
247
270
199
238
193
115
127
2,594
21
%
11
11
11
12
9
10
7
9
7
4
4
100
.7
.3
.3
.1
.8
.5
.4
.7
.2
.4
.4
.9
.0
Female
No.
278
244
242
276
263
193
152
177
184
106
122
2,237
21
\
12.
10.
10.
12.
11.
8.
6.
7.
8.
4.
5.
100.
.5
4
9
8
3
8
6
9
9
2
7
5
0
Total
No.
571
537
529
608
510
463
351
415
377
221
249
4,831
21
\
11
11
11
12
10
9
7
8
7
4
5
100
.6
.8
.1
.0
.6
.6
.6
.3
.6
.8
.6
.2
.0
Source: U.S. Census of Population, 1980
In general, it is anticipated that the region's future population structure will
tend toward a more normal age distribution. The ratio of minors will likely
decline and the number of young adults and, especially, older residents will
rise as a share of the total population. Corollaries of these trends will be
smaller average family and household sizes, lowered dependency ratios, and,
potentially, a relatively larger resident workforce.
IV - 64
-------
Table IV-15
BASELINE POPULATION FORECAST FOR THE
NANA REGION AND POINT HOPE, 1982 TO 2010
Kivalina
Kotzebue
Noatak
Rest of Region
Total
Point Hope
19821
253
2,470
2732
2£339
5,343
544
1990
285
2,782
317
2,635
6,019
612
2000
331
3,229
367
3^058
6,985
711
2010
384
3,749
427
3,550
8,110
826
Source: Kevin Waring Associates, 1983
1 Actual values.
2 1980 Census figure.
Economy
The NANA region has a mixed economy, combining traditional subsistence
economic activities with a growing cash economy supported by cash employ-
ment and other sources of cash income. Subsistence is vital to the region's
livelihood and will continue to be for the foreseeable future. It commands
significant expenditures of funds and time, and contributes importantly to
the food economy.
A comparison of gross employment and income data for 1970 and 1980 indi-
cates that there has been substantial aggregate growth in the cash economy
during the past decade. Total employment grew about 124 percent over the
decade while the region's population grew by about 19 percent. The percent
of total population employed nearly doubled from about 16 percent in 1970 to
about 30 percent by 1980. However, this aggregate growth was accomplished
with very little change in the region's basic economic structure. In develop-
mental terms, the region's economy has been static.
The economic multiplier is typically low for underdeveloped rural Alaskan
economies with little basic private employment and a strong subsistence com-
ponent. The mix of goods and services provided locally is limited by small
regional market size and low purchasing power. However, this mix has im-
proved over the past decade with the maturation of the region's cash econ-
omy. A low economic multiplier suggests that, apart from labor and essential
IV - 65
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transportation services, the region's economy may have few needed goods
and services to supply to new resource development projects.
Table IV-16 compares the distribution of employment by economic sector in
1970 and 1980. The outstanding constant feature was the dominance of pub-
lic sector employment and the negligible importance of private sector basic
employment. At both times, the public sector accounted for better than 60
percent of all employment, even though there was a wholesale shift in the
balance between federal and state/local government employment. Government
employment showed the biggest growth, and nearly all of that growth was in
state and local government employment. There was also strong but lesser
growth in services and minor growth in the construction industry. On the
other hand, the share of employment held by trade and transportation fell
somewhat. Overall, the structure of the region's basic economy changed
little, despite substantial aggregate growth.
While job and real income growth in the region greatly outpaced population
growth during the 1970 to 1980 period, factors that contributed to these
trends may be ending. Chief among those factors were improved resident
access to local employment opportunities, rapid expansion of public sector
employment, rising resident educational and occupational skill levels, in-
creased female labor force participation, and the emergence of Native-
managed business and public service organizations. In the future, it is
plausible that the region's workforce will grow slightly faster than the popu-
lation as a whole, mainly due to a shift in the age composition of the popula-
tion. It is also expected that residents will continue to adjust to shifts in
the economic outlook through migration within and beyond the region.
Data on sources of personal income (Tables IV-17 and IV-18) show there was
little change in the sources of earned personal income by economic sector,
although there was a large shift within the governmental sector as state and
local government replaced the federal government as the single most impor-
tant source of earned income. From 1970 to 1980, the share of personal in-
come derived from cash employment, dividends and transfer payments
changed very little. The average per capita personal income grew by 237
percent from approximately $2,142 to about $7,225, but still remained well
below the statewide average of $12,635.
According to the 1980 U.S. Census, the median household income for the
Kobuk region was $17,756, with wide variations among the communities.
Kotzebue had by far the highest median income ($23,371), consistent with its
more fully developed economic status and the reduced role of subsistence.
On the other hand, less developed communities still heavily dependent on
subsistence resources had relatively low median incomes (Kivalina, $8,304;
Selawik, $9,750; Noatak, $10,000).
Despite apparent economic improvements, long term unemployment rates show
a strong seasonal cycle, but remain relatively high in the region. In 1981,
the official average annual unemployment rate was 9.8 percent. The official
rate is generally thought to understate actual unemployment, mainly because
the labor force participation rate (and, thus, the official unemployment rate)
IV - 66
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Table IV-16
DISTRIBUTION OF EMPLOYMENT
KOBUK CENSUS DIVISION, 1970 & 1980
1970
Industry
Mining
Construction
Manufacturing
Transportation, Communication
& Utilities
Trade
Finance, Insurance & Real
Estate
Services
Federal Government
State & Local Government
Miscellaneous
Total
Number
*
*
*
106
100
*
17
300
104
*
641
Percent
*
*
*
16.6
15.6
*
2.7
46.7
16.3
*
100.0
1980
Number
*
81
*
125
133
18
168
218
692
*
1,438
Percent
*
5.6
*
8.7
9.2
1.3
11.7
15.2
48.1
*
100.0
*Withheld by Department of Labor to avoid disclosure or not available.
Source: Alaska Department of Labor, 1970, 1980
is depressed by the scarcity of employment possibilities. This is offset to
some degree by unreported subsistence activities and other self-employment,
which are omitted from official tallies.
IV - 67
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Table IV-17
SOURCES OF PERSONAL INCOME, BY SECTOR
KOBUK CENSUS
Industry
Agriculture
Mining
Construction
Manufacturing
Transportation & Public Utilities
Trade
Finance, Insurance & Real Estate
Services
Government
Federal
State & Local
Total
DIVISION, 1970 & 19801
$(000)
(L)
(L)
0
147
1,419
545
(L)
379
4,771
3,906
865
7,296
1970
Percent
N/A
N/A
0
2.0
19.4
7.5
N/A
5.2
65.4
53.5
11.9
100.0
1980
$(000)
(D)
(D)
1,609
(L)
4,244
2,044
(D)
2,852
17,141
5,006
12,135
28,527
Percent
N/A
N/A
5.6
N/A
14.9
7.2
N/A
10.0
60.1
17.5
42.5
100.0
(D) Not shown to avoid disclosure of confidential information,
(L) Less than $50,000.
1 By Place of Work
Source: U.S. Department of Commerce, 1982
IV - 68
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Table IV-18
PERSONAL INCOME, BY SOURCE
KOBUK CENSUS DIVISION, 1970 & 1980
1970
Net Earned Income
Dividends
Transfer Payments
Total
$
6,761
216
1,708
$8,685
Percent
77.8
2.5
19.7
100.0
1980
$
26,261
1,178
7,544
$34,983
Percent
74.8
3.4
21.5
100.0
Per Capita Total Personal Income $2,142 $7,225
Source: U.S. Department of Commerce, 1982
Regular cash employment does not preclude subsistence participation, al-
though some flexibility in work schedules is helpful to adapt to the seasonal
cycle of subsistence resources availability. Indeed, some recent studies in
the region have found that success in the cash employment economy is
associated with a high level of subsistence success.
Community Facilities and Services
The material standard of living in the region's communities has risen sub-
stantially over the past decade through widespread construction of basic
public facilities and improved public services. Most of the settlements have
benefited from ongoing programs to provide better housing, improved water
supply and sewer systems, electrification, local high schools, health clinics,
improved airports and telecommunications. Community services for public
safety, fire protection, health and social welfare, adult education and job
training have also generally been upgraded.
IV - 69
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Nevertheless, while recognizing the advantages of improvements, the region's
communities find it difficult to maintain basic community facilities and serv-
ices to meet current needs. The cost of public facilities and services is
high and local public revenue sources are low in the absence of the tax base
normally provided by private economic development. All of the NANA com-
munities are heavily dependent on non-local sources of revenues or non-local
public agencies for construction and operation of major community facilities
and programs, even when local agencies deliver services. As a result, the
localities, including Kotzebue, usually cannot absorb any sudden, large
population influx without strain on available resources for housing and com-
munity facilities and services, especially without a compensating increase in
public revenues. Similarly, many households find it difficult to afford the
higher cash outlays for utilities, energy, house payments and other factors
associated with an improved standard of living.
Local and Regional Governance
The proposed Red Dog mine site and related facilities fall within the juris-
diction of the North Slope Borough. The surface transportation route alter-
natives from the mine site to the coast, as well as the port site alternatives,
are in the so-called unorganized borough, outside any established local or
regional government.
All of the communities of the Kobuk census region, except Noatak which has
a traditional Indian Reorganization Act (IRA) council, are incorporated as
municipalities under Alaska statutes. There is no regional or borough gen-
eral purpose government encompassing the NANA region. A number of key
functions (education, public housing, coastal management) are provided
through special purpose regional agencies.
The North Slope Borough is a fully developed home rule regional govern-
ment. Among its area-wide powers, two are especially relevant to the mining
project: land use planning, and property assessment and taxation. The
Borough is also the primary provider of education, housing, utilities,
employment and other basic services to residents of North Slope villages.
Local governments in the NANA region have very limited tax bases and thus
are limited in their resources and powers. They are supplemented by a
variety of regional, federal and state organizations that provide community
facilities and services for such functions as education, transportation, health
and social services, housing, manpower development and coastal management.
Recreation
There is little published information on recreational use of the project area.
Most of the data presented in this study were collected by: interviews with
area residents; personal communication with guides, charter services and
resource personnel; and review of agency files and survey records. The
area of study is generally contained within Game Management Unit 23, which
is "...that area drained by all streams flowing into the Arctic Ocean and
Kotzebue Sound from Cape Lisburne on the north to, and including, the
drainage into Goodhope River on the south" (ADF&G, 1981). Since many
IV - 70
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recreational activities occur primarily within the National Park system, the
primary study area is defined as the western portion of the Noatak Pre-
serve, the northern portion of Cape Krusenstern National Monument, and
those portions of Unit 23 in the vicinity of the proposed project.
The recreational activities under study include hiking, flying, boating,
hunting, fishing, winter sports and sightseeing. However, local residents
pursue many of these same activities for a livelihood. It is therefore neces-
sary to distinguish between recreational use and subsistence use of local
resources. For purposes of this document, recreational activities are defined
as those outdoor activities pursued by non-residents of the region.
Recreational opportunities in the study area are somewhat limited compared to
other areas of the state. The restricted and costly access, the lack of sup-
port facilities, the fairly flat, wet terrain, long harsh winters and short
summers have kept recreational use to a minimum. In fact, non-resident
winter sport activities such as dogsledding, snowmobiling and skiing vir-
tually do not exist. Recreational flying was also determined to be almost
nonexistent. It is estimated that from 250 to 350 non-residents engaged in
recreational activities in the primary study area in 1982 (Cominco Alaska,
Inc., 1983b).
People that do visit the area generally engage in a variety of activities, and
it is often difficult to differentiate between individuals who come for such
diverse purposes as wildlife viewing, photography, archeology, ecological
observation and backpacking. However, because boating or rafting is the
usual means of travel in the study area outside Cape Krusenstern, it is
convenient to use boating as the recreational activity common to all such
visitors. Other major recreational use includes hunting, fishing and visiting
Cape Krusenstern National Monument. Again, it is not unusual for visitors
to engage in more than one activity, for example, sport fishing while on a
boating trip.
Boating
The Noatak River accommodates the greatest number of boaters using the
primary study area. Data collected from area guides and air taxi services
suggest that up to 200 non-residents may utilize the Noatak for recreational
boating each year. Most boaters disembark before leaving the Noatak
National Preserve; the rest continue on the river to the village of Noatak.
Few boaters continue beyond the village because of the usual high winds
over the flats.
Boaters commonly take a chartered plane from Kotzebue, Ambler or Bettles to
a gravel bar landing site on one of the Noatak River tributaries. For
approximately $1,600 per person, a licensed guide will provide a 14-day trip
with all gear included. Sport fishing is allowed, and with proper licensing,
sport hunting is allowed within the Noatak Preserve.
Hunting/Fishing
Non-resident participation is often limited to professionally guided hunting
and fishing trips. Licensed guides use the project area primarily for hunt-
IV - 71
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ing sheep, bear, moose and caribou; and for Arctic char, Arctic grayling
and chum salmon fishing. Approximately 150 people were flown into the area
in 1982, fishermen outnumbering hunters two to one. Costs for guided trips
range from $700 a day for fishing up to an average of $4,800 for a single
game hunt. Some local residents hunt and fish for recreation, and cabin
and tent camp facilities also exist in the area.
ADF&G data for Game Management Unit 23 show total harvests of 680 caribou
in 1981-82 and 1,038 caribou in 1982-83 (Coady, 1983). The large majority of
these is taken by residents. However, game biologists estimated that up to
4,000 caribou may actually have been harvested from Unit 23 (Cominco
Alaska, Inc., 1983b). This discrepancy between reported and probable
caribou harvesting indicates that game harvest records probably do not
accurately represent the take. Additional ADF&G data reported between 1962
and 1981 show the total average annual game harvest included 17 Dall sheep
and 23 bear. Moose harvest records are incomplete for Unit 23, but three
years of data show a yearly average of 71 moose taken from the Noatak,
Kobuk, Kukpuk, Kivalina and Wulik River areas. ADF&G records from 1982
show a total fish harvest of about 2,060 from the Noatak, 2,840 from the
Kobuk, 805 from the Wulik and 3,660 from all other rivers in Unit 23. It is
often difficult to distinguish between recreational harvest and subsistence
harvest, so harvest data may not accurately reflect type of use. It is evi-
dent however, that a great deal of resident hunting and fishing takes place,
and that subsistence use greatly exceeds recreational activities (Cominco
Alaska, Inc., 1983b).
Cape Krusenstern National Monument
Cape Krusenstern National Monument was established, and is to be managed,
for the following purposes:
0 To protect and interpret a series of archeological sites that depict
every known cultural period in Arctic Alaska.
0 To provide for scientific study of the process of human population of
the area from the Asian continent.
0 To preserve and interpret evidence of prehistoric and historic Native
cultures.
0 To protect habitat for seals and other marine animals.
0 To protect habitat for, and populations of, caribou herds and other
wildlife, and fish resources.
0 To protect the viability of subsistence resources.
Park Service statistics estimate 1982 Cape Krusenstern users at 10,200
people. This number was derived by noting snowmobile and three-wheel
vehicle tracks, periodic aerial surveys, reviewing camp records and conduct-
ing personal interviews. However, since the winter trail between Kotzebue
and Kivalina passes through Cape Krusenstern, this number is assumed to
reflect largely resident traffic. Local residents and air taxi service person-
IV - 72
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nel indicated that few, if any, non-residents visit Cape Krusenstern for
recreational purposes as there are no rivers adequate for boating and sport
hunting is not allowed. NPS representatives estimate that only two percent
of users currently visit the Monument for recreational purposes (Shaver,
personal communication).
IV - 73
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Chapter V
Environmental Consequences
-------
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V. ENVIRONMENTAL CONSEQUENCES
INTRODUCTION
This section contains the scientific and analytical basis for the comparison of
project alternatives. Potential impacts of the components which are common
to all alternatives, and therefore not dependent upon selection of a partic-
ular alternative are discussed first on a discipline by discipline basis.
Beginning on page V-36, the impacts of each project alternative are dis-
cussed on a discipline by discipline basis where certain components differ for
each alternative.
Since for almost all disciplines the impact of the No Action Alternative would
be the status quo, impacts of the No Action Alternative are not discussed
for each of the individual disciplines. Rather, the No Action Alternative is
discussed in a separate section which deals primarily with the socioeconomic
impacts of no project implementation. The No Action Alternative would result
from denial of at least one of the permits necessary for project development,
or it could result if the project sponsor chose not to undertake the project.
Potential project impacts on each discipline have been quantified where pos-
sible. Qualitative descriptions of effects are provided to identify differences
in magnitude, significance or duration among alternatives. Unless noted
differently, the discipline criteria which were used to initially screen project
options, as discussed in Chapter III (Table 111-5), are the same criteria that
were used to evaluate the impacts of project components on each discipline.
Throughout the individual discipline analyses references are made to mitiga-
tion, monitoring and reclamation measures. The impacts discussed for a
given discipline assume implementation of those specific measures. Later in
this chapter all mitigation, monitoring and reclamation measures are briefly
summarized.
COMPONENTS COMMON TO ALL ALTERNATIVES
Eight components of the project are common to each alternative: the mine
location, the tailings pond in the South Fork of Red Dog Creek, South Fork
mill site, South Fork location for worker housing, a campsite housing type,
Bons Creek water supply reservoir, diesel power generation and year-round
road. With the exception of the year-round road, these common components
are discussed here together in a separate section because they are not de-
pendent upon selection of the Preferred Alternative. They were not open to
alternative development either because their locations would be fixed (e.g.,
V - 1
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the mine location), or because they clearly represented the best option for
that component. As it would not be logical to discuss the consequences of
the road unless it were tied to a specific location, the environmental conse-
quences of the year-round road are discussed later in conjunction with the
location of the transportation corridor as a component specific to some alter-
natives. The Components Specific to Some Alternatives section (p. V-36)
discusses environmental consequences of the three components that differ for
each alternative, i.e., the transportation corridor location, the port site
location and the marine transfer facilities.
Vegetation and Wetlands
The mine area facilities (mine and overburden storage area, tailings pond,
mill site, worker housing, water supply reservoir, airstrip and all associated
access roads) would directly disturb a total of approximately 541 ha (1,336
ac) in Red Dog Valley. The mine, overburden storage area and supporting
access road system would eventually eliminate a total of approximately 235 ha
(580 ac) of ground cover, including 152 ha (375 ac) of dwarf shrub tundra
and 83 ha (205 ac) of low shrub tundra. The tailings pond would cover
approximately 237 ha (585 ac), including 68 ha (168 ac) of low shrub tun-
dra, 62 ha (152 ac) of dwarf shrub tundra and 107 ha (265 ac) of sedge-
grass tundra. Depending on the final contour, an additional 8 ha (20 ac) of
open low shrubland might also be disturbed.
Construction of the mill site, worker housing structures and the access road
between the two would directly disturb 26 ha (65 ac) of sedge-grass tundra.
The Bons Creek water supply reservoir and access road would disturb about
31 ha (76 ac) of dwarf shrub (mat and cushion) tundra. The airstrip and
associated service roads would disturb about 12 ha (30 ac), including 6 ha
(15 ac) of dwarf shrub tundra, 2 ha (6 ac) of open low shrubland and 4 ha
(9 ac) of sedge-grass tundra.
Because of the considerable amount of human activity associated with a large
scale mining operation, disturbance from foot traffic, off-road vehicle traffic
and dust might affect additional acreage of vegetation in Red Dog Valley.
Sensitive plants such as lichen species might exhibit a loss of vigor caused
by pollutants emitted at the mine site. There might also be a loss caused by
pollution from metal sulfides in dust mobilized in the mining and transport of
ore. Some elements (e.g., lead) might bioaccumulate in plant tissues (Olson,
1982). Communities adjacent to access roads would be contaminated by any
fuel, chemical or concentrate spill. The degree of impact would depend on
the nature of the site and spill, time of year and cleanup procedures (Brown
et al., 1980). The following vegetation types could be indirectly affected by
the project: low shrub tundra; open low shrubland; dwarf shrub tundra;
and sedge-grass tundra. The total vegetation and wetland loss, however,
would not be significant on more than a local basis.
Wetlands in the mine area include sedge-grass tundra and open low shrub
communities. Regulation of wetlands in most of the area would be covered
under a Nationwide 404 Permit, pending water quality certification by DEC
(see Appendix 5, Section 404(b)(1) Evaluation). The nationwide permit
would not be valid for the tailings pond dam or for the road from the mine
V - 2
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pit to the dam. These discharges of dredged or fill material would be
included in the DA permit review.
Terrestrial Wildlife
The discussion below primarily addresses four impacts upon major wildlife
species or groups: first, direct habitat loss, which is the actual physical
destruction of habitat; second, indirect habitat loss, which is the effective
loss of habitat use because of noise, human contact or other disturbance
directly associated with project construction and operation; third, the effects
on animal movements; and fourth, construction impacts. A fifth wildlife
impact, long-term increased public access to the project area, is discussed
separately in a general manner under "Other Project Impacts" later in this
chapter. It is also described more specifically here for components where
increased access impacts would likely be of major significance.
Direct habitat loss from construction of the mine area facilities would total
approximately 541 ha (1,336 ac). On a local basis this loss could be signi-
ficant for song bird and small mammal species, but it would not be signifi-
cant on a greater than local basis. For other wildlife such as birds of prey
or larger mammal species, direct habitat loss would not be significant even
on a local basis.
Indirect habitat loss, however, could be significant on a greater than local
basis. While local song bird and small mammal populations would likely
accommodate to the presence of the facilities and associated activities, birds
of prey and larger mammals would generally tend to avoid the area. The
degree of avoidance cannot be accurately predicted.
At least two inactive golden eagle nests were identified within the South
Fork Valley (Dames & Moore, 1983b), and other raptor nests might exist.
Both nests are within 1.6 km (1 mi) of proposed mine area facilities and
birds attempting to breed there would probably be affected by activities
associated with construction and operation of the project. This disturbance
would likely cause abandonment of the nests. The valley might also serve as
hunting territory for other birds nesting outside the valley, thus indirectly
limiting their habitat use of the area.
The South Fork Valley is generally to the northeast of the currently used
caribou wintering grounds in the lower Kivalina and Wulik drainages. This
area was not used by caribou during the 1981-82 or 1982-83 winters (Dames
& Moore, 1983a). However, caribou are capricious animals and the valley
may have been used many times in the past. Thus, development and opera-
tion of mine facilities in the South Fork Valley might have an indirect impact
upon caribou by displacing a few animals from this area during winter. The
major portion of the annual post-calving migration in July appears to pass
just to the northwest of Red Dog Valley and would probably not be signifi-
cantly affected by mine area development. However, some animals would
likely have to alter their movements to avoid the valley.
Bears, wolves, wolverines and foxes would also be impacted by disturbance
and human contacts. While not significant on a greater than local basis,
individuals would be displaced from the general area unless attracted by
V - 3
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improper disposal of garbage or outright feeding. To minimize such attrac-
tion, garbage collection sites, incinerators and the solid waste landfill site
would be fenced using adequately high, deep and strong Cyclone-type "bear
proof" fencing. In addition, workers involved with garbage disposal would
be instructed in proper collection, handling and incineration techniques.
Feeding of animals would be prohibited and this would be strictly enforced.
The ADF&G regulation prohibiting such feeding (5 AAC 81.218) would be
posted conspicuously throughout the camp. All workers would receive
environmental training which would stress the importance of this prohibition,
the usual consequences to the animals themselves from being fed, and the
potential danger to employees (e.g., bear/human contacts, rabid foxes).
These safeguards of proper garbage handling, fencing, feeding prohibition
and worker environmental training would: increase worker safety by reduc-
ing exposure to bears, foxes and other carnivores; reduce worker/carnivore
contacts that would detract from job performance; and reduce the time,
effort and expense for the applicant and/or ADF&G to trap, immobilize and
relocate nuisance animals, or to kill animals in defense of life or property.
The mine area facilities appear to be near the southern limit of present Dall
sheep range in the De Long Mountains. However, a group of five ewes and
lambs was reported in the South Fork Valley in June 1982 (Dames & Moore,
1983a). Development in the valley would initially displace most sheep activ-
ity in the vicinity. In time, depending upon human contacts in their pri-
mary mountain habitats, sheep might adjust to the project.
Indirect habitat loss in the South Fork Valley would not be significant for
moose, muskoxen or waterfowl.
Although wildlife would generally tend to avoid the area of the tailings pond,
it is possible that an animal could come into contact with the contaminated
water. Even if an animal swam in or drank a small amount of the tailings
pond water, it is highly unlikely that the animal would be harmed. Also,
adequate supplies of uncontaminated water would be available for wildlife
use in the mine site area (including Ikalukrok Creek, the North Fork of
Red Dog Creek, Buddy Creek, and the water supply reservoir created on
Bons Creek), so animals would quickly learn to avoid the caustic waters
of the tailings pond. Migrating waterfowl might land on the tailings pond
for short periods on a seasonal basis, but no feeding would occur and no
harm to waterfowl would result.
Construction activities, aside from direct habitat loss, would have relatively
little impact upon song bird or small mammal species. They would displace
larger mammals to a greater degree than during operation of the facilities.
This would probably not be of greater than local significance, except pos-
sibly for caribou.
Groundwater Resources
Project impacts related to groundwater concerns can be generally inferred
from established theories of groundwater movement in Arctic regions.
Groundwater movement in the project area is restricted by the presence of
V - 4
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permafrost and tightly bedded shales. Movement becomes significant only in
thawed substrate such as that found in thaw bulbs under stream surfaces
and in the active layer above permafrost during the summer. Groundwater
concerns can be related to design of the ore zone runoff collection ditch;
collection of seepage from the tailings pond; and containment of fuel and/or
chemical spills in the vicinity of the mill site.
To control sediment, a diversion ditch, possibly lined with plastic, would be
constructed between the ore zone and the main stem of Red Dog Creek. In
addition to its specific purpose of controlling sediment, the ditch would
likely intercept much of the natural ore zone seepage presently entering the
creek. If this were to occur, it would be reasonable to assume that mining
activities would improve existing water quality conditions in the main stem of
Red Dog Creek and downstream.
Some potential exists for seepage from the tailings pond through the abut-
ments or foundation of the dam embankment. Although the highly fractured
shale is currently impermeable due to ice-filled fractures, permeability and
resultant seepage rates might increase should these fractures thaw during
construction and operation of the pond. A seepage control facility would be
included as part of the tailings pond embankment construction and would
largely eliminate the risk of seepage entering Red Dog Creek. Any seepage
intercepted would be pumped back into the tailings pond.
Fuel or chemical spills would pose a high risk for groundwater contamination
because of the shallow water table depth in the project area. Although
groundwater resources are not significant, soils containing groundwater
would serve as conduits for contaminant migration to nearby streams. The
travel time between a spill site and nearby streams would depend on the
depth of the thawed layer, soil permeability, hydraulic gradient and travel
distance. Significant spills could cause surface water contamination within
days or weeks following the spill occurrence. However, the most likely
location for potential spills would be in the tailings pond drainage area where
no risk would exist to streams. The Spill Prevention, Control and Counter-
measure (SPCC) Plan (Appendix 2) would limit impacts of spills both there
and in other areas.
It should be noted that because of the presence of permafrost at shallow
depths, potential groundwater contamination likely would occur only in the
active thaw layer and would not impact deeper aquifers as could occur in
nonpermafrost areas.
Freshwater Resources
Hydrology and Water Quality
A description of the water balance of the tailings pond was required to
determine the quantity and quality of water that would enter the tailings
pond so that pond capacity and treatment requirements could be established.
The average annual water balance for the tailings pond is shown in Table
V-1.
Water quality data for the main stem of Red Dog Creek above South Fork
were analyzed to determine the loads of toxic metals coming from the ore
zone. The analysis was done for the toxic metals zinc, lead and cadmium
V - 5
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which would be of primary concern. Ninety-five percent of the metal loads
in the main stem above South Fork come from the area bounded by the ex-
posed ore zone. A diversion ditch would be constructed between Red Dog
Creek and the open pit to collect runoff from the mine area. Since approx-
imately 10 percent of the area of exposed ore occurs across the creek from
the proposed diversion ditch, the ditch would have the potential to intercept
about 85 percent of the total toxic metal loads. This would represent a 75
percent reduction of zinc, lead and cadmium loads reaching Ikalukrok Creek.
Table V-1
TAILINGS POND WATER BALANCE
Source
Surface runoff and net
precipitation on pond
Net mill discharge to pond
Mine drainage pumped to pond
Water trapped in tailings
Volume of water displaced
by dry tailings
Free water on top of tailings
Volume of tailings and water
after treatment
Treated water (annual average)
May to October discharge
(six months)
Initial Production
Phase
1/min
6,529
878
594
314
450
7,687
1,014
7,123
14,246
gal/min
1,725
232
157
83
119
2,031
268
1,882
3,764
Expanded Production
Phase
£/min gal/min
6,529 1,725
1,514 400
1,188 314
655 173
946 250
8,577 2,266
1,805 477
7,718 2,039
15,436 4,078
If the diversion ditch were fully effective at collecting the ore zone runoff,
it would annually divert 54 Mg (60 tons) of zinc, 1.8 Mg (2 tons) of lead
and 0.4 Mg (0.5 ton) of cadmium to the tailings pond during the initial
phase of production. This would represent an annual flow of 594 £/min (157
gal/min) of water containing 87 mg/£ of zinc, 3 mg/2 of lead and 0.8 mg/£ of
cadmium to the pond. Although the ditch might not be completely effective
at diverting these toxic metal loads initially, eventually the open pit would
V - 6
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reach across Red Dog Creek, and the entire stream would be diverted
around the open pit or isolated from ore contact during mine operation.
With this diversion, a 95 percent reduction in toxic metal loads to Red Dog
Creek above the South Fork might be attained. A monitoring program on
Red Dog Creek at its mouth would allow determination of improvements in
water quality as the open pit enlarged.
The drainage area to the tailings pond would be 7.12 km2 (2.75 mi2).
Approximately 1.8 km2 (0.7 mi2) of drainage would be diverted to Bons
Creek to avoid having to treat additional clean water and to replace water
removed from the Bons Creek water supply reservoir. The tailings pond
water surface area would eventually reach 2.6 km2 (1.0 mi2). Precipitation
over the drainage area would be 64 to 71 cm/yr (25 to 28 in/yr). Evapora-
tion from either water or land would be 15 to 23 cm/yr (6 to 9 in/yr). Net
runoff would be 48 cm (19 in) or 0.015 m3/s/km2 (1.4 ft3/s/mi2) or 6,529
£/min (1,725 gal/min).
EPA regulations issued in December of 1982 established discharge limitation
New Source Performance Standards (NSPS) for ore mining and processing
facilities (40 CFR 440). The standards that specifically apply to the Red
Dog facility include no discharge of process (mill) wastewater, restriction of
discharge to net precipitation over evaporation from the mine and mill areas
during the mine life, and limitations on mine drainage. Specific requirements
for metals and other parameters in discharged waters also apply (Table V-2).
Table V-2
TREATED WATER QUALITY PROJECTIONS
Parameter
Zinc (Zn)
Lead (Pb)
Cadmium (Cd)
Copper (Cu)
Mercury (Hg)
Total suspended
solids (TSS)
pH (units)
Typical Case
1 Day 30-Day
Worst Case EPA Standard1 EPA Standard1
0.86
0.010
0.020
<0.015
<0.00005
4.6
10.5
1.87
0.015
0.020
<0.015
<0.00005
4.5
10.5
1.50
0.600
0.100
0.300
0.002
30.0
6.0 to 9.0
0.75
0.300
0.050
0.150
0.001
20.0
6.0 to 9.0
1 EPA Standards from 40 CFR 440.104(a) Mine Drainage Standards,
V - 7
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The allowable discharge (net precipitation) is determined for an annual
volume of precipitation and evaporation, not the excess that may occur over
a few days or weeks. Short-term excesses would be handled by the free
board of the facility. Both precipitation and evaporation vary from year to
year. Normal average precipitation and evaporation are used in determining
net precipitation at a facility. Additional discharge would be allowed to
account for wet years and heavy snow packs. The volume of annual net
precipitation would be discharged so that daily discharge volume over the
discharge season would equal the total annual volume of excess precipitation.
At the Red Dog project, as previously discussed, some water would be im-
ported into the basin for process uses. Of this imported water a portion
would be tied up in voids of the settled tailings. The remaining portion
would be water that cannot be discharged in accordance with the EPA net
precipitation regulations. This would amount to an equivalent of 563 £/min
(149 gal/min) accumulation in the tailings pond. Reclamation of the tailings
pond would not be possible unless dewatering could occur. Interpretations
by EPA indicate that the tailings pond could be dewatered through the
treatment plant after the mining operations were permanently closed. This
would be regulated by a separate NPDES permit. Present regulations would
result in an accumulation of water during the mine life.
Net mill discharge to the tailings pond would include 45 £/min (12 gal/min)
of domestic wastewater. This wastewater would effectively be treated by
conditions in the tailings pond. Bacteria levels in the pond would not be
significant since dilution, toxic metal concentrations and low pH would lead
to rapid bacteria die-off.
During the initial five years of production, approximately 1,496 Mg/day
(1,650 tons/day) (dry weight) of tailings would enter the tailings pond.
This would increase to 3,129 Mg/day (3,450 tons/day) during the expanded
phase of production. The wet tailings would have 60 percent solids by
weight, which would reduce to 70 percent solids by weight after settling in
the pond.
The tailings pond would be built in stages, with the maximum sized dam
constructed by the fifth year of production. Maximum dam elevation would
be 289 m (950 ft) with the spillway at 288 m (944.6 ft). Staging of dam
construction would allow for the accumulated volume of dry tailings, water
trapped in tailings voids, inflows in excess of natural runoff, and the 10-
year recurrence 24-hour storm runoff event. A 1.5 m (5 ft) freeboard
would be maintained to prevent overtopping during the probable maximum
flood.
The Red Dog mine plan schedule for construction of the tailings dam in
stages would consider the influence of wet years. During the five-year con-
struction period, because of the limited capacity of the tailings pond, there
would be a significant risk that if a 50-year recurrence wet year occurred,
the dam might be overtopped. To prevent this, adequate capacity would be
maintained during the construction period to contain this event. Probability
analysis of Kotzebue annual precipitation data indicated that a 50-year recur-
rence would be approximately 1.8 times the annual mean. Precipitation in
the project area (mean annual 64 cm [25 in]) would therefore have a 50-year
recurrence of 114 cm (45 in). Capacity to handle an additional 51 cm (20
V - 8
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in) of runoff would be maintained in the pond at the beginning of each
runoff season (May). Treatment rates would be increased when it became
obvious that an unusually wet year (50-year recurrence interval or greater)
was in progress, and treatment would continue, if necessary, into winter
months until the extra runoff was treated. The increased discharge of
treated effluent and spring melt of accumulated icings would further improve
the water quality of Red Dog Creek compared to an average year.
The 10-year recurrence 24-hour storm event at Red Dog Valley would be at
least 10 cm (4 in). This value was derived by using the ratio of annual
precipitation at Red Dog Valley (51 to 64 cm [20 to 25 in]) to annual precip-
itation at Kotzebue (21 cm [8.4 in]) in order to adjust the Kotzebue 10-year
24-hour storm event which was 4.3 cm (1.7 in).
Natural inflows (South Fork and ore zone runoff) to the tailings pond
(7,114 £/min [1,882 gal/min]) would mix with the mill discharge and be
treated before discharge to Red Dog Creek. Discharge would occur during
the six-month period from May to October when the creek would be un-
frozen. Any discharge of treated water during winter months would not be
expected to be of environmental concern as long as the icing accumulation
would completely melt in spring and summer. The discharge point would be
on the main stem of Red Dog Creek 19 m (62 ft) below the confluence with
the South Fork. The average annual treated water discharge over that
six-month period would be 14,246 £/min (3,764 gal/min) or 0.23 m3/s (8.4
ft3/s). The treatment facility would be designed to handle greater treatment
rates during wet years.
The High Density Sludge (HDS) process would be used to remove toxic
metals from the tailings pond water. The process would use lime treatment
to precipitate metals as hydroxides, and then increase the densities of the
precipitated hydroxides to give a sludge with good handling and filtration
characteristics. The process plant would draw feed water from the pond,
discharge a clean effluent to Red Dog Creek and recover the sludge.
In order to design the treatment process, the predicted water quality of the
tailings pond water was forecast. Table V-3 shows typical and projected
worst case scenarios of anticipated tailings pond water quality as calculated
from baseline water quality data (Dames & Moore, 1983a).
Other chemicals used in the milling process may be present in tailings pond
water. Most flotation process suppressant reagents would remain with the
tailings and would settle in the tailings pond. Flotation aids would remain
with the ore concentrate. However, small fractions might accumulate in the
tailings pond water and might impact treatment plant design. Projected con-
centrations of the toxic process chemicals are shown below:
Typical Case Worst Case
Free Cyanide (CN"1) 0.01 0.03
Total Cyanide 0.02 0.05
Xanthate 0.005 0.01
V - 9
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Table V-3
TAILINGS POND WATER QUALITY PROJECTIONS
(Assuming Complete Mixing)
Parameter
Zinc (Zn)
Lead (Pb)
Cadmium (Cd)
Calcium (Ca)
Manganese (Mn)
Magnesium (Mg)
Iron (Fe)
Barium (Ba)
Aluminum (Al)
Copper (Cu)
Mercury (Hg)
pH (units)
Typical Case
(mg/£)
238.0
1.2
2.2
54.0
13.7
15.1
2.3
0.1
0.4
0.1
0.002
4.0
Worst Case
(mg/A)
586.0
1.3
4.0
70.0
17.8
19.4
2.8
0.4
0.7
0.1
0.002
4.0
These chemicals are oxidized in the presence of sunlight, decompose, or form
complexes in conditions that would be prevalent in the tailings pond. They
should, therefore, not present an impact. Treatment plant design would be
modified if necessary to reduce effluent concentrations of these chemical
parameters to non-toxic levels.
Pilot testing was used to estimate the efficiency of the treatment process
(Cominco Engineering Services, Ltd., 1983a). Typical and worst case
scenarios of water quality concentrations of the treated effluent are compared
to EPA effluent standards in Table V-2.
The treatment process would work most efficiently at pH 10.5. This would
be higher than the EPA pH limitation of 9.0. However, since the natural
surface waters would usually be slightly acidic, a basic effluent discharge of
V - 10
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pH 10.5 should serve as a buffer and might ameliorate conditions down-
stream. Under worst case conditions, zinc would be the only metal which
would not satisfy EPA regulations for mine discharge. The high concentra-
tions predicted result from high zinc concentrations in the total suspended
solids (TSS) remaining in the effluent after treatment. In actual practice,
effluent might contain lower TSS levels or additional dilution water so zinc
levels might be more closely in compliance with EPA standards. The pro-
jected worst case zinc concentration of 1.87 mg/SL would still represent a
substantial improvement over natural conditions (6 to 19 mg/£).
Zinc found in pilot test work was mostly in the form of a finely divided
precipitate that was not removed totally by conventional settling. Laboratory
tests using filtered test effluent indicated the soluble portion (non-filterable)
was projected to be less than 0.15 mg/£.
In many tailings pond environments, additional surface runoff dilution,
aging, mixing of pond water, and other conditions that cannot be fully
simulated result in treatment plant operations different from laboratory
results. The full scale operation of the tailings pond water treatment facility
would allow optimization of the treatment process. The tailings pond would
not fill during the first years of operation, so the operators would have
sufficient time to operate the treatment plant in a closed loop (discharging
back to the tailings pond) until the process performance was proven. If
in actual on-site, full scale treatment tests clarification could not remove
zinc to acceptable concentrations, other unit processes such as filtration
could be added to assure compliance with EPA standards.
Anticipated effluent water quality compared to pre-mining seasonally occur-
ring water quality in Red Dog Creek above South Fork is shown below:
Red Dog Creek
Parameter Effluent (mg/£) (mg/£)
Zinc (Zn) 0.75 to 1.50 6.0 to 19.0
Lead (Pb) 0.010 to 0.015 0.1 to 0.5
Cadmium (Cd) 0.02 0.05 to 0.14
A comparison of anticipated total annual loads to Red Dog Creek before and
during mining is shown below for downstream of the confluence of South
Fork with the main stem of Red Dog Creek:
Pre-mining Condition During Mining Operations
Parameter Mg/yr tons/yr Mg/yr tons/yr
Zinc (Zn) 66.21 73.00 10.6 to 12.0 11.8 to 13.3
Lead (Pb) 2.36 2.60 0.35 to 0.36 0.39 to 0.40
Cadmium (Cd) 0.77 0.85 0.24 to 0.48 0.27 to 0.53
These anticipated figures show that lead and zinc loads would be reduced by
approximately 80 percent and cadmium loads by 50 percent. Corresponding
V - 11
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reductions in Ikalukrok Creek would be 75 percent for lead and zinc and 45
percent for cadmium. Water quality in Red Dog Creek and Ikalukrok Creek
could, therefore, be significantly improved.
Since the treated effluent would be steadily discharged during a six-month
period between May and October (no winter discharge), flows in Red Dog
Creek below the South Fork confluence would change somewhat compared to
natural seasonal conditions as shown below:
During Mining
Natural Condition Operations
Season mVs ft3/s ma/s ft3/s
Summer low 0.31 11.0 0.48 17.0
Storm events 1.42 50.0 1.13 40.0
Winter 0.03 1.0 0.03 1.0
Spring 1.13 40.0 0.99 35.0
The most significant changes to flow would occur during low flow periods in
summer. During drought conditions the treated effluent could represent 60
to 75 percent of the flow in Red Dog Creek at the point of discharge below
the South Fork. Flows in Ikalukrok Creek below Red Dog Creek would have
corresponding treated effluent proportions of seven to 10 percent. This flow
increase would be expected to improve water quality in Ikalukrok Creek.
Overflows of untreated tailings pond water would occur only in the highly
unlikely combination of the following events:
0 a wet year with a recurrence interval over 50 years;
0 during the first five years of construction or the last year of opera-
tion;
0 during a runoff event of sufficient magnitude to also fill capacity
allocated to the 10-year, 24-hour storm;
0 and when inflow to the tailings pond exceeded the emergency treat-
ment capacity of the treatment plant (0.57 m3/s [20 ft3/s]).
Dilution of such an overflow would occur from simultaneous natural flood
flows in Red Dog and Ikalukrok Creeks. These natural flood flows would
reduce concentrations of lead, cadmium and TSS to levels below normal
natural flow conditions. The only significant concentration that would
exceed normal natural flow conditions would be zinc. The concentration of
zinc in tailings pond overflow water, after dilution due to precipitation and
local runoff, would approximate 100 mg/£. Based on a real runoff propor-
tion, dilution of an overflow by the time it reached the mouth of Red Dog
Creek would be nine to one. However, actual dilution would be much
greater since the overflow would be reduced by the emergency capacity of
the treatment plant. The highest possible zinc concentration at the mouth of
V - 12
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Red Dog Creek would therefore be less than 11 mg/S.. The maximum ob-
served zinc concentration at the mouth of Red Dog Creek was 5.0 mg/S.
(Dames and Moore, 1983a). However, higher winter concentrations at the
mouth were known to exist based on upstream measurements.
At the mill site, spill hazards would exist from the storage and use of mill
process chemicals and oil. Spillage control plans and rapid response to
spills would be the primary mitigative measures utilized. Appendix 2 (SPCC
Plan) outlines the proposed draft plan for spill reaction.
If the dam foundation were to thaw there would be a potential for dam seep-
age through cracks and fissures in the foundation rock. A seepage contain-
ment dam and pumpback system would be installed downstream of the dam to
pump back any seepage to the tailings pond without significant impact.
To protect the water quality of streams during construction, an erosion and
sediment control plan would be followed. This plan would describe pro-
cedures for removal of tundra vegetation, topsoil stockpiling and reestablish-
ment of vegetation on cleared areas. Sediment would be controlled in cleared
areas by sedimentation ponds. These ponds would be constructed in the mill
and accommodation areas, and would be designed to retain runoff from a 10-
year recurrence 24-hour storm event. After construction was completed,
runoff would be directed to the tailings pond.
Water quality protection in the vicinity of the worker accommodations, air-
strip and access roads would require control of sediment during construc-
tion, and revegetation of disturbed areas as soon as possible after construc-
tion was completed. Spill hazard control procedures for these areas are
described in the SPCC Plan (Appendix 2).
The Bons Creek water supply would be used for mill operations, domestic
purposes and for dust suppression. Since 1.8 km2 (0.7 mi2) of the South
Fork drainage would be directed to Bons Creek, this drainage would have a
net gain in water. An annual average of 1,703 £/min (450 gal/min) would be
directed to Bons Creek via diversion ditches and 1,136 £/min (300 gal/min)
would be pumped back for use in mine operations. Flows in Bons Creek
below the reservoir would be reduced during low flow periods and increased
during high flow periods. Reductions to flow in Dudd Creek where it enters
Ikalukrok Creek would be approximately two percent during low flow
periods. There would be no significant changes to water quality.
Biology
Invertebrates
Operation of the mine and tailings pond is expected to decrease the naturally
occurring metals content of Red Dog Creek. Depending on the amount of
metals reduced, the chemical speciation of the remaining metals, .and the
concentration of residual metals from past deposition, benthic production
could increase in the main stem of the creek. Sensitive taxonomic groups
presently absent from the most degraded areas (Nematoda, Neptageniidae,
Tubificidae and Ostracoda) could return, and presently depressed numbers
increase. However, this potential increase in benthic production would
V - 13
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probably not have a significant beneficial impact on Ikalukrok Creek fisheries
because of the offsetting loss of benthic habitat from the South Fork of Red
Dog Creek.
Construction of the tailings pond in South Fork Valley would remove 83 per-
cent of the creek, or approximately 5.3 km (3.3 mi) of clear water, gravel-
bottomed stream habitat. Benthic macroinvertebrate production is moderate
in this stream, with densities approximately half of those found in the most
productive streams of the project area (Dames & Moore, 1983a). While the
removal of this stream section would represent a significant benthic habitat
loss to the entire Red Dog Creek system (12 percent), direct impacts to
downstream fish species in terms of reduced food availability are negligible.
Closer and more productive drift food sources in the North Fork of Red Dog
Creek and Ikalukrok Creek should not be affected by the South Fork tailings
pond.
Construction of a water supply reservoir on Bons Creek would result in
temporary decreases in the downstream benthic productivity of Dudd Creek
due to altered stream flows and increased sedimentation. Flow changes might
affect overall productivity in Dudd Creek, but should not result in any sig-
nificant changes in Ikalukrok Creek fisheries. Bons Creek presently contri-
butes a relatively small portion of the total Ikalukrok Creek system flow.
During the construction of mine area facilities, sediment loads might increase
in Red Dog Valley streams. If care were taken to control or treat erosion
with diversion ditches, sedimentation basins and revegetation techniques,
construction impacts would be minimal and transitory. However, if erosion
were not controlled, benthic productivity would decrease, especially in clear
water streams (tributaries of the South Fork and main stem of Red Dog
Creek) located adjacent to project components.
Fish
Currently Red Dog Creek, and perhaps part of Ikalukrok Creek below the
confluence of Red Dog Creek, are toxic to fish at most times of the year.
Toxic metal loadings to Red Dog Creek would decrease as a result of diver-
sion ditch construction at the mine and water treatment. The combination of
a possible significant improvement of water quality in Red Dog Creek, and
the potential that a chemical barrier currently exists in Ikalukrok Creek,
could lead to the utilization of the upper Ikalukrok Creek by char and
salmon, as well as utilization of Red Dog Creek by grayling, char and
salmon. This has raised the concern for both Red Dog Creek and Ikalukrok
Creek that metal accumulation in fish tissue could increase and thereby
affect humans consuming these fish.
Baseline studies indicate that even with high metal loadings occurring at the
present time, only cadmium, zinc and copper accumulate in fish tissue. With
decreased metal loadings expected, it would be highly unlikely for other
metals to emerge as fish tissue contaminants. This is because in the lower
metal loadings scenario predicted, natural metal chelation* and precipitation
mechanisms would occur as they do now, but closer to the source. These
chelation and precipitation mechanisms are currently overloaded in Red Dog
* Defined in Glossary.
V - 14
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Creek and at the present time occur over a relatively short distance in
Ikalukrok Creek. Long-term exposure of fish to waters with low metal
concentration levels currently exists in Ikalukrok Creek downstream of Red
Dog Creek, and only small metal accumulations in fish tissues have been
found. Further, cadmium, zinc and copper vary seasonally in tissue concen-
tration, which indicates that metals excretion occurs when fish are not
directly exposed to metals (i.e., during migration or other movements away
from the metal source). This same migration or movement phenomenon would
occur in the mining situation and should not allow increased accumulation of
any of the three metals.
Presently, no guidelines exist which set dangerous levels for zinc, copper or
cadmium in fish tissues used for human consumption. Zinc and copper are
essential trace elements for humans, whereas cadmium is considered a toxic
chemical to humans. Cadmium would have to be ingested at a rate of
350 [jg/day for 50 years to reach a critical poisoning level (Reeder et al.,
1979). Based on the highest fish tissue levels of cadmium reported in the
baseline study, a person would have to daily ingest 6.4 kg (14.1 Ib) wet
weight (1.1 kg [2.4 Ib] dry weight) of the muscle tissue of char for cadmium
poisoning to occur in 50 years. Based on the average tissue levels found in
the study, a person would have to daily ingest over 11.6 kg (25 Ib) wet
weight (2.0 kg [4.5 Ib] dry weight) of char for 50 years before critical
levels were reached. These high consumption rates, especially considering
the seasonal usage of these fish, clearly demonstrate that the normal inges-
tion of fish containing small amounts of cadmium should not be of concern.
Initial development of the mine site would include establishment of collection
ditches, preproduction stripping and road construction. Blasting activities,
initial stripping and road construction should not impact Red Dog Creek.
Collection ditches and berms would be constructed quickly so that suspended
solids escaping to Red Dog Creek would be low. The effect of any increase
of small suspended solids on fish should not be detectable.
Eventual diversion of the main stem of Red Dog Creek around the ore body
would be expected to cause increased suspended solids loadings during con-
struction and upon initiation of discharge in the new channel. This increase
would be unavoidable and might cause some short-term downstream impacts on
fish. Suspended solids loading during construction and initiation of dis-
charge in the new channel would be analogous to suspended solids associated
with a major storm event. Any effects would be felt primarily within Red
Dog Creek with limited amounts of fine sediment reaching Ikalukrok Creek.
Increased suspended solids loadings from this source subsequent to stabiliza-
tion should only occur during the first subsequent annual high flow periods
and should not cause undue stress to fish populations.
Reclamation of all disturbed areas should occur as soon as practicable after
the completion of construction activities. This procedure would aid substan-
tially in the reduction of suspended solids loadings to surface waters.
Diversion and collection ditches should also undergo some reclamation to
assist in erosion control. In addition, it might be necessary to armor or
otherwise protect these ditches from erosion.
V - 15
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Operation of the mine, other than the implementation of the creek diversion,
should not cause rapid changes in water quality. Surface water collection
ditches for the open pit should continue to capture suspended solids. Metals
entering Red Dog Creek should diminish over time as ore removal occurred
and groundwater flow to the creek was altered.
Post-mining pit reclamation should ensure improved water quality and thus
fisheries values. The remaining pit would be flooded to stop further oxida-
tion of low grade mineralization. It is presumed that flooding of the pit
would be carried out in a manner that would maintain adequate downstream
flow during the period of filling. This approach would protect downstream
fish resources.
The tailings pond would be located on the South Fork of Red Dog Creek.
No fish have been found in this creek. Construction of the tailings dam
would result in some unavoidable increases in suspended solids. These in-
creased loadings should be of short duration. Because of the distance to
fish bearing streams and rapid stabilization of disturbed areas, these in-
creased loadings should have limited effects on downstream fish. The diver-
sion of clear water surface runoff to Bons Creek could contribute some sedi-
ment to the water supply reservoir, but should be of short duration if
proper protection works were employed in the ditches. This should cause no
discernible downstream effect in Bons Creek below the pond.
Water leaving the tailings pond would be treated to adequate levels to pro-
tect downstream fish resources. In the extreme event when treatment was
not possible (as discussed under Hydrology and Water Quality; see page
V-12), surface runoff would assist in dilution of tailings pond overflow to
prevent or reduce downstream effects on fishery resources.
Alteration of the hydraulic regime in both Bons Creek (and thus Dudd
Creek) and Red Dog Creek (and thus Ikalukrok Creek) would be possible.
These changes would be minimal in Dudd Creek where low flows would be
reduced by two percent and high flows would be slightly increased. These
changes would be no more than expected annual variation in stream flow and
would not affect downstream fishery resources. Stream flow in Red Dog
Creek would be decreased a small amount, but since no fish occur in the
main stem of this creek there would be no impact on this aquatic resource.
The effects of this small change on the larger Ikalukrok Creek would be
small and should not affect this creek's aquatic resources. Instream flow
studies have been carried out in both Dudd and Ikalukrok Creeks. Further
interpretation of these data could be employed to mitigate any effects of
hydraulic changes.
Construction of the mill site and worker housing facilities should have no
effect on fish as the facilities would be located away from most streams and
drainage would be diverted to the tailings pond. The same would be true
of the operation and reclamation phases of the mine. The greatest effect
on local fish populations would likely be the result of increased fishing
pressure from mine employees. This impact could cause significant depletion
of local fish populations and probably would require some regulation of sport
fishing effort.
V - 16
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Construction and operation of the Bons Creek water supply reservoir should
cause minimal hydrologic regime interruption. Fish are not present at or
above the reservoir site, so the only expected impact would be some increase
in suspended solids during construction of the dam. This impact should be
small because of the distance downstream to known fish populations and the
short-term nature of the increased suspended solids loadings.
Reclamation of the water supply reservoir might take place upon abandon-
ment, depending on the wishes of the landowner (NANA) and federal and
state agencies. Cominco is committed to satisfactory resolution of a reclama-
tion procedure, if necessary, during the life of the mine (see Appendix 1,
Reclamation Plan).
Air Quality
Because of its remote location, the project area is designated by EPA as a
clean air, or "attainment area", for the pollutants sulfur dioxide (SO2),
nitrogen oxides (NO [as NO2]), carbon monoxide (CO), particulate matter
(PM), ozone (O3) and lead (Pb). This means that the area has attained
(i.e., is better than) the National Ambient Air Quality Standards (NAAQS)
for these pollutants. The NAAQS are shown in Table V-4. Any project
must meet these standards before it can be permitted. The Red Dog mine
area facilities would emit all six of these pollutants.
Even if a project would otherwise meet these standards, if any of the indi-
vidual pollutants would be emitted above certain rates, pollution control
equipment qualifying as Best Available Control Technology (BACT) must be
installed to minimize that pollutant's emission rate. The EPA Significant
Emission Rates are shown in Table V-5.
Potential emissions in Red Dog Valley were analyzed to determine whether
any would cause or contribute to pollution in violation of any:
0 National Ambient Air Quality Standards (NAAQS); or,
0 Prevention of Significant Deterioration (PSD) increment concentra-
tions (SO2 and PM only).
Major point sources (e.g., power plant) and nonpoint sources (e.g., roads)
of emissions in Red Dog Valley would be the mine area, the mill crusher and
dryer facilities, and the diesel power plant (Table V-6). Gaseous emissions
from the open pit mine would come from diesel-powered equipment such as
ore haul trucks, dozers and front-end loaders. The primary source of dust
emissions would be from trucks hauling ore from the mine. Other sources of
dust emissions would include drilling and blasting operations, ore loading
operations, ore and waste rock unloading, and losses from the waste rock
stockpile due to wind erosion. Dust particulate emissions would be minor
from blasting and ore production operations if these operations were re-
stricted in strong wind and water sprays were used to control dust in the
pit staging areas. The floor of the pit would be relatively sheltered from
wind most of the year.
V - 17
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Table V-4
NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS),
ESTIMATED PREVENTION OF SIGNIFICANT DETERIORATION INCREMENTS,
AND WORST CASE PROJECTED CONCENTRATIONS
Pollutant and
Averaging Time
Sulfur Dioxide
3-hr
24-hr
Annual
Nitrogen Dioxide
Annual
NAAQS
((jg/m3)
1,300
365
80
100
PSD Increment
(pg/m3)1
512
91
20
NE2
Worst Case
Projected
Concentrations
(pg/m3)1
80
20
17
74
Carbon Monoxide
1 hr 40,000
8-hr 10,000
Particulate Matter3
24-hr 150
Annual 60
Ozone
1 hr 235
Lead
Calendar Quarter 1.5
NE
NE
37
19
NE
NE
NE
NE
13
13
NE
1.2
1 Source: Dames & Moore, 1983c.
2 Has not been established.
3 Fugitive particulate matter emissions were not included in
calculations of concentrations.
V - 18
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Table V-5
EPA SIGNIFICANT EMISSION RATES
Pollutant
Sulfur Dioxide (SO2)
Nitrogen Oxides (as NO2)
Carbon Monoxide (CO)
Particulate Matter (PM)
Ozone (O3)
Lead (Pb)
Significant
Mg/yr
36.3
36.3
90.7
22.7
36.3
0.5
Emission Rate
tons/yr
40.0
40.0
100.0
25.0
40.0
0.6
Dust controls would be most effective on the ore haul road and the waste
rock storage piles. Adequate controls on the ore haul road could be water
sprays (once or twice a day in dry weather), and an annual application of a
suitable stabilizer. Dust generation would be a potential problem 30 to 60
days a year, primarily from June through August, although some road dust
might be generated throughout the year.
A typical application of water necessary to control dust on the ore haul road
would involve approximately 125,000 & (33,000 gal) of water per day. This
volume represents about 0.12 dams/day (0.1 ac-ft/day), or less than one
percent of the flow of the main stem of Red Dog Creek during a low flow
period. An uncontaminated water source would be used for dust control,
probably Bons Creek, the main stem of Red Dog Creek or the North Fork of
Red Dog Creek. Chemical stabilizers such as calcium chloride (CaC12) or
magnesium chloride (MgC12) would be applied annually to those portions of
the ore haul road that were outside the tailings pond drainage area. These
common dust palliatives could potentially disrupt the chemical balance of the
tailings pond water if they accumulated in high enough concentrations.
Control of dust from the waste rock storage pile would require aerodynamic
shaping and orientation to the prevailing wind (north to south). Wind
screen berms of rock and water sprays could be used to protect fine grained
material. Revegetation would be attempted on those areas which had reached
their final configuration.
V - 19
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Significant point sources of emissions at the mill site would include concen-
trate dryers, the crusher baghouse and the power plant (Table V-6). Minor
and insignificant sources would be from utility and passenger vehicles, fuel
storage and aircraft operations.
Based on the significant emission rates in Table V-5, the Red Dog project
would be a significant pollutant source for SO2, NO , PM, O3 (calculated
from vohatile organic compound [VOC] emissions) and Pb, but not CO.
Therefore, BACT would have to be demonstrated for all five pollutants.
The type of power plant engines proposed for this project would be capable
of meeting BACT requirements. NO emissions would be within the proposed
standards without modifications. Tne recently set New Source Performance
Standards (NSPS) for stationary internal combustion engines (larger than 560
in3 per cylinder or 1,500 in3 per rotor) require that NO emissions not
exceed concentrations of 600 ppm. Satisfying the NSPS might also satisfy
BACT requirements. Meeting SO2 emission standards would require use of
low-sulfur diesel fuel. VOC and CO could be controlled by proper main-
tenance procedures. PM emissions from the dryers would be controlled with
a high-efficiency particulate collection system. Water sprays would be used
to control dust on access and ore hauling roads. Dust from the crusher
would be controlled by a baghouse. Lead would be controlled by the high-
efficiency particulate collection system on the dryers. Details of emissions
control systems would be provided through the PSD permitting process.
PSD increments are ambient pollutant concentration limits which legally define
to what extent pollutant concentrations in an area are permitted to increase
above a set baseline for all future time. The preliminary impact estimates
for the Red Dog project might be less than the PSD increments.
Overall air quality impacts of the power plant emissions plume were estimated
using the EPA Valley model. Assumptions made included a conservatively
low plume height, worst case meteorological conditions, and peak rate 24-
hour emission concentrations. Results of the model estimate indicated that
the most likely power plant plume impact area would still be in compliance
with the applicable NAAQS and PSD increments for all pollutants (Table
V-4). Thus, while the project would exceed the EPA Significant Emission
Rates and require BACT, impacts to the area would not be significant be-
cause the overall NAAQS would be met.
The worst case analysis discussed in the preceding paragraphs did not
consider a rather infrequent condition important for protection of the health
of workers. In extremely stable conditions when an inversion would be
located immediately above the power plant emission plume, the plume could
reach ground levels in the vicinity of the nearby worker housing complex.
Because of this possibility, it would be important that the accommodation
complex be located upwind from dominant wind directions from the power
plant, or sufficiently upslope to be above a low lying inversion over the
power plant.
Protection of air quality also would require proper operation of solid waste
incinerators. No visible dark or black smoke would be permitted. Refuse
V - 20
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Table V-6
ESTIMATED SOURCES AND AMOUNTS OF EMISSIONS FROM PROJECT COMPONENTS1
EMISSION SOURCES
Power Plant
Zinc Concentrate Dryer3
Lead Concentrate Dryer3
Barite Concentrate Dryer3
Crusher Baghouse
Drilling, Blasting
Ore Loading and Hauling
Crusher Feed
Waste Ore Stockpile
Fuel Storage
TOTAL
Mg/yr
5.2
25.2
6.6
6.6
0.0
0.0
1.3
0.0
0.0
0.0
44.9
S02
(tons/yr)
5.7
27.8
7.3
7.3
0.0
0.0
1.4
0.0
0.0
0.0
49.5
NOX (as N02)
Mg/yr
318.0
315.1
82.6
82.6
0.0
0.0
3.6
0.0
0.0
0.0
801.9
(tons/yr)
350.5
347.3
91.1
91.1
0.0
0.0
4.0
0.0
0.0
0.0
884.0
Mg/yr
9.3
45.5
12.0
12.0
0.0
0.0
2.7
0.0
0.0
0.0
81.5
CO
(tons/yr)
10.3
50.2
13.2
13.2
0.0
0.0
3.0
0.0
0.0
0.0
89.9
Mg/yr
0.2
18.2
4.8
4.8
4.4
9.2
113.8
0.5
0.7
0.0
156.6
PM
(tons/yr)
0.2
20.1
5.3
5.3
4.8
10.2
125.4
0.6
0.8
0.0
172.7
03
VOC (as hexane)2
Mg/yr
77.6
377.2
98.9
98.9
0.0
0.0
0.3
0.0
0.0
0.4
653.3
(tons/yr)
85.6
415.8
109.0
109.0
0.0
0.0
0.3
0.0
0.0
0.5
720.2
Mg/yr
0.0
0.9
3.4
0.0
0.2
0.4
0.1
0.0
0.1
0.0
5.1
Pb
(tons/yr)
0.0
1.0
3.7
0.0
0.2
0.5
0.1
0.0
0.1
0.0
5.6
1 Source: Dames & Moore, 1983c
2 Ozone (O3) levels may be calculated from volatile organic compound (VOC) emissions.
1 SO2, NO. CO and VOC emissions from the concentrate dryers would originate
in the power plant Internal combustion engines and would be ducted to the
dryers with power plant exhaust gases.
-------
which could not be burned with colorless or white smoke would be buried at
the solid waste landfill site.
Visual Resources
According to the Visual Resources Management (VRM) Program, Red Dog
Valley was generally rated as having high visual quality with a variety class
rating of common. However, the remoteness of the mine area limits the num-
ber and sensitivity of potential viewers. It should be kept in mind that all
mine area facilities would be located on private land and the VRM Program as
a management system is not applicable to private land. The discussion
below, therefore, would be primarily of benefit to NANA as the landowner in
its joint management of the project.
The mine site would be located within a partial retention Visual Quality
Objective (VQO) zone. This designation normally permits management activ-
ities which would not dominate the existing landscape. Activities which
would introduce different form, line, color or texture would be acceptable as
long as they would remain secondary to the visual strength of the landscape.
Activities which would repeat the form, line, color or texture of the land-
scape would be compatible with the partial retention objective.
The landscape character of the mine site area has a moderate ability to
absorb visual changes. The visual changes which would be associated with
the development include surface rock excavation and road construction be-
tween the mine and mill sites. The proposed changes would be viewed pri-
marily by construction and mine related workers at or arriving at the site.
Only a small proportion of these viewers would be expected to have a con-
cern for scenic quality.
The mine site following surface mine excavation would appear as an oblong
depression approximately 152 m (500 ft) deep, 305 m (1,000 ft) wide and
853 m (2,800 ft) long. Water and runoff would collect at the base of the
depression.
The tailings pond would be located in an area characterized by gently slop-
ing hills and valleys. Variety class at the pond site was rated as common
due to the typical character of the area landscape. Few visitors other than
mine related personnel would be expected to view the tailings pond. Due to
this consideration and the likelihood that few of the viewers would have a
specific concern for scenic qualities, the tailings pond site was rated as
having a low sensitivity level.
The VRM system visual quality objective for the tailings pond site has been
designated as partial retention. Again, to adhere to the visual objectives,
proposed changes should not visually dominate the area landscape.
The visual absorption capability of the area is moderate owing to the gentle,
consistent slopes surrounding the proposed tailings pond. During project
operation, the tailings pond would be visible from aircraft flying directly
overhead. Proposed pond reclamation activities would include regrading
waste rock, capping the surface and revegetating the slope. The resulting
color and textural changes would be secondary to the existing expansive
landscape character. The approximately 46 m (150 ft) high dam and flat
V - 22
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surface of the reclaimed pond would remain visible and create a contrast in
line and form to the surrounding landscape. The level of contrast, how-
ever, would be consistent with the partial retention objective.
The mill site, worker housing site and airstrip would be located to the west,
upslope from the tailings pond site. Visual variety was rated common for all
three sites and a low sensitivity level designation would be appropriate.
The visual quality objective for the three sites would be partial retention.
The facilities would be visible from aircraft and surrounding hilltops; how-
ever, they would be dwarfed by the expanse of the surrounding landscape.
Visual changes would include the construction of several buildings, a narrow
airstrip and connecting access roads. Again, few scenic viewers would
likely see the sites since the facilities would be located in the far back-
ground.
The visual absorption capability of the sites is moderate due to the gentle
slopes which characterize the area. Dark colored soils would blend with the
background vegetation. Reclamation plans would include disassembling all
structures to ground level. Access roads and the airstrip would be per-
mitted to return to a natural vegetated condition. Evidence of the facilities
eventually would not be visible.
The water supply reservoir on Sons Creek would be located on gentle slopes
southwest of the proposed airstrip. The partial retention visual quality ob-
jective assigned to the area would be maintained and possibly enhanced by
the reservoir that could add aesthetic variety to the landscape. The reser-
voir would not be removed at the end of the project unless desired by NANA
or state agencies.
Sound
Noise impact analysis of the proposed project requires an inventory of noise
sources and noise sensitive receptors. Noise sensitive receptors would be
people or wildlife that could be adversely affected. Noise sensitive people
would be basically restricted to visitors to Cape Krusenstern National Monu-
ment and, to a lesser extent, subsistence hunters who may feel that their
traditional hunting grounds would be adversely affected by noise. Wildlife
species most sensitive to noise would include caribou, bears, muskoxen and
nesting raptors.
Noise emanating from the open pit would not propagate past surrounding
slopes and ridgetops since sound normally travels in straight lines. Noise
sources would include blasting, dozers, front-end loaders and ore hauling
trucks.
Estimated sound pressure levels generated at mine area facilities are shown
in Table V-7. Blasting sound pressure levels are normally thought of as
relatively loud noises. However, blasting noise propagates in lower frequen-
cies somewhat like a thunderclap. Low frequency sound of this type would
usually be tolerable since it would normally occur at most only two or three
times a day. The other mine site sound sources, assuming six or seven
pieces of equipment would operate at any one time, would combine to a sound
level of 100 dB(A) at 15 m (50 ft) and 65 to 75 dB(A) at the surrounding
V - 23
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Table V-7
ESTIMATED SOUND LEVELS GENERATED BY
MINE AREA EQUIPMENT AND FACILITIES
Sound Source
Blasting
Bulldozers
Front-End Loaders
Ore Trucks
Primary/Secondary Crushers/
Grinding Mill
Diesel-Powered Generators
Utility Vehicles
Worker Accommodations
Aircraft Operations
For Comparison:
OSHA Regulation
(15 min exposure)
Discotheque
Jackhammer
OSHA Regulation
(8 hr exposure)
Automobile
(100 km/hr [62 mi/hr])
Typical Outdoor Noise
(wind, rain, birds)
Soft Whisper
Sound Pressure Level
dB(A)
170 @ 91 m (300 ft)
87 @ 15 m (50 ft)
90 @ 15 m (50 ft)
90 @ 15 m (50 ft)
95 @ 15 m (50 ft)
100 @ 15 m (50 ft)
80 @ 15 m (50 ft)
60 @ 15 m (50 ft)
95 @ 15 m (50 Ft)
115 (max. allowable)
110 on dance floor
95 @ 15 m (50 ft)
90 @ ear
71 @ 15 m (50 ft)
40 @ 15 m (50 ft)
35 @ 2m (6 ft)
1 The sound pressure level in decibels (dB) corresponding to a sound pres-
sure (P) is compared to a reference level of 20 micropascals. Sound pres-
sures for various frequencies of noise are weighted by factors (A weights)
which account for the response of the human ear. The sound pressure
level in dB(A) = 20 Log10 (P/20).
V - 24
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hilltops. There would normally be few sensitive receptors in the vicinity of
the mine other than workers.
Major sound sources at the mill site, worker housing site, access roads, air-
strip and water supply reservoir are estimated in Table V-7. Assuming a
time of simultaneous activity, the combined sound pressure level would be 66
dB(A) at a distance of 2.4 km (8,000 ft) on Volcano Mountain (Fig. 11-1); a
level above natural noise levels. Beyond the surrounding hills, sound gen-
erated by mine area facilities and equipment would not propagate at levels
above those caused by wind and rain.
Cultural Resources
Four archeological sites are located in the immediate area of the mine site.
Two of these could not be avoided during ore removal, and therefore they
would be evaluated for eligibility to the National Register of Historic Places.
If eligible, mitigation plans developed in consultation with the State Historic
Preservation Officer (SHPO) would be reviewed by the Advisory Council on
Historic Preservation (ACHP).
Wherever feasible, road alignments and other facilities would be designed to
avoid direct impact on known archeological sites determined eligible for the
National Register. If such sites could not be reasonably avoided, or other-
wise protected, recovery of data would be accomplished in accordance with
the comments of the ACHP. Similarly, sites in borrow pit areas would be
avoided if possible; if not possible, recovery operations would be accom-
plished pursuant to an approved research design. Pursuant to ACHP
comment, provisions would be made for emergency recovery operations at
sites discovered during construction.
Subsistence
Four impacts on subsistence resources and harvest activities are considered
below: habitat degradation; interference with fish and wildlife life cycles or
migration patterns; increased harvest pressures; and incompatible work
arrangements. In general, any event that alters the pattern of resource
availability or subsistence effort might redistribute the harvest pressure to
different species or populations, possibly with detrimental effects on some
species.
Kivalina and Noatak are the settlements nearest the project area. Since
Kivalina residents rely more heavily on a wider variety of subsistence re-
sources (e.g., caribou, Arctic char, marine mammals) present in the project
area, that community would be more likely to experience any adverse impacts
on the subsistence resource base. However, Noatak residents also rely for
an important part of their subsistence on the fish and wildlife resources of
the area.
The mine site vicinity possesses little value for subsistence or recreational
fishing and hunting. The South Fork of Red Dog Creek is utilized by cari-
bou to a lesser extent than areas outside the mine site, and the area is at
the margin of use areas for Noatak and Kivalina residents. Based on the
V - 25
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assessment of environmental effects of mine site operations on surface lands
and water quality, the mine would not cause any material loss of habitat.
The valley of the South Fork of Red Dog Creek is outside the prime winter-
ing grounds for caribou, but may support occasional winter grazing. Sub-
sistence would be adversely affected if mine construction and operation
disturbed established winter grazing in a way that reduced the caribou
resources usually available for harvest by Kivalina and Noatak residents.
Caribou might also become subject to increased local hunting pressure from
employees based at the mine, though hunting and trapping would be re-
stricted while workers were at the site. Presumably, resident employees
would be more inclined to hunt during off-duty hours than out-of-region
workers. Since most of the resident workers would come from villages that
do not usually hunt in the Red Dog area, any hunting by them could in-
crease subsistence harvest pressure above present levels. The dynamic
equilibrium between caribou habitat and migration patterns, and herd popu-
lation and harvest pressure, is complex. The net subsistence outcome from
geographical shifts in caribou movements or from increased hunting activity
would not be simple to predict.
There would be potential that employment at the mine would have adverse
effects on the persistence of traditional subsistence patterns. Whether these
effects materialized would depend in part on how well work schedules and
commuting patterns could be adapted to minimize conflicts with subsistence
requirements.
First, there would be some cause for concern that closer involvement in wage
employment and the cash economy might gradually erode interest in subsis-
tence or lessen subsistence success. There is some suggestive evidence to
the contrary in some recent sociocultural studies (John Muir Institute, 1983)
which conclude that regular but flexible employment can be compatible with
continued subsistence participation and superior subsistence success. The
John Muir Institute study found a strong positive correlation between high
cash income and subsistence success, perhaps because cash income enables
subsisters to acquire better equipment for their task.
Second, safe, efficient operation of the mine would require a stable, year-
round work force. Consequently, a high level of resident employment would
hold some potential to disrupt either traditional subsistence patterns or mine
operations, especially during the prime periods in the annual subsistence
cycle. Many of the subsistence resources that are most important to resi-
dents of the region are highly seasonal in availability. For example, the
prime periods to harvest salmon, Arctic char and marine mammals are very
brief, a few weeks or less each year. If the work rotation preempted these
opportunities, there would be some loss of subsistence income.
The mining plan tentatively calls for a two-week rotation schedule for the
on-site workforce, including employees who reside in the region. This would
allow for subsistence harvest participation during time off. Also, it should
be noted that the availability of subsistence resources and the seasonal sub-
sistence harvest cycle is not uniform throughout the region's communities.
This, too, might allow some leeway for adjusting work rotations to minimize
conflicts with subsistence. For the long run, the coexistence of traditional
V - 26
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subsistence activities and employment at the mine would depend on the flex-
ibility of work arrangements and the ability of individual mine workers to
retain and pass on their subsistence skills. This is an important project
objective for NAN A.
Socioeconomics
The proposed project's socioeconomic consequences would be largely deter-
mined by certain fixed features of the project, e.g., the isolation of the
mine, port site and transportation corridor from existing settlements, and
the choice of a transient campsite for workforce support rather than a per-
manent townsite. Socioeconomic impacts would also be sensitive to certain
entrepreneurial and managerial decisions. Under terms of the NANA/Cominco
agreement, NANA participates in decisions and policies about design and
operation of the mine that might affect local interests. NANA's official pos-
ture strongly reflects its perception of the development concerns and prefer-
ences of the region's residents. The NANA/Cominco agreement binds
Cominco to managerial and labor policies designed to magnify positive socio-
economic impacts and mitigate adverse social impacts. For this environmental
consequences assessment, it was assumed that the terms of this contractual
agreement would govern the project. Where the agreement aims at, but can-
not guarantee, such goals as a high level of resident hire, the analysis
relies on our most realistic estimate of project impacts.
Four potential socioeconomic impacts are considered below: regional employ-
ment and income; population growth and migration; demand for community
infrastructure; and social, political and cultural stability and autonomy.
Project alternatives mainly involve variations in the overland transportation
corridor, port site and type of transfer facility. However, the project
factors that critically affect socioeconomic impacts would be constant for all
options. In terms of the most important socioeconomic impacts, there would
be no material difference among the project alternatives.
Regional Employment and Income
The economic impact of the Red Dog project on the region would stem partly
from the new basic jobs and earnings the project would provide residents,
and partly from the stimulus that this basic economic growth would contrib-
ute to the secondary economy.
For purposes of regional economic impact analysis, the Red Dog project can
be usefully divided into a construction phase and a production phase. The
construction phase would cover the 30-month period during which the mine
project site and transportation system would be developed. As now planned,
construction would begin during the winter of 1985-86 and be completed by
the end of 1987 (Fig. I-2). The mine would begin production by early 1988
and reach full production by about 1994. This assessment assumes that the
project would proceed on schedule. A few years' delay in the start of the
project would postpone but not materially change the socioeconomic impacts.
Cominco's present mining plan aims at a total annual shipment of 434,450 Mg
(479,000 tons) of combined ore concentrates during the initial phase of pro-
duction. Changed market conditions or other factors could raise or lower
V - 27
-------
that production goal. However, the mining and milling operation could sup-
port higher output with only marginal added labor.
Cominco estimates that direct project employment would be 372 jobs for con-
struction and 424 jobs for production. Table V-8 shows the employment
breakdown by occupational group. There would be some overlap in the
occupational skills required for each phase, especially among equipment
operators and skilled trades.
Table V-8
AVERAGE ANNUAL EMPLOYMENT BY OCCUPATIONAL GROUP
CONSTRUCTION PHASE
Craft
Carpenters
Boilermakers
Electricians
1 nstrumentation
Insulators
Ironworkers
Laborers
Linemen
Millwrights
Painters
Pipefitters
Equipment Operators
Sheet Metal
Truck Drivers
Pile Drivers
Management & Clerical
Total
Number
29
10
21
4
3
31
57
6
11
4
21
78
4
54
14
25
372
PRODUCTION
Craft
Management
Supervisors
Professionals
Technical /Clerical
Equipment Operators
Mill Operators
Tradesmen
Trainees
Laborers
Catering
Total
PHASE
Initial
7
30
9
51
64
22
69
84
16
40
392
Final
7
30
11
53
72
28
93
68
22
40
424
Source: Cominco Alaska, Inc.
V - 28
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Cominco projects an annual gross payroll (1983 dollars) of $23.1 million for
the construction phase and $13.4 million for the final production phase.
Average annual earnings per job amount to about $62,000 during construction
and about $31,700 during production. This earnings differential would be
due to such factors as different work schedules and occupational mixes for
the two phases. By contrast, as stated in the Socioeconomics section of
Chapter IV, the 1980 median household income for the entire Kobuk region
was $17,756, although the respective median household incomes of Kivalina
and Noatak were $8,304 and $10,000.
In order to assess the economic impact of project payrolls on the NANA
region, it was necessary to estimate how many of these direct jobs would be
filled by residents, how many non-resident employees might eventually take
up residence in the region, and how much secondary employment might be
generated by basic employment in the mining project.
The management agreement between Cominco and NANA set a goal of maxi-
mum resident hire, entitled NANA to nominate the project personnel officer,
and established a joint committee to prepare a manpower inventory and iden-
tify manpower training needs. The success of the employment goal would
depend on a number of factors such as the number of qualified residents
seeking work at the mine, the effectiveness of resident training programs,
and the compatibility of work and rotation schedules with other important
interests of potential employees, particularly subsistence pursuits. An in-
tensive training program to maximize local hire has been initiated by the
Regional Strategy Training Placement Committee. In additicn, this committee
is also working to expand trade and minimize net migration from villages.
Because of the unprecedented nature of this project for the region, projec-
tions of the level of resident hire are necessarily speculative (Table V-9).
Based on a review of the construction workforce composition compared to the
size and occupational skills of the resident labor pool and current unemploy-
ment and workforce participation rates, it was estimated that about one-third
(124) of the construction jobs would be filled by present NANA region
residents.
During the production phase, all on-site positions would be filled on a rota-
tion basis by workers billeted in camp quarters. Cominco's preliminary
operating plan foresees a two-week on/two-week off rotation for all on-site
employees, with 12-hour work days for operating crews and 10 to 11-hour
days for support crews.
For the production phase, Cominco estimates that regional residents would
fill about 168 jobs at production start-up, climbing to about 267 jobs by the
final production stage. This is a relatively high level of resident employ-
ment for a large remote project in rural Alaska. However, these estimates
appear feasible in view of the skills employed by the project and available in
the region's workforce, and in view of the joint commitment of NANA and
Cominco to recruit, train and employ local residents.
The non-resident jobs would be filled by transient workers who would com-
mute between the jobsite and permanent residences outside the region.
Cominco would pay round-trip air transportation costs for all on-site em-
ployees. This transportation agreement would also make it easy for non-local
workers on the project to retain their prior residences and discourage them
from resettling into the region. For purposes of estimating economic and
population impacts, it was assumed that only five percent of the non-local
production workforce would take up permanent residency within the region.
V - 29
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This group would include former residents returning to the region as well as
newcomers.
Table V-9
ESTIMATED TOTAL RESIDENT EMPLOYMENT IMPACTS1
NANA REGION
Construction
Pre-production
Final Production
Direct2
Resident
.Employment
124
168
267
Secondary3
Resident
Employment
100
86
162
New3
Resident
Employees
75
96
118
Total3
Resident
Employment
299
350
547
1 For purposes of meaningful regional analysis, project employment is
assigned by residence of the worker rather than by the jobsite. By
Alaska Department of Labor and U.S. Census economic and demographic
statistical reporting units, the minesite is situated in the North Slope
Borough.
Source:
2 Cominco Alaska, Inc.
3 Kevin Waring Associates, 1983
Based on these assumptions, the prorated share of direct income to region
residents would be about $6.9 million during the construction peak and would
rise to about $8.4 million by the time the mine reached full production
(Table V-10).
In addition to direct employment of residents, the mine project would trigger
other changes in the region's employment and economic structure, especially
at Kotzebue. First, the added purchasing power injected by mine payrolls
would pump up local purchases of goods and services. This would stimulate
secondary economic growth, broadening the range of locally available goods
and services for everyone and creating new jobs in the support sector. In
order to calculate the effects of the mine payroll, a basic to nonbasic
employment ratio of 1.0 to 0.3 was used for the construction phase, rising to
1.0 to 0.4 for the production phase. This employment multiplier, though low
V - 30
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Table V-10
PROJECTED ANNUAL PERSONAL INCOME
($ million)
DIRECT INCOME INDIRECT INCOME
Resident1 Non-resident1 Total2 Resident Only1
Construction
Initial Production
Final Production
6.9
5.2
8.4
16.2
7.0
5.0
23.1
12.2
13.4
2.1
1.8
3.4
Source:
1 Kevin Waring Associates, 1983
2 Cominco Alaska, Inc.
by national standards, is typical of Alaska's remote regional centers and
allows for some expansion in the region's secondary economy.
Second, it is plausible that many, perhaps most, of the residents hired for
the mine would be recruited from other jobs in the region, leading to a
period of job shuffling. These vacated positions would become available for
other underemployed and unemployed resident workers. If the vacated posts
were not readily filled from the resident labor pool, some of the jobs might
draw newcomers to the region to replace mine hirees. In this way, resident
hire on the mining project would trigger upward job mobility throughout the
region's labor pool and might also attract some new residents to the region.
In all, it was estimated that about two-thirds of the combined vacated or new
secondary posts would be filled by residents, with the rest filled by new-
comers or former residents. On this assumption, there would be about 118
new workers moving into the region to take up jobs created by the mine
project.
The proposed project would provide permanent, year-round employment in a
developing region with substantial unemployment and underemployment. The
project management, as expressed by the NANA/Cominco agreement, places
high priority on policies and practical steps designed to make feasible a high
rate of resident hire. Apart from the mine, there are no projects in the
V - 31
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region that seem likely to improve economic or job conditions to a significant
extent. At final production, the project would contribute about 547 jobs and
an annual payroll of $11.8 million to NANA region residents. For compari-
son, the Alaska Department of Labor reports that in 1982, the average
annual employment for the Kobuk census division was 1,863 employees, with
a total annual payroll of $39.0 million. Thus, compared to 1982 levels, the
mine project at final production would increase resident employment by about
29 percent and resident earnings by about 30 percent. The project would
also create about 248 construction jobs and about 157 permanent production
jobs for workers commuting from other areas of the state, plus an undeter-
mined number of secondary jobs.
The economic impact of the project would accelerate during construction and
then level off as production began. Sudden prosperity might cause some
transitional problems (e.g., price and labor inflation) in the local economy
until the local supplies of goods and services and labor adjusted to meet new
consumer demand. For the long run, however, it seems probable that eco-
nomic growth would promote local diversification and economies of scale to
offset short-term inflation.
Development of a deep-draft port facility for shipment of ore concentrates
could lower shipping costs for fuel and other cargo delivered to the region.
A fuels and general cargo depot, from which in-bound goods could be redis-
tributed to villages, would avoid the lightering costs for shipment through
the port of Kotzebue.
Population Growth and Migration
It was estimated that the mining project would eventually add about 354 per-
sons to the total population of the region above the baseline forecast without
the mine (Table V-11). Much of this growth would occur at the early stages
Table V-11
PROJECTED POPULATION IMPACT
NANA REGION
Construction
Initial Production
Final Production
Newly Resident
Employees
75
96
118
Cumulative
Growth Impact
225
288
354
Source: Kevin Waring Associates, 1983
V - 32
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of the project. This would include an estimated 118 new resident workers,
plus their households. It was assumed that Kotzebue's more developed com-
merce, transportation and community facilities and services would make it
more appealing to newcomers than the smaller remote communities. Therefore,
nearly all (about 90 percent) of these new residents would probably reside
in Kotzebue, with the rest dispersed among the other rural villages (Table
V-12).
Table V-12
ESTIMATED POPULATION - BASE CASE AND IMPACT CASE
NANA REGION
NANA Region Kotzebue Villages
Year
1982
1986
1990
2000
Base Case
5,343
5,671
6,019
6,985
Mine Case
5,343
5,896
6,307
7,339
Base Case
2,470
2,622
2,782
3,229
Mine Case
2,470
2,824
3,041
3,548
Base Case
2,873
3,049
3,237
3,756
Mine Case
2,873
3,072
3,266
3,791
Source: Kevin Waring Associates, 1983
Recent decades show a pattern of intraregional migration to Kotzebue from
its hinterland villages, but this trend appears to be leveling off. The
effects of the mine project on population movements within the region are., at
best, speculative. On the one hand, Kotzebue's more developed cash econ-
omy and community services might prompt some migration there of village
residents working at the mine. However, provision for direct commuting
rather than via Kotzebue, plus a preference of village residents to use new
income to make their families better off in their home communities might
neutralize this tendency. A best guess was that the project would not have
much net effect on intraregional population movement.
V - 33
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Demand for Community Infrastructure
All elements of the proposed project (mine area facilities, overland transpor-
tation corridor and port facilities) would be remote from existing commun-
ities. Cominco would provide at the mine site all support infrastructure for
its employees, including camp quarters, recreational facilities and emergency
medical services. Worker housing would also be provided at the port for
emergency use, and for temporary use by ship loading and road maintenance
crews. Cominco would provide charter flight pick-up and return to the
home village of resident employees, and via Kotzebue or Point Hope to
Anchorage for non-resident workers. Thus, the mining project would not
compete with existing communities for state or federal community development
programs.
However, former residents and newcomers drawn to the region to work on
the project or to take advantage of other work opportunities opened up by
the project would generate some demand for new community facilities and
services. As the region's transportation and commercial center, Kotzebue
would feel the brunt of this growth. It is estimated that Kotzebue's popu-
lation would grow by about 200 persons during construction and by another
100 persons during production, for a net growth of about 300 persons or 10
percent due to the project (Table V-12). However, there is an effort by
the Regional Strategy program to help establish businesses in the villages to
create more jobs in the local economies.
The bulk of this population growth would derive from secondary economic
growth at Kotzebue rather than from the mine itself. Since this growth
would be concentrated during the construction and early production phases,
it would likely impose some short-term strains on the capacity of the com-
munity to meet the housing needs and other community facility and service
needs of new residents. It is also plausible that the incidence of social
problems might rise while resident workers and their families adjusted to new
working and living arrangements and to improved economic circumstances.
Coordinated advance planning by the City of Kotzebue and other responsible
public agencies, with programs linked to progress in the mine development
schedule, would help mitigate these stresses of rapid community growth.
Few new residents would be expected to settle in the rural communities, so
minimal impact on their community facilities and services would ensue from
the mining project.
Social, Political and Cultural Stability and Autonomy
The isolated, self-enclosed mine camp facilities would tend to buffer the
existing communities from the most disruptive social impacts often associated
with large resource development projects in undeveloped rural regions.
Cominco would not establish a permanent townsite that might eventually in-
corporate as a local government. Ultimately, more than half of the perman-
ent workforce would be drawn from the resident labor pool. An estimated
354 new residents or about a five percent increment to the base case regional
forecast would accrue from the project over a period when the region would
not be otherwise projected to undergo much economic or population growth.
All these circumstances would tend to moderate any potential disruptions of
the prevalent political, social and cultural equilibrium, except at Kotzebue
which would receive the brunt of growth impacts.
V - 34
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The collaborative role of NAN A Regional Corporation, to which most residents
belong, in the development and management of the proposed project would
also serve to avoid or moderate adverse impacts. The management agree-
ment between NANA and Cominco contains many features designed to elimin-
ate or blunt aspects of the project that might clash with traditional lifestyles
and cultural values. Undeniably, the project presents new choices to resi-
dents about how to make their livelihoods. However, these choices would
not be imposed by forces wholly outside local control, but would arise from a
purposeful, calculated development policy by the regional corporation.
Furthermore, the management agreement between NANA and Cominco provides
a flexible, ongoing framework for resident involvement in project decisions to
adjust for unexpected problems or changing conditions.
Because there would be no permanent incorporated settlement at the mine
site requiring public services, the mine facilities would not alter the govern-
mental status quo or impose any burdens on local governments.
Outside the incorporated cities, the NANA region is part of the unorganized
borough. There are no plans to alter that status. The mine and most of
the related facilities would be in the North Slope Borough. Thus, the pro-
ject would offer limited revenue potential for a borough that might be incor-
porated in the NANA region.
As noted earlier, Kotzebue would be subject to an influx of new residents.
This might dilute the cultural and social status of established residents and
perhaps upset the local political equilibrium. Apart from sales taxes, popu-
lation growth would not generate much additional local governmental revenue
since the City of Kotzebue does not levy a real property tax. If rapid
growth overtaxed the community's fiscal resources to maintain services for
both existing residents and newcomers, it might be a source of community
conflict.
It appears that the potential for any severe adverse or disruptive socioeco-
nomic impacts on the region would be well contained by the isolation of the
project from existing communities and by the mediating role of the NANA
Regional Corporation in the development and ongoing management of the
project. The relatively low level of adverse socioeconomic impacts would be
partly attributable to conscious policies and decisions jointly made by NANA
and Cominco about the development scheme and mode of operations for the
mine. In particular, the choice of workcamp quarters, rather than a full-
fledged permanent townsite, to support a transient workforce composed
mostly of local residents on a rotation schedule would avoid many of the
adverse and potentially disruptive impacts that a major remote resource
development project might have on a remote, lightly populated and unde-
veloped region.
On the other hand, the project has substantial potential for positive long-
term impacts on employment, income opportunities and the family stability of
the region's residents. Increased family income should significantly reduce
poverty-related stress, promote family stability, and decrease social problems
such as alcoholism, suicide and mental illness. However, capture of these
positive impacts would depend on the success of programs to recruit and
train workers from the resident labor pool. If the effort to achieve a sub-
stantial degree of resident hire fell short, then it would be necessary to im-
V - 35
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port more non-local workers. In that case, the income benefits to residents
of the region would diminish.
A high rate of resident hire would be triply beneficial in terms of socioeco-
nomic impacts. First, it would permanently boost resident income and
employment. Second, it would limit the scope of new demands on existing
infrastructure by reducing the number of non-local mine employees who
might opt to take up local residence. Third, by reducing the potential for
new settlement in the region, it would allow for economic development while
still conserving resident control over the region's political, social and cul-
tural institutions and resources.
Most of the growth impact anticipated from the project would be concentrated
on Kotzebue. This would impose some growth management problems on a
community whose fiscal and physical resources to accommodate much new
growth are already limited.
Recreation
As areas accessible to state population centers become more used, those
seeking fairly primitive recreational opportunities might be drawn to the Red
Dog project area. Recreational use of the project area currently represents
only a very small percentage of the total statewide recreation. However, as
more information about the area is made available to the public, local recrea-
tional use might change. The proposed project might affect the amount and
direction of such recreational use change.
When not engaged in work related activities, Cominco employees would be
free to recreate, thus potentially increasing competition for local resources.
To minimize these impacts, Cominco would prohibit employees from hunting or
trapping during their active phase of work and residence at project loca-
tions, or while moving to or from their homes and work sites on Cominco
transportation. Construction activities and mine operations could affect
wildlife species sensitive to development and human intrusion. There could
be temporary impacts and chronic local impacts, but no major impacts to
recreational hunting on an areawide basis would be anticipated just from
development of the Red Dog project.
COMPONENTS SPECIFIC TO SOME ALTERNATIVES
This section discusses the impacts of each project alternative on a discipline
by discipline basis where certain components differ for each alternative.
Components specific to Alternative 1 include a southern corridor to a port
site at VABM 28, with a short causeway/offshore island transfer facility
(Fig. III-3). Alternative 2 consists of a northern corridor to a port site at
Tugak Lagoon, also with a short causeway/offshore island transfer facility.
Alternative 3 consists of the southern corridor to VABM 28, with a short
causeway/lightering transfer facility.
Vegetation and Wetlands
Alternative 1
Construction of an 89.9 km (56.2 mi) road in the southern transportation
corridor from the mine area through Cape Krusenstern National Monument to
V - 36
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the coast at VABM 28 would directly disturb a total of approximately 197 ha
(487 ac) of vegetation. Approximately 55 percent of the corridor would be
in the Wulik River watershed, approximately 35 percent would be in the
Omikviorok River drainage, and approximately 10 percent would cross the
upper reaches of the Noatak River watershed. Approximate road surface
area intersection of vegetation types is shown in Table V-13. An estimated
additional 84.4 ha (208.5 ac) of ground cover would be directly disturbed by
development of borrow sites along the entire corridor (Table 11-3; Fig. 11-8).
Table V-13
APPROXIMATE AREA OF VEGETATION TYPES INTERSECTED BY ROADS
IN THE TRANSPORTATION CORRIDORS
Transportation Corridor
Southern
Northern
Total Length of Corridor
Total Area Intersected
89.9 km (56.2 mi)
197 ha (487 ac)
117.0 km (73.1 mi)
257 ha (634 ac)
Vegetation Type
Tall shrub & complexes
Low shrub tundra & complexes
Closed low shrub & complexes
Open low shrub & complexes
Mat & cushion tundra
Elymus tall grass
Sedge-grass tundra
Tussock tundra
Tussock tundra-low shrub complexes
Sedge-grass marsh
Sedge-grass wet weadow
Sedge-grass bog meadow
Wetland herbaceous
2
25
10
20
10
<2
<2
110
12
2
2
2
<2
ha
ha
ha
ha
ha
ha
ha
ha
ha
ha
ha
ha
ha
(5
(63
(24
(49
(24
(<5
(<5
(273
(29
(5
(5
(5
(<5
ac)
ac)
ac)
ac)
ac)
ac)
ac)
ac)
ac)
ac)
ac)
ac)
ac)
15
10
64
8
15
<2
18
110
2
<2
10
2
<2
ha
ha
ha
ha
ha
ha
ha
ha
ha
ha
ha
ha
ha
(38
(25
(159
(19
(38
(<6
(44
(273
(6
(<6
(25
(6
(<6
ac)
ac)
ac)
ac)
ac)
ac)
ac)
ac)
ac)
ac)
ac)
ac)
ac)
Source: Dames & Moore, 1982a
V - 37
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If borrow material were taken only from sites outside Cape Krusenstern
National Monument, approximately 49.1 ha (121.3 ac) of ground cover would
be directly disturbed by borrow site development (Table 11-4). Locations of
potential sites are shown on Figures 11-8 through 11-13. It is anticipated
that vegetation type disturbance would occur with a frequency and distribu-
tion similar to that for the main road.
Indirect effects associated with occasional foot traffic, off-road vehicle use,
and dust would impact additional acreage. Snow covered ground inundated
with off-road travel might be compacted, melt comparatively late, or show
impeded drainage and increased erosion. Direct damage to uncovered vege-
tation might include breakage of plant parts, depression of the ground sur-
face, ponding and increased erosion. In most cases the degree of impact
would be unpredictable and would depend on the nature of the disturbance
and the nature of the disturbed community (Brown and Berg, 1980).
Studies following three years of operation of the North Slope Haul Road from
Atigun Pass to Prudhoe Bay indicate that road dust impacts could be sub-
stantial. Maximum dust fall might occur up to a distance of 300 m (984 ft)
from the road, and early melt of dust covered snow might extend from 30 to
100 m (100 to 328 ft) on either side of the road. If borrow material was
extracted only from sites outside the Monument, road dust impacts during
road construction would be greater than if borrow sites were spaced along
the entire corridor. This would be due to borrow being hauled further.
Mosses and lichens would be most susceptible and might, with other heath
and herbaceous plants, die or experience a loss of vitality along the road.
Some taxa, for example cottongrasses, might increase in relative abundance
in the roadside environment (Brown and Berg, 1980). Communities adjacent
to the road would be contaminated by any fuel, chemical, or concentrate
spill. The degree of impact would depend on the nature of the site and
spill, time of year and cleanup procedures.
The road would compact the ground and might impede local drainage. In
general this impact could be minimized by proper bridge and culvert con-
struction, but might occur where drainage patterns were more diffuse. Some
impounding of water might occur on the upslope side of the road and some
draining or drying might occur on the downslope side of the road. Change,
more than loss, of vegetation would be expected in response to changes in
soil type, moisture regime and topographic setting caused by the road.
A large proportion of the road would pass through areas technically clas-
sified as wetlands, and wetland impacts would involve a number of vegetation
types occupying a range of sites that may differ in soil type and moisture
regime. Therefore, associated wetland values might also differ. Wetland
values are determined by the degree to which wetlands perform various
ecological functions. Such wetland functions include: providing productive
habitat; cycling nutrients and energy; maintaining water quality; moderating
erosion and flooding, and regulating surface water flow. As habitat values
cannot always be described by the vegetation classification system used
here, potential impacts on habitat are addressed in the Terrestrial Wildlife
and Biology sections of this chapter. Some interactions with and potential
impacts to the watersheds of the region are addressed in the Hydrology and
Water Quality Section.
V - 38
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Loss of sedge-grass tundra wetlands would be small. Loss of tussock
tundra, tussock tundra-low shrub complex and open low shrub and complex
wetland communities would be much larger. However, these impacts would
not be considered regionally significant, as the loss of these vegetation
types would be small relative to overall occurrence in the project area.
Wetland values associated with these vegetation types probably would be low
to moderate along the corridor, but might be somewhat greater for communi-
ties occurring in lowland basins or areas of diffuse drainage. Open low
shrub and complex communities occurring in riparian zones might also have
greater wetland value. In addition to open low wetlands, other tall and low
shrub riparian wetlands would be impacted by the 187 stream crossings re-
quired for development of the southern corridor. The loss, however, would
be small compared to overall occurrence and would not be considered region-
ally significant.
Vegetation types of generally moderate to high wetland value are the sedge-
grass marsh, wet meadow, and bog meadow communities. It is estimated that
6 ha (15 ac) of such vegetation would be directly lost. This would repre-
sent approximately 0.4 percent of such wetlands within a 0.8 km (0.5 mi)
wide corridor from the ore body to the port site. A regionally insignificant
loss of wetland herbaceous community might also occur.
Development of the port site at VABM 28 would directly disturb about 20 ha
(50 ac) of sedge-grass marshland, Elymus tall grass and tussock tundra
vegetation. In addition to storage and power generation facilities located on
the coast, a concentrate storage building would be located about 4.0 km (2.5
mi) inland in an area scheduled to be disturbed by the removal of gravel.
Elymus tall grass vegetation is not widespread and the loss would represent
greater relative impact than for more common vegetation types. Value of the
sedge-grass marsh wetlands would also be lost. However, these losses would
not be significant on more than a local basis. Port site development might
also cause erosion or aggradation of shoreline acreage with a resulting
change in nearby coastal community types. Breaching Port Lagoon would
cause salinity to increase in the lagoon waters. This would probably cause
the lagoon shoreline vegetation to shift from freshwater to halophytic com-
munity types. In addition, fuel, chemical or concentrate spills might impact
vegetation. The specific degree of change or loss would be unpredictable.
Alternative 2
Construction of a 117.0 km (73.1 mi) road in the northern transportation
corridor from the mine area to the coast at Tugak Lagoon would directly dis-
turb a total of approximately 257 ha (634 ac) of vegetation. Approximately
40 percent of the corridor would be in the Wulik River watershed, 40 per-
cent in the Kivalina River watershed, and 20 percent in the Asikpak River
watershed. Approximate road surface area intersection of vegetation types
is shown in Table V-13.
An estimated additional 105 ha (260 ac) of ground cover would be disturbed
in the development of borrow sites. These sites have not been specifically
determined, but it was estimated that vegetation type disturbance would
occur with a frequency and distribution similar to that for the main road.
V - 39
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Other impacts associated with road development would be similar to those for
Alternative 1, although as the northern road would be slightly longer, over-
all impacts would be slightly greater.
With respect to wetlands, collective impacts to sedge-grass tundra, tussock
tundra, tussock tundra-low shrub complex and open low shrub and complex
would be less than that for Alternative 1. The northern corridor would
cross three major river systems and numerous smaller streams for a total of
312 crossings, and would impact more associated tall and low shrub riparian
wetlands than Alternative 1. Of particular importance would be impacts to
the Wulik and Kivalina floodplain communities that offer some flood protection
and provide valuable wildlife habitat. Impacts, however, are small compared
to overall occurrence of these vegetation types and would not be considered
regionally significant. Impacts to the sedge-grass marsh, wet meadow and
bog meadow communities would also be slightly greater than those for Alter-
native 1. It is estimated that, up to 14 ha (37 ac) of these community types
would be lost. However, as in Alternative 1, the impact would be small
compared to the total of similar wetland resources in the area and would not
be considered regionally significant. A regionally insignificant loss of wet-
land herbaceous community might also occur.
Development of a port site at Tugak Lagoon would directly disturb about
20 ha (50 ac) of sedge-grass marsh wetland and complexes of Elymus tall
grass and wetland herbaceous communities. As in Alternative 1, distribution
of shoreline vegetation is more restricted on a regional basis and, therefore,
its loss would represent a greater relative impact than more common vegeta-
tion types. However, the total vegetation and wetland loss at Tugak Lagoon
would not be significant on more than a local basis. As for Alternative 1,
lagoon breaching, change in nearby shoreline characteristics or potential
spills might cause other changes in coastal vegetation types, but the specific
degree of change or loss would be unpredictable.
Alternative 3
Vegetation and wetlands impacts would be similar to those for Alternative 1.
Terrestrial Wildlife
Alternative 1
Construction of the southern corridor road would cause a direct habitat loss
of approximately 197 ha (487 ac). On a local basis this loss could be signi-
ficant for song bird and small mammal species, but it would not be signifi-
cant on a greater than local basis. For birds of prey and larger mammal
species, direct habitat loss would not be significant even on a local basis.
Indirect habitat loss, however, would be of significance on a greater than
local basis. While local song bird and small mammal populations would likely
accommodate to the presence of the road and associated activities, birds of
prey and larger mammals would generally be affected to differing degrees by
avoiding the area. The degree of avoidance cannot be accurately predicted.
V - 40
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Several nest sites of birds of prey, including three of the endangered pere-
grine falcon, have been reported along the southern corridor. While the
road alignment has been altered to provide a buffer of at least 3.2 km (2 mi)
around the peregrine nests, in at least one case that has caused the road to
more closely approach other species' nests (e.g., at Tutak Creek). Aside
from road construction disturbance that might cause nest abandonment dur-
ing the first two years of project development, long-term raptor breeding
would likely not be seriously affected by road activity because of the dis-
tances from the nests. Secondary road effects, e.g., increased use by bird
watchers, photographers, falconers and other visitors, if the road was even-
tually opened for general public use, would likely cause greater long-term
impacts. Just the presence of the road, however, would probably modify
feeding behavior and cause some avoidance of the road corridor.
Indirect habitat loss would likely be significant for caribou on a local basis,
and could even be of greater than local significance. The southern corridor
passes between current primary caribou low tussock tundra winter range in
the Wulik and Kivalina lowlands, and secondary winter range on the more
wind-swept slopes of the Mulgrave Hills to the southeast (Fig. IV-5). Road
activity would cause avoidance of the corridor, and hence displacement,
thereby limiting to some extent the use of otherwise available winter habitat.
There would also likely be some mortality due to vehicle collisions or added
stress from winter traffic.
Interruption of major movements would have the greatest potential impact
upon caribou. In addition to affecting local movements, primarily during the
winter, construction and operation of a road could cause major alterations in
the historic movement patterns of the western Arctic caribou herd. From
experience with other roads in Alaska, the approximately 20 to 25 vehicle
round trips per day (excluding maintenance) associated just with the Red
Dog project would be unlikely to cause such a major shift in movement pat-
terns.
A high volume of traffic generated by additional users in the future, how-
ever, could have a significant impact. During the spring migration north to
the calving grounds, the early summer post-calving concentration movements,
and again during the autumn when large numbers of caribou move southeast-
ward through the De Long Mountains and the project area, the presence of a
very active transportation corridor might cause a significant change in
migration patterns. Because of their dependence on often widely spaced
calving, concentration and wintering areas, such interruptions could have a
significant impact upon a large segment of the western Arctic herd, espe-
cially if they occurred with any frequency. In addition, many residents of
the region living southeast of the project area depend upon caribou as a
major staple of their subsistence diets and would be affected by any such
change in movements. Thus, although construction and operation of a road
for the Red Dog Project would not in itself likely cause major interruptions
to caribou movements, it would open a road to increased future traffic that
might cumulatively cause such interruptions.
The NANA/Cominco agreement specifically recognizes the possibility of major
caribou migration interruptions. NANA has retained the authority to sus-
V - 41
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pend operation of the project during periods when caribou movements are
imminent to minimize the possibility of such interruptions. Still, the capri-
cious nature of caribou may cause changes in movement patterns nonetheless.
To maximize the probability that such good intentions would work, a specific
monitoring plan would be developed in consultation with ADF&G to track
major movements and make suspension decisions. This plan would be estab-
lished before actual construction began so adequate baseline data would be
available.
Bears would be displaced from the area of the road corridor, and their
movements between the lowlands of the Wulik and Kivalina Rivers and the
Mulgrave Hills would probably be altered to some extent. No known areas of
specific importance for denning or salmon feeding would be affected. The
major impact to bears would likely be from long-term increased human access
to the project area as discussed later.
Moose would not likely be significantly impacted by indirect habitat loss.
The most important moose habitat is the riparian willow along Ikalukrok
Creek and the Wulik and Kivalina Rivers. The southern corridor would be
several miles to the east near the headwaters of the tributaries to the Wulik
River. The road would pose no physical barrier to movements, and moose
normally accommodate to vehicular traffic. There would be some mortality
due to vehicle collisions or added stress from winter traffic. The major
impact to moose would likely be from long-term increased human access to
the project area, particularly by hunters.
The southern corridor traverses the home range of the small herd of musk-
oxen that appears to winter in the Rabbit Creek drainage southeast of the
Mulgrave Hills. The potential impact on these animals from habitat loss due
to road construction and operation would be unknown. As with bear and
moose, the major impact upon muskoxen would likely be from long-term in-
creased public access to the project area.
Limited waterfowl habitat exists along the southern corridor, the best being
confined to small lakes, ponds and sedge-grass marshes. The road would
cause some direct and indirect habitat loss near Mud Lake due to dust, noise
and possibly altered drainage patterns. The major impact would be from
long-term increased human access to the project area, particularly by
hunters, or other visitors who might disturb molting or staging Canada
geese.
Construction activities along the corridor, aside from direct habitat loss,
would have relatively little impact upon song bird or small mammal species.
Waterfowl and raptor nests near the road alignment, however, might be
abandoned if construction activities occurred nearby during the critical
period from the latter part of incubation through the first few weeks after
hatching.
Construction activities would displace larger mammals to a greater degree
than during operation of the road. This would probably not be of greater
than local significance to bear, moose, sheep or muskoxen. Caribou, how-
ever, could be significantly impacted. With road construction scheduled to
commence in February 1986, some caribou wintering in the Wulik and Kivalina
V - 42
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River lowlands would likely be displaced. Local movements between that area
and current secondary winter habitat in the Mulgrave Hills would also likely
be affected. Impacts upon caribou would be lessened if schedules were
established which limited construction activities to the port site, South Fork
Valley, and the coastal end of the road corridor until the northward spring
migration had been completed (normally by early May).
Caribou early summer post-calving and autumn migrations might also be
affected by road construction activities. The autumn 1986 southeastward
migration in particular would be encountering the road corridor for the first
time. Its physical presence alone might have an impact. If actual construc-
tion activities were occurring during that first encounter, avoidance or dis-
placement actions might be magnified substantially, causing a change in the
historical movement pattern.
Port site development at VABM 28 would result in direct habitat loss of
approximately 20 ha (50 ac). In addition, storing the barge-mounted con-
struction camp or the lighter in the breached lagoon would result in tem-
porary or seasonal direct habitat loss of approximately 0.8 ha (2.0 ac). On
a local basis, habitat loss could be significant for song birds, a few species
of shorebirds, oldsquaws and dabbling ducks, as well as for small mammal
species. Impacts would not be significant on a greater than local basis.
For birds of prey and larger mammal species, direct habitat loss would not
be significant even on a local basis.
Indirect habitat loss would not be of significance on a greater than local
basis for song bird and small mammal populations as they would likely
accommodate to the presence of the facilities and associated activities. Birds
of prey and larger mammals, however, would generally tend to avoid the
area. The degree of avoidance cannot be accurately predicted.
No raptor nests have been identified near this port site and no direct im-
pacts on nesting would be expected. However, individual raptors, including
peregrine falcons, have been sighted over the hills 4.8 km (3 mi) to the
east. The presence of a developed port site would likely modify feeding
behavior of raptors presently using the area.
Caribou and moose would not be significantly impacted by the presence of a
port site at VABM 28. The important habitats for both species are generally
located further inland, and only an occasional small group or individual
would be likely to encounter the facility.
Bear and muskoxen could be impacted by indirect habitat loss on a local
basis. Both species have been reported to use the area between the
Mulgrave Hills and the coast as a movement corridor (Dames & Moore,
1983a). A facility at VABM 28 would likely interfere with normal northwest/
southeast movements. Bears use the coast extensively, often moving right
along the beach. The port facility with its associated noise and human
activity would displace normal bear movements at VABM 28. In addition, the
breached barrier beach could impede bear movements along the coast.
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Bears, wolves, wolverines and foxes would also be impacted from disturbance
and human contacts. While not significant on a greater than local basis,
individuals would be displaced from the general area unless attracted by
improper disposal of garbage or outright feeding. As described earlier for
the mine area facilities, mitigation measures would include "bear-proof" fenc-
ing of garbage collection and incineration facilities, worker training in
proper garbage handling techniques, and the removal of incineration residue
and nonburnable wastes for burial in the tailings pond. Feeding of animals
would be prohibited and this would be strictly enforced. All workers at the
port facility would also receive environmental training.
Development of this site and use of the lagoon for lighter storage would not
cause a significant indirect habitat loss for waterfowl. The lagoon and the
immediate surroundings are relatively unproductive and few waterfowl appear
to use the area, even during staging and migration.
Construction activities at the port site, aside from direct habitat loss, would
have relatively little impact upon song bird, shorebird, waterfowl or small
mammal species. However, construction would displace larger mammals to a
greater degree than during operation of the facility. This would probably
not be of greater than local significance except possibly for caribou. If the
major autumn southeastward migration moved close to the coast during con-
struction, a change in the historical movement pattern might occur.
Alternative 2
Construction of the northern corridor road would cause a direct habitat loss
of approximately 257 ha (634 ac). While this would be approximately 60 ha
(147 ac) greater than for the southern corridor road, direct habitat loss
impacts for all species would be similar to those for Alternative 1.
Indirect habitat loss would also be similar to Alternative 1 for song bird and
small mammal species.
The northern road corridor has more raptor nests than does the southern,
including four peregrine falcon nests as opposed to three. All peregrine
nests, however, would be at least 3.2 km (2 mi) from the road. The type
of indirect habitat loss impacts upon raptors would be similar to those for
Alternative 1, but the magnitude would be greater due to the higher number
of raptors.
Indirect habitat loss for caribou would be somewhat greater than for Alterna-
tive 1 due to the greater length of the road. Chances of a significant inter-
ruption of historical caribou migration patterns would also be greater with
the northern corridor road. Both the spring and early summer migrations
would be more likely to encounter that road than the southern corridor road,
with consequently greater risk of altering traditional routes.
Indirect habitat loss for bears would likely be greater than for Alternative
1. The Siatak Hills, immediately west of the Asikpak River, are important
for denning, and movements to and from that area might be affected by the
road. Also, as the road would parallel the river, road activities including
V - 44
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human disturbance would displace bears using the Asikpak River for salmon
feeding or other purposes.
Indirect habitat loss for moose would be greater than for Alternative 1, but
would still be small. Road activity would tend to displace moose where the
corridor crosses the riparian willow habitats favored by moose in winter. If
not seriously disturbed by hunters, moose would likely accommodate to road
activity associated with the project. There would be some mortality from
vehicle collisions and stress caused by winter traffic.
Impacts upon muskoxen from indirect habitat loss would likely be similar to
those for Alternative 1. While the Rabbit Creek herd would not be signifi-
cantly affected by a road along the Asikpak River, one or possibly two small
herds of muskoxen appear to range widely in the vicinity of the Singoalik
River, the next drainage to the west.
Indirect impacts on waterfowl would likely be less than for Alternative 1.
The northern corridor does not pass close to the same number or quality of
small lakes, ponds and sedge-grass marshes used by waterfowl for molting
and staging. Thus, disturbance by human activities, including hunting,
would not be as great.
Direct habitat loss at Tugak Lagoon would total approximately 20 ha (50 ac).
This would be the same area as at VABM 28, and the direct habitat loss for
all wildlife species would be similar to that for Alternative 1. Impacts asso-
ciated with the breached lagoon would also be similar to those for Alternative
1.
Indirect habitat loss at the port site for all wildlife would also be similar to
Alternative 1 with the exception of bears and muskoxen. These species
would likely be affected to a greater extent because of the presence of this
port site in a much narrower and more restricted area between the coast and
the first hills. Northwest/southeast movements could be displaced away from
the coast.
Construction impacts would be similar to Alternative 1, except that the
autumn northwest to southeast migration of caribou would probably not be
affected.
Alternative 3
Terrestrial wildlife impacts would be similar to those for Alternative 1.
Groundwater Resources
Alternative 1
Potential impacts associated with a road along the southern transportation
corridor would primarily involve the risk of groundwater contamination from
fuel and chemical spills. Soils containing groundwater might then act as
conduits for contaminant migration to nearby streams. Travel time between a
spill site and a nearby stream would depend on the location of the spill, the
substance spilled and the nature of intervening soil materials.
V - 45
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Potential groundwater impacts at the port site would also involve the hazard
of fuel and chemical contamination. Spillage control plans and rapid re-
sponse to spills would be the primary mitigative measures. Appendix 2
(SPCC Plan) outlines the proposed draft plan for spill reaction. The con-
centrate storage facility located inland at Borrow Site 1 would be constructed
on bedrock in an area of permafrost. As the concentrates would be com-
pletely enclosed, there would be little risk of concentrate contamination of
groundwater.
Alternative 2
Groundwater impacts would be similar to those for Alternative 1.
Alternative 3
Groundwater impacts would be similar to those for Alternative 1.
Freshwater Resources
Hydrology and Water Quality
Alternative 1
Improper road construction techniques used on permafrost and across Arctic
streams can lead to severe erosion problems and degradation of water quality
downstream from stream crossings. If proper methods of road construction
and drainage control were followed, environmental impacts could be held to
insignificant levels. Under authority of Title 16 (Anadromous Fish Protection
and Fishways for Obstructions to Fish Passage Permits), ADF&G must ap-
prove the design, construction and operation of any structures (e.g.,
bridge crossings, impoundment and drainage structures) that might affect an
anadromous fish stream as well as the passage of resident fish. These
permits specify certain stipulations that must be followed by the applicant to
mitigate potential impacts. The Red Dog project would follow acceptable
guidelines for road construction in the Arctic as summarized below. More
specific detail on road construction, including design of all bridges and
culverts, would be developed during the permitting phase of the project.
The design, construction and operation of the road system would be in full
accordance with agency permit stipulations.
The road would be constructed to protect the thermal regime. It would
generally be composed of a 2.0 m (6.5 ft) deep layer of crushed rock or 0.6
m (2 ft) of crushed rock over 7 cm (3 in) of insulation. These specifica-
tions would prevent permafrost thawing and resulting severe erosion prob-
lems. Borrow sites would be located to minimize potential water quality
impacts on local drainages. Buffer strips and sedimentation ponds would be
used at borrow sites located within 91 m (300 ft) of surface waters to pro-
tect water quality. Borrow excavation operations at surface gravel sources
would be conducted so that the resulting contoured edges could be reveg-
etated using appropriate Arctic techniques. Where natural gravel sources
were not available, rock quarries would be developed by drilling and blast-
ing operations. The side slopes of the quarries would be made to resemble
surrounding rock outcrops. Natural freeze-thaw cycles would eventually
V - 46
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erode the surface of these side slopes to create a natural scree* cover.
Depressions resulting from gravel and rock extraction would be allowed to
fill with water to form ponds or lakes.
Haul roads for construction materials would receive special attention due to
their temporary nature and potential for tundra and permafrost damage.
These roads would be built to have a stable wearing surface appropriate for
the time of year. Whenever possible preliminary construction work would be
done in the final road alignment. Construction using snow roads or
rolligons* would occur during winter months. Off-road construction activi-
ties during the thaw season would normally occur where exposed rock sur-
faces, finished gravel roads or gravel pads would be available as staging
areas. Construction on areas of ice-rich soils and wet areas would be
avoided during the thaw season.
The number and types of stream crossings required for the transportation
corridor alternatives are shown in Table V-14.
Temporary stream diversions during construction of crossings would be de-
signed to minimize erosion and sediment loads. Detailed design features of
these temporary stream diversions, including their size and location, would
be incorporated into ADF&G's Title 16 permits. In addition, the diversions
would require Department of the Army authorization. Stream crossings would
be surveyed for bank stability, stream character, icing occurrence and ice
jam potential. Scour and erosion risk would be evaluated at all stream cross-
ings. If bank excavation for bridge or culvert installation would expose
ground ice, the exposure would be covered with an insulating layer of syn-
thetic material, soil, gravel or rock. If a railroad were constructed in the
road corridor at a later date (see Chapter II), approaches to major bridge
crossings would have to be realigned. Although this might temporarily in-
crease stream sediment loads, long term impacts would be minimal with proper
bank stabilization.
Emphasis would be placed on minimizing clearance of vegetation and distur-
bance of soils. Erosion control measures would include revegetation, mulch-
ing, mat binders, solid binders, rock or gravel blankets and terracing.
Special problem areas would be associated with exposed ice or ice-rich
slopes. Areas of natural accumulation of winter icings would be completely
avoided. Care would be taken that the road embankment not restrict cross-
drainage of surface or groundwater. Improper drainage could create
impoundments behind the structure and result in destroyed habitat. Slope
drains and minor stream crossings would be designed to prevent hydraulic or
thermal erosion by use of channel liners, rock aprons, check dams and
energy dissipators.
Along the corridor there would be potential spill hazards due to transporta-
tion of mill process chemicals, diesel and fuel oil and ore concentrates. The
greatest risks to the environment would be from spills of toxic chemicals
near stream crossings. The most serious spill would be from an oil tanker
truck/trailer because of the potential large volume of oil involved. Spillage
control plans and rapid response to spills would be the primary mitigative
measures. Appendix 2 (SPCC Plan) outlines the proposed draft plan for
Defined in Glossary.
V - 47
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Table V-14
ESTIMATED NUMBER AND TYPE OF STREAM CROSSINGS REQUIRED FOR
SOUTHERN AND NORTHERN TRANSPORTATION CORRIDORS
Length of road
Major bridges1
Minor bridges2
Major culverts3
Minor culverts4
Total stream crossings
Icing locations at culverts
Fish passages at bridges
and culverts
Southern
Corridor
89.9 km
(56.2 mi)
1
4
49
133
187
14
11
Northern
Corridor
117.0 km
(73.1 mi)
6
7
81
219
313
24
13
Source: Cominco Alaska, Inc.
1 Bridge span >30.5m (100 ft).
2 Bridge span <30.5 m (100 ft).
3 Culverts > 137 cm (54 in) diameter, or the equivalent of using two to
three smaller culverts.
4 Culverts <137 cm (54 in) diameter at gullies, grassy swales and seasonal
drainages.
spill reaction. The concentrate storage facility located at Borrow Site 1
would be completely enclosed to prevent any concentrate contamination of
surface water. In addition, settling ponds would be constructed to collect
runoff from around the facility. This would further minimize potential for
surface water contamination.
V - 48
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Alternative 2
Major bridges on the northern corridor would be required at Ikalukrok
Creek, Main Fork Wulik River, West Fork Wulik River, Grayling Creek,
Kivalina River and Asikpak River (Fig. 11-6). In comparison, the southern
corridor would have only one major bridge (across the Omikviorok River).
With the exception of the Asikpak River, bridges on the northern road would
cross wide meandering or braided rivers with unstable banks. Protection of
these crossings from excess generation of sediment during construction and
high flows would be difficult. Icings and ice jams in these rivers would also
place unusual engineering constraints on design. The northern route would
have nearly twice as many minor culverts and more difficult icing and fish
passage problem crossings. Due to the number of stream crossings which
pose engineering difficulties, the northern route would have much greater
potential for significant environmental impacts related to increased stream
sediment loads and the risk of hazardous chemical spills reaching streams.
Alternative 3
Hydrology and water quality impacts would be similar to those for Alterna-
tive 1.
Biology
Invertebrates
Alternative 1
The southern corridor would cross approximately 187 streams primarily with
culverts. One major bridge would be constructed across the Omikviorok
River. Twenty-four of the streams would have gravel/cobble substrates and
18 grassy swales would be crossed. Benthic production would be lost at
stream crossings and downstream of crossings during construction as a re-
sult of instream work and sediment production. This would be a transient
loss, generally of less than one week. Longer term losses could result from
erosion of altered stream banks unless they were revegetated. The amount
of loss would depend on construction timing relative to insect life cycles.
The loss would not be significant overall since a small portion of total stream
length would be affected.
A small permanent loss of habitat would occur as a result of culverts replac-
ing natural substrates. This loss would be negligible compared to total
stream lengths and would not be expected to significantly affect fish produc-
tion. Provided culvert size were sufficient to allow spring gravel flushing,
and ongoing erosion were small, no additional impacts would be expected.
Loss of production would occur if ore concentrate or fuel spills occurred.
Alternative 2
The northern transportation corridor would cross approximately 313 streams
with six major bridges, seven minor bridges and 300 culverts (Fig. II-6).
Thirty-two of the streams would have gravel/cobble bottoms and 17 grassy
swales would be crossed. Construction impacts would be similar to those for
Alternative 1. However, greater impact would result due to the larger num-
V - 49
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ber of crossings and the greater amount of instream work required at the
six major bridge crossings.
Permanent impacts would occur in the same manner as those for Alternative
1. However, more streams would be crossed, so more habitat loss would
occur. Impacts on trophic* resources would not be significantly greater
since a similar number of streams containing fish would be impacted.
Alternative 3
Benthic invertebrate impacts would be similar to those for Alternative 1.
Fish
Alternative 1
The southern transportation corridor would be approximately 89.9 km
(56.2 mi) long and would cross approximately 187 streams ranging in size
from rivers to ephemeral drainages (Table V-14). Eleven of these streams
are known to contain fish (Fig. IV-9). Five tributaries to the Wulik River
would be crossed in their headwaters, well away from the main stem of the
river. Four of these tributaries support fish (Arctic char and/or Arctic
grayling) in the vicinity of the corridor crossings during the summer months
(Dames & Moore, 1983a). All four tributaries provide some fish spawning
habitat near the corridor crossings.
The Omikviorok River would be crossed at least once on three of its five
forks and once on the upper part of the main stem. The river provides
spawning and rearing habitat for char in its lower reaches. Tributaries to
the Omikviorok River would also be crossed, but none of these tributaries is
known to contain fish in the vicinity of the transportation corridor crossings.
New Heart Creek would also be crossed in its upper reaches and is known
to contain Arctic char near its mouth.
Both the Omikviorok River and New Heart Creek flow into Ipiavik Lagoon
where some subsistence fishing occurs. These systems are less critical than
the Wulik and Kivalina River drainages, but should be afforded the protec-
tion of proper crossing site selection, crossing design and construction
timing.
Potential impacts from road construction and operation along the southern
corridor would involve an increase in sediment loading, fish migration bar-
riers, risk of spills to major water courses and increased access to currently
inaccessible areas. Minor increases in sediment loading would be unavoidable
during construction and operation of the road in spite of mitigation measures.
Impacts on fish from sediment originating from the road could be minimized
to insignificant levels by good crossing location selection, and proper
crossing design and construction timing. Crossings where fish were present
or where migration occurred should have crossing structures that would not
impinge on the floodplain area. If a railroad were constructed in the road
corridor at a later date (see Chapter II), approaches to major bridge cross-
ings would have to be realigned. Although this might temporarily increase
* Defined in Glossary.
V - 50
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stream sediment loads, long term impacts would be minimal with proper bank
stabilization.
Preliminary detailed information on the amounts of materials and locations of
borrow sites along the entire corridor is shown in Table 11-3. Borrow sites
would be located as far from water courses as possible to minimize surface
runoff impacts. However, in cases where the borrow sites were within 91 m
(300 ft) of surface waters, provisions would be made for the collection and
settlement of suspended solids from runoff water. Provided these precau-
tions would be taken, borrow site impacts on fish resources should be small.
If borrow material was taken only from sites outside Cape Krusenstern
National Monument, the surface area and excavation depths of Sites 7 and 8
would increase (Table 11-4). Because Site 8 is located within 91 m (300 ft)
of a stream, potential impacts to fish from borrow site expansion might
become significant unless further protective measures were taken.
The transportation of concentrate and chemicals along the road poses a risk
of undetermined probability. The scenario of spillage directly to a stream
poses the most serious hazard. Spillage control plans and rapid response to
spills would be the primary mitigative measures. Appendix 2 (SPCC Plan)
outlines the proposed draft plan for spill reaction.
Timing of construction for crossings along the transportation corridor should
consider the individual stream. For streams without fish, the crossing could
be made at any time, but caution should be exercised to prevent as much
disturbance and sediment generation as possible. Streams containing fish
could be crossed with minimum impact after Arctic grayling fry emergence in
about mid-June, but prior to Arctic char and salmon spawning in late
August.
Alternative 2
The northern corridor would be approximately 117 km (73.1 mi) long and
would cross about 313 streams ranging in size from rivers to ephemeral
drainages (Table V-14). Three major drainages (Wulik, Kivalina and
Asikpak Rivers) would be involved along with four minor drainages. The
Wulik River drainage would have approximately 28 stream crossings, five of
which would require bridges over the main stem or main forks. Fish are
present at all of the major crossings. Three of the 23 smaller tributary
streams also contain fish. The Kivalina drainage would experience about 23
crossings, three of which would require bridges for main stem or main fork
crossings. These three crossing areas all contain fish, whereas the 20
tributary crossings contain no fish (Fig. IV-9). The Asikpak River drain-
age would have 13 stream crossings. One of these crossings would require a
major bridge over the main stem near the river mouth where fish are
present. Only one of the 12 tributary streams to be crossed contains fish.
Between the Asikpak River and Tugak Lagoon four other drainages would be
crossed. These are small drainages which do not contain fish. Two of
these drainages enter Asikpak Lagoon; another enters Kavrorak Lagoon; and
the other flows directly to the sea.
V - 51
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Potential impacts to fish from road construction and operation would be
similar to those for Alternative 1, but of a significantly greater magnitude
due to the greater number of crossings of important habitat. The northern
corridor would cross the major fish streams in the project area (the Wulik
and Kivalina Rivers and tributaries) at several locations. These streams are
very important for spawning, rearing and overwintering fish and as such are
also migration corridors. Proposed crossings occur in main stem areas and
in significant and highly sensitive char spawning areas in both drainages.
Several of these crossing areas have highly unstable and very mobile stream
beds where lateral movement occurs readily. It would be particularly diffi-
cult to ensure that crossings in these areas did not cause barriers to fish
migration. The design of appropriate crossings to prevent migration bar-
riers and allow crossing stability would require considerable effort. Proper
crossings in these areas would be critical since any migration blockage of
main stem areas would eliminate large sections of spawning and rearing areas
used by Arctic char and Arctic grayling.
The increase in access available to local residents or mine employees could
adversely impact fish resources in streams that are crossed by the corridor.
These impacts would result from fishing and associated disturbance during
the late summer char spawning period, and could severely impact char
populations in the Kivalina drainage. Other impacts such as sediment from
construction and borrow pits, concentrate spillage, and timing and location
of crossings would be similar to those described for Alternative 1, but of a
significantly greater magnitude because of the higher number of major stream
crossings.
Alternative 3
Fish impacts would be similar to those for Alternative 1.
Marine Biology
Marine Invertebrates and Fish
Alternative 1
Port site construction activities would result in increased suspended sediment
and turbidity in neighboring waters. Port Lagoon, located adjacent to the
port site, would be breached to shelter a barge-mounted construction camp,
but no dredging would take place within the lagoon. The short causeway
construction would involve driving or vibrating sheet pile, placing of armor
rock and the placing of fill.
In open water areas, the suspended sediment resulting from construction
would be dispersed by wind and waves. Sessile organisms, including poly-
chaete worms, gammarid amphipods and ophiuroid seastars, would be
smothered in areas of high sedimentation. More mobile organisms such as
shrimp, crabs and fish would abandon the area. Construction impacts would
last approximately one season.
Breaching Port Lagoon would result in saltwater intrusion, with insect larvae
slowly replaced by euryhaline* crustaceans (isopods, amphipods and mysids),
* Defined in Glossary.
V - 52
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molluscs (bivalves and gastropods) and oligochaete worms. Euryhaline fish
species which might also penetrate the breached lagoon could include Arctic
flounder, starry flounder, Pacific herring, and anadromous species such as
humpback whitefish and pink salmon. The lagoon would, therefore, become
more similar to other open lagoons on the coast. These lagoons generally
have greater fish and invertebrate species diversity than closed lagoons, and
appear to be more productive. Although local impacts from breaching would
be significant, they would be of a short duration, and a relatively more
stable saline lagoon environment would result. Impacts would not be signifi-
cant on a greater than local basis because of the large number and area of
coastal lagoons (207 km2 [80 mi2]) between Cape Krusenstern and Point
Hope.
Additional construction impacts would result from heavy equipment moving
over shallow subtidal areas; vibrations from pile driving and rock placement;
oil and gas spills and leaks from construction equipment; and possible dredg-
ing. With the exception of dredging, these impacts should not add signifi-
cantly to the impact of suspended sediment and turbidity increases. Dredg-
ing impacts would depend upon the amount of area dredged and the water
depth. Dredging from greater depths would result in the loss of a larger
number and biomass of organisms than shallow depths.
Construction of the short causeway would remove approximately 0.9 ha
(2.2 ac) of shallow subtidal and intertidal habitat. Densities of infaunal*
organisms range from 16.7/m2 (1.6/ft2) (Dames & Moore, 1983b) to 266.6/m2
(24.8/ft2) (Dames & Moore, 1983a). The infauna is characterized by nema-
todes, amphipods, polychaetes and tunicates. Approximately 66.2 to 77.6 kg
(146 to 171 Ib) (Dames & Moore, 1983b) of organisms would be lost.
Epifauna* (typically gammarid amphipods, mysid shrimp, seastars and crabs)
would be displaced and habitat for foraging bottomfish would be lost.
The short causeway would add hard substrate habitat in the form of armor
rock and sheet pile. The armor rock (approximately 0.3 ha [0.7 ac] nominal
surface area) would provide habitat for hard substrate organisms such as
barnacles, shrimp and gammarid amphipods. Exposed hard faces (sheet pile
and exposed armor rock) would only provide seasonal habitat due to ice
scouring.
Sediment would generally be deposited on the northwestern side of the
causeway structure and eroded from the southeastern side, though at some
point in the future an equilibrium would be reached. Infauna and epifauna
communities would be altered by these erosional and depositional patterns,
but it would be impossible to predict overall effects.
Construction of the transfer facility would have a minimal impact on anadrom-
ous and marine fish. There would be a possibility that fish moving along
the shore could be impeded by the causeway, but its short length would not
likely cause a substantial barrier to migration. The causeway should be
constructed in July or early August to prevent any interference with migrat-
ing fish that could be caused by sediments or noise.
Construction of the offshore island transfer facility would require initial
dredging followed by placement of berms on which the tanker would rest.
* Defined in Glossary.
V - 53
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Once in place, dredged sediment would be pumped into interstices beneath
the ship. Dredging for site preparation would impact about 24 ha (60 ac) of
bottom. The density of infaunal organisms in this area ranges from 3.1 x
106/m2 (2.9 x 105/ft2) to 7.9 x 109/m2 (7.3 x 108/ft2) and biomass from 0
mg/m2 (0 mg/ft2) to 785.5 mg/m2 (73.0 mg/ft2). This means approximately
90.5 kg (200 Ib) of biomass would be removed. Affected species would in-
clude polychaete worms, bivalves, gammarid amphipods, crangon shrimp and
ophiuroid seastars.
Dredging operations would also create suspended sediment and turbidity. A
reduced infauna and epifaunal community would result from this, and fish
would tend to avoid the area. These impacts would be significant on a local
basis, but not on a greater than local scale. Turbidity and suspended sed-
iment impacts would cease shortly after dredging stopped. Recolonization
would occur within the next growing season. Transient impacts would also
likely result from small fuel and motor oil leakages or spills.
Once in place the offshore island would result in the loss of approximately
24 ha (60 ac) of soft bottom benthic habitat. Although the submerged sides
of the ship would represent new hard substrate, attached community
development would be reduced by ice scouring. An increase in deposition
would tend to occur on the northwestern side of the ship and increased
erosion would tend to occur on the southeastern side. This might result in
some alteration of the biotic communities, although the changes would prob-
ably not be significant.
During construction and operation, fuel, chemical and ore concentrate spills
might occur. These could occur on a small continuing basis or from a
catastrophic event. In either case, some toxicity would result. The amount
of toxicity would depend on the size of the area affected, as well as on the
type and concentration of toxicants. Small spills would have a locally sig-
nificant impact, but would probably not be significant on a greater than local
basis. Larger spills could have greater than local impacts on fish and
invertebrate populations. Spillage control plans and rapid response to spills
would be the primary mitigative measures. Appendix 2 (SPCC Plan) outlines
the proposed draft plan for spill reaction.
The offshore island transfer facility would have little effect on nearshore
fish and invertebrate migrations. The tanker would be approximately 1,097
to 1,219 m (3,600 to 4,000 ft) from the shore in 7.6 m (25 ft) of water at its
shoreward end. This should be ample space for the movement of mobile
species. Movement in deeper water seaward of the facility would be unim-
peded.
The offshore island should not negatively affect fish resources but might, in
fact, act as an artificial reef for orientation and attachment of food organ-
isms.
Alternative 2
Overall impacts would be similar to those described for Alternative 1, al-
though the density and diversity of benthic organisms appear to be greater
than at the southern port site. The benthic community assemblage also
appears to be composed of longer-lived species rather than short-lived,
opportunistic species as found at VABM 28.
V - 54
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Construction related impacts to nearshore invertebrate communities at Tugak
Lagoon might include a community shift towards shorter-lived, colonizing
species typical of shallow water habitats. Eventually, a longer-lived com-
munity would return after disturbance ceased. The port site would remove
approximately 72 kg (159 Ib) of biomass, while the offshore island ship would
remove about 90.5 kg (200 Ib).
<
The construction and operation of the port site facility at this site should
have no adverse effects on fish provided that oil/ chemical and concentrate
spills were contained. Some sediment loss to the environment might be
expected, especially during construction. However, no anadromous fish
spawn or rear in the vicinity of Tugak Lagoon so no impact would be ex-
pected. The lagoon would be breached for storage of construction and
lightering barges, but this should have no impact on anadromous fish since
the lagoon is not used by these fish. Other species of marine fish would
likely be affected by modification of the lagoon in a manner similar to that
described for Alternative 1.
Impacts of the short causeway and offshore island would be similar to those
for Alternative 1. The offshore island might provide suitable substrate for
herring spawning thought to occur in this area. This could have a bene-
ficial effect on herring stocks if spawning habitat is presently limited.
Alternative 3
Port site and lagoon impacts would be similar to those described for Alterna-
tive 1. There would be less removal of benthic habitat and generally less
dredging activity because no offshore island would be constructed. Elimina-
tion of the offshore island transfer facility would increase the risk of a
chemical or concentrate spill. Transfer of concentrates would be more likely
to occur in the limited time frames when the bulk cargo carriers were pres-
ent, even if weather conditions were unfavorable. The direct effect of a
spill on fish would depend on the time of year (i.e., during migratory or
nonmigratory periods) and on the nature of the spilled material. Impacts on
both anadromous and marine species could range from low to moderate.
Marine Birds and Mammals
Alternative 1
The persistent polynya that typically forms offshore between Kivalina and
Point Hope would likely attract greater use by marine mammals, including
endangered whales, and marine birds. Therefore VABM 28 as a port site
location, approximately 26 km (16 mi) southeast of Kivalina, would likely
have less general impact upon these groups than would a port site at Tugak
Lagoon located closer to the polynya.
Direct habitat loss from construction of the short causeway and ballasted
ship would total approximately 24.9 ha (62.2 ac). This would not be a
significant loss to either marine birds or mammals.
Indirect habitat loss for marine birds would not be significant as they do not
use the nearshore areas for feeding. For marine mammals indirect habitat
loss could be significant, but probably only on a local level. There might
be some displacement of ringed seal pupping in late March/early April, but
V - 55
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this would be very local in nature. The noise and activities associated with
lighter and bulk carrier traffic, and the corresponding loading and unloading
activities at the short causeway and the ballasted ship, would cause marine
mammals to generally avoid the area. Neither the causeway nor the ballasted
ship would present a physical obstacle to movements.
The endangered bowhead and Gray whales exhibit excellent hearing and re-
spond to sounds caused by human activities. Whales demonstrate avoidance
reactions to ship and helicopter noise at distances of 1.6 to 3.2 km (1 to 2
mi). While some noise and disturbance would occur year-round, most dis-
turbance would occur during the ice-free shipping season from late June
until early October. The bowhead whale in particular is slow-moving, timid,
and sensitive to sound. Bowhead whale migrations from mid-April to early
June would be unimpeded as most individuals move well offshore. However a
few moving closer to shore might be displaced seaward of the facilities to
some extent by noise. Any significant noise-generating activities on the
dock or on the ballasted ship would be restricted during the April through
early June whale migration period to keep impacts to bowhead whale migra-
tions past Kivalina to a minimum. The autumn return migration of bowheads
is usually well offshore to the west in the Chukchi Sea. The Gray whale,
which normally moves and feeds nearshore, would likely avoid the port
facilities also, thus reducing feeding habitat to some extent.
Initial vessel traffic associated with the port would be low, approximately 16
to 20 bulk ore carriers, tankers and supply ships per year. These vessels
would be active only during the ice-free shipping season from late June to
early October and would not overlap the normal bowhead whale migration
period. The small number of vessels would probably not significantly impact
any marine birds or mammals.
Transfer facilities construction would have essentially the same kind of im-
pacts as described for indirect habitat loss above, but of a greater magni-
tude. Disturbances from driving sheet pilings, rock filling of the short
causeway, dredging and ballasting the ship could cause significant local dis-
placement of marine mammals. If these activities occurred during northward
bowhead whale migrations from mid-April to early June, there might be dis-
placement of individuals seaward of the facilities. Following completion of
construction, noise and disturbance levels would decrease to those of on-
going operation.
Transfers of concentrates from the short causeway to the lighter, the lighter
to the ballasted ship, and from the latter to the bulk carriers would create
an unknown risk of spillage, as would movement of petroleum products, rea-
gents and other toxic materials in the opposite direction. Chronic spillage
or a severe spill could have significant impacts on both marine birds and
mammals, depending upon the time of year and local weather conditions.
The stable nature of the two platforms at each point of transfer (i.e., the
short causeway and the ballasted ship) would tend to lower the probability
of such spills. The buried pipeline from the ballasted ship to the short
causeway would also lower the probability of petroleum spills.
Alternative 2
Because of the polynya which forms offshore between Kivalina and Point
Hope, the Tugak Lagoon port site in this alternative would likely have a
greater general impact upon marine birds and mammals than would a port site
at VABM 28.
V - 56
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Impacts associated with the short causeway and ballasted ship transfer facil-
ity would be similar to those for Alternative 1.
Alternative 3
Impacts associated with construction and operation of the port site facility
would be the same as those for Alternative 1.
Direct habitat loss from construction of the short causeway only would total
approximately 0.9 ha (2.2 ac). This would be approximately 24 ha (60 ac)
smaller than Alternative 1, and would not be a significant loss to either
marine birds or mammals.
Indirect habitat loss for marine birds would be similar to that for Alternative
1. For marine mammals it would likely be less. For this alternative the
peak periods of activity and disturbance would be limited to approximately 16
to 20 times during the ice-free shipping season when the lighters would
directly load or unload the bulk ore carriers, tankers or supply ships. In
Alternative 1, there would be more constant activity offshore as concentrates
were steadily moved to the ballasted ship and routine maintenance and opera-
tions generated noise.
Transfer facilities construction would have somewhat less of an impact than
Alternative 1 because there would be no dredging or ballasting of the ship.
However, this would not likely be a significant difference.
To the extent marine birds and mammals would be affected by concentrate
and other toxic spillages, this alternative would likely have a greater impact
than Alternative 1. The lack of a stable concentrate transfer platform dur-
ing periods of rough weather, as would exist with the ballasted ship, would
increase the probability of chronic or major spills. Also, petroleum products
would have to be transferred to the short causeway by lighters, and not
through a buried pipeline. This would also increase the risk of spills.
Physical and Chemical Oceanography
Coastal Geologic Processes
Alternative 1
According to Hopkins (1977), the net drift of the sediments in the area of
the proposed port facility at VABM 28 is to the southeast. Moore (1966)
estimated that approximately 22,000 m3 (28,780 yd3) of sediment move down
the coast to be deposited at Sheshalik Spit each year. However, Woodward-
Clyde (1983) recently estimated that about 82,580 m3 (108,000 yd3) of sedi-
ment is transported annually.
It would be extremely unlikely that Cape Krusenstern would be affected by a
sediment barrier 32 to 48 km (20 to 30 mi) away since: (1) large volumes of
sediment, compared to potential trapped sediment, exist between the VABM
28 port site and the Cape Krusenstern beaches; and (2) the entire coastline
is eroding and providing an ample sediment source. Placement of a solid
V - 57
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causeway at either port site would affect areas limited to a distance of ap-
proximately eight to 10 lengths of the structure. Local and offshore sedi-
ment sources exist which would compensate for the trapped sediment. The
total maximum sediment entrapped by the causeway would be about 183,500
m3 (240,000 yd3) (Woodward-Clyde, 1983), though the actual amount trapped
would probably be closer to 137,630 m3 (180,000 yd3). Because total en-
trapment is approximately 1.7 to 2.2 times the yearly sediment transport, it
would take about one and a half to two years for sediment to begin bypass-
ing the causeway structure. This would have only local impacts.
The port site causeway would have an effect on the beach adjacent to the
causeway. The up-drift (northwest) side of the causeway would temporarily
fill in and stop sediment movement. Erosion would occur on the down-drift
(southeast) side of the causeway, and would be approximately equal in
volume to the sediment trapped on the up-drift side. The impacts would be
significant locally, but would represent an insignificant percentage of the
total volume of sediment moved toward Cape Krusenstern southeast of the
port site. Down-drift erosion due to the causeway could potentially breach
the barrier beach between Port Lagoon and the sea. However, the lagoon
would be breached anyway to provide shelter for the construction barge and
the lighters, so this erosion-caused breaching would result in no additional
impacts to the lagoon.
Construction of a breached causeway was initially considered as a means of
reducing local down-drift erosion. Although a breached causeway would
allow more net sediment movement along the shore (and thereby reduce local
erosion impacts), such a causeway would be technically more difficult to
construct and maintain, and was, therefore, not considered to be cost effec-
tive. Neither causeway would affect sediment movement on a greater than
local basis.
Storms can produce waves that would cause sediment movement in either
direction along the coast. The amount of material moved by such storms
could be as large as the net sediment transport for the year. Therefore,
alternate erosion and filling would be expected to take place on either side
of the causeway. The erosion could also threaten portions of the port facil-
ity if they were not properly protected. On the up-drift side of the cause-
way, where sediment would be deposited, the effect would be to alter the
depth of water and composition of the nearshore substrate. This could have
a local impact on the marine organisms as previously discussed.
The effect of the causeway on the beach ridges at Cape Krusenstern, 38 km
(24 mi) to the southeast, would be insignificant since the main impact of ero-
sion would be near the causeway. Material would fill the area on the north-
west side of the causeway, and would then begin passing around the cause-
way to the southeast to maintain the net transport rate. Most of the mate-
rial traveling to the Monument originates down-drift of the VABM 28 port
site (Hopkins, 1977).
An offshore island would have little or no effect on sediment transport along
the coast because, in the depth of water at the island, wave-induced water
velocities and wave force impacts on the bottom which are the primary forces
in sediment movements would be smaller than near the shore. The reduced
forces on the bottom sediments would tend to move only the finer-grained
V - 58
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materials. The amount of material moved at the depth of the offshore island
would, therefore, be insignificant compared to the material moved along the
beach.
Alternative 2
The forces acting to move material along the beach at this port site would be
different than the forces acting at the VABM 28 port site. The effects of
deposition and erosion in the area adjacent to the causeway would be approx-
imately the same as those at the VABM 28 port site, except that the net
movement of sediment would probably be to the northwest.
At this site the nearest lagoons (Tugak and Kavrorak) would be at least
1,050 m (3,452 ft) distant from the causeway. Because of this separation,
the only likely effects of the causeway would be erosion and deposition adja-
cent to the port facility. This could endanger the port facilities if they
were not properly protected. The composition of the substrate in the vicin-
ity of the causeway would also be changed, but this would only be of local
significance. There would be no effect on Cape Krusenstern since several
sediment nodes exist between this location and Ipiavik Lagoon (Hopkins,
1977).
Alternative 3
Coastal process impacts would be similar to those for Alternative 1.
Marine Water Quality
Alternative 1
Port site construction could increase sediment loading for a short period
until a beachhead were established. During construction and operation, the
lagoon barrier beach would be breached for barge access to the lagoon.
Sediment impact of limited beach construction would not be significantly
different from that experienced during summer storms which move consider-
able quantities of beach sediments. Impacts would be local.
Onshore port construction activities could cause erosion and sediment con-
taminated runoff into the marine environment. Sedimentation ponds to cap-
ture and treat runoff would be constructed early in the schedule to limit
impacts on marine water quality.
Offshore construction impacts would be comprised of limited sediment in-
creases during the short causeway construction and seabed preparation for
the ballasted tanker. The short causeway would be comprised of sheet
piling facing with backfill from the shore out to the piling. Sedimentation
would be limited by the piling facing. No significant long-term water qual-
ity impact would result.
Seabed preparation for the ballasted tanker would require dredging and
placement of bottom material in an approximate 61 x 305 m (200 x 1,000 ft)
area to accommodate the ship. Granular material would be pumped under the
ship to give uniform support, and the tanker's outer holds would be bal-
lasted with approximately 72,628 m3 (95,000 yd3) of granular material. The
granular material would be dredged from the seabed adjacent to construction
sites.
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Excavation and placement of the bottom and ballasted material would resus-
pend small sediment fractions of the existing seabed. There is evidence that
such resuspension occurs regularly during summer storms. Construction
activities would not be significantly different and would produce no long-
term water quality impact. Corps guidelines would be followed for dredge
and fill operations.
Wave-induced scour of ocean bottom sediments has been noted in 9 m (30 ft)
water depths. Observations of the project area seabed indicate signs of
such movement. During storm events it is not uncommon to have design
waves in the area exceeding 6 m (20 ft) in height. Such waves might in-
duce a velocity along the seabed in excess of 1.8 to 2.4 m/s (6 to 8 ft/s).
A ship ballasted in place and exposed to such waves would experience wave
forces and velocities in excess of the normal bottom velocities. The design
of the ballasting system should be such that wave forces and velocity would
be considered. Appropriate design considerations along the boundaries of
the ballasted ship would be necessary to control scour and to protect the
ballasted tanker foundation. The design evaluation process must address
scour causes, anticipated scour effects and methods of scour control. The
design wave selection should consider events likely to occur during the life
of the mining activity. Proper design features would limit the potential of
impacts due to sediment movement or ship damage.
The tanker would also be designed to withstand anticipated forces from ice
movements. The tanker would have a sidewall height of 24 to 27 m (80 to
90 ft) and be ballasted down in 9 to 12 m (30 to 40 ft) of water to provide a
freeboard of approximately 12 to 18 m (40 to 60 ft). Limited experience with
a similar structure in the Beaufort Sea (Dome Petroleum's structural steel
drilling caisson) indicates that ice override of the ballasted tanker might not
be a problem. Reports show that the ship essentially creates a barrier to
ice movements and the resulting ice pile-up builds against the ship, grounds
out, and forms its own rubble field of protective ice. This effect is ex-
pected to provide adequate protection from wind-driven ice impacts on the
ballasted tanker. The added ice strengthening steel plate around the water-
line of the ship, and the additional internal bulkhead bracing, would be
designed to withstand anticipated ice forces. An ice load monitoring system
would also be installed in the hull.
Detailed design engineering for the ballasted tanker concept has not been
performed to date and is beyond the scope of this document. Detailed and
very complex design efforts including modeling of scour and ice forces might
be necessary for full evaluation. Little experience exists with similar facil-
ities so it is impossible to statistically evaluate the probability of various
risks associated with the ballasted tanker. Detailed designs would consider
potential risks and address safety factors that could reduce risks to accept-
able levels. Such design detail would be included in pertinent state and
federal permit applications.
Other potential marine water quality impacts involve shipping and material
handling spill risks. The risk of spill of fuel and materials might be some-
what higher during construction. However, the quantities of material and
frequencies of shipments during operation would present a much higher over-
V - 60
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all risk. Since spill risk analysis is a statistical problem that has not been
quantified, the impacts for construction will be discussed along with opera-
tional impacts.
Spillage during construction or operation could result from transfers between
the "ship island" and lighter barges, or between lighter barges and the
short causeway (and vice versa); shipping accidents; or weather related
hazards. During construction, the items that would be most likely to result
in a spill problem would be fuel, cement and concrete additives and oil.
Spillage during operation could include fuel, ore milling process chemicals
and concentrate. Impacts from spill events would vary depending upon the
magnitude of the spill and the material spilled. The area of impact would
vary depending upon the weather conditions (wind, waves and currents).
Impacts of fuel or oil spills could be heavy on local area aquatic life. Over-
all water quality impacts would be short-term for small spills, but major
spills could have greater than local significance and result in longer term
hydrocarbon-induced water quality degradation. Under adverse weather
conditions, oil spills could impact beaches anywhere in the area from Cape
Krusenstern to Point Hope.
On an annual basis, approximately 214,000 bbls of fuel oil would be con-
sumed by project power generators, on-site equipment and for regional fuel
use by villages. A year's supply of fuel would be stored primarily in the
ballasted offshore tanker. Oil to be stored on the tanker wound be trans-
ferred from bulk carriers using flexible hoses. Transfer would be rapid and
the primary spillage potential would be on the ships where hose connections
would be made. Spillage on the ship should be contained onboard.
Onboard fuel storage and handling facilities would be in center compartments
protected from the sea by two layers of steel (Fig. 11-17). Containment
capacity in the tanker would be 10 percent above the projected necessary
storage volume. Large protective wing tanks on either side of the fuel
storage tanks would contain gravel ballast material, thus providing a con-
siderable degree of protection from side impacts. Status monitoring of the
stored fuel would be continually conducted by instrumentation, and the
bilges between hull compartments would be routinely inspected.
Transfer of fuel from the tanker to shore would be through a buried 10-cm
(4-in) diameter steel pipe surrounded by a 15-cm (6-in) diameter steel guard
pipe. Flow detectors would be used to monitor fuel transfer operations to
give immediate indication of pipeline leakage or unusual transfer conditions.
As an extra precaution, a fuel leak detection system would be installed to
detect leakage from the 10-cm (4-in) transfer pipe into the space between
the two pipes.
To preclude the possibility of pipeline break impacts, the transfer pipeline
should be purged of fuel oil between transfers. An oil spill under ice or in
open water could have significant impacts on fish and wildlife if unnoticed
and not immediately reclaimed. Fuel oil spills under ice would be especially
harmful unless quickly detected because they could not be effectively cleaned
up. With proper design, construction and monitoring, the buried pipeline
V - 61
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with associated leak detection systems could be installed and operated in a
manner which would minimize the potential for fuel oil spills occurring during
fuel transfer operations.
Onshore fuel storage tanks would be constructed on well drained gravel pads
or on pilings, with spillage containment dikes and synthetic liners con-
structed around the tanks. Trucks would be used to transfer oil to the
mine site. Truck transfer areas should be constructed to drain to spill
containment areas, and should be sealed to prevent undue soil contamination.
Spills of mill process chemicals that disperse or dissolve in seawater could
result in buildup of toxic concentrations in the immediate area of the spill.
Process chemical spills could be extremely significant. Chemicals such as
sodium cyanide, copper sulfate and sulfuric acid could result in direct toxic
reactions and degradation of surrounding water quality to below aquatic life
standards. Depending upon weather (wind, wave, current) conditions, the
toxic area would be dispersed in hours or days. Impacts of small spills
would be locally significant, while large spills could have a greater than local
significance.
Potential for spills at the port site would be low because all unloading,
handling and storage of concentrates would be done under cover in an en-
closed area. Conveyors would be covered to protect against wind pick up of
concentrate particles, and the structural supports at conveyor transfer
points would be skirted at the bottom to contain any minor spills which might
result during handling operations. These spills would be cleaned up and
returned to the storage building.
The port site area would be served by drainage collection channels and a
sedimentation pond to control suspended particulate matter generated by
runoff erosion. This system would also be able to contain miscellaneous
spills of concentrates or fuel oil which were not controlled at the source.
Accumulated water in the onshore containment system would require treat-
ment and discharge during the summer months to maintain adequate storage
volume in the event of a fuel tank rupture. Any contaminated sediment
which was collected in the pond would be reclaimed and transported to the
mine site for disposal in the tailings pond. Annual sampling of site materials
and pond sediments would be conducted to determine concentrations of lead,
zinc, barium, cadmium and fuel oil which might accumulate due to spills and
normal operations.
The primary source of potential concentrate spillage to the marine environ-
ment would be during the dock/lighter/tanker/bulk carrier loading and un-
loading operations. All points of material transfer for this alternative would
be relatively secure. The dock transfer and two ballasted ship transfers
would be stable, and would occur in protected conditions using conveyors or
cranes operating from a stable platform. It would be expected that at some
point weather might be a significant factor in the environmental safety of
loading operations. All loading and unloading would be suspended during
extreme wind and sea conditions.
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The lead and zinc concentrates would be essentially sulfides of the respec-
tive metals, while the barium concentrate would be barium sulfate. Sulfides
are insoluble and release toxic contaminants very slowly upon prolonged
exposure to the elements. If submerged under most marine or freshwater
conditions, they would be expected to remain intact and not oxidize to the
corresponding soluble metal sulfates over short time periods of days or
months. However, upon dilution and mixing with water, some initial release
of surface adsorbed flotation reagents would occur. Impacts would be of low
to moderate local significance.
Most reagents used in the milling process have been evaluated for toxic im-
pacts by Hawley (1972). The impacts at low concentrations are significant
for many of the reagents. The quantities anticipated in the event of a spill
and the short exposure would not present a significant long-term impact,
however, rapid implementation of cleanup measures would be necessary. In
the event of a soluble material spill, dispersion and resulting dilution would
reduce the significance of local impacts.
Barium sulfate has a low water solubility of about 2 mg/£ and is not re-
garded as being particularly toxic. Quantities released to the environment
would depend on the degree of contact with water and the duration of expo-
sure. Therefore, mitigation in control of concentrate spills would require
rapid implementation of cleanup measures where practicable.
The impact of a concentrate spill would also depend upon quantities and
weather conditions. Small spills during ship transfers would be dispersed
rapidly and would not cause even a short-term impact. Small spills which
occurred repeatedly over years of operation could increase sediment concen-
trations of lead, zinc and barium. Present sediment concentrations for these
elements are as follows:
Sediment Concentrations at Port Sites
Lead (Pb) 2.7 to 6.3 mg/kg
Zinc (Zn) 25 to 46 mg/kg
Barium (Ba) 22 to 283 mg/kg
Spills of 0.9 Mg (1 ton) of concentrate per day would be anticipated to in-
crease sediment concentrations spread evenly along an 8 km (5 mi) segment
of the coastline approximately one percent in 20 years of operation. Concen-
trations near large spill sources could approach pure concentrate strengths.
However, mixing energy and sediment transport would be strong influences.
The high inherent mixing energy and fine concentrate grind would tend to
disperse concentrate spills. The slowly settling concentrate would create
suspended solids water quality impacts for major spill occurrences. Cleanup
of all but the largest spills would not be feasible. Direct impacts to water
quality would be minimized since the concentrates would be relatively insol-
uble and background seawater concentrations would be likely to be well
below normally accepted aquatic life standards.
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The most prevalent summer wind conditions, from the west or northwest,
would tend to move spills down the coast toward Cape Krusenstern. For
large oil spills, this movement could increase the extent of impact such that
a spill could have greater than local significance. For chemical or dispers-
ible spills, the transport would tend to disperse the material rapidly.
The risk of spillage would be directly dependent upon the number of trans-
fers, the number of transfers between unstable platforms and the number of
ships involved (Table V-15).
The SPCC Plan (Appendix 2) required by EPA would also be certified by
the state. The plan would outline rapid spill reaction measures, materials
and equipment required for containment and cleanup procedures. Training
programs and spill contingency staffing requirements would be outlined in
detail.
Table V-15
TRANSFER AND SHIPPING FREQUENCY
Alternatives
Number of Concentrate Ships/Year
Number of Concentrate Barges/Year
Number of Concentrate Transfers/Year
Number of Concentrate Transfers/Year
1 & 2
13
420
853
0
3
13
84
168
84
at an Unstable Platform
Number of Material and Equipment
Ships/Year
13
13
Note:
Transfer =
movement from one ship to a
dock or another ship on or
over water.
Unstable Platform = a floating ship or barge subject
sea conditions.
Source: Cominco Alaska, Inc.
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Alternative 2
The marine water quality impacts of this alternative would be similar to those
for Alternative 1.
Alternative 3
The marine water quality impacts of this alternative would be similar to those
for Alternative 1 with the following exceptions:
0 Oil would be stored onshore at the port site thus increasing the risk
of onshore fuel spill contamination.
0 Oil would be lightered instead of piped to shore. Lightering pre-
sents different spill risks and, since more connections to pipelines
and more transfers would be made, oil spill risk would increase.
Fuel transfer by lightering would be subject to wind and weather
limitations as discussed below.
0 Lightering ore concentrate to a moored ship would be subject to
interruption due to adverse weather conditions. Transfers between
the lighter and the ship, two unstable platforms, would not be pos-
sible when wave heights were over 1.5 m (5 ft). These conditions
exist approximately 20 percent of the time during the 100-day ship-
ping season. Delay of the ore concentrate vessels would cause sub-
stantial increased costs. In addition, these increased costs would
force attempts to work in marginal weather conditions, greatly in-
creasing the chance of significant spills of hazardous substances to
the marine environment.
0 Two tug-assisted 4,535 Mg (5,000 ton) barges would be used instead
of one 907 Mg (1,000 ton) self-propelled barge. This would reduce
the number of barge trips.
0 According to shipping companies, neither clam shell loaders mounted
on the bulk carrier or barge-mounted conveyors provide the neces-
sary speed for open sea transfers. They also present more of a
risk for equipment damage and spillage.
0 Shipping frequency and number of transfers differ from Alternatives
1 and 2 as shown in Table V-15.
Approximately one-fifth the number of concentrate transfers would be made
using Alternative 3. However, half of these transfers would be between two
unstable platforms in the open sea (bulk carrier and lighter). Since con-
centrate transfers for Alternatives 1 and 2 would be all from or to a stable
platform (dock or ballasted ship), and either under cover or by conveyor,
the risk of spills for Alternative 3 would be considered slightly greater
because of the following factors:
0 Pressure of weather to speed transfers;
0 Unstable open sea transfers; and,
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0 Transfer methods would be unproven and not desirable to shipping
companies.
Air Quality
Alternative 1
Air pollutant emissions from the concentrate haul trucks' and supply trucks'
exhaust would be negligible when averaged over nine to 12 trips per day
and the 180 km (112 mi) round-trip distance. However, dust generation
would be a serious concern. Measurements along the North Slope Haul Road
from Atigun Pass to Prudhoe Bay have shown that dust accumulations
exhibited a logarithmic distribution on both sides of the road, with greater
accumulations downwind from the prevailing wind direction. Measured
accumulations in one summer ranged from 50 to 100 g/m2 at 30 m (98 ft)
from the road, and from 2 to 3 g/m2 at 1,000 m (3,280 ft) from the road
(Brown and Berg, 1980). Dust accumulations were found toxic to many
species of mosses and lichens with noticeable changes to vegetation alongside
the road. Total accumulations during a 67-day period in summer were 28 to
56 Mg/km (50 to 100 tons/mi) of road.
Dust control measures would keep dust generation to low levels. These
measures might include: road constructed of hard crushed rock; use of a
subsurface fabric; water sprayed on dry days; use of chemical stabilizers
and binders; use of wind screens and berms; and revegetation of road
shoulder embankments and cuts and fills. Adequate sources of water exist
along the transportation corridor so dust control spraying would not signifi-
cantly reduce surface water flows or impact biological resources. If applied
properly at the beginning of a dry period, common dust palliatives such as
calcium or magnesium chloride could effectively prevent suspension of up to
90 percent of visible dust. These stabilizers might have to be reapplied
after rain storms or during heavy traffic periods, but they would have no
significant impact on surface water quality. Revegetation procedures would
include mulching, fertilization and irrigation (if necessary due to drought).
Rooted willow cuttings would be suitable for revegetation of wet slopes and
stream crossing areas. Use of appropriate dust control measures would
reduce potential impacts to roadside vegetation to insignificant levels. Dust
control measures would be especially important to reduce impacts to vegeta-
tion in Cape Krusenstern National Monument. Dust generation would be
monitored as part of EPA's PSD permit.
Potential air pollutant sources at the port site facility include a small diesel
power generator and ore concentrate unloading activity involving trucks and
front-end loaders. Emissions from the power plant and loading equipment
would be much lower than those discussed for the mine area, and would rep-
resent an insignificant percentage of National Ambient Air Quality Standards.
Dust control at the port site facility would include water sprays and chemical
stabilizers. Revegetation would be attempted in areas not subject to ve-
hicles. The ore concentrate would be unloaded in an enclosed area and
stored under cover.
Offshore air pollution sources would include emissions from the lightering
transfer operation and a small power generator on the ballasted ship. The
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emission plumes from either of these sources would not reach any nearby
terrain in significant concentrations. The greatest potential source, the
lighter, would be moving from ship to dock, which would disperse its emis-
sions under even the most stagnant atmospheric conditions.
Alternative 2
Air quality impacts would be similar to those for Alternative 1, with the
exception that there would be no concern about the effect of road dust
plumes on Cape Krusenstern National Monument.
Alternative 3
Air quality impacts would be similar to those for Alternative 1. Slightly
greater emissions from the lighter tugs would have no significant impact on
air quality.
Visual Resources
Alternative 1
The southern corridor passes through Cape Krusenstern National Monument
and would be visible in the middle and background view of travelers. Use
level of the National Monument is presently extremely low; less than five
visitors per year visit the site from outside the region. However, their
concern for scenic qualities would be expected to be very high.
The southern corridor would be located in an area of moderate visual vari-
ety. Road construction would meet the visual subordinate criterion if sur-
facing material were selected which would not contrast with the natural land-
scape. Gravel borrow sites would be contoured and revegetated, while rock
quarries would be made to resemble surrounding rock outcrops. Depressions
resulting from borrow extraction would eventually fill with water to create
small ponds and lakes along the corridor. If borrow material was extracted
only from sites outside the Monument, the surface area and excavation
depths of Sites 7 and 8 would increase. This would result in greater visual
impact at those areas (Fig. 11-8). Reclamation could permit road closure
through the National Monument with subsequent natural revegetation of the
road bed.
The proposed port site and transfer facilities would be located in partial re-
tention Visual Quality Objective (VQO) areas. The proposed facilities could
meet the VQO provided some design considerations were made.
As noted earlier for the mine area facilities, the port site facilities would be
located on private land and the VRM Program as a management system is not
applicable to private land. The discussion below, therefore, would be pri-
marily of benefit to NANA as the landowner in its joint management of the
project.
The port site would be the project component which would be most visible to
those visitors with a major concern for visual quality. Located on the sea-
coast near Cape Krusenstern National Monument, the port site would be
visible in the middle ground view of the majority of scenic viewers to the
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area. Since it is possible these facilities would be used well into the future,
the port site and appurtenant facilities would require mitigating design
measures to achieve the partial retention VQO. Port facilities which would
complement the color, form, line and texture of the shoreline would be
necessary and appropriate. If borrow extraction was not allowed within the
boundaries of the Monument, the main concentrate storage building would be
located at the port site rather than 4.0 km (2.5 mi) inland at Borrow Site 1
(Fig. 11-16). The visual impact of this large structure would be substantial.
The offshore island tanker facility would be located approximately 1,097 to
1,216 m (3,600 to 4,000 ft) from the shoreline where highly scenic features
occur. Because of its tremendous size, the visual impact would be sub-
stantial and visual quality considerations should be considered during facility
design to achieve the partial retention VQO.
Alternative 2
All components of this alternative would occur in partial retention VQO zones
except for two separate segments of the northern transportation corridor.
Although scenic viewers would have a background view of the corridor,
approximately 19 km (12 mi) of road corridor would cross retention VQO
zones. This classification directs development activities to repeat the form,
line, color and texture of the characteristic landscape. These sections of
corridor would be considered more distinctive landscapes because they would
traverse the highly scenic basins of the Kivalina and Wulik Rivers. Well
planned design and reclamation techniques would be important to the main-
tenance of the retention VQO.
The port site location is considered highly scenic due to the distinct visual
variety class of the coastline. The port site would require mitigating design
measures to achieve the partial retention VQO. The visual impact of the off-
shore transfer facility would be similar to Alternative 1.
Alternative 3
This alternative would be similar to Alternative 1 except the lightering
transfer system would not involve a ballasted tanker offshore. Visual im-
pacts, therefore, would be substantially less than those for Alternative 1.
Sound
Alternative 1
During construction of the road, significant noise disturbance would occur
from drilling and blasting activities at the borrow sites. If borrow material
was extracted only from sites outside the Monument, there would be more
noise generated during road construction than if borrow sites were spaced
along the entire corridor. This would be due to borrow being hauled longer
distances. During operation, the southern corridor road would be used
consistently for nine to 12 round trips per day by concentrate truck/trailer
units. Additional daily tanker and supply truck trips and one or two trips
per day by light utility vehicles would occur. Use would be primarily
during daylight hours with no traffic during periods of hazardous weather,
such as fog or whiteout.
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Sources of noise along the transportation corridor are shown below:
Concentrate truck/trailer units 90 dB(A) at 15 m (50 ft)
Tanker/supply trucks 90 dB(A) at 15 m (50 ft)
Utility/passenger vehicles 80 dB(A) at 15 m (50 ft)
Helicopter 82 dB(A) at 152 m (500 ft)
Helicopter 76 dB(A) at 305 m (1,000 ft)
Helicopter 70 dB(A) at 610 m (2,000 ft)
Maximum sound levels would be approximately 90 dB(A) at 15 m (50 ft).
Sound levels from the road would be intrusive (to human conversation)
under optimum propagation conditions (low temperature inversion) out to a
distance of 0.8 km (0.5 mi), and noticeable above normal background sound
levels of wind and rain to approximately 8 km (5 mi) from the road.
Assuming 12 round trips per day along the road corridor by concentrate
truck/trailer units or tanker/supply vehicles (i.e., excluding other road
vehicles, aircraft, etc.), at an average speed of 48 km/hr (30 m/hr), noise
would be intrusive to humans at roadside under optimum propagation condi-
tions approximately 3.3 percent of the time during a 24-hour period (or
approximately 6.6 percent during a 12-hour "daytime" period). Under
similar conditions, noise would be noticeable above normal background sound
levels to humans at roadside somewhat less than 33 percent of the time dur-
ing a 24-hour period (or somewhat less than 66 percent of the time during a
12-hour daytime period). At a distance of 4.8 km (3 mi) from the road, the
percentages would be somewhat less than 27 and 53, respectively. Animals,
which are generally more sensitive to noise than humans, would likely notice
sound for a greater percentage of time at similar distances.
Helicopter and light plane flights from the mine area to the port site or to
Kivalina should follow the road corridor or stay at elevations of 610 m (2,000
ft) or greater above ground level to the extent weather and destinations
would allow. Helicopters and light planes should be required to detour
around known raptor nest sites by 1.6 km (1 mi) or greater horizontally and
vertically. No route deviation should be allowed to investigate wildlife,
particularly muskoxen, caribou, grizzly bears, or nesting birds. Air trans-
portation to and from Kotzebue should also follow a consistent route and
maintain 610 m (2,000 ft) above ground level to the extent weather and
destinations would allow. Failure to adhere to these restrictions could have
significant local impacts on wildlife species; during caribou migrations the
impacts could be significant on a greater than local basis.
Noise disturbance to visitors at Cape Krusenstern National Monument would
be unavoidable within 8 km (5 mi) of the road corridor. The relative brief-
ness of any potential exposure and the present infrequent visitation to this
portion of the Monument would suggest that noise impacts due to traffic on
the road would not be significant.
Potential noise sources at the port site and transfer facilities can be divided
into those which propagate through the air and those through the water.
Onshore air-propagated noise sources would include:
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Concentrate truck/trailer units 90 dB(A) at 15 m (50 ft)
Tanker/supply trucks 90 dB(A) at 15 m (50 ft)
Diesel power generator 85 dB(A) at 15 m (50 ft)
Crane loader 70 to 85 dB(A) at 15 m (50 ft)
The combined sound level at 15 m (50 ft) would be approximately 93 dB(A)
assuming all sources were operating simultaneously. During normal wave and
wind conditions (generating 30 to 50 dB[A]), such a sound level would be
discernible at a distance of approximately 1.6 to 3.2 km (1 to 2 mi). The
relatively consistent nature of port facility sounds would be unlikely to cause
terrestrial wildlife avoidance at distances greater than that also caused by
sight and smell stimuli.
Offshore underwater noise sources are shown below:
dB at 305 m
(1,000 ft)
Transfer barge/lighter/tug 106
Shipboard generator 102
Ore ship transfer operations 92
Noise levels are given in dB instead of dB(A) since the characteristics of
marine mammal hearing are different from those of humans. Most noise would
be restricted to the June through mid-October period when the transfer
facility would be operated. Ice-free conditions would likely exist from late
June to early October. Summer natural underwater sound levels would range
from 30 to 75 dB. Natural ambient sound levels underwater with moving ice
present would range from 75 to 85 dB. In comparison, moderate to heavy
shipping noises would range from 70 to 75 dB.
Background underwater noise sources would include ice action, waves, wind,
rain and marine life. Potential sounds from the port and transfer facilities
would be discernible above natural background sound levels for approxi-
mately 8 to 16 km (5 to 10 mi) underwater. They would be capable of mask-
ing sounds from some marine mammals, thus limiting the range over which
these animals could detect members of their own and other species. Most
sounds produced by port operations would be below 2,000 Hz with a greater
proportion below 200 Hz. Seal communications are not disturbed by offshore
operations sounds since most seals generate sounds in a fairly broad spec-
trum, up to 3,000 Hz. Belukha whales vocalize above 2,000 Hz. Noises
generated by Gray and bowhead whales, however, are belches and moans,
mostly below 500 Hz. This sound range would overlap those frequencies
generated by offshore operations. Thus, communication among Gray and
bowhead whales could be affected at least up to 16 km (10 mi) from the port
site. The sounds might cause these whales to avoid the vicinity of the port
site during summer operations. This avoidance would probably not be sig-
nificant since bowhead whales would normally not be present at this time and
Gray whales would be relatively infrequent visitors.
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Alternative 2
Sound impacts would be similar to those for Alternative 1 with the following
exception. The northern corridor would pass through areas more important
to wildlife and subsistence users. Traffic noises would cause greater im-
pacts on both.
Alternative 3
Sound impacts would be slightly less than those for Alternative 1. The off-
shore island facility would not exist, but sounds from the lighter operations
would be similar in intensity to the ballasted ship operations.
Cultural Resources
Alternative 1
For those of the 13 archeological sites that could not reasonably be avoided
by realignment of the southern corridor road, it would be proposed to the
Advisory Council on Historic Preservation (ACHP), through the State
Historic Preservation Officer (SHPO), that professionally designed recovery
operations be conducted to preserve the site data and material that could not
be preserved in place. On a site specific basis, measures to protect sites
near the transportation corridor from indirect impacts would be proposed to
the ACHP for approval.
The historical reindeer herding facility remains at the VABM 28 port site
would be either directly or indirectly impacted depending on the specific
port facilities location. Priority consideration would be given to a design to
avoid the site, and to provide protection from indirect impacts. If avoidance
were not a reasonable option, recovery and recording operations would be
developed in consultation with the SHPO and the ACHP.
Because of ice scouring and littoral transport along the coastline, it is not
likely that submerged archeological sites or historical shipwrecks would be
encountered by construction of the offshore island transfer facility.
Management decisions relating to sites within Cape Krusenstern National
Monument would be based on federal regulations, and on the additional
consideration of their relationship to the prehistorical data base of the
Monument.
If all these measures were taken, impacts would not be significant.
Alternative 2
For those of the 23 archeological sites that are determined eligible for the
National Register and that could not reasonably be avoided by realignment of
the northern corridor road, the same mitigation measures would be used as
described for Alternative 1. This would also apply to the cabin at the
Tugak Lagoon port site. As at the VABM 28 port site, it is not likely that
archeological sites or historical shipwrecks would be encountered by con-
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struction of the offshore island facility. If all these measures were taken,
impacts would not be significant.
Alternative 3
Cultural resource impacts would be similar to those for Alternative 1.
Subsistence
Alternative 1
The southern road corridor would be shorter than the northern corridor and
would tend to parallel the natural topographic and drainage features of the
region. As a result, it would traverse more upland habitat and have fewer
stream crossings than the northern corridor. The upland and freshwater
habitats along the southern corridor also tend to be less accessible and lower
in quality and productivity and thus of less established value to subsistence
hunters.
The western Arctic caribou herd is the primary subsistence resource along
the southern corridor. The flanks of the Mulgrave Hills between Kivalina
and Noatak provide good winter range. The southern corridor follows along
a natural buffer zone between the primary winter caribou range in the
Kivalina and Wulik River drainages and the secondary winter range on the
wind-swept western slopes of the Mulgrave Hills. If the road were to
grossly impede customary movements between these ranges, there would be
immediate adverse impact on the Noatak subsistence harvest of caribou and
perhaps on the long-term herd size.
The NANA/Cominco agreement would permit NANA to curtail road use during
caribou migration periods when traffic might interfere with the normal pas-
sage of caribou through the vicinity. This option, if exercised properly,
could mitigate many of the adverse impacts of road activity on caribou move-
ments near the road corridor.
The southern corridor would cross about 187 streams, including tributaries
of the Wulik and Omikviorok Rivers and New Heart Creek. Eleven of these
stream crossing sites contain resident fish populations or spawning grounds.
These sites are relatively remote from Noatak and Kivalina and are not
routinely used for subsistence. However, degradation of spawning habitat
or new fishing pressure as a result of increased access might impair down-
stream subsistence fisheries.
While the southern route passes near and through some habitat supporting
moose and furbearers, habitat impacts would probably be local and minor,
with minimal impacts on subsistence. Near the coast the corridor would
enter wetlands and lagoon areas that support waterfowl populations, so there
would be some local habitat loss and displacement of waterfowl.
The VABM 28 port site falls within a marine mammal harvest area. Accord-
ing to a 1974 survey by Mauneluk (Maniilaq) Association, marine mammals
were the single most important subsistence food resource for Kivalina resi-
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dents. Seals and ugruk (bearded seal) were most important, followed by
walrus, and belukha and bowhead whales.
Marine mammal hunting is generally confined to the winter and spring months
when the port would be ice-bound, so ship traffic from the port should not
significantly disrupt harvest activities. However, port construction and
year-round activities aboard the offshore transfer facility would likely dis-
place some marine mammals from the immediate area, resulting in a reduction
in size of the local marine mammal harvest area. Any mishaps such as epi-
sodic or chronic spillage of fuels or chemicals that could seriously damage
habitat quality might adversely affect marine mammal populations. However,
the net impact of ordinary port operations on marine mammal resource avail-
ability would not be significant.
Alternative 2
The northern corridor would traverse an area important to caribou as pri-
mary winter range and for migration. This area is intensively used by
Kivalina hunters. As noted in the assessment of impacts on terrestrial wild-
life, disturbances from construction and traffic along the road corridor would
likely result in reduced use of this habitat by caribou. There would be an
unknown risk that road-related disturbances could cause an unfavorable shift
in winter grazing habits or deflect traditional caribou migration routes so
that subsistence access to this important food resource would be reduced.
The upper reaches of the Wulik and Kivalina Rivers support moose popula-
tions that are harvested by Kivalina residents, but moose generally adapt
more easily to human intrusions. Finally, where the road corridor would
cross the Ikalukrok, Wulik, Kivalina and Asikpak drainages, it would pass
through habitats of small furbearers important to Kivalina trappers. How-
ever, the impact on these species would likely be local and minor.
The northern corridor would make numerous crossings of the main streams
and tributaries of the Kivalina, Wulik and Asikpak drainages. The crossing
areas would impact fish spawning areas and other productive habitat. Kiva-
lina residents depend heavily on downstream sections of the Wulik and Kiva-
lina Rivers for their fall subsistence harvest of Arctic char. Road construc-
tion and use have the potential to impair both local habitat and important
downstream subsistence fisheries if water quality were degraded or fish
passage interrupted.
Lagoons and wetlands along the coast provide habitat for waterfowl. Con-
struction and use of road and port facilities near Tugak Lagoon could pos-
sibly result in reduction of waterfowl habitat of minor importance to subsis-
tence hunters.
The area offshore from the Tugak Lagoon port site is used by Kivalina
residents for harvest of marine mammals like the VABM 28 port site. The
relative level of subsistence hunting effort offshore from Tuguk Lagoon
reportedly has shifted southeastward in recent years. Braund and Asso-
ciates (1983) found that the area from Kivalina south to Rabbit Creek is now
most intensively used for marine mammal harvest. An earlier study (Saario
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and Kessel, 1966) reported marine mammal hunting was most intensive north
of Kivalina to Cape Seppings. This may be a dynamic phenomenon which
periodically undergoes change. In general, it appears that the local impacts
of the Tugak Lagoon port site and transfer facility on subsistence would be
similar to the impacts noted for the VABM 28 site in Alternative 1.
Alternative 3
Subsistence impacts for this alternative would be similar to those for Alter-
native 1, except that the absence of the ballasted ship should lessen the
potential for disturbance of marine mammals during the spring subsistence
hunting period. This would not represent a substantial difference.
Recreation
Alternative 1
Recreational hunting and trapping activities by Cominco employees would be
prohibited during their active phase of work or residence at project loca-
tions, or while moving to or from their residences and work sites on
Cominco transportation. The southern road corridor would cross areas used
by migrating fish and game species. The route would be public in that it
would be available for use by other future resource developments in the
region, but it would not be open for general public use. Current recrea-
tional use of Cape Krusenstern National Monument is extremely low due to
difficult access and overland travel.
Development and human use of the port facility could also lead to a potential
increase in recreational activity near the coast. Similarly to the road, the
port and transfer facilities would be for industrial resource use. However,
if eventually they were made available for public use, access would be im-
proved for non-residents, and hunting, fishing, sightseeing and coastal
boating might increase. Good waterfowl habitat would be more accessible and
these species would probably receive greater exploitation.
Project facilities would replace a roadless and generally undeveloped recrea-
tional experience with a developed setting. However, the impacts on exist-
ing recreational activities would be minimal. In fact, recreational use of the
project area might increase due to more people residing in the area; better
access and support facilities; more publicity; and establishment of an indus-
try for which Alaska is known worldwide. Some people might be discouraged
from using the area as its wilderness character would decrease, but more
might be encouraged to engage in local recreational activities as cultural
development increased.
Alternative 2
Impacts from development of this alternative would be generally similar to
those from Alternative 1. However, the northern road corridor would inter-
sect more important moose, caribou and fish habitat, and would thus have a
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greater potential for increasing hunting and fishing activities. In partic-
ular, major fish streams of the area would be crossed at several locations,
and increased recreational fishing activities could adversely impact important
fishery resources in those streams. If angling and associated disturbance
occurred during the late summer char spawning period, char populations
could be severely impacted in the Kivalina drainage.
Alternative 3
Recreational impacts would be similar to those for Alternative 1.
Regional Use
Analysis of regional use impacts must be made in light of the stated positions
of the landowners in the project area regarding use of the transportation
system right-of-way and port site.
The State of Alaska, through its Department of Natural Resources, has
stated that it will authorize development of a single industrial use transporta-
tion corridor to connect mineral deposits in the Western De Long Mountains
with tidewater. The route would be public in that it would be available for
use by other future resource developments in the region (but not to the
general public). As a public industrial use route, reciprocal right-of-way
agreements would be required whenever individual, corporate or other pri-
vate ownership was encountered to ensure public access across these private
lands. Likewise, tideland and associated upland port development would also
be available to other users such as oil, gas, coal and other hardrock mineral
exploration, development or support services (Wunnicke, 1983).
The National Park Service has also stated that if a Title XI right-of-way was
issued across Cape Krusenstern National Monument, it would be for indus-
trial resource use only and not open to the general public.
NAN A Regional Corporation, as owner of the private land at the proposed
VABM 28 port site, and probable owner of the land at the proposed Tugak
Lagoon port site, has stated that it would make available a reasonable amount
of land for other resource users at either port site at fair market value.
Also, while use of the road by other industrial resource users would be
permitted, such users would be expected to reimburse the Red Dog project,
or other appropriate entity, reasonable costs for building and maintaining
the road.
Thus, from the perspective of access to the transportation corridor and port
site, any of the three alternatives would provide a guarantee of reasonable
access and use by other industrial resource users, and such reasonable
access and use are considered assured for the following impact analysis.
Alternative 1
This alternative would provide a relatively flexible transportation system
between the coast and the foothills of the De Long Mountains. The port site
location would have adequate soils and be large enough to handle major ex-
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pansion, if needed. Also, since the 122 m (400 ft) causeway would exist in
all three alternatives, the presence of the ballasted tanker would add extra
flexibility for transshipment of materials or supplies into or out of the
region.
Alternative 2
The effects of this alternative would be similar to those for Alternative 1.
At this early stage of development of the De Long Mountains area of Alaska,
the differences between this alternative and Alternative 1 cannot be ac-
curately assessed with respect to the geographic ability of the port sites and
road corridors to serve other users. GCO's Lik prospect would be more
easily accessible from the northern corridor, but would also be reasonably
accessible from the southern corridor. From the standpoint of access to the
port and road corridor by residents of Kivalina, the three alternatives would
be approximately equally distant from the village.
Alternative 3
The regional use impacts of this alternative would be similar to those for
Alternative 1 except that the absence of the offshore island would somewhat
limit the flexibility of the port facility in serving other users.
Technical Feasibility
Alternative 1
Since all the options used to develop the alternatives were technically feasi-
ble, in determining the potential technical impacts of the alternatives,
emphasis was placed on the technical complexity of the options.
The southern corridor road would have one major multi-span bridge over
30.5 m (100 ft) in length, and would have four minor single span bridges
under 30.5 m. The road would be built through soil, slope, elevation and
river bottom conditions that would be classified as moderately difficult or
difficult to construct for 19 percent of its length.
The VABM 28 port site location would have suitable soils and bedrock at a
depth of approximately 16.8 m (55 ft).
The offshore island transfer facility would use a technically complex system
involving a self-propelled lighter and three concentrate transfers using con-
veyors. It would also employ a buried fuel pipeline that would be subject to
ice-scour problems during the winter.
Alternative 2
The northern corridor road would have six major multi-span bridges (over
30.5 m [100 ft] in length) and would have seven minor single span bridges
under 30.5 m long. The road would be built through soil, slope, elevation
and river bottom conditions that would be classified as moderately difficult or
difficult to construct for 41 percent of its length.
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The Tugak Lagoon port site location would likely have suitable soils, but the
depth to bedrock is not known.
The technical impacts of the offshore island transfer facility would be the
same as those for Alternative 1.
Alternative 3
The technical impacts of this alternative would be the same as those for
Alternative 1 except for the transfer facility. This alternative would employ
a technically complex lightering system using two larger lighter barges towed
by two tugboats. Concentrate transfers to the bulk carriers would be by
clam shovels between two unstable platforms. This facility would not have a
buried pipeline subject to ice-scour problems during the winter, but would
have to lighter fuel ashore from ocean-going ships.
Cost
Capital and operating costs can be calculated for eight of the project com-
ponents: the mine, tailings pond, mill, worker housing, water supply,
power generation, transportation system and port facility. All components,
except the transportation system and the port facility, are common to all
three alternatives and would, thus, cost approximately the same regardless
of which alternative were selected. Any significant differences in cost
among alternatives, therefore, would result from the transportation corridor
location and the type of port facility selected. Table V-16 presents the
estimated road system and port facility capital and annual operating costs for
each of the three alternatives.
NO ACTION ALTERNATIVE
The No Action Alternative is identical to the base case forecasts for economic
and population growth and regional change.
Generally, the base case forecasts for the near future anticipate a slowing
population growth and a static or deteriorating regional economy. Over the
past decade, growing federal and state expenditures have accounted for the
major share of the region's cash economic expansion. Paralleling this trend
has been a marked shift toward local control over the administration of
public resources. Now, curtailed federal expenditures and shrinking state
revenues and expenditures make it unlikely that the economic expansion of
recent years would persist. Since local government and other local public
service agencies are heavily dependent on federal and state funds, their
ability to improve or sustain current levels of community services might be
impaired. Even so, in the absence of private economic development, the
public sector would likely continue to dominate the region's economy.
The potential impact of the No Action Alternative on the cultural and social
evolution of the region is not clear. To the degree that the project is seen
to favor modernization and a departure from established cultural values, the
No Action Alternative would forego those social changes. However, it is
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Table V-16
ESTIMATED ROAD SYSTEM AND PORT FACILITY CAPITAL1 AND
ANNUAL OPERATING COSTS ($000) FOR EACH ALTERNATIVE
ALTERNATIVE 1
Southern Corridor
VABM 28 Port Site
Offshore Island Fac
Component
Road System
Port Facility
TOTAL COST
Capital
Cost
74,700
54,700
$129,400
Annual
Operating
Cost
2,614
1,605
$4,219
ALTERNATIVE 2
Northern Corridor
Tugak Lagoon P. S.
Offshore Island Fac
Capital
Cost
125,700
54,700
$180,400
Annual
Operating
Cost
3,334
1,605
$4,939
ALTERNATIVE 3
Southern Corridor
VABM 28 Port Site
Lightering Facility
Annual
Capital Operating
Cost Cost
74,700
74,000
$148,700
2,614
2,966
$5,580
Source: Cominco Alaska, Inc.
1 Based on July 1983 capital costs.
plausible that if public sector growth flagged, the No Action Alternative
could mean a halt in the shift of political and social power to resident
institutions. This, in turn, might tend to stall the movement now underway
to restore traditional Native cultural and social values.
The Red Dog Mine property represents a major economic asset of the NANA
Regional Corporation, which is the most important non-governmental economic
and political institution in the region. The No Action Alternative, which
would mean no development of this asset, might adversely affect the long-
term viability of the NANA Regional Corporation.
MITIGATION
The term "mitigation" can have several meanings in an EIS process.
include:
These
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(a) Avoiding the impact altogether by not taking a certain action or
parts of an action.
(b) Minimizing impacts by limiting the degree or magnitude of the
action and its implementation.
(c) Rectifying the impact by repairing, rehabilitating, or restoring the
affected environment.
(d) Reducing or eliminating the impact over time by preservation and
maintenance operations during the life of the action.
(e) Compensating for the impact by replacing or providing substitute
resources or environments.
In this EIS, no significant impacts were found that would require, or would
be capable of being mitigated by, compensation as defined in (e) above.
Mitigation by avoiding impacts altogether, as in (a) above, was incorporated
extensively throughout the EIS process through elimination or alteration of
options or designs to avoid significant effects (Chapter III). The other
three forms of mitigation, i.e., minimizing impacts, rectifying impacts
through repair, and eliminating impacts over time (as in [b], [c] and [d]
above), are the forms of mitigation generally grouped in this EIS under the
term "mitigation" and are referred to as "mitigative measures" in the text.
Without these numerous mitigative measures, or environmental safeguards,
which have been incorporated in the Red Dog project plans for design, con-
struction and operation, there could be many significant impacts. In the
following paragraphs, these mitigation measures are briefly described to pull
together in one place the major environmental safeguards that would be used
in project development. Details of these mitigative measures are discussed
under individual discipline environmental consequences earlier in this chap-
ter.
Vegetation and Wetlands
Vegetation would be restored in disturbed areas not subject to vehicle use or
scheduled for future disturbance to the extent feasible under Arctic condi-
tions.
Terrestrial Wildlife
Aircraft and helicopter operators would be provided maps and required to
travel corridors and at altitudes which would avoid known raptor nesting
sites and wildlife concentrations to the extent weather and destinations would
allow. Harassment would be prohibited. Flight areas would be updated as
required to avoid caribou movements. Vehicle use of the road would be
restricted or eliminated when caribou movements occurred near the road.
Workers would not be permitted to hunt or trap during the active phase of
their work and residence at project locations, or while moving to or from
their residences and work sites on Cominco transportation.
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All garbage collection sites and incinerators would be fenced using adequate
"bear-proof" fencing, and workers involved with garbage disposal would be
instructed in proper collection, handling, and incineration techniques.
Incinerator wastes and unburnable solid wastes would be buried in the tail-
ings pond to eliminate landfills and their associated wildlife attraction prob-
lems.
Feeding of animals would be prohibited and this would be strictly enforced.
The ADF&G regulation prohibiting such feeding (5 AAC 81.218) would be
posted conspicuously throughout the camp. All workers would receive
environmental training which would stress the importance of this prohibition,
the usual consequences to the animals themselves from being fed, and the
potential danger to employees (e.g., bear/human contacts, rabid foxes).
Groundwater Resources
Runoff from the ore body would be collected by a diversion ditch and routed
to the tailings pond. If seepage occurred from the tailings dam foundation it
would be collected and pumped back to the tailings pond.
Freshwater Resources
Hydrology and Water Quality
The ore body diversion ditch would collect surface runoff and sediment and
route it to the sump sedimentation pond and tailings pond. All mill and
domestic wastewater would also be routed to the pond. Mine, mill and
domestic wastewater in the tailings pond would be treated to meet appropri-
ate permit standards before being discharged. The pond would be sized to
handle the 10-year recurrence 24-hour flood event. Spillage control plans
and rapid response to spills would be the primary mitigative measure for
spill impacts. Appendix 2 (SPCC Plan) outlines the proposed draft plan for
spill reaction.
Guidelines for road construction in the Arctic would be followed to prevent
sedimentation impacts. The most important guidelines would include: use of
erosion control measures which prevent restriction of cross-drainage; avoid-
ance of icings and ice-rich soils; and use of stream crossing designs which
minimize bank erosion and channel scour. Development of specific construc-
tion schedules should include consideration of: ground conditions most suit-
able for construction (e.g., frozen); raptor breeding, incubation and hatch-
ing periods; caribou wintering areas and major movement timing; fish pres-
ence at stream crossings; and marine mammal migrations and subsistence
hunting periods.
Biology
Mitigation measures which protect water quality would also protect aquatic
plant, invertebrate and fish resources.
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Air Quality
Permit requirements would ensure control of gaseous and particulate emis-
sions from mill operations and power generation. Dust suppression measures
such as watering and chemical treatments would be used for mine access
roads, the open pit, overburden storage piles and the road to the port site.
Sound
Offshore port site noise would be minimized during the March through June
period when it might affect subsistence seal hunting and whale migrations.
Helicopter and fixed-wing operations would be restricted to the road corridor
or to altitudes above 610 m (2,000 ft) outside the corridor to the extent
weather and destinations would allow.
Cultural Resources
The preferred course of action would be to avoid all prehistorical and his-
torical sites. Based on a plan of mitigation developed in cooperation with
the SHPO and approved by the ACHP, data recovery operations would be
conducted at those sites that could not be avoided, or which were discovered
during construction.
Subsistence
Hunting activities would be restricted for project personnel in order to pro-
tect traditional Native subsistence activities. Road activity would be
restricted or eliminated during periods of major caribou movements or at
other times when such activities might threaten or interfere with subsistence
resources or harvests.
Socioeconomics
Cooperation with NANA and local community officials in Kotzebue and the
villages would ensure that mitigative measures were applied to problems
which developed.
MONITORING
Monitoring programs are usually established in response to permit require-
ments. However, additional monitoring requirements have been suggested
here to answer environmental concerns since: (1) the baseline data collec-
tion period of two years, while adequate for EIS writing purposes, may have
been insufficient to document the full range of natural fluctuations (e.g., in
caribou migration routes and timing; runoff and water quality); and, (2)
some potential environmental impacts associated with project operations were
difficult to accurately predict in advance and can only be understood after
actual experience.
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Vegetation and Wetlands
Dust from gravel roads can be detrimental to nearby vegetation. Road cor-
ridor vegetation would be examined at five-year intervals to ascertain if dust
generation from the road were excessive and/or damaging vegetation commun-
ities.
Terrestrial Wildlife
It is not possible to predict the influence of the road corridor and associated
activity on caribou movements and timing. Before and during the first few
years of project operation, caribou movements would be monitored to deter-
mine both a baseline and then the extent of avoidance and alteration of
traditional movement patterns due to road activities.
Groundwater Resources
Seepage through the dam foundation might occur if the foundation thawed.
Seepage rates and water quality measurements would be made annually at
mid-summer to determine seepage trends with time.
Freshwater Resources
Hydrology and Water Quality
DEC and NPDES permit requirements specify a water quality monitoring pro-
gram at the confluence of Red Dog and Ikalukrok Creeks. This monitoring
program would include a flow-through biomonitoring facility that would con-
tinuously test the discharge water's toxicity to cold water fish species.
Sedimentation ponds at the ore zone diversion ditch sump, the tailings dam
seepage collection facility and the port site would be checked on an annual
basis and excess sediment accumulations removed. An ongoing maintenance
program along the road corridor and access roads would check for: (1)
excess icings in stream crossing structures; (2) excess bank erosion or
scour at stream crossings; (3) excess icings along the road embankments
showing evidence of interference with cross-drainage; (4) excess settlement
and erosion of fine soil ice-rich subgrades; and (5) excess erosion or slump-
ing of cuts, ditches and culvert outfalls. Potential problems should be cor-
rected before environmental impacts to water quality or fish passage could
occur.
Physical and Chemical Oceanography
Predictions in this document on nearshore sediment transport would be
checked after several years of operations. Qualitative assessments would be
made of the extent of sediment scour and deposition near the dock, and
ballasted ship (if selected).
Marine Water Quality
In order to determine any cumulative influence of small spills on the marine
environment, bottom sediment sampling would be done at five-year intervals.
Transects parallel to the beach near the dock and offshore would collect
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bottom samples and analyze for concentrations of zinc, lead, cadmium and
petroleum hydrocarbons.
Air Quality
Records would be kept of typical plume behavior for the power generator
and driers to avoid any possibility of air quality degradation at the worker
accommodations. A notice would be posted at the accommodations for
workers to report any episodes of objectional odors and gases reaching the
area from the mill. Permits would require periodic monitoring of emissions
from the mill operations.
Cultural Resources
The Cultural Resources Management Program would be periodically checked to
verify compliance with the ACHP commenting procedures developed in con-
sultation with SHPO and the federal agencies permitting the project.
Subsistence
Monitoring of project influence on subsistence hunting would be in response
to NANA concerns as raised by the Red Dog Project Subsistence Committee
presently organized to identify and minimize potential subsistence problems.
Socioeconomics
Continued coordination with NANA and local community officials in Kotzebue
and the villages would identify project related social, cultural and economic
problems as they might develop.
Recreation
Monitoring of potential problems associated with increased recreation would
be in response to NANA and National Park Service concerns.
RECLAMATION PLAN
Under existing law there are no specific requirements for reclamation other
than those desired by the landowner. This section presents a summary of a
conceptual plan developed by Cominco Alaska for NANA for the protection
and reclamation of land and water resources potentially affected by various
components of the Red Dog project. The conceptual Reclamation Plan may be
found in Appendix 1.
Open Pit Mine
The area of land disturbed by the open pit mine and access roads would
ultimately reach approximately 134 ha (330 ac). Soils in this area are shal-
low, stony and contain toxic levels of zinc, lead, copper and iron. There
appears to be little potential for stockpiling soil for later use. Reclamation
of the open pit would have unusual problems due to the proximity of the ore
body to Red Dog Creek and the steep, rocky sides of the pit. Backfilling
the pit, resloping pit walls to natural contours and restoring the original
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course of Red Dog Creek would probably not be practical under existing
Arctic conditions. Upon completion of mining, Red Dog Creek would be
diverted back into the pit, creating a lake with a water level at the 274 m
(900 ft) elevation. The surface area of the lake would be approximately 40
ha (100 ac) with maximum depths to approximately 122 m (400 ft).
Water quality of the lake would be dependent on the extent of contact with
residual ore materials. The volume of the lake would be approximately five
times the annual mean inflow of Red Dog Creek at this point. This means
that the water quality of the lake discharge would show lower seasonal fluc-
tuations compared to pre-mining conditions. Because of the existing de-
graded water quality of Red Dog Creek, mean water quality of the lake dis-
charge might substantially improve over present natural conditions. All of
the ore with high concentrations of lead and zinc would be removed, leaving
only low grade material in contact with the lake water. The depth of the
lake would restrict oxygen contact with remaining mineralized rock, reducing
dissolution and release of toxic metals. The lake surface would be frozen
over from October through May, further restricting circulation of oxygen-
rich water to mineralized areas. In summer the lake would stratify with
warmer water overlying cold water, which would also restrict lake circula-
tion. As a result, a substantial improvement in the water quality of Red
Dog Creek might be expected.
Overburden Storage
Mineralized and unmineralized overburden rock not suitable for mill process-
ing would be stockpiled on the east side of the tailings pond. The surface
area of this storage site would be approximately 101 ha (250 ac). Vegetation
types present in the area include dwarf shrub tundra and low shrub tundra.
Underlying a shallow organic layer is approximately 1 m (3.3 ft) of annually
thawed silty soil material. This material would be removed where necessary.
Overburden storage areas would be constructed by dumping and spreading
methods designed to increase overburden stability, accelerate freezing of the
overburden and prevent leaching. To restrict significant leaching of toxic
materials, the surface of the sites would be compacted and covered with a
frozen layer or other impervious material to prevent infiltration of rain or
snowmelt. Overburden storage areas would be recontoured as required to
achieve permanent slope stability and facilitate revegetation and restoration
to natural appearance. Soil cover and vegetation would be placed over the
impervious surface layer of the dumps. Particular care would be taken to
control runoff from waste piles of oxidized overburden and low grade miner-
alized ore. If it proved infeasible to completely restrict runoff from miner-
alized overburden piles, they would be moved to the tailings pond and
placed in a layer over the tailings.
Tailings Pond
The area of land disturbance associated with the tailings pond would be
approximately 237 ha (585 ac). The reclamation plan for this project com-
ponent would include removal and stockpiling of surface organic materials
and soils for future use if feasible under Arctic climatic constraints. The
pond would impact an area currently covered with dwarf and low shrub
tundra and sedge-grass tundra along the streams. Soils of the drier tundra
areas are similar to those described in the waste dump area. The wetter
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bottom samples and analyze for concentrations of zinc, lead, cadmium and
petroleum hydrocarbons.
Air Quality
Records would be kept of typical plume behavior for the power generator
and driers to avoid any possibility of air quality degradation at the worker
accommodations. A notice would be posted at the accommodations for
workers to report any episodes of objectional odors and gases reaching the
area from the mill. Permits would require periodic monitoring of emissions
from the mill operations.
Cultural Resources
The Cultural Resources Management Program would be periodically checked to
verify compliance with the ACHP commenting procedures developed in con-
sultation with SHPO and the federal agencies permitting the project.
Subsistence
Monitoring of project influence on subsistence hunting would be in response
to NANA concerns as raised by the Red Dog Project Subsistence Committee
presently organized to identify and minimize potential subsistence problems.
Socioeconomics
Continued coordination with NANA and local community officials in Kotzebue
and the villages would identify project related social, cultural and economic
problems as they might develop.
Recreation
Monitoring of potential problems associated with increased recreation would
be in response to NANA and National Park Service concerns.
RECLAMATION PLAN
Under existing law there are no specific requirements for reclamation other
than those desired by the landowner. This section presents a summary of a
conceptual plan developed by Cominco Alaska for NANA for the protection
and reclamation of land and water resources potentially affected by various
components of the Red Dog project. The conceptual Reclamation Plan may be
found in Appendix 1.
Open Pit Mine
The area of land disturbed by the open pit mine and access roads would
ultimately reach approximately 134 ha (330 ac). Soils in this area are shal-
low, stony and contain toxic levels of zinc, lead, copper and iron. There
appears to be little potential for stockpiling soil for later use. Reclamation
of the open pit would have unusual problems due to the proximity of the ore
body to Red Dog Creek and the steep, rocky sides of the pit. Backfilling
the pit, resloping pit walls to natural contours and restoring the original
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course of Red Dog Creek would probably not be practical under existing
Arctic conditions. Upon completion of mining, Red Dog Creek would be
diverted back into the pit, creating a lake with a water level at the 274 m
(900 ft) elevation. The surface area of the lake would be approximately 40
ha (100 ac) with maximum depths to approximately 122 m (400 ft).
Water quality of the lake would be dependent on the extent of contact with
residual ore materials. The volume of the lake would be approximately five
times the annual mean inflow of Red Dog Creek at this point. This means
that the water quality of the lake discharge would show lower seasonal fluc-
tuations compared to pre-mining conditions. Because of the existing de-
graded water quality of Red Dog Creek, mean water quality of the lake dis-
charge might substantially improve over present natural conditions. All of
the ore with high concentrations of lead and zinc would be removed, leaving
only low grade material in contact with the lake water. The depth of the
lake would restrict oxygen contact with remaining mineralized rock, reducing
dissolution and release of toxic metals. The lake surface would be frozen
over from October through May, further restricting circulation of oxygen-
rich water to mineralized areas. In summer the lake would stratify with
warmer water overlying cold water, which would also restrict lake circula-
tion. As a result, a substantial improvement in the water quality of Red
Dog Creek might be expected.
Overburden Storage
Mineralized and unmineralized overburden rock not suitable for mill process-
ing would be stockpiled on the east side of the tailings pond. The surface
area of this storage site would be approximately 101 ha (250 ac). Vegetation
types present in the area include dwarf shrub tundra and low shrub tundra.
Underlying a shallow organic layer is approximately 1 m (3.3 ft) of annually
thawed silty soil material. This material would be removed where necessary.
Overburden storage areas would be constructed by dumping and spreading
methods designed to increase overburden stability, accelerate freezing of the
overburden and prevent leaching. To restrict significant leaching of toxic
materials, the surface of the sites would be compacted and covered with a
frozen layer or other impervious material to prevent infiltration of rain or
snowmelt. Overburden storage areas would be recontoured as required to
achieve permanent slope stability and facilitate revegetation and restoration
to natural appearance. Soil cover and vegetation would be placed over the
impervious surface layer of the dumps. Particular care would be taken to
control runoff from waste piles of oxidized overburden and low grade miner-
alized ore. If it proved infeasible to completely restrict runoff from miner-
alized overburden piles, they would be moved to the tailings pond and
placed in a layer over the tailings.
Tailings Pond
The area of land disturbance associated with the tailings pond would be
approximately 237 ha (585 ac). The reclamation plan for this project com-
ponent would include removal and stockpiling of surface organic materials
and soils for future use if feasible under Arctic climatic constraints. The
pond would impact an area currently covered with dwarf and low shrub
tundra and sedge-grass tundra along the streams. Soils of the drier tundra
areas are similar to those described in the waste dump area. The wetter
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sedge-grass tundra soils are organic with an active depth of approximately
0.6 m (2 ft). When mining operations ceased, free standing water in the
tailings pond would be treated and discharged to Red Dog Creek. After the
then-exposed tailings froze, lined channels for runoff would be constructed
across the tailings to stabilized spillways in the dam. Coolant pipes might
be installed in order to enhance freezing of the tailings to permit access of
equipment.
The surface of the pond area would be restored to an appearance resembling
that of the surrounding terrain. Application of lime might be required to
neutralize the potential acid generating surface of the tailings. The depth
of material spread over the tailings to support vegetation would be sufficient
to prevent thawing of the tailings when the active layer reached maximum
depth of 0.5 to 1.0 m (1.6 to 3.3 ft) in late summer. If feasible under
Arctic climatic constraints, stockpiled surface and organic material would be
used. Revegetation, reseeding, mulching, fertilizing and irrigation would be
done as needed to restore a tundra-like appearance to the reclaimed pond.
Mill Site, Worker Housing, Airstrip and Access Roads
The area of land disturbance associated with these facilities would be
approximately 38 ha (95 ac) of sedge-grass tundra, dwarf shrub tundra and
open low shrubland. At completion of the operating life of the mine, the
facilities would be removed and the sites rehabilitated. All equipment, build-
ings and other surface structures would be dismantled and removed from the
site. Where remaining concrete foundations would be significant obstacles to
regrading, they would be removed to ground level. The airstrip, service
areas and access roads would be scarified to relieve compaction, and recon-
toured, if necessary, to restore natural drainage. Culverts and bridges
would be removed and open drainage channels would be restored. Water
bars would be constructed to control erosion. Suitable vegetation would be
established on disturbed sites by applying revegetation techniques developed
during the operating life of the project.
Sons Creek Water Supply Reservoir
The area of land disturbance associated with the reservoir would be approx-
imately 31 ha (76 ac) of dwarf shrub tundra. Reclamation of the water
reservoir would involve either breaching the dam structure, or allowing the
lake to remain with a permanent spillway. An evaluation of regulatory
agency desires at the time of mine closure would be required to determine
the most satisfactory action for reclamation.
Transportation Corridors
The area of land disturbance associated with the southern corridor would be
about 197 ha (487 ac). The area disturbed along the northern corridor
would be about 257 ha (634 ac). It is possible that the road corridor would
be used for other regional purposes beyond the operating life of the mine,
and reclamation would not be required. If reclamation were required, all
bridges and stream crossing structures would be removed and drainage
courses restored. The road surface would be scarified to relieve compaction
and, where necessary, recontoured to restore a natural appearance. Water
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bars would be constructed to control erosion. Native plant species would be
established on disturbed areas using revegetation techniques developed
during the operation period of the project.
Borrow pits would be reclaimed when no longer needed for maintenance pur-
poses. Where practical, slopes would be recontoured to an appearance com-
patible with the surrounding terrain and revegetated using appropriate
Arctic techniques. The side slopes of rock quarries would be made to
resemble surrounding rock outcrops. Depressions resulting from gravel and
rock extraction would be allowed to fill with water to form ponds or lakes.
Port Site
The area of land disturbance associated with the port site would be approx-
imately 20 ha (50 ac). It is possible that the port site would be used for
other regional purposes beyond the operating life of the mine and reclamation
would not be required. In the event the facility were abandoned, all build-
ings, equipment and other surface structures would be dismantled and re-
moved from the site. Concrete foundations would be removed, if necessary,
to allow site recontouring. Crushed rock pads would be scarified to relieve
compaction and perimeter slopes would be recontoured. Shoreline features
would be restored following removal of the dock. Natural shore transport
processes would restore the original beach slopes and profiles within a few
years. Native plants would be established on disturbed areas. The bal-
lasted ship transfer facility would be refloated and removed.
Reclamation Research
During the operating period of the project, revegetation techniques would be
assessed and refined on sites representative of the major kinds of land dis-
turbance. Techniques investigated would depend on the nature and severity
of factors identified as limiting to plant growth on the various waste mate-
rials. Development of practical methods for conserving surficial soil and
organic material for use in reclamation of waste rock, tailings and borrow
pits might also be necessary.
OTHER PROJECT IMPACTS
The Red Dog project as a whole would have impacts irrespective of which
specific alternative were ultimately implemented. Several of these are dis-
cussed below.
Regional Impacts
The NAN A region, together with the western quarter of the North Slope
Borough and the federal outer continental shelf off the western Arctic coast,
is thought to be endowed with substantial energy and other mineral re-
sources. Development of the Red Dog mine would be the most advanced
effort to date to develop a major resource deposit in the region. The other
natural resources of outstanding interest in the larger region are oil and
gas, hardrock minerals and coal. The presence of some of these other re-
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sources is well established and some are as yet of only speculative interest.
In every case, their feasible development for export awaits either better
definition of resource values through further exploration, more favorable
commodity market conditions or provision of transportation and other devel-
opment infrastructure.
While development of these other economic resources is not imminent, it is
possible that their future development feasibility might depend on shared use
of transportation sites, corridors or other infrastructure (particularly the
surface transportation route and port site) established for development of
the Red Dog mine. Since both the road and port site would be available to
other industrial resource users and support services, the most important
resource prospects are reviewed below.
Oil and Gas Resources
Alaska's western Arctic is generally suspected to possess substantial oil and
gas resources. The areas of highest interest are outside but close to the
project area. To date, there has been spotty, fruitless exploration for oil
and gas in the Kotzebue Sound upland perimeter, and north and east of the
study area. Now, within the next five years, a series of major federal and
state oil and gas lease sales are scheduled.
The federal Department of the Interior has two offshore lease sales pending
for the outer continental shelf waters of the Chukchi Sea north and west of
the project area. These are: the Barrow Arch Sale #85 (February 1985);
and the Barrow Arch Sale #109 (February 1987). The State of Alaska has
two lease sales scheduled for the region: the Hope Basin Sale #45 (Sep-
tember 1985) in the vicinity of Kotzebue Sound; and the Icy Cape Sale #53
(September 1987) north of the NAN A region. There are also some existing
leases and more proposed in the western quarter of National Petroleum
Reserve in Alaska. Finally, the NANA Regional Corporation and the Arctic
Slope Regional Corporation each have landholdings with petroleum potential in
northwestern Alaska. Both have sponsored limited exploration programs in
the northwestern Arctic, without commercial success to date.
It would certainly be premature at this stage to settle on whether, where or
in what volume oil or gas reserves might be discovered in the region. Still,
some general features for a feasible transportation system for oil export (at
present, natural gas finds do not appear likely to be commercially valuable)
would be fairly well fixed in advance by certain economic, technical, geo-
graphic and environmental conditions. Due to the remote, frontier status of
the region and its lack of transportation and other economic infrastructure,
the threshold for pioneer commercial discovery would be extremely high,
especially for the Chukchi Sea offshore province. A recent economic
analysis (Dames & Moore, 1982b) estimated that the minimum economic field
size would be about 1.5 billion barrels of recoverable oil. The minimum
economic size for an upland oil field would be smaller, but still must be large
enough to absorb the cost of an overland pipeline spur eastward to the
Trans Alaska Oil Pipeline or westward to a tidewater port, plus the cost of a
marine terminal if none existed.
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Assuming that offshore or upland commerical reserves would eventually be
discovered in the western Arctic, it would be most likely that the specific
configuration and siting of offshore, surface, pipeline or port facilities for
development and transport of crude oil would be dictated by considerations
as yet unknown and independent of the status of the Red Dog project.
First, geographic, technical, environmental and economic factors would
strongly favor a choice of overland and/or marine facilities specifically de-
signed for, and exclusively dedicated to, petroleum handling, without regard
for transport facilities installed for the Red Dog mine. Second, the crude
oil production threshold would be extremely high. It would entail a multi-
billion dollar capital investment in production and transportation facilities
that would dwarf the anticipated cost of the Red Dog project. For these
reasons, there would be a relatively low probability that future decisions
about petroleum facilities would be much influenced by the comparatively
modest capital investment committed to the Red Dog mine.
Hardrock Minerals
The Western Brooks Range/De Long Mountains area is a highly mineralized
region whose potential has not yet been fully explored. Apart from the Red
Dog mine, the two hardrock mineral deposits that have so far been most
seriously considered for large-scale commercial development are the copper-
zinc-silver deposits in the Ambler District, approximately 275 km (172 mi)
southeast of the Red Dog mine site, and GCO Minerals' Lik lead-zinc-silver
deposit 19 km (12 mi) northwest of the Red Dog mine site.
The 1981 Western and Arctic Alaska Transportation Study (WAATS) examined
10 transportation systems, involving combinations of six corridors and four
transport modes, for export of mineral production from the Ambler District.
The shortest route to tidewater was an overland corridor for a road, rail or
slurry pipeline system to the coast near Cape Krusenstern. This corridor
traversed parts of Kobuk National Monument, Noatak National Preserve and
Cape Krusenstern National Monument. Bear Creek Mining Company, a sub-
sidiary of Kennecott Copper Company and holder of substantial reserves in
the Ambler District, has stated its preference for this general route, ter-
minating at a port site in the vicinity of Tasaychek Lagoon in Cape Krusen-
stern National Monument, about 38 km (24 mi) south-southeast of VABM 28
(Bear Creek Mining Company, 1983). Since this route from the Ambler Dis-
trict and the proposed Red Dog southern corridor converge on the coast at a
right angle, a common overland corridor would not seem feasible. A common
port site would require a coastal link or a rerouting of the final leg of the
overland route from the Ambler District. Thus, apart from the potential for
a common port site, presently proposed transportation corridors for the
Ambler District do not seem likely to be affected by development of the Red
Dog project.
On the other hand, the Lik deposit is similar in mineral content and infra-
structure requirements to the Red Dog mine, as might be other deposits
discovered in the immediate vicinity of the Red Dog mine. The economic
feasibility and development plans for these as yet speculative prospects
might be affected by the development scheme for the Red Dog mine, espe-
cially by the location, design and capacity of common-use transportation
facilities, including the port site. For smaller mining operations, however,
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especially placer gold, construction of a road from the coast into the De
Long Mountains could be an important stimulus.
Coal
The State's Division of Geological and Geophysical Survey (DGGS) estimates
that the western Brooks Range north and east of the Red Dog project area
holds Alaska's most massive coal deposits, perhaps a trillion tons of recover-
able coal. However, the costs of surmounting the obstacles to production
and transportation of these deposits under Arctic conditions place these
deposits at a serious competitive disadvantage with other sources of supply.
Therefore, development of these Arctic coal reserves does not appear likely
in the foreseeable future. As with oil and gas development, geographic,
technical, environmental and initial high capital investment factors associated
with coal development would largely dictate the choice of overland and/or
marine facilities specifically designed for coal production. There would be a
relatively low probability that future decisions about coal development would
be significantly influenced by the Red Dog project.
The Morgan Coal Company is in the initial stages of considering the devel-
opment of a coal field 32 km (20 mi) east of Point Lay (180 km [112 mi]
northeast of Cape Lisburne). The company has expressed some interest in
using the proposed Red Dog port site. BLM will begin an EIS process in
1984 to review the major project components and determine the preferred
option for coal shipment.
If construction of a road and port for the Red Dog project does promote
development of other industrial resource projects in the region, their incre-
mental impacts would raise the ultimate overall impacts from initial develop-
ment of Red Dog. Dust and noise pollution from increased use of the road,
and its extensions, could additionally impact vegetation, caribou and other
wildlife, and recreational users. Likewise, increased use of the port facil-
ities would likely result in additional vessel traffic with a higher possibility
of spills and effects on marine mammals. Other developments would impact
visual resources and wilderness values, and could cumulatively affect the
existing subsistence uses and historical lifestyles of local residents.
Since selection of the preferred alternative for this project has taken into
consideration the regional use perspective, and since the State has specif-
ically stated that there will be only one transportation corridor between the
De Long Mountains and the coast, overall regional impacts should be some-
what mitigated by prevention of a proliferation of other corridors and port
sites for future developments.
Increased General Public Access
Although the road right-of-way permit would limit use to industrial resource
users, there cannot be any guarantee that such a restriction would apply
indefinitely. Therefore, one of the most significant long-term impacts of
development of the Red Dog project could be its effect on "opening up" the
De Long Mountains region of northwest Alaska to people by construction of a
regional port and surface transportation system. This could take the form
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of increased access from outside the area as well as increased ease of access
for moving around within the area.
While the ability of people from outside the area to initially access the port
and road systems would be limited, in time other projects (e.g., new mines
in the De Long Mountains or further energy developments on the North
Slope) would increase the ease of access and use of these systems. If the
port facility and road were ever opened for use by the general public, they
would be increasingly used by hunters, fishermen, hikers, birdwatchers,
sightseers, etc. The mere presence of these additional people could ulti-
mately have substantial impacts on several resources. In particular, wildlife
and fish populations would be affected by increased harvests, requiring
additional financial commitments and management efforts by the Departments
of Fish and Game and Public Safety. ADF&G in particular would need to
substantially increase resource assessment and monitoring efforts to minimize
impacts of project development on fish and wildlife. Additional management
efforts would likely be required to identify and close areas to (or limit)
hunting, trapping and fishing in the vicinity of Red Dog Valley, the trans-
portation corridor and the port site. Disturbance of caribou could have
regional impacts if it caused a shift in traditional wintering areas or migra-
tion routes.
The archeological sites in the area might be affected by unauthorized collec-
tion of artifacts from sites within walking or off-road vehicle distance of the
transportation facilities. Traditional subsistence activities could be affected
either by direct competition with, or disturbance during, subsistence har-
vests. The impacts upon the fish and wildlife resource base discussed above
could also affect subsistence harvests.
Additional access by off-road vehicles (ORVs) could have severe impacts
upon vegetation in heavily traveled areas, especially at shallow fords at
stream crossings. Such use might cause erosion which could cause increased
siltation in the area's streams. Depending upon the severity, this might
impact fish spawning and ultimately the subsistence use of that resource. If
the southern corridor road along the less vegetated Mulgrave Hills was
chosen, ORV trails might cause substantial erosion at those altitudes.
Harassment of wildlife could also become a problem, particularly during the
winter. Even though only industrial resource users would be permitted to
use the road initially, ORV use would be very difficult to control. Past
history shows that regulation of ORVs by land managing agencies has been
largely ineffective. The degree to which ORVs might impact the Monument
would depend upon how successfully the NPS could regulate their use.
Just the development of the project itself would have a significant impact on
the wilderness values of the area. While not specifically recognized by re-
cent federal or state actions as being of wilderness quality, the area is
undeveloped land and project development would irrevocably change that.
The increase in the number of people using the area due to the easier access
would certainly put some additional developmental pressures on the area.
Increased access to Cape Krusenstern National Monument by recreational
users would also detract from the wilderness experience of all users.
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Increased ease of access within the area could also have substantial impacts
on resources and how they are used, including subsistence. In particular,
establishment of a road could intensify local subsistence use of fish and
wildlife resources along the transportation system. The prohibition of hunt-
ing and fishing by workers during their active work phase would signifi-
cantly reduce the impacts. If, however, such restrictions were not applied,
the continuous presence of the camp workforce might result in off-hour
casual recreational activity concentrated near the mine and along the road
corridor. The northern road corridor would give camp occupants ready
access to upriver fish populations not previously harvested. Both routes
would allow access to caribou and other species on their winter ranges. The
ultimate impact of the mine workforce upon the subsistence resource base
would thus depend heavily on the restrictions placed on firearms and recrea-
tional use of camp vehicles, and on recreational fishing, hunting and trap-
ping by mineworkers.
If the roadway became a convenient and popular overland transportation
route for resident subsistence hunters, it might tend to extend the range
and redistribute the subsistence harvest effort. It is hard to foresee
whether such an adaptation would, over the long run, have a positive,
negative or neutral effect on the resource base. Possibly, it would merely
amount to a more efficient use of subsistence effort over a larger range.
Thus, while careful design, construction and operation of the project might
be able to limit impacts upon fish, wildlife, vegetation, archeological and
other resources, the improved ease of access both into and within the area
for the public, which would be very difficult to restrict, would have definite
and perhaps substantial long-term effects.
Cape Krusenstern National Monument Impacts
The purposes for which Cape Krusenstern National Monument was created are
listed in Chapter IV. The various environmental impacts which would affect
the Monument would be largely the same as those for other portions of the
project area. These impacts have been described earlier in this chapter.
However, because a portion of the southern road corridor in Alternatives 1
and 3 would cross the Monument, and because of Title XI requirements if
the southern corridor were selected, a brief summary of the environmental
impacts on the Monument is presented below. More detailed descriptions of
these impacts may be found earlier in this chapter under the specific dis-
cipline headings.
Vegetation and Wetlands
The southern road corridor would cross approximately 38 km (24 mi) of the
Monument. Approximately 77 ha (190 ac) of vegetation would be destroyed
by actual road construction. Generally, more productive wetlands, e.g.,
waterfowl habitat, would be avoided by this road corridor. Road dust could
have effects on vegetation to a distance of approximately 300 m (984 ft) from
the road. A vegetation survey after five years of operation would determine
these impacts and could recommend additional dust control measures, if
necessary.
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Terrestrial Wildlife
Other than the insignificant local loss of habitat from construction of the
road itself, the major terrestrial wildlife concern would be indirect habitat
loss from disturbance and possible interference with caribou movements. A
program during initial years of project operation to monitor caribou move-
ments as a basis for implementing NANA's authority to close operation of the
road during major caribou movements would mitigate this concern substan-
tially.
Freshwater Resources
Within the Monument, the southern road corridor would have only one major
bridge crossing the Omikviorok River, and 20 minor bridge or culvert cross-
ings. The road construction and maintenance guidelines as described earlier
in this chapter would largely protect against water quality degradation due
to sediment.
As described earlier, the most serious potential impact to water quality would
be due to spills of oil, concentrates or toxic chemicals. Use of spillage con-
trol plans (draft SPCC Plan outlined in Appendix 2) and rapid response to
spills would significantly reduce the probability that a spill would reach a
water course via surface or groundwater paths.
The protection of freshwater quality would also serve to protect the inver-
tebrate and fish species and habitats in those streams.
Air Quality
Vehicle traffic on the road would be the only source of air pollutant emis-
sions within the Monument. Pollutant concentrations from these vehicle emis-
sions would not reach significant levels even under the worst atmospheric
dispersal conditions since the number of vehicles using the road per day
would be so low.
Visual Resources
The degree of visual impact of the road, port site and transfer facility would
be dependent on the attitude of the viewers. While present visitor use to
this portion of the Monument is very low, the road, port site and the trans-
fer facility would be obvious to viewers from most parts of the western por-
tion of the Monument. Using the USFS VRM system in combination with NPS
visual standards, the layout and colors of the port facility would be designed
to mitigate much of the visual impact. If the offshore island transfer facility
were selected, the visual impact of the large ballasted tanker would be high,
but not significant considering the purposes for which the Monument was
established. Dust plumes from road traffic could prove to be the most
visible manifestation of the road. Proper use of dust suppressants could
substantially reduce that impact.
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Sound
Sound produced by trucks using the road within the Monument would nor-
mally be discernible to the human ear up to five miles from the road. Hel-
icopters and light aircraft following the road corridor, while considerably
less frequent in number, would generate sound to greater distances. In
addition to the impacts of these noises on recreational users within the
Monument, they would likely cause some avoidance of the corridor by cari-
bou, bears and muskoxen.
Cultural Resources
There are six archeological sites in the Monument that would be within
1.6 km (1 mi) of the southern corridor road. As presently aligned, the
road would not directly impact any of these sites. Potential indirect impacts
would be mitigated by protective measures approved by the ACHP. Provi-
sions would be made for emergency recovery operations under ACHP guide-
lines at sites discovered during construction. Intensive preconstruction
surveys would make the likelihood of such site discovery during construction
unlikely. If these measures were adhered to, there would not be significant
impacts.
Subsistence
The presence of the road would likely have a mixed impact upon traditional
subsistence use in that portion of the Monument. Road disturbance noted
above would likely cause some displacement of large mammals and could, at
the extreme, affect major caribou movements that traditionally cross the cor-
ridor. While initially the road would not be used to any significant extent
by persons from outside the region, use of the road by people from outside
the area would eventually increase. If this increased ease of access caused
substantial numbers of hunters and fishermen to use the area, competition
for subsistence resources could occur.
The increased ease of movement within the area, however, might serve to
increase success of subsistence users by providing easier and quicker access
to subsistence resources.
Recreation
The road and port site would also likely have a mixed impact upon recrea-
tional use. If the general public was ever permitted use of the road, easier
access would increase the use by photographers, birdwatchers, hikers, etc.
However, visitors to the Monument desiring a more primitive or wilderness
experience would tend to avoid that area of the Monument.
The de facto wilderness nature of the project area would be permanently
altered, with the loss of wilderness characteristics such as solitude and the
opportunity for primitive types of recreational experiences. Also, since the
Secretary of the Interior is required by Section 1317 of ANILCA to conduct a
wilderness suitability study of Cape Krusenstern National Monument by
December 1985, issuance of a right-of-way permit might preclude a signifi-
cant portion of the Monument from being included in that study.
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Coastal Geologic Processes
While no project related facility actually within the Monument would affect the
transport of sediments, the possibility of development of a port facility has
raised questions concerning potential impact upon the historic beach ridges
at Cape Krusenstern. As discussed in greater detail earlier in this chapter,
the location of a port site at VABM 28 with a short causeway and ballasted
tanker would have only a relatively minor and local effect on sediment trans-
port, and no significant effect on the Cape Krusenstern beach ridges.
Cumulative Impacts
Cumulative impacts are those which, when viewed individually, might not be
significant, but which when viewed cumulatively could have significant im-
pacts. In a project such as this, which would represent the first major
development in an area, cumulative impacts would be very few by definition.
Impacts which might qualify as cumulative in another area would be the first
impacts within the Red Dog project area. They would therefore need to be
taken into consideration during future development proposals within the
region. Still, some cumulative impacts would exist.
Development of the Red Dog project, with its economic benefits including the
additional people who would come into the region, would put additional pres-
sures on existing social institutions and cultural traditions. While measures
would be taken to minimize the impact on existing social and cultural pat-
terns, particularly at the village level, the increased activity caused by
project development would incrementally move the region toward a more
"developed" status. While not necessarily negative, it would represent a
cumulative impact to an ongoing process.
The construction of a road would ultimately make human access considerably
easier to this presently isolated area. Easier access would likely result in
increased use of the area by persons from outside the region for many pur-
poses. This would likely have a cumulative impact on the subsistence use
and lifestyles of the current residents within the project area.
Also, the development of a port facility on the coast with associated in-
creased vessel traffic could cause a measure of disturbance to migrating
endangered whale species. This facility, when considered with the proposed
port facility at Nome, the possibility of an DCS supply base on St. Matthew
Island, and the existing oil and gas activity in the Beaufort Sea, must be
considered a cumulative impact.
While not recognized by recent federal or state actions for its wilderness
quality, the area is undeveloped. Increased use of airplanes, off-road
vehicles, and the exploration camps such as those which presently exist
in the Red Dog Valley have all cumulatively impacted the wilderness char-
acter of the area to date. Full development of the Red Dog project with its
road corridor and port site would significantly increase the cumulative im-
pacts upon the wilderness character of the area.
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UNAVOIDABLE ADVERSE IMPACTS
With one possible exception, there have been no significant adverse impacts
identified by this EIS that could not be markedly reduced to minimal levels
of impact by proper selection of alternatives and application of mitigation
measures in the design, construction and operation of the project.
It is possible that there could be an unavoidable adverse impact upon the
major caribou migration movements within the region, although this would be
unlikely strictly from implementation of the Red Dog Project alone. The
unpredictability of movements of this species, and the great historical
changes in home range and migration of this species which have been
recorded without apparent cause, make it impossible to predict the specific
impact of this project. However, while construction and operation of a port
and road by this project alone would likely not cause major interruptions to
caribou movements, it would open a corridor to increased future traffic that
might cumulatively cause such interruptions. Selection of the preferred
alternative (Alternative 1) would avoid to a large extent the current primary
winter habitat of caribou in the project area. Development of an appropriate
monitoring program to identify and track major caribou movements, when
used in conjunction with NANA's intention and authority to restrict or close
operation of the road to Red Dog project activity during major movements,
would probably prevent such a significant adverse impact.
SHORT-TERM USES VERSUS LONG-TERM PRODUCTIVITY
In this section the short-term uses of resources are related to the long-term
effects of the project on productivity of those same resources. The purpose
is to weigh the project's net benefits to residents of the project area, the
region, and society as a whole. In general, short-term uses would be those
which would occur during the lifetime of the project. Long-term productiv-
ity would generally refer to the time beyond the life of the project.
Estimated ore reserves of the Red Dog project area, if developed at antici-
pated rates, would last at least 40 years. There is a reasonable probability
that additional reserves will be identified in the future which could signifi-
cantly prolong th-e life of the project.
Many of the impacts discussed earlier in this chapter would be considered
short-term, with many of the greatest impacts occurring during the initial
construction and early operational phases of the project. If these impacts
were properly mitigated, as also discussed, their impacts on productivity
would be short-term.
Use and operation of the project facilities, particularly the road, would cause
disturbance to fish and wildlife. In the long-term, depending upon the
magnitude of such a disturbance, behavior and movement patterns could be
significantly affected. In particular, the major seasonal caribou migrations
could be interrupted, causing a major shift in location of portions of the
western Arctic caribou herd. This could have a very definite long-term
subsistence impact on residents of the region.
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In addition to possible direct long-term impacts upon subsistence, the short-
term benefits of project employment might have long-term indirect impacts
upon traditional subsistence lifestyles. Increasing dependence upon the cash
economy caused by project employment could lead to a lessening of participa-
tion in the subsistence lifestyle. While this would not necessarily be bad, at
completion of the project villages and families might have become so depen-
dent upon the cash economy that they would be unable to fully readapt to
the subsistence lifestyle as an integral part of their existence if other types
of employment were not available.
In a similar manner, the increase in economic activity, influx of new resi-
dents from outside the region, and other pressures associated with increased
human populations in the short-term could have a significant impact upon
existing regional social and cultural traditions and values.
In other ways, long-term productivity might be increased. The development
of the project-related transportation system could lead to a long-term in-
crease in natural resource productivity in the western Brooks Range (e.g.,
hard rock minerals, coal, oil and gas). An overall improvement in marine
and aircraft transportation systems, with related increases in economic bene-
fits and the efficiencies of distribution, could also accrue to the region.
If archeological and other cultural sites were properly mitigated during pro-
ject development and operation, long-term knowledge of the region's earlier
inhabitants would be enhanced. An adverse impact could occur, however, in
the unlikely event that subsurface archeological desposits undetected in pre-
construction surveys were encountered during construction. An emergency
salvage plan designed for this contingency would be in place to mitigate such
impact.
Also, there would be the possibility that removal of the Red Dog ore body,
in conjunction with proper wastewater management and treatment measures,
could significantly improve the water quality and therefore long-term
productivity of Red Dog Creek itself.
IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES
A decision to permit the Red Dog mining project, and its subsequent con-
struction and operation, would irreversibly and irretrievably commit several
resources.
At least 85 million tons of ore, and perhaps more, would be removed and
consumed. A lake would be created at the mine site in the main stem of Red
Dog Creek, and the topographic features of the South Fork would be per-
manently altered by the creation and ultimate reclamation of the tailings
pond.
If traditional caribou movements were significantly changed, and their pres-
ent winter range in the project area abandoned, this could prove to be an
irreversible loss.
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If the southern transportation corridor location was chosen, the land status
of Cape Krusenstern National Monument would likely be permanently altered
by issuance of a right-of-way, or through a land exchange. In either
event, the undeveloped nature of the project area would be permanently
altered, with the loss of wilderness characteristics such as solitude and the
opportunity for primitive types of recreational experiences. Also, since
the Secretary of the Interior is required by Section 1317 of ANILCA to con-
duct a wilderness suitability study of Cape Krusenstern National Monument
by December 1985, either action might preclude a significant portion of the
Monument from being included in that study.
The extraction and processing of the ore would require a large commitment
of energy resources (diesel oil, gasoline) which would be irretrievably con-
sumed. Project development would require a significant input of capital both
for construction and operation. Dollars spent would be irreversible and,
depending upon the amount of risk involved and success of the project,
possibly irretrievable.
SECTION 810, SUMMARY EVALUATION AND FINDINGS
This section was prepared to comply with Section 810 of the Alaska National
Interest Lands Conservation Act of 1980 (ANILCA). It summarizes the
evaluation of potential restrictions to subsistence activities which could result
from the granting of a right-of-way permit pursuant to Title XI of ANILCA
across Cape Krusenstern National Monument.
Only the environmentally preferred alternative as identified in Chapter III
for construction of an access road to the Red Dog project has been analyzed
here. Further, the portion of the route which crosses the National Monu-
ment is the focus of this section. The entire evaluation of potential effects
upon subsistence activities is addressed in Chapters III and V of this Red
Dog project EIS with explanation of existing baseline conditions presented in
Chapter IV and in Braund & Associates (1983).
ANILCA (Public Law 96-487) provides in Section 810(a) that:
In determining whether to withdraw, reserve, lease, or otherwise
permit the use, occupancy, or disposition of public lands..., the
head of the Federal agency having primary jurisdiction over such
lands or his designee shall evaluate the effect of such use, occu-
pancy, or disposition on subsistence uses and needs, the availabil-
ity of other lands for the purposes sought to be achieved, and
other alternatives which would reduce or eliminate the use, occu-
pancy, or disposition of public lands needed for subsistence pur-
poses. No such withdrawal, reservation, lease, permit, or other
use, occupancy or disposition of such lands which would signifi-
cantly restrict subsistence uses shall be effected until the head of
such Federal agency -
(1) gives notice to the appropriate State agency and the appro-
priate local committees and regional councils established pur-
suant to section 805;
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(2) gives notice of, and holds, a hearing in the vicinity of the
area involved; and
(3) determines that (A) such a significant restriction of subsis-
tence uses is necessary, consistent with sound management
principles for the utilization of the public lands, (B) the pro-
posed activity will involve the minimal amount of public lands
necessary to accomplish the purposes of such use, occupancy,
or other disposition, and (C) reasonable steps will be taken
to minimize adverse impacts upon subsistence uses and
resources resulting from such actions.
ANILCA further mandates that if the federal action would significantly
restrict subsistence uses and if an EIS is prepared on the federal action
then the Section 810(a)(3) findings must appear in that EIS.
This section of the EIS represents a summary of the evaluation process
which has occurred among the applicant, the local residents and the federal
agencies.
Baseline data were collected in the summer of 1982 (Braund & Associates,
1983) to augment existing subsistence data. This information served as the
basis for the evaluation of potential impacts from the alternatives considered
for the project. The EIS process has served as the formal vehicle to
identify potential impacts to subsistence resources and to obtain public
input.
To keep residents of the villages of Noatak and Kivalina informed as to how
the project might be developed, a committee of local residents was formed to
review the development plans. This committee was given briefings on the
development alternatives and was asked by the co-lead agencies to validate
baseline data gathered in 1982.
The 810 Evaluation Process
ANILCA created new units and additions to existing units of the National
Park System in Alaska. Cape Krusenstern National Monument was estab-
lished by Section 201(3) as a new unit for the following purposes, among
others:
To protect and interpret a series of archeological sites depicting
every known cultural period in arctic Alaska; to provide for scien-
tific study of the process of human population of the area from the
Asian Continent; in cooperation with Native Alaskans, to preserve
and interpret evidence of prehistoric and historic Native cultures;
to protect habitat for seals and other marine mammals; to protect
habitat for and populations of, birds and other wildlife and fish
resources; and to protect the viability of subsistence resources.
Subsistence uses by local residents shall be permitted in the monu-
ment in accordance with the provisions of title VIII.
In addition, Title XI of ANILCA allowed for: "transportation and utility
systems in and across, and access into, conservation system units as long
as:
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(1) such systems would be compatible with the purpose for which
the unit was established; and
(2) there is no economically feasible and prudent alternative route
for the system (Section 1105).
The potential for significant restriction of subsistence uses must be evalu-
ated for the proposed action's effect upon "...subsistence uses and needs,
the availability of other lands for the purposes sought to be achieved and
other alternatives which would reduce or eliminate the use." Restriction of
subsistence uses would be significant if there were large reductions in the
abundance of harvestable resources, significant losses of habitat supporting
harvestable resources, major redistributions of those resources, substantial
interference with harvester access to active subsistence sites or a major
increase in non-resident hunting.
By asking the following series of questions relative to the area and the pro-
posed action, and analyzing the responses, an evaluation of significance was
possible.
0 Would the preferred alternative cause a significant reduction in the
population of wildlife, fish, or other resources upon which subsis-
tence harvesting depends; and/or would the preferred alternative
cause a redistribution in those harvestable resources by either
causing a decline in the population of wildlife or fish harvested for
subsistence or by altering the distribution of those harvestable
resources?
0 Would the preferred alternative cause a restriction of access to the
harvestable resources where harvesting historically has taken place?
0 Would the preferred alternative lead to increased competition for
subsistence resources?
Proposed Action on Federal Public Lands
For the Red Dog Mine project, a permit for a right-of-way through Cape
Krusenstern National r/Ionument is being sought. The National Park Service
is considering this right-of-way request under Title XI of ANILCA. The
application is for a 89.9 km (56.2 mi) road, 38.4 km (24.0 mi) of which
would traverse the northwest corner of Cape Krusenstern National Monument.
Figure 11-6 shows the southern corridor (Kruz route) preferred alternative.
Affected Environment
This section reviews the subsistence activity areas which are used by the
residents of Kivalina, Noatak and Kotzebue. Kivalina and Noatak are small
Eskimo villages with populations of approximately 260 and 273, respectively
(1982 estimates). Kotzebue is a town of approximately 2,470 and is the
trade and service center for the NANA region. Figure 1-1 shows the loca-
tion of each population center.
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Subsistence activities greatly add to the economic well being and nutrition of
most of the region's residents. The extent of its importance is indicated by
the findings of a 1978 survey of about one-third of the region's households.
Approximately 55 percent of all households estimated they obtained half or
more of their food supply by subsistence hunting, fishing and gathering
(Table IV-11). This survey found that subsistence dependence was wide-
spread throughout the region, but was much more pronounced in the out-
lying villages, including Kivalina and Noatak, than in Kotzebue. In a region
where imported foodstuffs are costly and cash income depressed, the eco-
nomic importance of the subsistence food supply is evident. Within this
general pattern of reliance on subsistence, there is a great deal of variation
from settlement to settlement, season to season, and year to year in sub-
sistence harvest patterns (Social Research Institute, 1982).
The region encompasses a great diversity of terrestrial, freshwater, marine
and wetland habitat types which support many valuable subsistence species.
Virtually the entire region and most of its nearshore marine waters fall
within the subsistence use area of one or more villages (Fig. IV-12).
Among the most important subsistence food resources are land mammals
(caribou, moose), fish (Arctic char, chum salmon, sheefish, whitefish,
tomcod, smelt), sea mammals (bearded, ringed and spotted seals; belukha
whales) and waterfowl. However, nearly all edible animal species are used
to add variety to the customary diet or in times of scarcity. Berries and
other wild plant foods are also extensively gathered for consumption.
The current subsistence use areas of Kivalina and Noatak residents that
overlap the project area were recently described and mapped by Braund &
Associates (1983). The two communities make common use of some subsis-
tence resource areas. However, a 1972 survey (Mauneluk Association, 1974)
of overall harvest patterns found distinctive differences in the subsistence
orientations of coastal Kivalina and inland Noatak residents (Table IV-12).
In general, Kivalina was most heavily dependent on sea mammal and fisheries
harvests, with land mammals seasonally important. Noatak residents were
mostly dependent on land mammals and fisheries; sea mammals were of rela-
tively minor importance.
The project area is part of the western Arctic caribou herd's range.
Changes in the herd's migration routes and winter range conditions greatly
influence hunting success.
Subsistence fishing is important to both Kivalina and Noatak residents
throughout the year. The fall run of Arctic char is especially important to
those communities, while the Noatak River chum salmon and char runs are
important to the villages of Noatak, Kivalina and Kotzebue. Kivalina marine
mammal hunters intensively search the nearshore areas off Kivalina and along
the coast north and south of Kivalina in season. Both Kivalina and Noatak
residents harvest waterfowl in coastal lagoons and wetlands.
Subsistence Uses and Needs Evaluation
The traditional cultural system in this region is based upon a subsistence
economy which is reflected in all aspects of the social fabric. The specific
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evaluation of physical changes in the subsistence resources is easier to
quantify than the potential modification in the subsistence lifestyle. This
evaluation considers the "opportunity" for subsistence activities to occur.
To determine the potential impact on existing subsistence activities, three
evaluation criteria were analyzed relative to existing subsistence resources
which could be impacted. The range of potential impacts which might occur
are described in Chapter V. The evaluation criteria were:
0 The potential to reduce important subsistence fish and wildlife popu-
lations by a) reductions in numbers, b) redistribution of subsistence
resources, or c) habitat losses;
0 What effect the action might have on subsistence fisherman or hunter
access;
0 The potential for the action to increase fisherman or hunter competi-
tion.
The subsistence resources which are utilized in the project area include
caribou, anadromous fish (specifically Arctic char), marine mammals, moose,
furbearers and waterfowl. The potential impacts on subsistence are reviewed
on pages V-72 through V-74. A summary of those impacts is presented
below.
Arctic Char
Potential to Reduce Populations
The major Arctic char resources that could be affected within the pro-
ject area exist in the Wulik and Kivalina Rivers. The southern corridor
would pass no closer than 10 km (6 mi) from the Wulik River, but
above Arctic char spawning areas (Fig. 11-6). Along the entire
southern corridor route five tributaries to the Wulik River would be
crossed well away from the main stem of the Wulik River. A total of
187 stream crossings would occur along this route. Eleven of the
streams crossed are fished in their lower portions. Assuming proper
stream crossing techniques were used, the road would not significantly
affect existing fish habitat, reduce populations or cause the redistri-
bution of fish in the Wulik or Kivalina Rivers. In addition, the
Omikviorok River, located within the National Monument, would be
crossed above Arctic char spawning areas. Chapter V does not predict
a significant loss of habitat, or redistribution or reduction in fish
populations. Mitigation proposed to ensure reduction of impacts
includes proper stream crossing location, proper crossing design,
sediment control during construction, and proper construction timing.
Restriction of Fishing Access
Development of the southern corridor would not restrict fishing access.
Present access to the Arctic char fishery is via river boat. The
development of the roadway would not reduce present access available
to subsistence fishermen in the Wulik, Kivalina or Omikviorok Rivers.
V - 101
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Increase in Fishing Competition
The NANA/Cominco agreement gives as one of its goals 100 percent
Native hire for the Red Dog project. The employees would come from
surrounding villages and would live in a hotel-type complex accommoda-
tion. Workers would be employed on a shift basis which would call for
them to return to the villages on a regular basis. No new town would
be developed as part of the Red Dog project. Chapter V states that
only limited population growth would occur, and this is not anticipated
to have a significant effect on fishing competition.
The route would be public in that it would be available for use by
other future resource developments in the region (but not by the gen-
eral public).
Caribou
Potential to Reduce Subsistence Wildlife Populations
Development of the entire southern road corridor would eliminate 201 ha
(497 ac) of caribou habitat. This direct loss of habitat would result in
an insignificant loss of caribou habitat within the project area.
Without proper management and precautions, indirect habitat loss would
likely be significant for caribou on a local basis, and could even be of
greater than local significance. The southern corridor passes between
current primary caribou low tussock tundra winter range in the Wulik
and Kivalina lowlands, and secondary winter range on the more wind-
swept slopes of the Mulgrave Hills to the southeast (Fig. IV-5). Road
activity would cause avoidance of the corridor, and hence displacement,
thereby limiting to some extent the use of otherwise available winter
habitat. There could also be some mortality due to vehicle collisions or
added stress from winter traffic. Chapter V states that, based upon
experience with other roads in Alaska and the Arctic in general, the
approximately 20 to 25 vehicle round trips per day (excluding main-
tenance) associated just with the Red Dog project would be unlikely to
cause a major shift in movement patterns.
To maximize the possibility that road construction and operation would
not affect the distribution of caribou, a specific monitoring plan would
be developed to track major movements and make project activity
suspension decisions. This plan would be established before actual
construction begins so adequate baseline data would be available.
Therefore, road construction and operation should not result in a
significant loss of habitat or result in a redistribution of the caribou
herd.
Effect on Hunter Access
Chapter V states that development of a road would not limit access to
subsistence activities.
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Increase in Hunter Competition
The impact for caribou would be essentially the same as for Arctic char
as described above.
Marine Mammals
Marine mammal hunting is generally confined to the winter and spring months
when the port would be ice-bound, so ship traffic from the port should not
significantly disrupt harvest activities. However, port construction and
year-round activities aboard the offshore transfer facility would likely dis-
place some marine mammals from the immediate area, resulting in a reduction
in size of the local marine mammal harvest area. Any mishaps such as epi-
sodic or chronic spillage of fuels or chemicals that could seriously damage
habitat quality might adversely affect marine mammal populations. However,
the net impact of ordinary port operations on marine mammal resource avail-
ability would not be significant. Pages V-55 to V-57 provide a more detailed
discussion of potential impacts.
Other Subsistence Resources
Chapter V reviews the potential effects to furbearers, moose and waterfowl.
The level of impact from development of the southern corridor is considered
insignificant. (See pages V-72 through V-74.)
Availability of Other Lands
The development of the Red Dog lead/zinc deposit is the impetus behind the
analysis of alternatives for developing an access road to remove the metal
concentrates. The location of the deposit determines the area which would
be considered for potential development. This document has reviewed and
evaluated all reasonable options to provide access to the mine. It has
identified the environmentally preferred alternative which has been the sub-
ject of this Section 810 compliance review. Pages III-8 through 111-51 review
how the preferred alternative was identified.
The only alternative identified which would use another corridor and port
site, Alternative 2, would have greater subsistence impacts than the pre-
ferred alternative. Pages V-73 and V-74 provide a more detailed discussion
of those potential impacts.
Alternatives Considered
Table III-9 identifies the options which were used to form the project alter-
natives. Figure III-3 identifies the alternatives considered for the Red Dog
project. Alternative 1 was selected by the co-lead agencies as the preferred
alternative and has been the subject of this Section 810 compliance review.
Consultation and Coordination
The following individuals and their respective agencies have been consulted
on this Section 810 Summary Evaluation. Their comments were noted and in
V - 103
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most cases incorporated into this section as part of the EIS consultation
process.
0 FWS - Robert Leedy
0 EPA - William Riley
0 ADF&G - Steve Behnke, Richard Stern
0 BLM - Laun Buoy
0 Corps - Joe Williamson
Findings
Based upon the above process and considering all the available information,
this evaluation could not forecast any reasonable foreseeable events that
would entail a significant restriction of subsistence use.
V - 104
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Chapter VI
Permit and Regulatory
Programs
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VI. SUMMARY OF PERMIT AND REGULATORY PROGRAMS
INTRODUCTION
One of the purposes of an Environmental Impact Statement process is to
address the environmental and other concerns of federal, state and local
agencies responsible for the various regulatory functions associated with
ultimate approval of a project. The EIS process recognizes the informational
needs of these agencies as they proceed through their permitting processes
and seeks to incorporate relevant information to assist those agencies in
their permitting decisions. The public hearings, which are an integral part
of the EIS process and cover all concerns pertinent to the project, also
serve as public participation forums for state and federal permitting proc-
esses.
The major federal, state and local permits, contracts and other approvals
required for development of the Red Dog project are described in Table
VI-1. How each of these is addressed in this EIS is briefly discussed
below. These descriptions are not detailed and are only meant to give the
reader a general idea of how the EIS process complements the various
individual permitting processes.
FEDERAL APPROVALS
NPDES Permit (EPA)
The EIS describes the existing water quality and quantity conditions in the
project area; the expected pollutants, concentrations, quality and locations
of wastewater treatment facilities and discharges; and the expected impacts
resulting from discharges. It identifies the type and location of the various
project components, and also describes the process by which they were
sited. The EIS discusses the need for monitoring of water quality during
operation of the project and generally describes the type of monitoring pro-
gram that might be used. It also discusses reclamation plans and the need
to ultimately discharge water in order to reclaim the tailings pond. A copy
of the proposed final NPDES Permit and public notice are included in
Appendix 4. A second NPDES Permit (separate from the major permit) is
required for the port facility. A draft copy of that permit is also included
in Appendix 4.
Department of the Army (Section 404 - dredged or fill material) Permit
Review (EPA)
The same information provided by the EIS which is needed by the Corps in
its Clean Water Act Section 404 permitting process (discussed below) is also
VI - 1
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Table VI-1
MAJOR FEDERAL, STATE AND LOCAL PERMITS, CONTRACTS OR OTHER APPROVALS
REQUIRED FOR PROJECT DEVELOPMENT
Regulated Activity
(Required Approval)
ro
Federal Authority
Waste discharge into a waterway
(National Pollutant Discharge
Elimination System [NPDES] Permit)
Discharge of dredged or fill mate-
rial into U.S. waters, including
wetlands (Review of Corps' Depart-
ment of Army Section 404 Permit)
Discharge of dredged or fill mate-
rial into U.S. waters, including
wetlands (Department of Army Permit)
Construction of structures or work
in or affecting navigable waters of
the U.S. (Department of Army
Permit)
Construction of transportation system
in and across conservation system
unit (Right-of-Way Permit for Trans-
portation System)
Construction of transportation system
in and across conservation system
unit (NPDES Permit and Department
or Army Permit, respectively)
Regulatory Agency
U. S. Environmental
Protection Agency
(EPA)
EPA
U. S. Army Corps of
Engineers (Corps)
Corps
Authority
U. S. National Park
Service (NPS)
EPA & Corps
Section 403, Federal Water
Pollution Control Act of 1972,
as amended in 1977 (Clean
Water Act) (33 USC 1251)
Section 404, Federal Water Pol-
lution Control Act of 1972, as
amended in 1977 (Clean Water
Act) (33 USC 1344)
Section 404, Federal Water Pollu-
tion Control Act of 1972, as
amended in 1977 (Clean Water
Act) (33 USC 1344)
Section 10, River and Harbor Act
of 1899 (33 USC 403)
Title XI, Alaska National Interest
Lands Conservation Act of 1980
(ANILCA) (16 USC 3161)
Title XI, Alaska National Interest
Lands Conservation Act of 1980
(ANILCA) (16 USC 3161)
Description
EPA must authorize any activity or wastewater
system which would discharge waste from one or
more points into a waterway.
EPA reviews Corps' Department of Army Section
404 Permit under its Section 404(b)(1) "Guidelines
for Specifications of Disposal Sites for Dredged or
Fill Material".
The Corps must authorize the discharge of
dredged or fill material into U. S. waters,
including wetlands. Includes siting of facilities,
roads, etc. Corps determines compliance with
the Section 404(b)(1) guidelines.
The Corps must authorize: the construction of
any' structure in or over navigable waters of the
U. S.; the excavation of material in such; or the
accomplishment of any other work affecting the
course, location, condition or capacity of such
waters.
NPS must .determine that a proposed transporta-
tion system would be compatible with the
purposes for which the conservation unit was
established, and that there is no economically
feasible and prudent alternative route for the
system.
EPA, Corps & NPS would concurrently issue their
respective permits for the transportation system.
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Table VI-1
(Continued)
MAJOR FEDERAL, STATE AND LOCAL PERMITS, CONTRACTS OR OTHER APPROVALS
REQUIRED FOR PROJECT DEVELOPMENT
Regulated Activity
(Required Approval)
Federal Authority (Continued)
Use, occupancy or disposition
of public lands having subsistence
uses (Subsistence Compliance
Findings)
— Development possibly affecting
( threatened or endangered terrestrial
plant or animal species (Section 7
CO Consultation)
Development possibly affecting
threatened or endangered marine
fish, reptile and mammal species
(Section 7 Consultation)
Development possibly affecting
historical or archeological sites
(Review and Comment)
Occupancy and modification of flood-
plains (Floodplain Management
Considerations )
Regulatory Agency
NPS
Authority
U. S. Fish & Wildlife
Service (FWS)
U. S. National Marine
Fisheries Service
(NMFS)
Advisory Council
on Historical Preserv-
ation (ACHP)
All federal agencies
Section 810, Alaska National
Interest Lands Conservation
Act of 1980 (ANILCA)
(16 USC 3120)
Section 7, Endangered Species
Act of 1973, as amended
(16 USC 1531)
Description
Section 7, Endangered Species
Act of 1973, as amended
(16 USC 1531)
National Historic Preservation
Act of 1966, as amended
(16 USC 470)
Executive Order 11988
(Floodplain Management)
May 24, 1977
NPS must determine if issuance of a Title XI
ROW would significantly restrict subsistence
uses. If it would, a finding must be made
that: such ROW is necessary and consistent
with sound management principles; it would
involve the minimal amount of lands neces-
sary; and reasonable steps would be taken to
minimize impacts on subsistence resources.
If threatened or endangered terrestrial or fresh-
water plant or animal species were determined to
be present in the project area, biological assess-
ments of potential impacts to those species would
be required. If impacts were anticipated, a for-
mal Section 7 consultation with FWS would be
required to determine conditions under which
the project should be permitted.
Same as above, except for marine fish, reptile
and mammal species, and consultation with NMFS.
ACHP must be given a reasonable opportunity to
review and comment on the adequacy of the man-
agement plan for historic or archeological sites
potentially impacted by any federally permitted or
licensed project.
All federal agencies must avoid, to the extent
possible, adverse impacts associated with occu-
pancy and modifications of floodplains, including
direct or indirect support of floodplain devel-
opment whenever there is a practicable alterna-
tive.
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Table VI-1
(Continued)
MAJOR FEDERAL, STATE AND LOCAL PERMITS, CONTRACTS OR OTHER APPROVALS
REQUIRED FOR PROJECT DEVELOPMENT
Regulated Activity
(Required Approval)
Federal Authority (Continued)
Destruction or modification of
wetlands (Wetlands Protection
Considerations)
State of Alaska Authority
New sources of air pollution
(Air Quality Permit to Operate)
(Prevention of Significant
Deterioration [PSD] Permit)
Discharge into navigable waters
(Certificate of Reasonable Assurance)
Regulatory Agency
All federal agencies
Authority
Department of Envi-
ronmental Conserva-
tion (DEC)
DEC
Wastewater discharge into all waters
of the state
(Wastewater Disposal Permit)
Solid waste disposal
(Solid Waste Disposal Permit)
Alteration of stream flow (Title 16,
Anadromous Fish Protection Permit)
Fish Passage (Title 16, Flshways for
Obstructions to Fish Passage Permit)
DEC
DEC
Department of Fish
and Game (ADF&G)
ADF&G
Executive Order 11990
(Protection of Wetlands)
May 24, 1977
Description
AS 46.03.140 to .170
Clean Air Act of 1963, as
amended (42 USC 1857)
Section 401, Federal Water
Pollution Control Act of 1972,
as amended in 1977 (Clean
Water Act) (33 USC 466)
AS 46.03.090 to .110
AS 46.03.720
AS 46.03.020
AS 46.03.100
AS 16.05.870
AS 16.05.840
All federal agencies must avoid, to the extent
possible, adverse impacts associated with
destruction and modification of wetlands, in-
cluding direct or indirect support of new con-
struction in wetlands wherever there is a
practicable alternative.
DEC must authorize plans and specifications for
construction that would be undertaken and must
assess emission standards and possible air con-
tamination resulting from that construction. As
of July 1983, the Prevention of Significant Deter-
ioration (PSD) Permit formerly granted by EPA
was incorporated under DEC'S authorization.
DEC must issue a certificate stating that the
proposed activity would comply with the require-
ments of the Federal Water Pollution Control Act.
Completion of all federal permits, including
NPDES, Section 404 and Section 10, would
depend upon DEC's granting of a Certificate of
Reasonable Assurance.
DEC must authorize the discharge of wastewater
into or upon all waters or land surface of the
state. Includes review and approval of treatment
facility plans. For projects requiring a federal
Section 402 (NPDES) Permit, DEC'S Certificate
of Reasonable Assurance serves as the Wastewater
Disposal Permit.
DEC must authorize plans, specifications and pro-
posed methods of operation for a facility to dis-
pose of solid waste.
ADF&G must approve methods and schedule of
any project which would alter the natural flow or
bed, or use equipment In specified anadromous
rivers, lakes, or streams.
ADF&G must certify that any stream obstruction
has a durable and efficient fishway and a device
for efficient passage of fish.
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Table VI-1
(Continued)
MAJOR FEDERAL, STATE AND LOCAL PERMITS, CONTRACTS OR OTHER APPROVALS
REQUIRED FOR PROJECT DEVELOPMENT
Regulated Activity
(Required Approval)
i
Ul
State of Alaska Authority (Continued)
Transportation across state lands
(Right-of-Way Permit)
Use of public water
(Water Rights Permit)
Dam construction
(Dam Safety Permit)
Temporary use of tidelands
(Tidelands Use Permit)
Permanent use of tidelands
(Tidelands Lease)
Materials (gravel) sale
(Materials Sale Contract)
Protect the natural environment (Land
Use Permit)
Development possibly affecting
historic or archeological sites
(Cultural Resources Concurrence)
Development within the coastal zone
(Coastal Zone Management Consistency
Determination)
Regulatory Agency
Department of Natural
Resources (DNR)
DNR
DNR
DNR
DNR
DNR
DNR
Office of History and
Archeology/State
Historic Preservation
Office (SHPO)
Governor's Office of
Management and
Budget (OMB),
Division of Govern-
mental Coordination
Authority
Description
AS 38.05.035
AS 38.05.330
AS 46.15.030 to .185
AS 46.15.020 to .180
AS 38.05.330
AS 38.05.330
AS 38.05.070 to .300
AS 38.05.110
AS 38.05.035
AS 38.05.330
National Historic Preservation Act
of 1966, as amended (16 USC 470)
AS 41.35.010 to .240, Alaska
Historic Preservation Act
Coastal Zone Management Act of
1972, as amended in 1976
(16 USC 1451)
AS 46.40 Alaska Coastal Manage-
ment Program Act of 1977
DNR must issue a right-of-way or easement per-
mit for any road, pipeline, transmission line or
Other improvement that crosses state lands.
DNR must issue a permit before appropriation of
state waters can be made. Once use of appro-
priated water has commenced, rights to that
water can be secured by a "Certificate of
Appropriation".
DNR must approve construction of any dam
structure over 3 m (10 ft) high or which im-
pounds over 62 dam3 (50 ac-ft) of water.
DNR must grant a one year land use permit for
use of tidelands for nonrecurring activities which
do not involve permanent structures.
DNR must Issue a tidelands lease for projects
involving permanent structures on tidelands.
Issuance of lease would be competitive.
DNR must issue a Materials Sale Contract for
use of gravel or other materials from state lands.
Volumes over 19,114 m3 (25,000 yd3) would be
sold by competitive bid.
DNR must approve surface activities and the
usage of equipment on land that has been
designated Special Use Lands.
For any federally permitted, licensed or funded
project, the SHPO must concur that cultural
resources would not be adversely Impacted, or
that proper methods would be used to minimize
or mitigate impacts which would take place.
Concurrence must be received before federal
permits can be granted.
OMB must concur with the applicant's Coastal
Zone Management Consistency Determination that,
to the extent practicable, a development project
would be consistent with the approved State
Coastal Zone Management Plan.
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Table VI-1
(Continued)
MAJOR FEDERAL, STATE AND LOCAL PERMITS, CONTRACTS OR OTHER APPROVALS
REQUIRED FOR PROJECT DEVELOPMENT
Regulated Activity
(Required Approval)
Local Authority
Major project development
(Land Use Permit)
Regulatory Agency
North Slope Borough
(NSB)
Authority
Title 19, North Slope Borough
Municipal Code
Description
NSB must issue a land use permit indicating the
proposed project would be consistent with the
approved Master Plan.
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used by the EPA for its Section 404(b)(1) review of Corps Section 404
Permit applications.
Title XI Application Review (EPA)
The same information provided by the EIS which is needed by the NPS for
its Title XI review and permitting responsibilities is also used by EPA for its
Title XI review and permit responsibility.
Department of the Army (DA) Permit (Corps)
The Corps issues a DA Permit that combines its authorities under Section 404
(dredged or fill material) and Section 10 (navigable waters). To address the
Section 404 requirements the EIS identifies the existing waterways and wet-
lands within the project area, and describes the various wetlands types and
their importance from functional and productivity standpoints. It describes
the type and location of project components, and also describes the process
by which they were sited. The EIS identifies the type and amount of wet-
lands and other waters that would be impacted by each alternative, and
discusses mitigating measures that might be used to minimize waters or wet-
lands impacts. It also describes reclamation plans. The Corps evaluation of
compliance with Section 404(b)(1) guidelines is included as Appendix 5.
To address the Section 10 requirements, the EIS describes the existing
navigable waters within the project area and how the project components
would affect them. It discusses the types of facilities, the process by which
they were sited, and how they would be constructed and operated. The EIS
describes the various options (e.g., short causeway/lightering versus short
causeway/offshore island), and compares them with respect to impacts upon
the integrity of the coastline and sediment movements past the facilities. It
also discusses mitigative measures to minimize impacts, and reclamation of the
structures.
Title XI Application Review (Corps)
The same information provided by the EIS which is needed by the NPS for
its Title XI review and permitting responsibilities is also used by the Corps
for its Title XI review and permit responsibility.
Title XI Right-of-Way Permit (NPS)
The EIS describes the existing land status situation within the project area
and the potential impacts of various project components on Cape Krusenstern
National Monument. It discusses the transportation corridor, port site and
transfer facility options individually and describes the process by which the
alternatives were identified and the preferred alternative selected. A copy
of the Title XI Application is included in Appendix 6. The NPS would be
the agency that would actually issue the right-of-way permit for the trans-
portation corridor.
Section 810 Subsistence Compliance Findings (NPS)
The EIS describes the subsistence resources in the vicinity of the southern
corridor, within the Monument and in surrounding areas, as well as their
VI - 7
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uses by time and location. It describes the significance of potential impacts
to subsistence resources and uses from a corridor through the Monument as
well as alternative corridors that avoid the Monument. It describes mit-
igative measures that would be taken to minimize adverse impacts upon sub-
sistence uses and resources, and it discusses the reasons why selection of
the preferred alternative through the Monument is consistent with sound land
management principles. The Section 810 Subsistence Compliance Findings are
contained near the end of Chapter V.
Section 7 (Endangered Species) Consultations (FWS and NMFS)
The EIS process identified the threatened Arctic peregrine falcon as nesting
within the project area. This finding required that a biological assessment
be prepared to determine if the project might affect this species. The
assessment was prepared and submitted to FWS.
The EIS process also identified the endangered bowhead and Gray whales as
using the area off the proposed port sites during migration. This finding
required that a biological assessment be prepared to determine if the project
might affect these species. The assessment was prepared and submitted to
FWS. A more detailed discussion of endangered species considerations is
included in Appendix 3 (Endangered Species Biological Assessment).
Historic and Archeological Review and Comment (ACHP)
The EIS identifies the reports and other documents that describe known
archeological and other cultural resources which might be impacted by the
project. It also discusses potential impacts and suggests mitigative measures
to be taken to protect historic and archeological resources. Correspondence
between the ACHP and co-lead agencies is included in Appendix 7 (Protec-
tion of Cultural Resources).
Floodplain Management Considerations (All Federal Agencies)
The EIS identifies existing floodplains within the project area, locates the
various project options as being within or outside those floodplains, and
describes the potential impacts of facilities located within floodplains. This
information is used by all federal agencies for their floodplain management
considerations as required by Executive Order 11988.
Wetlands Protection Considerations (All Federal Agencies)
The same information provided by the EIS which is needed by the Corps in
its Section 404 permitting process (discussed earlier) is also used by other
federal agencies for their wetlands protection considerations as required by
Executive Order 11990.
STATE APPROVALS
Air Quality Permit to Operate (DEC)
The EIS describes the existing air quality conditions and parameters, as well
as the quality and quantity of pollutants that would be emitted from the
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facilities. Analysis of this information would indicate whether a Prevention
of Significant Deterioration (PSD) Permit would be required. Additional base-
line information and analyses would likely be needed after completion of the
EIS before the permit could be issued.
Certificate of Reasonable Assurance (DEC)
The EIS provides analysis of hydrology and water quality baseline conditions
and predicts the hydrology and water quality of receiving streams during
operation and after reclamation. Water quality monitoring would continue
through the life of the project to verify the water quality projections made
in the EIS. Refer to the NPDES description for additional details.
The same information provided by the EIS which is needed by the Corps for
its Sections 404 and 10 permitting processes (discussed earlier) is also used
by DEC in its consideration of issuance of a Certificate of Reasonable Assur-
ance.
An NPDES permit with the required state Certificate of Reasonable Assur-
ance, when issued, serves as the state wastewater disposal permit for
projects such as Red Dog. DEC may issue individual wastewater permits for
small discharges which do not require an NPDES permit. The EIS describes
the mine area wastewater treatment process. Estimates are provided for the
type and concentrations of all significant water quality parameters in the
tailings pond, and for the projected water quality of the treated effluent. A
complete water balance for the mill process and the tailings pond is provided
as the basis for these projections.
Solid Waste Disposal Permit (DEC)
Some elements of a solid waste disposal plan (e.g., tailings pond location,
overburden disposition) are presented in the EIS. Incineration would be
used for all wastes whose burning would not violate air quality restrictions.
Other wastes would be incorporated in the tailings pond. The ultimate dis-
posal of buildings and discarded equipment would be determined near the
time of mine closure.
Title 16 (Anadromous Fish Protection) Permit (ADF&G)
Streams containing anadromous fish within the project area are identified in
the EIS, and the locations of project components which might affect them are
described (e.g., impoundment and drainage structures, bridge crossings,
port facilities). Design, construction and operational measures are sug-
gested to mitigate potential impacts.
Title 16 (Fishways for Obstructions to Fish Passage) Permit (ADF&G)
The EIS identifies streams within the project area that contain resident and
migratory fish, and identifies the locations of stream crossings. Design de-
tails of fishways to ensure efficient passage of fish would be provided to
ADF&G after completion of the EIS process.
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Right-of-Way Permit (DNR)
Descriptions and maps, including land ownership status, are provided in the
EIS for proposed transportation corridors across state lands. Detailed plans
for the selected road corridor would be provided after completion of the EIS
process and additional field surveys.
Water Rights Permit (DNR)
The EIS provides detailed descriptions of the location and type of proposed
water diversions, and estimated amounts of water consumption.
Dam Safety Permit (DNR)
The EIS describes the location, size and general composition of the tailings
pond and water supply dams and associated impoundments.
Tidelands Use Permit (DNR)
A conceptual plan for tidelands use during project mobilization and construc-
tion of the dock and offshore island is presented in the EIS. Detailed con-
struction plans concerning dredging, fill and grading would be provided
after the EIS process has identified the location and type of facilities.
Tidelands Lease (DNR)
Plans for the long-term use of tidelands facilities would be provided to DNR
after completion of the EIS process.
Materials Sale Contract (DNR)
The location and size of alternative project components requiring gravel for
construction are identified in the EIS. Detailed information about the
amounts and location of gravel or rock needed from state lands would be
developed by field survey after the EIS process has determined the specific
facility and route locations.
Land Use Permit (DNR)
The EIS describes surface activities and the use of equipment on state-owned
lands. Details of these activities would be provided after completion of the
EIS process.
Cultural Resources Concurrence (SHPO)
The EIS identifies the reports and other documents that describe known
archeological and other cultural resources which might be impacted by the
project. It also discusses potential impacts and suggests mitigative measures
to be taken to protect cultural resources. Correspondence between the
SHPO and co-lead agencies is included in Appendix 7 (Protection of Cultural
Resources).
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Coastal Zone Management Consistency Determination (OMB)
The EIS provides a sufficient description of the location, type and operation
of the proposed road corridor, port site and marine transfer facilities to
allow OMB to review the applicant's determination of consistency with the
approved State Coastal Zone Management Plan. A draft Coastal Zone Manage-
ment Plan has been prepared for the NANA region, but the state master plan
will be followed until the regional plan is finalized. If the State's response
to the applicant's consistency determination is available, it will be included
in the FEIS.
LOCAL APPROVALS
Land Use Permit (NSB)
The EIS describes the locations and types of project facilities, the process
by which they were sited, and some of the solid waste disposal plans. It
also points out potential environmental impacts which might be of specific
concern to the Borough (e.g., possible effects upon endangered whale
migration movements). Detailed construction plans and specifications would
be provided for individual project elements after completion of the EIS.
VI - 11
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Chapter VII
Consultation and Coordination
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VII. CONSULTATION AND COORDINATION
INTRODUCTION
A designated purpose of an EIS is to actively involve regulatory agencies
and the public in the decision-making process. EPA and DOI, as co-lead
agencies, conducted a broad public and interagency consultation and
coordination program throughout the development of this FEIS. Input was
solicited from the beginning of the project, and this input has been incor-
porated into the document. Specific public and agency involvement is
described below.
SCOPING
The scoping process conducted by EPA provided an opportunity for members
of the public, special interest groups, and agencies involved in the EIS
process to assist in defining significant environmental issues. Main objec-
tives of these scoping meetings were:
0 To present an overview of the proposed Red Dog Project;
0 To identify the major environmental issues to be addressed in the EIS;
0 To receive comments and questions regarding environmental impact con-
cerns; and
0 To incorporate those comments and questions into the EIS planning
process.
The scoping meetings, and the approximate number of persons in attendance,
were as follows:
Date
Location
Feb. 14, 1983 Anchorage
Feb. 16, 1983 Fairbanks
Attendance
10
Participants
34
7
16
Alaska Center for the Environ-
ment; Trustees for Alaska;
National Audubon Society;
public
State and federal agencies
Northern Environmental Center
Public meeting
VII - 1
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Date Location Attendance Participants
Mar. 9, 1983 Kotzebue 34 Maniilaq Association; state,
federal, and local agencies;
public
" " 15 Public meeting
Apr. 1, 1983 Barrow 7 North Slope Borough
The oral and written comments and questions received during and following
the scoping meetings were documented in a Responsiveness Summary (EPA,
1983). Its purpose was to provide a public record of the issues and con-
cerns raised, to provide a response to those issues and concerns, and to
serve as a blueprint for the EIS process to follow. A summary of the com-
ments received at the scoping meetings and from written responses is shown
in Table Vll-l.
AGENCY INVOLVEMENT
The federal, state and local agencies involved with this EIS and the nature
of their involvement is described in Chapter VI (Summary of Permit and
Regulatory Programs). The first formal agency meeting was held
February 16, 1983 in Fairbanks. Agency involvement has continued through-
out the study via: 1) formal review of the Responsiveness Summary and
issue identification process; 2) field visits to the Red Dog project site; 3) an
August 10, 1983 meeting to describe the options elimination and project
alternatives selection process; 4) agency review of a preliminary draft of the
DEIS and a November 3, 1983 meeting to discuss the draft; and 5) informal
phone calls between EIS team members and agency personnel and the public.
In addition/ the Corps is a formal cooperating agency for the EIS, as pro-
vided for in the Council on Environmental Quality Regulations governing
preparation of an EIS. As such, the Corps provided throughout the EIS
process technical assistance in its area of expertise and in matters relating
to permits within its jurisdiction.
PUBLIC INVOLVEMENT
Public meetings were held in Anchorage, Fairbanks and Kotzebue in Febru-
ary and March, 1983. In addition, meetings were also held with environ-
mental groups in Anchorage and Fairbanks during that time period. Com-
ments from the general public and these groups were documented and
addressed in the Responsiveness Summary (Table VI1-1).
Environmental groups in Anchorage and Fairbanks reviewed a preliminary
draft of the DEIS, and a meeting with these groups was held on November
4, 1983 to discuss that draft.
VII - 2
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Table Vtl-1
MATRIX OF COMMENTS RECEIVED FROM SCOPING MEETINGS AND WRITTEN RESPONSES
Comment Sources
Issue
A. PHYSICAL ENVIRONMENT
1. Water:
Quality
Appropriation
2. Littoral Processes
3. Air Quality
B. BIOLOGICAL ENVIRONMENT
1. Vegetation & Wetlands
2. Freshwater Biology
3. Marine Biology
4. Wildlife
C. HUMAN ENVIRONMENT
1. Employment:
Opportunities
Conditions
2. Economic
3. Social/Cultural
4. Subsistence
5. Archeology
6. Local Government
7. Land Use
8. Visual
9. Recreation
D. PROJECT DESIGN &
CONSTRUCTION
1. Port & Housing Facilities
2. Blasting
3. Mill Processes
4. Tailings Pond & Dam
S. Wastewater Treatment
6. Transportation System
7. Spills
8. Economics
9. Mitigation & Reclamation
E. EIS PROCEDURES
1. General Comments
2. Address All Options
3. Regional Perspective:
Accommodate Others
Secondary Impacts
Meetings
. Environ. Groups
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VII - 3
-------
Formal public hearings on the DEIS were held in Washington D.C., Anchor-
age and Kotzebue on April 24, May 2 and May 3, 1984, respectively. A
summary of these public hearings is located in Chapter X of this FEIS.
FUTURE ACTIONS
Following a 30-day public review period, EPA, DOI and the Corps will pre-
pare their respective Records of Decision (RODs). A ROD is a concise pub-
lic record of each agency's permit decision(s) or, in the case of Title XI,
the DOI recommendation to Congress. The RODs will describe the agencies'
preferred alternative and summarize all mitigation and monitoring require-
ments. In the case of Title XI, the RODs will also address the decision
criteria contained in Section 1104(g) and Section 1105 of ANILCA. Any
comments received on the Final EIS will also be summarized and addressed
in the RODs.
TENTATIVE DECISION SCHEDULE
Distribute Final EIS: October 19, 1984
Close of Public Comment Period: November 18, 1984
Distribute RODs: December, 1984
PROJECT INFORMATION CENTERS
Project information and related documents such as the baseline studies, the
project overview, and the draft EIS with appendices (when completed) are
available for review during normal business hours at the EPA and Ott Water
Engineers offices listed above, and also at the following locations:
Z. J. Loussac Library Maniilaq Association Offices
524 West 6th Avenue Shore Street
Anchorage, AK 99501 Kotzebue, AK 99752
Noel Wien Public Library Environmental Protection Agency
1215 Cowles 3200 Hospital Drive, Suite 101
Fairbanks, AK 99701 Juneau, AK 99801
AGENCY CONTACTS
For additional information or submitta! of questions and concerns relating to
the proposed Red Dog Project or the EIS, please contact:
VII - 4
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EPA
William M. Riley
EIS Project Officer
Environmental Evaluation Branch
(M/S 443)
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Telephone: (206) 442-1760
EIS Third Party Consultant
Michael C. T. Smith
Project Manager
Ott Water Engineers, Inc.
4790 Business Park Blvd.
Building D, Suite 1
Anchorage, AK 99503
Telephone: (907) 562-2514
DO I
Paul D. Gates
Regional Environmental Officer
Department of Interior
Box 100120
Anchorage, AK 99510
Telephone: (907) 271-5011
VII - 5
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-------
Chapter VIII
List of Preparers
-------
-------
VIII. LIST OF PREPARERS
U.S. ENVIRONMENTAL PROTECTION AGENCY
William M. Riley
Red Dog EIS Project Officer
U.S. NATIONAL PARK SERVICE
Floyd Sharrock
Special Assistant
U.S. ARMY CORPS OF ENGINEERS, ALASKA DISTRICT
Joe Williamson
Environmental Engineer
OTT WATER ENGINEERS, INC. (Third Party EIS Consultant)
Name
Michael C. T. Smith, Ph.D.
(Terra Nord, Inc.)
Roderick W. Hoffman, Ph.D.
Joanne E. Richter, M.S.
James K. Barrett, M.S.
Patricia Bendz
Sandra L. Christy, M.S.
Gene R. Crook, M.S., P.E.
Responsibility/Discipline
Project Manager and Wildlife
OTT Project Manager, Freshwater
and Marine Biology
Assistant Project Manager and
Technical Editor
Groundwater Hydrology
Draftsperson
Vegetation and Recreation
Marine Water and Wastewater
Quality
VIII - 1
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Name
Dennis E. Dorratcague, M.S., P.E.
John H. Humphrey, Ph.D., P.E.
Arthur J. LaPerriere, Ph.D.
Anne S. Leggett, B.A.
John E. Lobdell, Ph.D.
James G. Malick, Ph.D.
(Norecol Environmental
Consultants)
William L. Ryan, Ph.D., P.E.
Kevin Waring, B.A.
(Kevin Waring Associates)
Responsibility/Discipline
Coastal Geologic Processes
Surface Water Quality and
Hydrology, Air Quality, Sound and
Visual Resources
Vegetation
Proofer
Cultural Resources
Fishery Resources
Geological, Geotechnical and
Permafrost
Subsistence and Socioeconomics
ROSS & MOORE ASSOCIATES, INC. (Word Processing)
Marilee Moore Bourne
Tami Jean Fillbrandt
Judith Ross Fowler
ADDITIONAL STUDIES, REPORTS AND INFORMATION CONTRIBUTED BY:
Gerald G. Booth, Cominco Alaska, Inc.
Henry M. Giegerich, Cominco Alaska, Inc.
Walter J. Kuit, Cominco Alaska, Inc.
Terry J. Mannings, Cominco Alaska, Inc.
Harry A. Noah, Cominco Alaska, Inc.
James A. Rae, Cominco Alaska, Inc.
Stephen R. Braund & Associates
Dames & Moore
Thomas J. Gallagher
Edwin E. Hall & Associates
Larry A. Peterson & Associates
R & M Consultants
Woodward-Clyde Consultants
VIII - 2
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Chapter IX
Distribution
-------
-------
IX. EIS DISTRIBUTION LIST
The following list of recipients of the EIS is arranged with federal agencies
first, followed by state agencies, local agencies, media, interested groups
and businesses and citizens.
FEDERAL AGENCIES
U.S. Environmental Protection Agency
Office of Environmental Review EIS Filing Section
Alaska Operations Office
Office of Federal Activities
Regional Offices
U.S. Department of the Interior
Office of Environmental Project Review, Washington, D.C.
Regional Environmental Officer, Anchorage
Bureau of Land Management
State Director's Office, Anchorage
Fairbanks District Office
U.S. Fish and Wildlife Service
State Director's Office, Anchorage
Fairbanks District Office
Selawik National Wildlife Refuge
National Park Service
Regional Director's Office, Anchorage
Cape Krusenstern National Monument
Denali National Park and Preserve
Denver Service Center
U.S. Geological Survey, Menlo Park, CA
Minerals Management Service, Reston, VA
Bureau of Indian Affairs, Juneau
Bureau of Mines, Juneau
Alaska Resources Library
IX - 1
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U.S. Department of Commerce
National Marine Fisheries Service, Anchorage
Director's Office, Juneau
National Oceanic and Atmospheric Administration, Juneau
Federal Highway Administration, Juneau
Office of Coastal Management, Washington, D.C.
U.S. Department of Agriculture
Coordinator of Environmental Quality, Washington, D.C.
Soil Conservation Service, Anchorage
U.S. Forest Service, Juneau
U.S. Department of Transportation
U.S. Coast Guard, Anchorage
U.S. Department of Defense
Department of the Army, Alaska District, Corps of Engineers, Anchorage
District Engineer
Regulatory Functions Branch
Environmental Resources Section
Department of the Army, North Pacific Division, Corps of Engineers,
Portland, OR
U.S. Department of Health and Human Services
Regional Environmental Officer, Seattle, WA
Advisory Council on Historic Preservation, Washington, D.C.
U.S. Federal Energy Regulatory Commission
Regional Office, San Francisco, CA
U.S. Department of Housing and Urban Development, Anchorage
U.S. Congress
Honorable Ted Stevens, U.S. Senator
Honorable Frank Murkowski, U.S. Senator
Honorable Don Young, U.S. Congressman
IX - 2
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JOINT FEDERAL/STATE
Alaska Land Use Council
State Co-Chairman
Federal Co-Chairman
STATE AGENCIES
Office of the Governor
Honorable William Sheffield, Governor
Office of Management and Budget, Division of Governmental Coordination
Governor's Office, Kotzebue
Department of Environmental Conservation
Commissioner's Office, Juneau
Northern Regional Office, Fairbanks
Nome Area Office
Water Quality Management Office, Juneau
Department of Fish and Game
Commissioner's Office, Juneau
Habitat Protection Division, Fairbanks
Nome Regional Office
Kotzebue Area Office
Department of Natural Resources
Commissioner's Office, Juneau
Division of Land and Water Management, Anchorage
Northcentral District Office, Fairbanks
State Historic Preservation Office, Anchorage
Division of Mining, Anchorage and Fairbanks
Department of Transportation and Public Facilities
Commissioner's Office, Juneau
Regional Environmental Coordinator, Fairbanks
Office of Planning, Fairbanks
Department of Community and Regional Affairs
Division of Community Planning, Juneau
IX - 3
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Department of Commerce and Economic Development
Office of Minerals Development
Department of Revenue
Commissioner's Office
Department of Labor, Juneau
Commissioner's Office
Department of Law
Office of the Attorney General, Juneau
LOCAL AGENCIES
Mayor Clement Frankson, Sr., Point Hope
Mayor Amos Agnasagga, Point Lay
IRA Council, Noatak
Ukpeagvik Inupiat Corporation, Barrow
Mayor Raymond Hawley, Kivalina
Tagara Village Corporation, Point Hope
Fish and Game Advisory Board, Deering
Kikiktakruk Inupiat Corporation, Kotzebue
Kotzebue Elders Council
Alaska Area Native Health Service, Anchorage
Kotzebue Fire Department
Ninilchik Native Association
Mayor Sigfried Aukongak, Golovin
Village Council, Nuiqsut
City Council, Barrow
Point Lay Village Council, Point Lay
Kaktovik Inupiat Corporation, Kaktovik
Olgoonik Corporation, Wainwright
Village Council, Kaktovik
Village Council, Point Hope
Anaktuvuk Pass Village Council, Anaktuvuk Pass
Atkasook Village Council, Barrow
Village Council, Atkasook
Wainwright City Council, Wainwright
Kuukpik Corporation, Nuiquat
Maniilaq, Kotzebue
Mayor Joe Hill, Kotzebue
Mayor Eugene Brower, North Slope Borough, Barrow
Kotzebue Technical Center
Northwest Arctic School District, Kotzebue
Golovin Native Corporation, Golovin
Ahtna, Inc., Anchorage
Aleut Corporation, Anchorage
Arctic Slope Regional Corporation, Barrow
IX - 4
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Bering Straits Native Corporation, Nome
Bristol Bay Native Corporation, Anchorage and Dillingham
Calista Corporation, Anchorage
Chugach Natives, Inc., Anchorage
Cook Inlet Region, Inc., Anchorage
Doyon Ltd., Fairbanks
Koniag, Inc., Kodiak
NAN A Regional Corporation, Anchorage and Kotzebue
Sealaska Corporation, Juneau
MEDIA
KOTZ, Kotzebue
KUAC-FM, Fairbanks
Tundra Times, Anchorage
All-Alaska Weekly, Fairbanks
Yukon Sentinel, Fort Wainwright
Alaska Industry Magazine, Anchorage
Anchorage Daily News
Anchorage Times
Marine Digest, Seattle, WA
Cheechako News, Kenai
Nome Nugget
The Peninsula Clarion, Kenai
Alaska Construction and Oil Report, Anchorage
The Associated Press, Anchorage
Daily Journal of Commerce, Seattle, WA
Daily News Miner, Fairbanks
INTERESTED GROUPS AND BUSINESSES
National Parks and Conservation Association, Washington, D.C.
AEIDC, University of Alaska, Anchorage
Alaska Center for the Environment, Anchorage
National Audubon Society, Anchorage
Sierra Club, Anchorage
Trustees for Alaska, Anchorage
Northern Alaska Environmental Center, Fairbanks
National Wildlife Federation, Washington, D.C.
Everest Minerals Corporation, Corpus Christi, TX
Pierce-Atwood-Scribner, Portland, ME
GCO Minerals, Anchorage, Kotzebue; and Houston, TX
Cominco Engineering Services, Ltd., Northport, WA
Dames & Moore, Anchorage; Seattle, WA and Golden, CO
EVS Consultants, Sidney, British Columbia, Canada
L.A. Peterson and Associates, Fairbanks
Robertson, Monagle, Eastaugh and Bradley, Juneau
Getty Mining Company, Salt Lake City, UT
Wright-Forssen Association, Seattle, WA
U.S. Borax, San Francisco, CA
Northwest Alaska Chamber of Commerce, Nome
Kotzebue Sound Area Fisheries, Kotzebue
IX - 5
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Yutana Barge Lines, Nenana
Alaska Legal Services, Barrow
Golovin Fisheries, Golovin
Alaska Riverways, Inc., Fairbanks
Arctic Lighterage, Kotzebue
Doyon Construction, Fairbanks
I.U.O.E. Local 302, Fairbanks and Juneau
Labor Local 942, Fairbanks
Alaska Oilfield Services, Anchorage
Shell Oil Co., Anchorage
District Council of Laborers, Anchorage
Alaska Pacific Bank, Anchorage
Alaska International Air, Anchorage
ARCO Alaska, Anchorage
Woodward-Clyde Consultants, Anchorage
Yutan Construction, Fairbanks
Fairbanks Sand and Gravel, Fairbanks
Bering Straits CRSA Board, Unalakleet
Rural CAP, Anchorage
Alaska Miners Association, Anchorage
Envirosphere Co., Bellevue, WA
Boatel Rocky Mountain, Denver, CO
Agri Environment Systems, Hudsonville, Ml
Pacific Marine Center, Seattle, WA
Alaska Railroad, Anchorage
Sitka Conservation Society, Sitka
Alaska Maritime Agencies, Inc., Valdez
Foss Launch and Tug Co., Anchorage and Seattle, WA
Campbell Towing Co., Wrangell
Crowley Maritime Corp., Seattle, WA
Canonie Pacific, Portland, OR
AMMCO, Nashville, TN
Sliattery Equipment, Seattle, WA
EMRA, Gresham, OR
Foss Alaska Lines, Sitka
Alaska Freight Services, Seattle, WA
Best Pipe and Steel, Seattle, WA
Raymond International Builders, Houston, TX
Skyline Steel Corp., Larkspur, CA
Wright Construction Co., Seattle, WA
Only Way Construction, Sitka
Underwater Construction, Inc., Anchorage
Chevron Shipping Co., Edmonds, WA
Samson Tug and Barge Co., Sitka
Puget Sound Tug and Barge, Anchorage
Maskell-Robbins, Inc., Anchorage
Plumbers and Pipefitters Local 262, Juneau
Blue Water Marine Supply, Houston, TX
Swalling Construction Co., Anchorage
Sandstrom Sons, Inc., Anchorage
Leigh Flexible Structures Ltd., Buffalo, NY
United McGill Corp., Columbus, OH
HWW Consultants, Anchorage
IX - 6
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Moolin and Associates, Anchorage
Alaska Explosives Ltd., Anchorage
Great Lakes Dredge and Dock Co., Oak Brook, IL
Lounsbury and Associates, Anchorage
S&G Construction Co., Anchorage
Burrell Heppner Construction Co., Anchorage
Oceaneering International, Inc., Santa Barbara, CA
Marinas International Ltd., McLean, VA
Associated Sand and Gravel Co., Elma, WA
Reidel International, Portland, OR
Mississippi Valley Equipment, Ontario, CA
Nordic Marine Floats, Everett, WA
MEECO Marinas, Inc., McAlester, OK
Alaska Resource Analysts, Inc., Anchorage
ABAM Engineers, Inc., Federal Way, WA
ERTEC Northwest, Anchorage
A.C. Hoyle Co., Iron Mountain, Ml
Peter Kiewit Sons, Anchorage
Petroleum Information Corp., Anchorage
NORTEC, Anchorage
J.G. Fisher and Associates, Anchorage
Thompson Flotation, Inc., Newport Beach, CA
Alaska Diving Service, Ketchikan
I.U.O.E., Anchorage
Johnson Division, UOP, St. Paul, MN
Coast Marine Construction, Portland, OR
Teledyne Pipe, Galveston, TX
Construction and Rigging, Anchorage
Pacific NW Waterways Association, Vancouver, WA
Project Proposal Northwest, Seattle, WA
Bellingham Marine Industries, Bellingham, WA
SKW Clinton, Inc., Anchorage
Dravo Corporation, Pittsburgh, PA
Green Construction Co., Anchorage
Amak Towing, Ketchikan
Willamette-Western Corp., Portland, OR
L.B. Foster Co., Anchorage and Federal Way, WA
Teamster Local 959, Anchorage
Dillingham Construction, Anchorage
Chevron USA, Anchorage
Trident Marine, South Haven, Ml
Alaska Oil & Gas Commission, Anchorage
Kaiser Steel Corp., Oakland, CA
Rotocast Plastic Products, Brownwood, TX
TAMS Engineers, Anchorage
Washington Fish & Oyster Co., Seattle, WA
Pan-Alaska Fisheries, Inc., Kodiak
Mitchell Marine, Lafayette, LA
Columbia-Ward Fisheries, Seattle, WA
Topper Industries, Inc., Vancouver, WA
Kalispel Marine Structures, Cusick, WA
West Build Structures, Portland, OR
Morrison-Knudsen Co., Boise, ID
IX - 7
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Far West Modular, Inc., Jefferson, OR
Zebron Corp., Tualatin, OR
Gulf-Navigation, Seward
Martech International, Anchorage
General Construction Co., Seattle, WA
Piledrivers Local 2520, Anchorage
Elmer E. Rasmuson Library, University of Alaska, Fairbanks
Earthmovers of Fairbanks, Fairbanks
DMC Properties, Inc., Redmond, WA
National Mechanical Contractors, Anchorage
BP AK Exploration, Inc., San Francisco, CA
Nicolon Corp., Atlanta, GA
ERIS, Anchorage
Reading & Bates Construction, Houston, TX
Marathon Oil Co., Anchorage
McDonald Industries, Anchorage
Morris Marine Consultants, Anchorage
Harding Lawson Associates, Anchorage and Novato, CA
Texota, Inc., Rochester, MN
Pacific Management and Engineering, Anchorage
Construction Resources, Anchorage
Roger and Babler, Anchorage
Armortec, Norcross, GA
Gulf Oil, Anchorage
Emerald International Sales, Houston, TX
Yutana Barge Lines, Inc., Nenana
Alaska Legal Services Corp., Barrow
Alaska Riverways, Fairbanks
Arktos Associates, Anchorage
Steffen Robertson and Kirsten, Lakewood, CO
Union Oil Co., Anchorage
Sohio Alaska Petroleum Co., Anchorage
PSEG, Hancocks Bridge, NJ
Wilderness Society, Washington, D.C.
AMAX Exploration Inc., Golden, CO
Stephen Braund & Assoc., Anchorage
ABAM Engineers, Federal Way, WA
Verity, Smith & Clark, P.C., Tucson, AZ
Colorado State University Libraries, Fort Collins, CO
CONOCO, Inc., Houston, TX
Battelle PNW Lab, Richland, WA
Utah International, San Francisco, CA
Stone & Webster, Denver, CO
Timcock, Allen and Holt, Tucson, AZ
IMODCO, Los Angeles, CA
Northwest Mining Assn., Spokane, WA
Harza Engineering Co., Anchorage
Environmental Services, Ltd., Anchorage
WGM, Inc., Anchorage
Anaconda Minerals Co., Anchorage and Denver, CO
Derbyshire & Assoc., Anchorage
Bear Creek Mining, Anchorage
Miner's Advocacy Council, Fairbanks
IX - 8
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Kotzebue High School, Kotzebue
Burlington Northern Railroad, Seattle, WA
Applied Economic Assoc., Seattle, WA
Air Sciences Inc., Lakewood, CO
Department of Geological Studies, University of Arizona, Tucson, AZ
George Francis Memorial Library, Kotzebue
Wisconsin Dept. of Natural Resources, Madison, Wl
Seattle City Light, Seattle, WA
Tippetts-Abbett-McCarthy-Stratton, Anchorage and Seattle, WA
Environmental Management Services Co., Fort Collins, CO
Utility Data Institute, Inc., Washington, D.C.
Johnson Terminals, Vancouver, British Columbia, Canada
E.C. Jordan Co., Portland, ME
James M. Montgomery Consulting Engineers, Inc., Boise, ID
Van Ness, Feldman and Sutcliffe, Washington, D.C.
Earth Technology Corp., Anchorage
PRAXIS, Calgary, Alberta, Canada
Billiton Exploration USA, Inc., Denver CO
Railfax, Portland, OR
Kennecott, Salt Lake City, UT
The Ralph M. Parsons Co., Pasadena, CA
INTERESTED CITIZENS
Mike Nies, Boulder, CO
Robert Weeden, Fairbanks
Robert W. Sprague, Placentia, CA
Judy Larquiere, Fairbanks
Louie Larquiere, Fairbanks
Kate Wedemeyer, Fairbanks
Mark Standley, Fairbanks
Bob Ritchie, Fairbanks
Paul R. Huff, Fairbanks
Jacquelline La Perriere, College
James W. Alderich, Fairbanks
Nina Mollett, Fairbanks
Bob Dittrick, Anchorage
Mike Holloway, Indian
H. Paul Friesema, Evanston, IL
Pat Metz, Anchorage
Rachel Craig, Kotzebue
Rita E. Ryder, Kotzebue
Clara Taylor, Kotzebue
Paula Anderson, Kotzebue
Henry McLuke, Kotzebue
Joe Hill, Kotzebue
Lou Jones, Kotzebue
Reggie Joule, Kotzebue
Kent Hall, Kotzebue
Bev Minn, Kotzebue
Reed Henry, Kotzebue
Boris McLuke, Kotzebue
IX - 9
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Marie A. Jones, Deering
Robin Pritkin, Seattle, WA
Roger Burggriff, Fairbanks
Ed Bur, College
Burt Adams, Kivalina
Jack Morrow, Valdez
Herbert Zieske, Pt. Baker
George Atkinson, Jr., Anchorage
Bruce Barrett, Craig
Andrew Hughes, Juneau
J. Phillip Henry, Anchorage
John Osias, Seattle, WA
Tim Sutherland, Vancouver, WA
Bill Miller, Olympia, WA
Jim Glaspell, Eagle River
Nancy Hemming, Anchorage
Leo Roberts, Kenai
Chuck Muscio, Anchorage
P. Massey, Juneau
James McElroy, Anchorage
Felix Toner, Juneau
Betzi Woodman, Anchorage
Phillip Mathew, Sherman Oaks, CA
P. Robinson, San Francisco, CA
Robert Arvidson, Cordova
John Spencer, Portland, OR
David Vick, Houston, TX
Federick Goettel, Leonard, MD
Marie Adams, Anchorage
Scott Edson, Palmer
Bob Kent, Washington, D.C.
Richard Ehrlich, Kotzebue
Chuck Hutchens, Anchorage
Bill Wolter, Anchorage
Earnest S. Burch, Jr., Harrisburg, PA
Nancy Sheldon, Ketchikan
Bob Sanders, Anchorage
Bette J. Gates, Anchorage
N. H. Brewer, Eagle River
Tom Gates, Anchorage
Phillip Smith, Anchorage
Bruce Rummel, Anchorage
Bob Mallaham, Anchorage
IX - 10
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Chapter X
Public Response
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X. PUBLIC RESPONSE TO DEIS
PUBLIC HEARING SUMMARY
On Tuesday, April 24, Wednesday, May 2 and Thursday, May 3, 1984, DOI
and EPA conducted public hearings on the Red Dog Mine Project draft EIS in
Washington, D.C., Anchorage, Alaska and Kotzebue, Alaska, respectively.
The purpose of these public hearings was to solicit local citizens' comments
on the draft EIS and the proposed mine project. No witnesses attended the
public hearing conducted by DOI in Washington, D.C. and no testimony was
heard. However, approximately 60 people attended each of the hearings
conducted by EPA in Anchorage and Kotzebue. Summaries of those two pub-
lic hearings are presented below.
Mr. Richard Thiel of EPA Region 10 acted as hearing officer at the May 2
public hearing held in Anchorage. The hearing was organized into three
parts, the first being an introduction to the National Environmental Policy
Act (NEPA) process by Mr. Thiel, and an introduction to the EIS process by
Mr. William Riley, EPA's project manager on the Red Dog EIS. Part two of
the hearing involved the actual testimony or statements by the public, and
part three involved a question and answer session. A panel made up of
representatives from EPA, NPS, the Corps, the State Office of Management
and Budget, Division of Governmental Coordination and Ott Water Engineers,
Inc. responded to questions and comments from the audience during part
three of the hearing.
The Anchorage public hearing was officially convened at 7:38 p.m. and con-
cluded at 9:40 p.m. The entire hearing proceedings were recorded by a
court reporter and published in a 59-page hearing record which is on file
with EPA Region 10 in Seattle. Any person wishing a copy of the hearing
record may remit $22.50 to the U.S. Environmental Protection Agency and
request the document from:
Mr. William Riley
U.S. Environmental Protection Agency
Environmental Evaluation Branch M/S 443
1200 Sixth Avenue
Seattle, Washington 98101
Thirteen people made formal statements during part two of the Anchorage
public hearing, and one person asked questions during part three of the
hearing. Of the 13 people making formal comments on the DEIS, all gave
conditional support for the preferred alternative and many commented on the
professional quality of the document. A panel of local citizens from the
project area presented testimony in favor of the preferred alternative, and
discussed their participation in the planning and management aspects of the
X - 1
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project. A summary of the concerns raised at the hearing, in terms of the
12 primary EIS scoping issues, is shown in Table X-1. The main areas of
concern were protection of wildlife habitat in general and subsistence re-
sources in particular; minimizing social, cultural and economic impacts to
residents of the region; and the technical feasibility of the project. Several
people also raised concerns about water quality and impacts to Cape Krusen-
stern National Monument.
The more significant or commonly raised concerns at the Anchorage public
hearing and responses to those concerns are shown below:
0 Concern: The railroad transportation mode appears to be more envi-
ronmentally favorable.
Response: Please see the response to Comment Letter 18-B in the
following DEIS Comment Responses section of this chapter.
0 Concern:
Response:
The ballasted tanker should be placed offshore for at least
a year for testing prior to project start-up.
Please see the response to Comment Letter 18-D in the
following DEIS Comment Response section of this chapter.
0 Comment: Indirect impacts to caribou have been overstated.
Response: Please see the response to Comment Letter 10-A in the
following DEIS Comment Responses section of this chapter.
0 Concern:
Response:
Zero discharge regulations are overly restrictive for the
Red Dog project.
Please see the response to Comment Letter 10-B in the
following DEIS Comment Responses section of this chapter.
0 Concern: Visual impacts have been overstated.
Response: Please see the response to Comment Letter 10-C in the
following DEIS Comment Responses section of this chapter.
0 Concern:
Response:
Guaranteed access to the port and transportation corridor
is not adequately addressed.
Please see the response to Comment Letter 13-A in the
following DEIS Comment Responses section of this chapter.
X - 2
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Table X-1
SUMMARY OF CONCERNS RAISED AT THE ANCHORAGE AND KOTZEBUE
PUBLIC HEARINGS, MAY 2 AND 3, 1984
Number of People
Concerned with Issue
1.
2.
Red Dog Scoping Issues
Maintaining the quality and quantity
Maintaining the quality and quantity
of
of
water
fish-
Anchorage
Hearing
2
Kotzebue
Hearing
-
ery habitat, and minimizing disruption of fish
movements
3. Maintaining the quality and quantity of wild-
life habitat and minimizing impacts on wildlife
4. Minimizing impacts on coastal geologic processes
5. Minimizing impacts on marine life
6. Protecting subsistence resources and their use
7. Protecting cultural resources
8. Minimizing the social, cultural and economic
impacts on residents of the region
9. Designing project components from a regional
use perspective
10. Impacts on Cape Krusenstern National
Monument
11. Technical feasibility
12. Economic feasibility
2
3
1
6
1
X - 3
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Mr. William Riley of EPA Region 10 acted as hearing officer at the May 3
public hearing held in Kotzebue. This hearing was also organized into three
parts, the first being an introduction by Mr. Riley and a presentation by
Mr. Floyd Sharrock of the National Park Service on the Title XI process.
Part two of the hearing involved testimony and statements by the public
(presented in Inupiaq with an English translation), and part three involved
a question and answer session with a panel of agency representatives.
The Kotzebue hearing was convened at 7:53 p.m. and concluded at 9:57 p.m.
The entire proceedings were recorded by a court reporter and published in
a 50-page hearing record which is available from EPA Region 10. Fifteen
people made formal statements during part two of the Kotzebue public
hearing, and one person asked questions during part three of the hearing.
All of the people testifying gave their conditional support for the preferred
alternative. A summary of the concerns raised at the hearing is shown in
Table X-1.
The main areas of concern raised at the Kotzebue hearing were the protec-
tion of subsistence resources and the subsistence lifestyle; and minimizing
social, cultural and economic impacts to residents of the region. The more
significant or commonly raised concerns at the Kotzebue public hearing and
responses to those concerns are shown below:
0 Concern:
Response:
Job training programs need to ensure that local residents
derive the maximum benefit from available jobs.
As stated on p. V-29, the NANA/Cominco agreement specif-
ically sets a goal of maximum resident hire, as well as
stating that NANA would appoint the project personnel
officer. In addition, an intensive training program to max-
imize local hire has been initiated by the Regional Strategy
Training Placement Committee.
0 Concern:
Response:
The DEIS population estimate for Kotzebue appears unrea-
sonably low and the effect of the project on Kotzebue's
services should be re-evaluated.
Please see the response to Comment Letter 5-A in the fol-
lowing DEIS Comment Responses section of this chapter.
0 Concern:
Response:
The DEIS does not adequately address the net migration
from villages to Kotzebue.
Please see the response to Comment Letter 5-B in the fol-
lowing DEIS Comment Responses section of this chapter.
0 Concern:
Response:
The anticipated demand for community services in Kotzebue
is understated.
Please see the response to Comment Letter 5-C in the fol-
lowing DEIS Comment Responses section of this chapter.
X - 4
-------
0 Concern:
Response:
Anticipated work-force displacement is not adequately ad-
dressed.
Please see the response to Comment Letter 5-D in the fol-
lowing DEIS Comment Responses section of this chapter.
0 Concern:
Response:
Project-related financial benefits at the family level should
be better quantified.
A discussion has been added to p. V-29 to better quantify
anticipated changes to family income. The expected average
annual earnings per job have been contrasted with the 1980
median household income for the Kobuk region.
0 Concern:
Response:
The EIS should address the fact that an increase in income
should help stabilize the family structure and reduce
poverty-related stress and social problems.
A discussion has been added to p. V-35 to emphasize the
benefits of increased family income and the resulting de-
crease is stress-related social problems.
0 Concern:
Response:
0 Concern:
The EIS should mention the Regional Strategy Training
Placement Committee which is responsible for an intensive
training program to maximize local hire.
A discussion of this committee has been added to p. V-29.
The EIS should mention the effort by the Regional Strategy
Committee to recreate local businesses in the villages.
Response: A discussion of this effort has been added to p. V-34.
X - 5
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DEIS COMMENT RESPONSES
X - 6
-------
DARBYSHIRE & ASSOCIATES
land monogement ond community plonning consulting
April 17, 1984
23 m
SNYIRONMENTM. EVALUATION
BRANCH
Mr. William M. Riley, EIS Project Officer
Environmental Evaluation Branch M/S 443
Environmental Protection Agency, Region 10
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Riley:
There are two portions of the "Draft Environmental Impact
Statement Red Dog Mine Project Northwest Alaska" on which we wish
to make comments.
(/-/iVirstly, all the comments under "Visual Resources," p. V.-21, go
beyond the jurisdiction of the EPA. No citation to the CFR for
authority is given for the Visual Resource Management (VRM)
Program. That oversight aside, the statement of the author
admits VRM programs do not apply to private lands. The EPA is
not funded to act as a consultant to NANA Corporation. The
comments in this section have no place in the study,_
r/-S)Secondly, under the section entitled "Irreversible and
Irretrievable Commitments of Resources," p-96, the study makes
mention of "de facto wilderness." It is not a land
classification having a basis in regulation. It is an opinion of
the author. The area could also be designated "de facto
developmental," if one considers the potential for development.
The opinion should be deleted from the report. It is
unsubstantiated and an improper use of a word having legal
significance where no legal basis for such classification exists..
Cordially yours,
Hary ane Sutliff
Senior Land Specialist
An evaluation of visual resources impacts is an integral part of the
EIS interdisciplinary review process mandated by Section 102(2)(A)
of NEPA. The VRM system developed by the U.S. Forest Service
was applied throughout the Red Dog project area to give a consis-
tent and accurate evaluation of visual impacts without regard to
specific land ownership.
Any mention of "de facto wilderness" has been eliminated from the
text. The fourth line on p. V-97 now reads, "...event, the un-
developed nature of the project area..." Similar changes were
made on pp. V-90 and V-94.
528 "N" street / anchorage, obska 99501 / 907-279-5-S43
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APR 23 1984
ENVIRONMENTAL EVALUATION
BRANCH
NORTHWEST \ ; MINING ASSOCIATION
^B 633 PEYTON BUILDING SPOKANE, WASHINGTON 99201 (509) 624-1158 KARL W MOTE EXECUTIVE DIRECTOR
m. Osmond Or* Conoctflg Co *na
M*e<»* me
Ve» *•«»»< KM W Mm
X
I
00
E,i»»on Manager
PM« J ftutfi
OaraOnoyii
an Coco* i NCMI Co. inc.
v GcftMn SuiWgM Um. inc
April 18, 1984
Mr. William M. Riley
EIS Project Officer
Environmental Evaluation Branch (M/S 443)
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Riley:
On behalf of the members of the Northwest Mining Association, I wish
to comment on the Draft EIS for the Red Dog Mine Project, Northwest
Alaska.
Our Association was chartered in 1895 to serve the minerals industry
of the northwest states, western Canada, and Alaska. Our membership
exceeds 2,500, many of whom live in Alaska or have mineral interests
and activities there.
We feel that the draft environmental impact statement thoroughly studies
the alternatives and impacts of the proposed project. We also feel
that the importance of the deposit to the NANA Regional Corporation
and to our domestic mineral supply far outweigh the few remaining unmiti-
gated and unavoidable impacts.
We encourage you to approve the preferred alternative one, to include
a transportation route along the southern corridor.
Sincerely,
KARL W. MOTE
Executive Director and
Vice President
KWM/sr
Thank you. Comment noted.
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BILL SHEFFIELD. GOVERNOR
IIKI'AKTJIE.VT OF .\ATITKAL
DIVISION OF PARKS AND OUTDOOR RECREATION
ANCHORAGE ALASKA
PHONE (907)2762653
April 24, 1984
Re: 1130-17
3130-1 (EPA)
William Rile/
EIS Project Officer
Environmental Evaluation Branch M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Riley:
We appreciate your efforts at forwarding the Red Dog Mine Project DEIS. It is
an interesting and well prepared document. We feel that the DEIS addresses
•the cultural resources concerns in an adequate manner up to the point of
consultation with the Advisory Council on Historic Preservation. We look
forward to participating in that consultation process, and to developing
appropriate mitigation procedures wherever necessary.
Sincerely,
Neil C. Johannsen
Director
Thank you. Comment noted.
/<
By: Tim Smith jr'l~'. , ='ln
Deputy State Historic Preservation Officer I!;-,.'—1 -_i_ -J L^;| I
DR:clk
lk!
M. ' '- 138*
ENVIRflNMC'TAl ?/ALUATIO«l
ALASKA STATE PARKS —
Let's Put Then on the Hap!
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CITY OF KOTZEBUE
PO. BOX 4«
CITY HALL
907-442-3401
ALL AMERICA
CITY
KOTZEBUE POLICE DEPARTMENT
907-442-333!
PUBLIC WORKS DEPARTMENT
GEORGE FRA
907-442-3BI6
May 3, 1984
Mr. William M. Riley
EIS Project Officer
Environmental Evaluation Branch
(M. S. 443)
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Re:
Environmental Impact Statement
Red Dog Mine Project
Dear Mr. Riley:
First, please accept our congratulations and thanks for the
comprehensive yet readable Draft Environmental Impact
Statement provided for the Red Dog Mine project. The
variety and depth of discussion of the issues allows (and
even requires) all concerned parties to take a practical
look at the issues and an opportunity to take constructive
actions to mitigate adverse impact and to maximize the
opportunities for improvement of our community and region.
A3 far as concerns that the city of Kotzebue has over the
Draft EIS, they reflect the effect of Red Dog Mine project
on the growth and changes that may be experienced by the
City.
Thank you. Comment noted.
- ,4) Population
The City has struggled for several years with population
estimates that have appeared unreasonably low. After a 1982
City census and a 1983 City survey, the state Department of
The critical datum for the assessment of project impacts is the
estimated population growth increment attributed to the mining
project alternative. With regard to Kotzebue's current population
and the baseline population forecast, we believe that the EIS
"GATEWAY TO NORTHWEST ALASKA"
-------
William M. Riley; Page 2
<'£-/)Comniunity & Regional Affairs has agreed with us on a
population estimate for Kotzebue at 2,981 as of July 1,
1983. This estimate is significantly different than those
provided in the draft and in fact, approximated the "Base
Case" estimates for 1995 on Table V-12 of the draft. A
re-evaluation of the effect of the project on Kotzebue's
population and the community's overall capacity for service
delivery should be considered for the final EIS.
(5-B)Intraregional Migration
Along with population changes goes the concern over what
choices individuals will make when intraregional earnings
and personal income increase due to the project. The draft
suggests that there will be "a preference of village
residents to use new income to make their families better
off in their home communities..." and makes a "best guess"
(V-33) that Red Dog "would not have much net effect on
intraregional population movement.
With the expected growth impact on the City of Kotzebue and
with past experiences, we feel that some individuals will
choose to 'relocate to Kotzebue to spend their "new income"
where there may be more choices and economic alternatives.
Some net migration from the villages to Kotzebue should be
X considered for its effect upon the city.
1 (s- C} Demand for Community Infrastructure
_> The draft plan reasonably addresses the problems of
community service demands and concludes that since Kotzebue
will bear the brunt of the growth, "it would likely impose
short term strains on the capacity of the community to meet
the housing needs and other community facility and service
needs of new residents." (V-34). This past winter,
Kotzebue experienced excessive demand on its water and sewer
utility which approached projections made for 1988. The
higher than expected consumption may be attributable to the
low population estimates, inherent problems with the City
water delivery system, and water use that is not
conservation-oriented.
The anticipated "rapid community growth" compounds the
already difficult task of keeping up with the demand for
water and sewer. Studies and plans to meet water and sewer
requirements to projected consumption rates for the year
2000 are either being implemented or re-avaluated to
complete system expansion in the next few years.
With our struggle to "keep up" with ever increasing demand,
the City of Kotzebue has not completed its water and sewer
utility to provide safe water and waste removal to all its
current residents. With actual and anticipated growth
figures are consistent with a variety of demographic indicators
(e.g., 1980 Census data, school enrollment and utility hook-up
trends between 1979-1983), notwithstanding the City of Kotzebue's
1982 and 1983 population surveys, which were also reviewed. We
suggest that Kotzebue's rapid development - evident in new
housing construction, extensive public works, and rising per
capita consumption of utility services - partly accounts for demand
upon infrastructure well in excess of population growth per se.
Demographic data do not support the premise that a stronger cash/
consumer economy at Kotzebue would draw net in-migration from
the surrounding villages. Kotzebue enjoyed a large and widening
advantage in cash employment opportunities over the rest of the
region's villages during the 1970-1980 decade. By 1980, Kotze-
bue's median household income was about double the figure for the
rest of the region. Regardless, Kotzebue's share of the region's
total population was virtually unchanged: 41.9 percent in 1970
and 42.5 percent in 1980. Kotzebue's share of the region's total
Native population actually declined between 1970 and 1980.
It is acknowledged that the City of Kotzebue's continuing efforts
to improve community facilities and services for its residents
already impose substantial burdens on local government. These
burdens stem primarily from a commitment to progressively better
living standards and only partly from population growth.
-------
William M. Riley; Page 3
X
I
—»
ro
expanding the community, major work projects and innovative
solutions are necessary in Kotzebue just to meet existing
demand. The level of "strain" imposed by the project may
become a reality for our current residents in addition to
new residents.
Workforce Displacement
As secondary and "replacement" employment opportunities
become available for Kotzebue residents and newcomers, there
may certainly be corresponding headaches for Kotzebue
employers. As a significant employer in Kotzebue, the City
must be concerned that our brightest and best employees will
be attracted to the opportunities and excitement of the
project, leaving vacancies which must be filled from
possibly an uncertain or unstable new workforce. All this,
at the time of the most rapid growth, and "strain" on
community services and finances. We feel this should be a
particularly important consideration for the Community and
Socio-economic impact of the project.
Project Anticipatation
The Red Dog Mine has received considerable scrutiny and
publicity state-wide over the last few years. Depending
upon the economic climate and availability of jobs in other
parts of the state and Northwest U. S., the City may be
subject to an influx of job-seekers, developers and
entrepreneurs prior to any final decisions on the start-up
of the Red Dog project. Local residents may decide to "get
in on the bottom floor" by developing rental properties or
businesses in anticipation of rapid population and consumer
growth. Other parts of the State have experienced such
anticipation and it may be adverse to the interests of the
people of Kotzebue and the region. Effective measures to
minimize such impact may include state-wide publicity to
provide periodic status reports of the Red Dog project and
local access to economic development assistance for small
businesses to reduce the potential of business failure prior
to significant economic growth.
The Red Dog project will provide challenges and
opportunities to the individuals and institutions of the
region. The City of Kotzebue looks forward to meeting these
challenges and working closely with the NANA Regional
Corporation and others to improve City services and minimize
potential adverse impact of the project.
Sincerely,
The City of Kotzebue should be anticipating and preparing for
some change in work force as a result of the Red Dog project.
Thank you. Comment noted.
Bruce Kovarik
City Manager
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United Slates Soil Professional Center - Suite 129
Department of Conservation 2221 East Northern Lights Boulevard
Agriculture Service Anchorage, AK 99501! (907) 276-'t2146
May 3, 1984
William M. Riley
EIS Project Officer
Environmental Evaluation Branch M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, UA 98101
X
I
_A
U>
Dear Mr. Riley:
I would like to compliment you on an excellent job compiling the Red Dog
Hine DEIS.
SCS has not been on the site and we have no additional technical data that
could be used to support this DEIS.
The proposed S-year program to survey vegetation will be very important to
evaluation of long range impacts. The SCS has been collecting range and
soil survey information on the Baldwin and Seward Peninsulas. Information
collected has been related to Boil erosion, fire impact, range condition,
trend, utilization by herbivores, waterfowl and other wildlife values. This
information could be useful for design of the program for the Red Dog Xioe
area.
Sincerely,
Thank you. Comment noted.
//•
Burton L. Clifford-/-
State Conservationist
1984
-------
Bill Sheffield, Governor
DEPARTMENT OF TRANSPORTATION AND PUBLIC FACILITIES
REGlON, Deputy Commissioner
2301 PEGER ROAD
FAIRBANKS, ALASKA 99701
1907)452-1311
1584
May 3, 1984
Re: Comment Draft Environmental
Impact Statement (DEIS)
Red Dog Mine Project
William M. Riley
EIS Project Officer
Environmental Evaluation Branch
Mail Stop 443
Environmental Protection Branch
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Riley:
We are pleased to have been involved in the project and thank you for
the opportunity to comment on the Draft Environmental Impact Statement
(DEIS). We find the DEIS to be well written. Our Regional Planning
office has previously commented on the regional transportation aspects
of the transportation corridor. We would like to take this opportunity
to add a few comments on the proposed roadway.
On page iv, the first sentence of the last paragraph and on page
11-16, the comment was made that the road would be "...composed of a
granular fill about 2.0 m (6.5 ft.) thick to prevent degradation of
permafrost." Given the location, the concept of an embankment of
uniform thickness to prevent degradation of the permafrost may be
misleading. With the mean annual temperature of 21°F at Kotzebue, the
proposed fill depth of 6.5 ft. would assume some thaw into the existing
terrain, thus some settlement will result, depending on soil type and
existing ground conditions. This method is consistent with existing
practice, with the final depth/depths selected being dependent on soil
groupings, foundation conditions and topography. Selection of the final
typical sections will be a major engineering effort for this project.
Along with the incorporating design procedures suitable for roadway
construction in the Arctic, one of the governing factors will be
allowable settlement, necessary to minimize maintenance and provide a
safe, suitable roadway surface for the large haul vehicles. Some
information on the actual design process could be added for clarity.
The text on p. iv (last 11) and p. 11-16 (114) was modified to indi-
cate that 2.0 m (6.5 ft) would be an average thickness of roadbed
fill, and that the fill thickness would be adequate to prevent ther-
mal degradation. The road would be designed to meet Arctic
engineering specifications for roadway construction. Before a
right-of-way permit were issued by the State, detailed road de-
signs would be submitted by Commco for review by appropriate
agencies including DNR, DOT/PF and ADF&G.
-------
William M. Riley
EIS Project Officer
Environmental Evaluation Branch
Environmental Protection Branch
Seattle, Washington
-2-
May 3, 1984
(7-&y\\\e typical section on page 11-17 shows a corridor boundary width of
65 ft. The width of the boundary or right of way should be increased or
qualified. As an example, if the design fill can be accommodated in
65 ft. on flat terrain, it would take a right of way 90 ft. wide to
construct on a hillside or gentle sideslope. Our intent is a caution
that the DEIS content not be used as a "design" but more of a concept.
(7-£)lf the materials sources will be used for maintenance, a statement to
that effect should be added.
There is an ongoing need for construction material in Kivalina. If it
would be possible to keep the closest materials site to the port
facility for maintenance, perhaps it could be used for local projects
such as airport construction or local streets.- A winter haul would be
required but is feasible.
Sincerely,
cn
Glentfef
Deputy Eomtri&ioner
Northern Region
The text on p. 11-16 (H4) was modified to clarify that the 20 m (65
ft) wide road corridor represents an average width for flat ter-
rain; corridor width would increase on steeper slopes depending on
cut and fill requirements.
The first paragraph under Borrow Sites (pp. 11-16 and 11-19) has
been modified to indicate that borrow sites would supply gravel for
road construction as well as road maintenance. It has not been
determined at this time which borrow sites would be used for road
maintenance, or whether gravel would be available to Kivalina.
MT/dj
Mim Oixon, Director, Planning & Programming, Northern Region
Henry Springer, Director, Maintenance & Operations, Western Region
-------
Robert B. Sanders Ph.D.
Consulting Geologist
SRA Box 25
Anchorage. Alaska 99SO7
(9O7) 345-O2O3
&RMICH
April 27, 198*
Wm. Riley, EIS Project Officer
Environmental Evaluation Branch M/S **3
Environmental Protection Agency
1200 Sixth Ave
Seattle, Washington, 98101
Dear Mr. Riley:
Tne DOT/EPA team is to be congratulated on the
thoroughness and objectivity of the discussion of
the various impacts of the Red Oog Mine Project
and the several alternatives. The only complaint
I might have, and that a very minor one-, is in the
use of the term "degradation" used to describe
water quality impact (Page 1-6) in an area where
the natural heavy metals induced toxicity of some
of the streams (e.g. Red Dog Creek) would actually
be decreased under this project. This is such an unusual
situation that I would have preferred greater recog-
nition of the fact through use of, for example,
"Degradation or enhancement of..." for use in headings
and lists. It is truely unusual where mining will tend
to enhance water quality and I hate to see it not
given equal status to that of the negative impacts.
Likewise it is unusual to have one alternative (No.
1) so markedly more favorable thafi the others. Although
Alternative No. 1 has greater impact on Cape Krusenstern
National MDnument as an entity, the relative rankings
of the impacts of the alternatives as shown in Table 2
clearly shows it to be the obvious preferable plan,
and would have little actual impact on the stated purposes
for which the Cape Krusenstern National Monument was
established.
This initial test of Title XI of ANILCA will be watched
with great interest as it is the ultimate test as to
whether the National Park Service will honor in good faith
one of the most important of the ANILCA compromises.
The EIS acknowledges the possible enhancement of the water qual-
ity of Red Dog Creek on pp. V-5 to V-8, p. V-13 and p. V-14.
Thank you. Comment noted.
Y ou r s ,
Or. Robert B. Sanders
-------
MAY 9 13W
ENVIRONMENTAL EVALUATION
May 7, 1984 BRANCH
E. L. Kulawik
3215 Westmar Circle
Anchorage, Alaska 99508
William M. Riley
EIS Project Officer
Environmental Evaluation Branch M/S 443
Environmental Protective Agency
1200 Sixth Avenue
Seattle, Washington 98101
Subject: Red Dog Mine Project - Northwest Alaska
Dear Sir:
I strongly reccmtend that Cominco Alaska, Inc., and MAMA Regional Corporation be
allowed to develop the Red Dog Mine Project. Cominco is an able, established
mining company with extensive experience working in northern and/or arctic regions.
They are familiar with both the environment and the people of the arctic regions
and have successfully developed mining projects dealing with both. Cominco has
spent years studying and designing this project. They have utilized their expertise
to design a project with a minimum of environmental impact. Cominco and NRNA have
formed a joint venture with a goal of utilizing the local residents for the con-
struction and development of the mine facilities. I believe that Cominco's
design is both practical and cost effective. The design satisfactorily addresses
environmental impacts.
The development of the Fed Dog Mine Project as a source of strategic minerals for
the United States certainly establishes a priority for the project to be constructed
and placed in operation as soon as possible.
I spent three years involved with the construction of the Alaska Pipeline System.
I have also spent additional time working at Prudhoe Bay. From this experience
I am aware of the need to control and monitor a major project so that all facets
of the project are considered and addressed. Cominco has the experience to sat-
isfactorily construct and operate this mining project, (tore importantly, they
have the desire and ccranitment to get the job done.
Thank you. Comment noted.
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In sunmary I recormend the development of the Bed Dog Mine Project
because of the following:
1. Ccminco has the experience.
2. local residents will be enployed.
3. The design is adequate.
4. Environmental considerations will be adequately addressed.
5. The construction plan is practical.
6. The mine will supply needed strategic minerals.
7. The project will eiplcy native workers.
8. The project will utilize a regional native corporation as a
business partner.
Very truly yours.
Thank you. Comment noted.
Eugene L. Kulawik
General. Superintendent
EUC/cc
pc: file
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Frank MurtowM
May 5, 1984
Mr. William W. Riley
BIS Project Officer
Environmental Evaluation Branch M/S
Environmental Protection Agency
1200 Sixth Avenue
Seattle/ WA. 98101
Dear Mr. Riley:
The Resource Development Council appreciates the
opportunity to comment on the Draft Environmental
Impact Statement on the Red Dog project in Northwest
Alaska. The Resource Development Council is Alaska's
largest private economic-development corporation/
consisting of individuals and organizations
representing all resource sectors. We work together
to influence decisions and policies to achieve a
sound/ diversified private-sector economic base for
Alaska.
After reviewing the Draft EIS/ the Counci-1 gives its
support to Alternative I/ the environmentally
preferred alternative. A review of Table 2 clearly
shows the preferred plan having little actual impact
on the purposes for which Cape Krusenstern National
Monument was formed.
ough the Resource Development Council is pleased
with the selection of Alternative I as the preferred
plan/ we do have some points of concern with the draft
EIS. We believe indirect impact to caribou has been
overstated. This project should have little or no
impact on caribou migrations. There is no clear basis
to suggest significant impacts.
also express concern at the zero discharge
regulations adopted by EPA. These standards seem
overly restrictive/ especially since Red Dog Creek is
a naturally toxic stream. Considering that the mine
discharge will be many times cleaner than the natural
stream water is at the present time/ we feel that it
is ridiculous to hold the project developer to the
proposed water quality regulations. The bottom line
is that this mine development will actually enhance
water quality.
Thank you. Comment noted.
Although recent research. (Bergerud et al., 1984) has indicated
that industrial activities and transportation corridors do not affect
caribou productivity, these activities do alter caribou habitat and
may influence migration patterns. The scoping process for this
EIS identified major concerns for protection of wildlife, wildlife
habitat and subsistence activities. Discussion of caribou impacts
on pp. V-3 and V-41 states that although the Red Dog project
probably will not significantly impact caribou, increased future
traffic on the road might alter migration patterns or habitat utiliza-
tion. The EIS does not overstate caribou impacts, but instead
objectively addresses the legitimate concerns raised in the scoping
process.
At the present time, there is no process available to Cominco to
seek a variance to the zero discharge regulations.
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Page 2
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point of concern centers around the visual impact
section of the draft EIS. We believe these impacts have also
been overstated. It is difficult to determine how one would
be able to even see the road or port from a distance. We
question whether an analysis of visual impact should be
included in the document for those areas of private land. The
Council suggests the visual impact section be revised to show
that visual impact associated with this project is
insignificant.
Should the Cape Krusenstern Land exchange not take place/
the Red Dog project will be the ultimate test as to whether
the National Park Service and other agencies and groups will
honor in good faith one of the most important compromises of
ANILCA/ Title XI, the governing of transportation corridors
across national parks, monuments and wildlife refuges. We
will watch with great interest in how the process serves those
firms that require reasonable access across these areas to
develop their resources.
cV-p)cominco has taken a great deal of effort to address
environmental concerns in the planning of the Red Dog
project. We must question whether all the mitigation measures
proposed in the Draft EIS are necessary, especially those
pertaining to water quality.
The Resource Development Council commends the Environmental
Protection Agency for its thoroughness and objectivity in
compiling the draft EIS.
Sincerely,
RESOURCE DEVELOPMENT COUNCIL
for Alaska, Inc.
An evaluation of visual resources impacts is an integral part of the
EIS interdisciplinary review process mandated by Section 102(2)(A)
of NEPA. The VRM system developed by the U.S. Forest Service
was applied throughout the Red Dog project area to give a consis-
tent and accurate evaluation of visual impacts without regard to
specific land ownership.
Comment noted.
All mitigative measures have been carefully formulated to address
the environmental concerns raised in the scoping and draft review
processes. AM these measures serve a specific purpose and are
not deemed overly restrictive.
Thank you.
Carl Portman
Public Relations Director
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KORTH SLOPE BOROUGH
OFFICE OF THE MAYOR
P.O. Box 69
Barrow, Alaska 99723
Phone: 907-852-2611
Eugen* Browar, Mayor
May 10, 1984
X
I
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William M. Riley
EIS Project Officer
Enviornmental Evaluation Branch M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Riley:
This letter is in response to the Environmental Protection
Agency's (EPA) public meeting notice ftAK-003865-2 concerning
public comment upon the Draft Environmental Impact Statement
(DEIS) entitled, Red Dog Mine Project Northwest Alaska..
This DEIS has been well prepared document. It is clearly
organized and the various alternatives are presented in sufficient
detail for the making of reasoned judgements. It seems to have
fairly taken environmental and subsistence concerns into
consideration and presents a clear decision making sequence
regarding the choosing of a preferred alternative.
Upon review of the document I call your attention to the
following specific comments which are presented below by page.
.^ Page IV-65 : the title of Table IV-15 is misleading in that Point
Hope seems to be also considered under the title "Baseline
Population Forecast NANA Region, 1982 to 2010". The title
might better read "Baseline Population Forecast (1982 to
2010) For The NANA Region and Point Hope".
.p^Pages V-14 through V-17: In this section there is reference
to the possible implications of the human consumption of
fish which contain small amounts of metals such as cadmium,
zinc and copper.
The earlier expressed concerns of the North Slope Borough
regarding human health are still relevant and in that regard
Thank you. Comment noted.
The title of Table IV-15 (p. IV-65) has been clarified.
Concerns about human contamination from the ingestion of fish con-
taining trace metals are addressed on pp. V-14 & 15. A person
would have to daily ingest over 11.6 kg (25 Ib) (wet weight) of
char for 50 years before critical levels of cadmium were reached.
In addition, fish would be monitored for lethal and sublethal
effects due to the treatment plant discharge water through the
NPDES permit monitoring program. It might be appropriate for a
state or local agency to initiate a monitoring program similar to the
one proposed by this comment letter. However, such a program is
not deemed the responsibility of the EIS co-lead agencies or the
applicant.
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William M. Riley
May 10, 1984
Page Two
I refer you to my earlier letter to you (dated April 13,
1983, text of letter attached and to be included as part
of these comments).
(//-C.~}Paqe V-35: In this discussion of social, political and cultural
matters there is reference (paragraph 3) to the possible
"adjusting" of the boundaries of the North Slope Borough.
I am not sure why this matter is raised in the DEIS, however
the Borough views its boundaries as having been fixed at
its founding.
Pages V-81 to V-83: The brief consideration of monitoring is
somewhat disappointing, however, it correctly points out
that more precise monitoring programs will be established
in response to permit requirements.
01-
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ro
>) Unfortunately there doesn't seem to be mention of a
fish monitoring program (metals) however it might be implied
in the "water quality monitoring program" mentioned on page
V-82. I feel that such a program should be clearly stated
since the fish are potential human food.
fi£> Unfortunately there doesn't seem to be mention of a
human health monitoring program. Such a program should
include the mine workers as well as people who are down
stream, that is, the residents of Kivalina. In this regard
I refer you to my attached earlier letter (April 13) to
EPA.
Appendix 1, pages 20-50, Reclamation Plan: It is good to see
that a firm committment has been made to the concept of
site reclamation. The Borough should be involved in the
design of the specific reclamation projects and in the
longterm evaluation of their adequacy.
Regarding reclamation of the open pit mine (section
5.3.1), the last paragraph on page 28 notes that soluable
metal contributions to the Red Dog Creek will be minimal
after operations cease since "the mining plan calls for
the recovery of all ore with a high metal sulphide content
_ _ _ _". Although this may be the case, there should be
some discussion included that would consider a shut down
of the mine (for whatever reason) before all such ore has
been removed.
The first sentence on page 37 concerning
of the tailing impoundment doesn't seem to
possibly some words have been omitted.
In conclusion let me again note that this DEIS clearly
sets forth the data needed for a factual consideration of the
ing termination
:o make sense, r
1
The last sentence of 113 (p. V-35) has been modified. The sen-
tence now reads, "...borough that might be incorporated in the
NANA region."
This sentence now follows the first sentence of 114 (p. V-82):
"This monitoring program would include a flow-through biomoni-
toring facility that would continuously test the discharge water's
toxicity to cold water fish species."
Provisions for the mine workers' health and safety fall under the
jurisdiction of the Mining Safety and Health Administration (MSHA).
NANA or the NSB might want to initiate a human health monitoring
program for the residents of Kivalina, but such a monitoring pro-
gram is not believed to be the responsibility of the applicant or the
EIS co-lead agencies.
Thank you. Comment Noted.
In the event the mine were closed before all the ore was recovered/
all permit stipulations including treatment plant discharge water
quality would continue to be met.
Corrections have been made to this page of the Reclamation Plan.
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William M. Riley
May 19, 1984
Page Three
various alternatives. As can be seen from my above comments,
our major concerns focus upon long term monitoring, particularly
regarding human health and fish and caribou resources. Since
this project with its transportation corridor will likely provide
an impetus to other industrial activities within the southwestern
portion of the Borough we are very interested in seeing that
this development project moves forward in an environmentaly
sound manner.
I hope that these comments are useful to you and feel free
to contact me if additional detail is required.
Thank you. Comment noted.
Sincerely,
XJ «?•-"
Eugene Brower, Mayor
Attachment (Letter of April 13)
cc: Warren Matumeak, NSB Permitting
George Stevens, NSB Planning
Lester Suvlu, MSB Environmental Protection Office
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NORTH SLOPE BOROUGH
OFFICE OF THE MAYOR
P.O. Box 69
Barrow, Alaska 99723
Phone:907-852-2611
X
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Eugene Brewer, Mayor
April 13, 1983
Mr. Bill Reilly
Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Reilly:
In a recent meeting in Barrow, I understand that you and
some of my staff personnel reviewed various concerns that the
North Slope Borough has regarding the development of the Red
Dog Mine. In order to assist you in your planning efforts
relevant to the mine, let me urge that you consider the following
major concerns of the Borough:
1. Protection of Human Health
(a) Longterm residents of the area. The village
of Kivalina appears to be located downstream
from the proposed mine site. Since there has
been long term drainage through the proposed
mine site, it is possible that the people may
already be subject to some accumulation of
the ore body's heavy metals, possibly through
consumption af food items' (fish, caribou,
etc.) that themselves may have been affected.
It, therefore, seems reasonable that
prede.velopment ("baseline") data should be
obtained from long term residents of the area
regarding the possibility of heavy metal
accumulation. Such accumulation may be
unlikely, but it should be investigated at
the outset.
As development progresses a long term
monitoring effort should be established.
(b) Mine Workers. Since the workers will be
associated with mining, ore concentration,
and concentrate transportation, it seems
essential that a long terra health monitoring
program be implemented.
Mr. Bill Reilly
April 13, 1983
Page Two
2. Protection of the Environment and its Wildlife.
(a) Living Environment. Since there are
subsistence use species in the area (fish,
birds, caribou), there must be some long term
monitoring of such animals for the
accumulation of heavy metals.
In discussions with my staff, I
understand it was mentioned that the waters
flowing through the proposed mine site will
actually be made less toxic as time goes on.
If this is the case, then one would expect
greater use of the local streams by fish and
possibly by birds. This would provide for
longer residence times in less toxic (not
acutely toxic) water and thereby provide more
time for the bioaccumulation of heavy metals.
If this were to occur, there might actually be a
greater number of organisms using the area,
each becoming somewhat contaminated, who may
become human food at a site far removed.
An example might be greater fish use of
the streams and a subsequent greater catch
of these fish at some downstream site.
Thoughts such as this argue for a long term
monitoring program.
(b) Physical Environment. With the mining,
concentrating, and transporting of such ores,
it is essential that there be a long term
monitoring of the nearby waters, of the air
(stack emissions, dust) and of downwind soil
areas. It seems reasonable that as
development progresses, discharges to the
waters and air must be carefully monitored.
Regarding air contamination, it seems
possible that downwind areas could become
contaminated so that potential impacts to the
vegetation could affect caribou and other
such consumers.
3. Employment .of North Slop_e Borough Residents.
As the various forms of resource development
continue within the Borough, we seek to have these
activities also provide jobs for Borough
residents. In this instance, it seems quite
likely that residents of the village of Point Hope
would seek employment at the mine site.
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Mr. Bill Reilly
April 13, 1983
Page Three
It is also possible that other resources within
the Borough, such as coal, for power generation,
could be utilized and, therefore, be a source of
employment for Borough residents.
4. Compliance with North Slope Borough Regulations.
The Borough's Comprehensive Plan and Land
Management Regulations (CP&LMR) require that
operations associated with the Red Dog project be
reviewed for compliance with the policies of the
CP&L1IR. The proposed Red Dog activities will be
received and permitted under Chapter 60 of the
Land Management Regulations for Development
activities.
For informational purposes, I have enclosed a copy
of the Borough's permit application as well as the
permitting schedule. Should you have any
questions regarding this permitting process, you
should contact Mr. Warren Matumeak at 852-2611,
Ext. 269.
It is also essential that the Borough be involved
in matters relating to protection of human health
and protection of the environment as noted in
items 1 and 2 above.
In conclusion, let me note that the North Slope Borough is
pleased to see that there is interest in development of the ore
bodies in the Red Dog area/ If such development is to occur
within the Borough, it must go forward in a safe and
environmentally acceptable manner. This will be possible with
the application of gqod planning, good, technology and due
consideration to the interest of the parties involved.
I hope that you find these brief comments to be helpful and I
look forward to additional discussions on these matters.
Sincerely,
Eugene Brower, Mayor
Enclosures (2)
cc: George 0. Stevens, Planning Director
Warren Matumeak, MSB Zoning Administrator
Thomas F. Albert, MSB Senior Scientist
Shehla Anjum, Planning Liaison, Anchorage
Harry Noah, Cominco, Alaska
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AtlantlcRlchlleldCompany 555 Seventeenth Street
Denver. Colorado 80202
Telephone 303 293 7577
J. R. Mitchell
Manager
Public Lands Coordination
Government Relations
May 11, 1984
MAY 141984
ENVIRONMENTAL EVALUATION
BRANCH
William M. Riley
EIS Project Officer
Environmental Evaluation Branch M/S 443
U.S. EPA
1200 Sixth Ave.
Seattle, WA 98101
RE:
Draft Environmental Impact Statement
Red Dog Mine Project, Northwest Alaska
Dear Mr. Riley:
Atlantic Richfield Company would like to take this
opportunity to provide the U.S. Environmental
Protection Agency with our comments concerning the
Draft Environmental Impact Statement, Red Dog Mine
Project, Northwest Alaska. Upon careful review of
the DEIS, we concur that Alternative 1, comprised of
the southern corridor, UABM-28 port site and the
offshore island facility is the environmentally
(/2-/4) preferred alternative. We do, however, take
^ exception to the reference to "... de facto
wilderness ..." found in the section on "Irreversible
and Irretrievable Commitments of Resources" on page
V-97. The Alaska National Interest Lands
Conservation Act (ANILCA) is a very specific piece of
legislation that contains no reference to "de facto
wilderness" and provides no implications of any such
land use category. Additionally, the land use
planning legislation and regulations of the
Department of the Interior do not recognize such a
land use classification. It was the clear intent of
ANILCA to allow, if not encourage, development in an
environmentally sound manner in the Red Dog Mine
Project area. For these reasons, we believe the
reference to "de facto wilderness" is inappropriate
and genuinely misleading. As such, it should not be
used in the Final EIS.
Atlantic Richfield supports effective land and
resource management planning and actions that provide
for reasonable protection of the environment, while
at the same time, providing for the exploration and
development of natural resources. Inflexible
environmental laws and regulations have often
characterized the manner in which the government has
Any mention of "de facto wilderness" has been eliminated from the
text The fourth line on p. V-97 now reads, "...event, the un-
developed nature of the project area..." Similar changes were
made on pp V-90 and V-94.
Thank you. Comment noted.
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William M. Riley
May 11, 1984
Page 2
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constrained the search for and development o£
additional energy and mineral supplies. Such
constraints have severely limited the accessibility
and utilization of energy and mineral resources
needed to add stability to the nation's economy and
to reduce its dependence on insecure foreign imports.
Atlantic Richfield Company believes that energy and
mineral resources must play a major role in land
management decisions. The exploration for and
development of resources, such as those at Red Dog,
should be provided for by opening and maintaining
access to areas which may contain these resources.
By doing this, we as a nation will achieve the goals
and objectives of multiple use management.
We appreciate this opportunity to provide comments on
the DEIS for the Red Dog Mine Project. If you would
like to discuss our comments or require further
information, please do not hesitate to contact us.
Sincerely,
J. R, Mitche
Thank you. Comment noted.
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GCO Minerals Company
10)11
li*
MAY 141984
ENVIRONMENTAL EVALUATION
BRANCH
May 11, 1984
1031 WEST 4TM
ANCHORAGE
MTJ9UI
X
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Mr. William M. Riley
EIS Project Officer
Environmental Evaluation Branch (M/S 443)
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
HOUSTON Tf HAS 7-210
Ml 65' ^61
TWX 910681 2>-B
RE:
Red Dog Project
Draft Environmental Impact Statement
Dear Mr. Riley:
GCO Minerals Company (GCO) has been active in mineral explora-
tion and development in Alaska for over ten years. In particular,
GCO has been very active in, and currently controls substantial
mineral holdings in, the Red Dog project area. Because of our
background in mineral development in Alaska and our mineral
interests in the Red Dog project area, we feel we are uniquely
qualified to provide the following comments on the Red Dog pro-
ject Draft EIS.
GCO enthusiastically supports che development of "the Red Dog
project and feels that the Red Dog project will greatly benefit
the HANA Region and the State of Alaska. The Draft EIS demon-
strates that the project, as proposed, can be developed in an
environmentally sound manner. GCO believes that most components
of this project have been adequately addressed and the necessary
mitigations outlined. However, GCO does have specific concerns
related to the location of the possible portsites and portions of
the environmentally preferred transportation corridor on private
land and how this relates to the regional use aspect of the pro-
ject.
Regional use was identified during the scoping process as one
of twelve issues of major concern. It is one of the issues asso-
ciated with the Red Dog project which compels the EIS process to
examine the effects of the project development in the broader
context of a program EIS as well as a project EIS. The broader
aspect of this issue is addressed indirectly by the DEIS in the
recognition of the fact that the portsite will serve as a regional
distribution point for the local villages, and the transportation
corridor and portsite may encourage and enhance the feasibility
of many future resource developments, including oil & gas, coal
and hardrock minerals. This aspect of the regional use issue is
magnified by the State of Alaska's position that only one road
Thank you. Comment noted.
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Mr. William M. Riley
Page 2
May 11, 1984
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and portsite will be permitted and that this transportation
system is to be used by all resource developments in the project
area. The transportation corridor and portsite will thus have a
significant impact on the future development of the region which
will extend far beyond the Red Dog project.
) Because of the regional importance of the transportation facili-
ties to future development of the region and given the facts that
these facilities will, to a large extent, be located on private
lands and that only one road and portsite will be permitted, GCO
Minerals Company, as one of the potential future resource developers,
feels strongly that the DEIS does not adequately address the issue
of guaranteed access to the transportation and portsite facilities
by other industrial users. While the DEIS presents the stated
positions of the State of Alaska, the federal government and Nana
Regional Corporation as the affected landowners in the project
area (Chapter V, page 75), it sidesteps the issue of guaranteed
reasonable access by assuming that these stated positions are
guarantees. In fact, the positions of the state and federal
governments are policies which can be changed by directive or
political pressure, and Nana's position can easily be changed by
corporate directive. Therefore, these stated positions in no way
constitute a guarantee of reasonable access and use by "other
industrial resource users.
In order to clarify the issue for the record, it is suggested
that any written documents stating the position(s) of any of the
affected landowners be included in the EIS in their entirety.
Additionally, the guarantee of access should be addressed more
directly to ensure that the public interest is adequately served.
GCO suggests that a reasonable approach to addressing this issue
can be found in the method in which the DEIS addresses the issue
of Nana's authority to suspend operations of the project during
periods of caribou migration. The DEIS states in Chapter V, page
42, "To maximize the probability that such good intentions would
work, a specific monitoring plan should be developed . . . This
plan should be established before actual construction begins ..."
GCO feels that similiar treatment of the issue of guaranteed access
is certainly warranted and would substantially increase the prob-
ability that the good intentions which currently exist are
carried forward to a conclusion which will satisfactorily serve
the public interest.
The EIS should recognize that should the assumption of guaran-
teed access fail to materialize for any reason, the probability
of construction of other transportation facilities in the region
will be substantially increased. Not only would this cast aside
the State of Alaska's prudent and environmentally sound policy of
restricting these multiple transportation facilities, but would
also invalidate the EIS impact analysis which is based solely on
the one regional transportation system scenario. Under the
scenario of multiple transportation facilities, there would be
As stated on p. V-75 (14), the State would only authorize develop-
ment of a single transportation corridor and port site in northwest
Alaska, and has stated that those improvements must be available
to other users. Public access to the privately owned facilities
would be guaranteed through reciprocal right-of-way agreements
between the land owner and the potential user. In addition,
guaranteed access to other users would be a condition of the
State's right-of-way permit which would have to be issued prior to
construction. The State's position on guaranteed access has not
changed (see the letter from DNR at the back of this section).
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Mr. William M. Riley
Page 3
May 11, 1984
substantial increases in the environmental consequences determined
by this EIS due to the high probability of additional resource
developments in the region. In the context of a multiple trans-
portation facilities scenario, this DEIS as currently prepared
and written would be totally inadequate.
Therefore, in order for the EIS to adequately address the
issue of guaranteed access, to validate the impact analysis used
for the regional use issue, and to ensure the adequacy of the
entire document, the EIS must clearly state that comprehensive,
reciprocal right-of-way agreements covering the transportation
corridor, tidelands and associated port development areas should
be acquired prior to construction of the facilities. There is no
question of the need for these guarantees, and inclusion of such
a statement of need is clearly within the scope of the document.
Sincerely,
J. M. Britton
District Geologist
JMBislg
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X
GO
Bear Creek Mining Company
Exploration Division of Kennecott Corporation
Of/ICC
May 11, 1984
William M. Riley
EIS Project Officer
Environmental Evaluation Branch (M/S 443)
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
MAY 14193*
EWIRONMHHJLWIUATION
Re: Draft Environmental Impact Statement, Red Dog Mine
Project, Northwestern Alaska
Dear Mr. Riley:
Bear Creek Mining Company has received and reviewed the Draft
Environmental Impact Statement for the Red Dog mine project
and appreciates this opportunity to submit written comments
on the Draft. Bear Creek is the exploration division of
Kennecott and is currently active in minerals exploration in
northwestern Alaska.
In general, we feel that the EPA and DOI have done a good job
in preparing the Red Dog EIS and are to be complemented for
their efforts. We strongly agree that Alternative r (road
along southern corridor to a port site at VABM 28 and an off-
shore island) is the Preferred Alternative. This alternative
is not only the most economically feasible option, but will
also have the least environmental impact. Although the
Preferred Alternative will require a road through the north-
west corner of Cape Krusenstern National Monument, the E.I.S.
clearly shows that there is no economically feasible and
prudent alternative.
(//y-/t)We do have some concern with regard to the chapter on the
environmental consequences (Chapter V) of the Red Dog mine.
The discussion of the impacts that the Red Dog project will
have on terrestrial wildlife appears to exaggerate the poten-
tial impact on caribou. Several statements are made that are
conjectural in nature. Several recent studies show that
development projects such as Red Dog have little or no impact
on caribou habitat and migrations; data from these studies
should be incorporated in the Red Dog EIS.
(Vy-S>With regard to water duality, the "zero discharge" require-
ment for process wastewater from the Red Dog mill makes
little sense. Because of this restrictive requirement, the
tailings pond at Red Dog must be much larger than normal and,
consequently, the surface disturbance will be much greater.
The processed wastewater at Red Dog will be cleaner than the
Thank you. Comment noted.
Although recent research (Bergerud et al., 1984) has indicated
that industrial activities and transportation corridors do not affect
caribou productivity, these activities do alter caribou habitat and
may influence migration patterns. The scoping process for this
EIS identified major concerns for protection of wildlife, wildlife
habitat and subsistence. Discussion of caribou impacts on pp. V-3
and V-41 states that although the Red Dog project probably will
not significantly impact caribou, increased future traffic on the
road might alter migration patterns or habitat utilization. The EIS
does not overstate caribou impacts., but instead objectively
addresses the legitimate concerns raised in the scoping process.
1111 DOWUNG ROAD
ANCHORAGE, ALASKA 99502
PHONE: 19071 3*4-1322
TELECOPIER: (907) 3*4-0433
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William M. Riley
May 11, 1984
Page 2
existinq water in Red Dog Creek. This wastewater must even--
tually be discharged in order to reclaim the tailings pond
upon termination of the mining operations. It makes more
sense to allow regulated discharge of processed wastewater
during the mining operations in order to keep the surface
disturbance of the tailing pond to the minimum. The EPA
should use some flexibility in administering the "zero dis-
charge" requirement, and look at projects on a case by case
basis. The Red Dog project is a case where EPA should allow
regulated discharge in order to reduce the overall environ-
mental impact of the project.
We take exception to the discussion on the impact the project
will have on visual resources. Much of the development will
take place on private lands. Those public lands affected by
the project have little or no recreational use. We feel the
visual impact of the project will be insignificant.
-^Finally, we feel the EIS should address the impact on the
local residents should they be denied the opportunity of
employment should the project be delayed or not allowed to
proceed. The project will provide several hundred year-round
jobs where little other employment opportunity exists. Bear
Creek Mining Company strongly supports the development of the
Red Dog project.
We ask that you take into consideration our comments when
preparing the final EIS and thank you for giving us the
opportunity to comment on the Draft. Please contact us
should you have any questions regarding our comments.
JaM 'A\ Hammitt
SeWolf Geologist
JWH:dk
At the present time, there is no process available to Cominco to
seek a variance to the zero discharge regulations.
An evaluation of visual resources impacts is an integral part of the
EIS interdisciplinary review process mandated by Section 102(2)(A)
of NEPA. The VRM system developed by the U.S. Forest Service
was applied throughout the Red Dog project area to give a con-
sistent and accurate evaluation of visual impacts without regard to
specific land ownership.
The economic and sociocultural consequences of forfeit or delay of
the mining project are discussed in the No Action Alternative (pp.
V-77 & 78) and are implicit in the discussion of socioeconomic
impacts of the proposed project alternatives (pp. V-27 through
V-33).
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DEPARTMENT OF THE ARMY
ALASKA DISTRICT. CORPS OF ENGINEERS
POUCH 898
May 11, 1984
Regulatory Branch
Special Actions Section
MAY 14193*
ENVIRONMENTAL EVALUATION
BRANCH
X
I
to
CO
Mr. Bill Rlley
Environmental Evaluation Branch M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Riley:
The Corps of Engineers (USCE) has completed its review of the Draft
Environmental Impact Statement (EIS) for the Red Dog Mine Project. Our
review of the Draft EIS was restricted to those portions of the project
which are under the USCE regulatory jurisdiction.
In general the Draft EIS addresses the majority of the USCE concerns
and the draft tends to satisfy our Department of the Army implementing
regulation for the National Environmental Policy Act (33 CFR Part 230).
Our specific comments are as follows:
(is-/fy 1- Page x Paragraph 2 Identification of Preferred Alternative
Add: "The USCE has not indentified a preferred alternative and will
not until the Record of Decision."
Pursuant to our implementing regulations (33 CFR Part 230, Appendix B)
the USCE cannot identify a perferred alternative until the Record of
Decision. The primary reason for this requirement is that the District
Engineer must remain unbiased during the processing of an application. He
must allow for a public review of the project and must consider all
comments before making a permit decision. By identifying a preferred
alternative the District Engineer is no longer unbiased. However, an
environmentally preferred alternative can be identified in the EIS.
(/S-B)2. Page 1-1 Paragraph 2 Last Sentence
Modify the sentence to read: "...(CEQ), EPA, Department of the Army,
and..."
(IS'-£$3. Page 1-1 Paragraph 5
Modify the sentence to read:
over this action..."
"...Alaska District, has jurisdiction
He did not exert jurisdiction over this action. The USCE has
jurisdiction as a result of the passage of the River and Harbor Act of
1899 and the Clean Water Act.
The following sentence has been added to the end of 112! (p. x):
"The Corps has not identified a preferred alternate anf will not
until the Record of Decision."
The 9th line of 12 (p. 1-1) now reads, ";••(«<}>, EPA the u.S
Department of the Amy and the U.S...." The second I me of 12
(p I-2) now reads, "...Alaska District, has jurisdiction over...
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-2-
X
I
U>
-U
^/jr- e} 4 . Page 1-2 Paragraph 1
Delete: "of 1972"
f/5-c)5. Page 1-2 Paragraph 1, next to Last Sentence
Modify the sentence to read: "could result in the denial of the
permit, issuance of the permit, or..."
The District Engineer will deny the DA permits if he determines that
the project is not in the public's interest.
f/s -C>)6. Page 1-8 Paragraph 6 U.S. Environmental Protection Agency:
Delete: "Review of U.S. Army Corps of Engineers Section 104 Permit
for comformance with Section 404(b)(l) guidelines."
The purpose of this section is to identify what permits and approvals
Cominco must obtain prior to the construction and operation of the Red Dog
Mine project. Cominco is not required to obtain approval from EPA
concerning compliance with 404(b) (1) guidelines. For additional comments
see our November 17, 1983 comments on the preliminary Draft EIS.
£75~ti)7. Page 1-8 paragraph 7 U.S. Army Corps of Engineers:
Modify the sentences to read: "...Section 404 of the Clean Water
Act..." and ...Section 10 of the River and Harbor Act of 1899..."
f/£-fy&. Page II-4 Paragraph 2
Define "unmineralized wastes". Any dredged or fill material that is
.used in the construction of the tailings dam or road must meet 404(b)(l)
guidelines. More specifically 40 CFR 230.11(d).
(/s-ty). Page 11-19 Paragraph Z
A more detailed discussion is required as to the practicability and
feasibility of only using material sites out side the Monument. Describe
how the road would be constructed if material sites within the Monument
are not authorized.
CV5--
/010. Page 11-33 Last Paragraph
Define: "suitable mine wastes". See comment 8
Page 111-51 Last Paragraph
See comment 1
The second paragraph of p. 1-2 has been modified. In the second
line, "...of 1972..." was deleted, and the seventh line was mod-
ified to read: "...Corps could result in denial of the permit,
issuance of the permit, or issuance..."
The second bullet under EPA (pp. 1-9 & 10) was changed to read:
""Review of U.S. Army Corps of Engineers Section 404 Permit."
The first bullet under Corps (p. I-10) was changed to read,
"...authority of Section 404 of the Clean Water Act (discharge...11.
The second bullet under Corps (p. 1-10) was changed to read,
"...of Section 10 of the River and Harbor Act of 1899 (any..."
The fourth line of 112 (p. 11-4) now reads, "Unmineralized over-
burden would..." The fifth line of 112 (p. 11-4) was changed to
read, "Mineralized overburden would..."
The text discusses the impacts of only utilizing borrow sites
located outside Cape Krusenstern National Monument on pp. 11-16
and 11-19, V-37 & 38, V-50 & 51 and p. V-67. In addition, the
Title XI application provides further discussion of the practicability
and feasibility of acquiring borrow only outside the Monument.
The sixth line of the first paragraph (p. 11-36)
"Suitable mine overburden would..."
now reads,
The following sentence was added to the paragraph on p. 111-52:
"The Corps has not identified a preferred alternative and will not
until the Record of Decision."
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-3-
Page IV-33 Last Paragraph
Both Bering Cisco and least Cisco are normally considered migratory.
Page V-19 Paragraph 1
Experience with the Prudhoe Bay Waterflood Environmental Monitoring
Program indicates that dust from roads occurs throughout the year
including the winter. '
)l4. Page V-47 Paragraph 3
Any temporary stream diversions constructed in waters of the United
States will require Department of the Army authorization. The EIS should
describe these diversion structures in detail (size, location, purpose,
7)15. Page V-58 Paragraph 4
Describe in more detail the dredging that could occur on the shore.
Where would the dredging take place? Would dredging occur in Navigable
Waters of the United States? What is the purpose of and need for the
dredging?
f/?-fl)\f>. Page V-58 Paragraph 2:
A more detailed disucssion of the local effects of the causeway on
™ littoral drift is required. Is it expected that erosion down drift from
the causeway would breach the port lagoon? Would some maintenance
dredging be required in the future?
17. Appendix 6 ANILCA Application
Attachment C of the ANILCA Application is missing the first four
pages. Enclosed is a copy of those pages.
Thank you for the opportunity to comment of the Draft EIS. Should you
co"ments' Please contact Mr- J°e Williamson
I
The seventh line of the last paragraph (p. IV-33) was changed to
read, "Other species present in the Wulik include..."
The last sentence of the first paragraph (p. V-19) was changed to
read, "...June through August, although some road dust might be
generated throughout the year."
Discussion of the temporary stream diversions needed for road con-
struction has been added to p. V-47 (H4).
Dredging activities would occur at those locations described in the
Corps Section 404 Permit application (Appendix 5) and authorized
by the Department of the Army in their permitting process. The
second sentence in the first paragraph under Marine Biology (p.
V-52) has been modified to read, "Port Lagoon,..., would be
breached to shelter a barge-mounted construction camp, but no
dredging would take place within the lagoon." The fourth sen-
tence in the next to the last paragraph on p. V-59 has been
deleted.
The discussion on p. V-58 (112) has been expanded to indicate that
down-drift erosion could breach Port Lagoon, but since it would be
intentionally breached anyway, additional impacts would be insig-
nificant (see pp. V-52 and V-59).
These missing pages have been included in the application.
Sincerely,
Enclosure
Larry L\ Reeder
Chief, Special Actions Section
Regulatory Branch
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x:
i
JO
CD
ALASKA MINERS ASSOCIATION, INC.
509 W Third Ave . Suite 17 Anchorage. Alaska 99501 (907) 276-0347
May 10, 1984 fn
MAY 141984
ENVIRONMENTAL EVALUATION
BRANCH
Mr. William W. Riley
EIS Project Officer
Environmental Evaluation Branch
M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Riley:
The Alaska Miners Association appreciates the opportunity to comment on the
Draft Environmental Impact Statement for the Red Dog. Mine Project. We would
like to commend the hard work and obvious professionalism of those who have
compiled this DEIS. The Red Dog Project represents an unparalleled
opportunity to enhance the minerals industry in Alaska through a unique
cooperative effort by private industry, native corporations, and local, state,
and federal agencies. Much of the world's mineral industry and financial
leadership will watch the progress of Red Dog Mine for an indication of what
lies in store for mining in our state.
Alaska Miners Association strongly urges that Alternative I be adopted as
the most appropriate plan for this project. Alternative I is the most
environmentally sound proposal as it would have the least impact on fisheries,
wi-ldlife, and subsistence activities of the area. The Alaska Miners
Association would like the DEIS to state that the disturbance of natural
landscape may frequency have positive benefits for wildlife habitat. Some of
the benefits may include improved quality and increased quantity of vegetation
and nesting areas. The disturbance of the natural landscape may be compared
to a habitat that is created by a beaver. While some benefits are lost,
others are gained as the beaver creates a home for itself and a habitat for a
variety for other animal life.
^z believe that the potential indirect impact on caribou cited in the DEIS
is negligible. A recent report on the caribou in the Dunkle Mine area of Denali
National Park concluded that mining in the area have little effect on the the
caribou population. Certainly, evidence of the caribou utilizing the lands
that the Trans-Alaska Pipeline cross has shown that the migratory patterns of
those animals are not adversely affected.
The Alaska Miners Association is extremely concerned at the overly restrictive
water quality criteria imposed by the Environmental Protection Agency. The
water quality criteria adopted by the EPA in 1982 is unrealistic for the Red
Dog Creek and many other creeks and rivers in Alaska. We suggest a re-
evaluation of the discharge requirement to insure a realistic obtainable
standard.
Thank you. Comment noted.
Potential impacts to wildlife habitat are discussed on pp. V-3 & 4,
and V-40 to V-45.
Although recent research (Bergerud et al , 1984) has indicated
that industrial activities and transportation corridors do not affect
caribou productivity, these activities do alter caribou habitat and
may influence migration patterns. The scoping process for this
EIS identified ma|or concerns for protection of wildlife, wildlife
habitat and subsistence Discussion of caribou impacts on pp V-3
and V-41 states that although the Red Dog project probably will
not significantly impact caribou, increased future traffic on the
road might alter migration patterns or habitat utilization. The EIS
does not overstate caribou impacts, but instead objectively
addresses the legitimate concerns raised in the scoping process.
At the present time, there is no process available to Commco to
seek a variance to the zero discharge regulations.
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ALASKA MINERS ASSOCIATION, INC.
Mr. William H. Rlley
May 10, 1984
Page 2
00
•vj
) The visual resource section within the DEIS is misleading and should be
rewritten. The method used to evaluate the visual resources should be looked
at closely. The area in which the Project and access route is located has a
low recreational use and the visual impact associated with this Project is
insignificant. It should also be noted that reclamation will restore the
Project area to an appearance resembling its natural surrounding terrain.
>The Alaska Miners Association objects to the DEIS' reference to de facto
wilderness. Such terminology has the effect of suggesting a new land
classification status. The term de facto should be removed from this text.
Wilderness is a legal term used for classifying lands. The U.S. Congress has
the final responsibility for making wilderness classifications. In this Draft
Environmental Impact Statement, lands should not be termed wilderness or
de facto wilderness based on a visual perception, but only on Congressional
approval. We would like to suggest that this DEIS refrain from creating a new
land status in Alaska and simply report that the lands are presently
undeveloped.
measures suggested in the DEIS seem out of place. Cominco/NANA
have taken a common sense approach when addressing environmental concerns in
the planning process of the Red Dog Project. We would like to ask the EPA and DOI to
take a close look at mitigation measures. We believe that it will be
discovered that no mitigating measures will be necessary.
The Alaska Miners Association is particularly supportive of the DEIS citing of
the minimal impact of road construction through Cape Krusenstern National
Monument. It is in our view that this is the prudent Alternative and that it
is compatible for the purposes for which the Cape Krusenstern National
Monument was established.
Alternative I provides for the most economy access route for this Project. It
takes into consideration the economic future of Alaska. Alaska Miners
Association wholly supports this type of planning.
An evaluation of visual resources impacts is an integral part of the
EIS interdisciplinary review process mandated by Section 102(2)(A)
of NEPA. The VRM system developed by the U.S. Forest Service
was applied throughout the Red Dog project area to give a con-
sistent and accurate evaluation of visual impacts without regard to
specific land ownership.
Any mention of "de facto wilderness" has been eliminated from the
text. The fourtrT7ine on p. V-97 now reads, "...event, the un-
developed nature of the project..." Similar changes were made
on pp. V-90 and V-94.
All mitigative measures have been carefully formulated to address
the environmental concerns raised in the scoping and draft review
processes. All these measures serve a specific purpose and are
not deemed overly restrictive.
Thank you. Comment noted.
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8/11 SHtrrilLD, GOVERNOR
00
00
OFFICE OF THE GOVERNOR •
OFFICE OF MANAGEMENT AND BUDGET '
DIVISION OF GOVERNMENTAL COORDINATION
May 14, 1984
TOUCH AW
JUNEAU. ALASKA 99811
PHONE (907)465-3562
'•iAY : 5 1984
ENVIRONMENT/". EYALUAI.ON
BRANCH
Mr. William Riley
EIS Project Officer
Environmental Evaluation Branch
Mail Stop 443
Environmental Protection Branch
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr Riley:
Thank you for this opportunity to review and comment on the Draft
Environmental Impact Statement (DEIS) for the proposed Red Dog
Mine Project in Northwest Alaska. The DEIS materials are
extremely well organized, comprehensive, and reflect a firm
commitment to project compatibility with the environmental
conditions. The succinct documentation and cooperative attitude
of the involved federal agencies and NANA-Cominco has facilitated
our review effort.
The State reviewing agencies unanimously support Alternative 1,
the preferred alternative. Our page-specific comments are listed
as an addendum to this letter (enclosed) .
Although the DEIS appendix contains notice of the project related
federal permits, this response is focused on the conceptual
design of the project alternatives and the support information.
The State's comprehensive permit review will be conducted in
conjunction with the Alaska Coastal Management Program
consistency review which is scheduled for completion prior to
your final record of decision.
We appreciate the responsiveness you have shown to the state's
preliminary recommendations for the Red Dog project and your
consideration of the attached comments.
Sincerely,
Enclosure
cc: Distribution list
Thank you. Comment noted.
L. Grogan
Associate Director
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State of Alaska
Page-Specific Comments on the Red Dog DEIS
Enclosure: Grogan letter to Bill Riley, May 11, 1984
CHAPTER I
W
CO
1-9; State of Alaska Permits.
Under Title 16, the Department of Fish and Game has two
distinct approvals; the Anadromous Fish Protection permit
(AS 16.05.870), and the Fishways for obstructions to fish
passage permit (AS 16.05.840).
The Department of Natural Resources' Land Use Permit also
should be added to this list.
Under ADF&G (p. 1-10) the following bullet was added: "° Title 16
Fishways for Obstructions to Fish Passage Permit." Under ONR
(p. 1-11) the following bullet was added: "° Land Use Permit."
Chapter II
f!7-&)'S. 11-16; Road Construction.
While it is common practice to overlay a subbase material
for a roadbed in permafrost environments, the 2 meter
thickness may not be adequate for some soil groups. It
should be noted that final road bed depth will be dependent
on soil types, foundation conditions, topography, and
The text on p. iv (last fl) and p. 11-16 (114) was modified to indi-
cate that 2.0 m (6.5 ft) would be an average thickness of roadbed
fill, and that the fill thickness would be adequate to prevent ther-
mal degradation. The road would be designed to meet Arctic
engineering specifications for roadway construction. Before a
right-of-way permit were issued by the State, detailed road de-
signs would be submitted by Cominco for review by appropriate
agencies including DNR, DOT/PF and ADF&G.
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allowable settlement. Information on the actual design
criteria and process could be added for clarity.
11-16; Borrow Sites.
A statement that some material sites will remain active for
road maintenance should be added. Also, there is an ongoing
need for construction material in Kivalina. Material sites
which remain open for road maintenance may provide options
for meeting Kivalina's gravel needs.
The first paragraph under Borrow Sites (pp. 11-16 & 11-18) has
been modified to indicate that borrow sites would supply gravel for
road construction as well as road maintenance. It has not been
determined at this time which borrow sites would be used for road
maintenance, or whether gravel would be available to Kivalina.
X
I
11-19; Port Site.
The COE public notice (Appendix 5, sheet 11 of 1'3) shows a
typical borrow pit cross-section, including the drainage
ditch. No additional drainage design is portrayed for
Borrow Site 1, the location of the Coastal Concentrate
Storage Facility. What is the planned drainage and collec-
tion system for this area? What risks exist and what
preventative measures are to be taken regarding potential
ground water contamination or hazardous substance spill in
the area?
Additional description of the concentrate storage facility has been
added to the paragraph on pp. 11-19 and II-30. Settling ponds
would be constructed to collect any runoff from around the site.
Discussion of potential impacts of drainage from the concentrate
storage facility has been added to pp. V-46 and V-48.
Fig. 11-19, Fig. 11-15; Onshore Port Site Facility.
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X
I
Regional use of the project components, particularly the
port, is identified as a major project issue (#9, p. 1-8).
In response to this issue, the onshore port site facilities
should be located in a manner which will allow unobstructed
use and maneuverability for other future port users.
11-30; Offshore Island.
The DEIS concludes that the 544 Mg steel plates, 181 Mg
steel bulkhead reinforcement, and 95,000 yd3 of gravel will
provide the ice strengthening and stability necessary for
the Northwest environment. Assumptions about the forces of
ice, wave, and scour, along with a generalized version of
the engineering calculations is necessary for a -critical
project review.
. 11-17; Ballasted Tanker.
The width of the tanker is omitted from the diagram. This
information is necessary to develop, and compare, storage
volume estimates for each alternative.
Figures 11-14 and II-15 (pp. 11-28 & 29) are conceptual depictions
only. The actual design of the port site facilities would be incor-
porated into DNR's Tidelands Use Permit and reviewed by appro-
priate state and federal agencies. As stated on p. V-75 (114), the
State has authorized development of a single transportation corri-
dor and port site in northwest Alaska, and stated that those
improvements must be available to other users. Public access to
the privately owned facilities would be guaranteed through recip-
rocal right-of-way agreements.
Additional design information on the ice, wave and scour forces
that are expected to act on the ballasted VLCC tanker (offshore
island) is provided in a letter from Mr. Harry Noah of Cominco
Alaska to Mr. Keith Kelton of DEC (Noah, 1984). A summary of
the information contained in that letter is presented below.
The ship would be situated on the sea floor in such a way as to
induce compressive forces in the ship's steel (see p. 11-30). Steel
in compression will not fail by embrittlement in cold weather. The
global ice forces expected to be exerted on the length of the ship
would be 36,280 Mg (40,000 tons). Ice strengthening would be
applied to the ship to allow it to withstand up to 108,840 Mg
(120,000 tons) of global ice forces. This would provide a safety
factor of three to prevent crushing by expected ice forces. Data
indicate that pressures between 453 and 635 Mg (500 and 700 tons)
of penetrating ice force can be expected on any one square meter
of the ship's side at the waterline. The design criterion for the
ice strengthening of the ship's sides to resist penetration would be
1,270 Mg (1,400 tons) on any one square meter. Local denting
but not puncture would be tolerated. This would provide a safety
factor of two to prevent puncture by expected ice forces. Wave
velocities in the vicinity of the tanker would be expected to pro-
duce near-bottom currents with velocities ranging from 0.9 to 1.5
m/s (3 to 5 ft/s). A storm event might produce near-bottom cur-
rents with velocities ranging from 1.8 to 2.4 m/s (6 to 8 ft/s).
Cominco does not expect these current velocities to produce signi-
ficant scour around the tanker. However, if the stability of the
tanker were jeopardized by erosion during a severe storm event,
measures would be taken to replace eroded material and/or prevent
additional erosion.
The text on p. 11-32 and Figure 11-17 (p. II-33) have been mod-
ified to show the approximate width of the ballasted tanker.
Chapter VI
{V7-/OP.VI-92; Marine Birds and Mammals.
1
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#y Bowhead whales are not adequately addressed. This species
is pursued annually by subsistence hunters from Kivalina.
Though they have not always been successful, this April-the
hunters did take a bowhead whale. Supply and concentrate
shipping activities could affect the bowhead whale migration
patterns.
. IV-54; Subsistence.
The DEIS overlooks the local subsistence utilization of
bowhead whales, ptarmigan, hares, Arctic fox, and driftwood.
All of these are important to the continued cultural
practices of the residents within the area, and could be
impacted by the Red Dog development.
ro
(/7-J*).P. IV-59; Subsistence.
We agree that a "typical year" can not be realistically
described for a subsistence activity. However, the FEIS
should acknowledge that detrimental impacts could shift the
intensity of subsistence pursuits to alternative species,
thereby causing an indirect impact.
Bowhead whale migration patterns are discussed on p. IV-43 (112).
Subsistence use of bowhead whales by Kivalina residents is shown
on Fig. IV-14 (p. tV-58). Impacts to marine mammals, specifically
bowheads, are discussed on p. V-56 (112). Impacts to the subsis-
tence use of marine mammals (including bowheads) are discussed
on pp. V-72 & 73. In addition, the Endangered Species Biological
Assessment (Appendix 3) lists guidelines that would be adhered to
in order to prevent any harassment of endangered whales (includ-
ing bowheads) in the project area.
The discussion of subsistence resources on p. IV-54 (115) was
expanded to discuss the use of bowheads, ptarmigan, hares,
Arctic fox and driftwood.
The first paragraph of the Subsistence discussion (p. V-24) has
been modified to note that harvest pressure could shift to different
populations and result in adverse impacts to some species.
We believe the, DEIS oversimplifies the subsistence
activities of Noatak and Kivilina by characterizing them as
land animal or marine mammal oriented, respectively. This
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(l-j-ff)analysis omits the importance of the overlapping pursuits of
species and the importance of the trade and barter between
communities, households, and individuals. The lumping of
subsistence activity also deleted or masked much of the
variability (seasonal, family, and annual) in subsistence
efforts and success.
-)p. IV-72; Hunting and Fishing.
The data on caribou harvest (paragraph .2) should be attri-
buted to J. Coady instead of A. Ott. The citation used
referred to A. Ott's letter which was a transmittal of DFG
information provided by J. Coady.
The last paragraph on p. IV-54 has been modified to further
explain variability in subsistence patterns and the importance of
sharing and trade.
The citation on p. IV-72 (([2) was changed from "(Ott, 1983)" to
"(Coady, 1983)." The change was also made in the bibliography.
OO Chapter V
. V-3; Terrestrial Wildlife.
Two minor ommissions are noted in this section. First, we
believe ptarmigan utilize the shrub and tundra habitats
which will be affected by the development of the mine site
and the transportation corridor. This species should be
addressed in the FEIS. Second, while minor, there will be
direct loss of moose habitat when the mine site is
developed. As evidence for this statement we offer the
observation of an adult male moose k mile NW of the Red Dog
On pp. IV-12 and IV-17, the terrestrial wildlife discussion was ex-
panded to include information on the occurrence of ptarmigan and
moose in the project area. The potential impacts to wildlife from
the development of the mine site are addressed on pp. V-3 & 4.
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airstrip June 29, 1983, by three Department of Fish and Game
(DFG) biologists.
P. V-4; Terrestrial Wildlife.
) The fencing proposal is thought to be inadequate to mitigate
bear problems, even with the proposed training of workers.
We recommend a more comprehensive fencing proposal which
includes fencing of the entire living and dining facilities
at both the mine and port sites.
The fencing proposal (as discussed on p. V-4) would protect the
workers and reduce worker/carnivore contacts. Fencing all living
and dining facilities would be impractical and would not signifi-
cantly reduce the potential for "bear problems."
f//-O) State policy does not support any type of water fill for
disposal of solid waste, give the numerous dry land sites
potentially available. Cominco is currently operating
under a Department of Environmental Conservation (DEC)
temporary solid waste permit which will be re-written when
the permanent camp is constructed and its associated land
fill located.
The first paragraph on p. V-4 has been modified to indicate that
incinerator wastes and unburnable solid wastes would be buried in
a landfill, not in the tailings pond. The specific conditions of
waste disposal would be detailed in DEC'S Solid Waste Disposal
Permit.
f/7-/9p- v~13' 14' 15-' Freshwater Resources.
Is the Erosion and Sediment Control Plan currently
available? Please include it in the FEIS appendix.
(/7-<^P. V-19; Air Quality.
Erosion and sediment control mitigation measures are discussed on
p. V-13 (U4 & 5), p. V-14 (114), p. V-15 (H3, 4 & 5), p. V-16, p.
V-47, p. V-49 and p. V-50. An "Erosion and Sediment Control
Plan" does not exist as a formal planning document. However,
more detailed mitigative measures to control erosion and sedimenta-
tion during project construction and operation would be included in
the State's right-of-way permit as well as ADF&G's Title 16 permits.
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£"/7-<3)Dust control, including water spray and an annual
application of a "suitable stabilizer", is discussed as a
mitigation for potential degradation to air quality. Tfie
FEIS should also identify potential water sources and
address the effects of water removal and possible mitigative
measures. In addition, a discussion of potential
stabilizers and their respective advantages and
disadvantages should be included.
Discussion was added to pp. V-19 and V-66 to address potential
water sources for dust control, the impacts of water removal for
dust control, and potential chemical stabilizers that could be used
for dust control.
X
I
en
>. V-25; Subsistence.
The second sentence, paragraph 3, and first sentence, para-
graph 4, are contradictory. In paragraph 4, it is acknowl-
edged that caribou may use the South Fork of Red Dog Creek
for occasional winter grazing. Paragraph 3 states there are
no fish and wildlife resources of any importance. It is
more appropriate to state that the South Fork of Red Dog
Creek is utilized to a lesser degree by caribou than areas
outside the mine development area.
The last paragraph on p. V-24 and the first on p. V-26 were
modified to eliminate contradictory information about caribou utili-
zation of the mine site area.
V-46; Freshwater Resources - Alternative 1.
The DEIS addresses the need for an DFG approval for
structures in, and alterations to, anadromous fish streams
(AS 16.05.870). However, the requirement to also obtain
The fourth paragraph on p. V-46 was modified to indicate that
ADF&G must approve all activities that could affect resident fish
passage as well as anadromous fish streams.
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approval for activities which could affect resident fish
passage (AS 16.05.840) was omitted.
J
(17-T^f- V-58; Coastal Geologic Process, Alternative 1.
The brief analysis of sediment transport at the offshore
island concludes that the material moved would be
insignificant. Given the importance of the VCLL stability,
an expanded discussion of these forces, including the scour
depth at the site, material movement during storm surge
events, and the effect of ice rubble around the island,
would provide a better basis for this conclusion.
P. V-59 and 62; Marine Water Quality.
The port site drainage collection system with water
treatment and ocean discharge does not appear in the port
site NPDES permit shown in Appendix 2.
(l7-li)P. V-64; Marine Water Quality.
The State does not certify the SPCC plan required by EPA.
However, the SPCC plan may be submitted to DEC to satisfy
the Oil Discharge Contingency Plan required under 13 AAC
75.305. The SPCC plan, as presented in Appendix 2, does not
meet these state provisions.
Additional design information on the ice, wave and scour forces
that are expected to act on the ballasted VLCC tanker (offshore
island) is provided in a letter from Mr. Harry Noah of Cominco
Alaska to Mr. Keith Kelton of DEC (Noah, 1984). Cominco has not
yet specifically quantified the depth of scour expected at the
ballasted tanker site. This is detailed design information that
would be formulated during the design and permitting phase of the
project and reviewed by appropriate state and federal agencies
including DNR and the Corps. Cominco does not anticipate that a
significant amount of material would be moved by a storm event.
See the response to Comment 17-F and discussion on p. V-58 of
the EIS.
The draft port site NPDES permit discusses the port site drainage
collection system. This permit is included in the FEIS as part of
Appendix 4.
Figures 11-14 and II-15 (pp. 11-28 & 29) have been modified to
show oil containment berms around the fuel storage tanks at the
port site. A formal SPCC Plan will be submitted to DEC at a later
date. The SPCC Plan located in Appendix 2 is a preliminary
informational document that will be expanded prior to submission as
part of a permit application.
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V-77; No Action Alternative.
More detail on the regional effects of the no action alter-
natives would enhance this discussion. The continuation of
high rates of unemployment and lack of alternative economic
opportunities for the regional could be highlighted.
The economic and sociocultural consequences of forfeit or delay of
the mining project are discussed in the No Action Alternative (pp.
V-77 & 78) and are implicit in the discussion of socioeconomic
impacts of the proposed project alternatives (pp. V-27 through
V-33).
<-/7-W~)p. v-95; Unavoidable Adverse Impacts.
Mention of NANA's "authority" to restrict or close operation
of the road is misleading the final project area ownership
X patterns and the terms of the reciprocal right-of-way
1 agreement for the entire corridor.
f'7-X/P. V-97; Irreversible and Irretrievable Commitments of Resources.
The de facto wilderness reference is inappropriate. Either
"undeveloped lands" or "wild lands" are preferable
substitutes.
On p. V-95 (112) the text mentions "NANA's intention and authority
to restrict or close operation of the road to Red Dog project activ-
ity." This statement relates to the NANA/Cominco agreement that
would permit NANA to curtail use of the road if traffic might
interfere with the normal passage of caribou through the vicinity
(see p. V-72). Details of this agreement and other potential
binding provisions would be resolved in the State's right-of-way
permit.
Any mention of "de facto wilderness" has been eliminated from the
text. The fourth line on p. V-97 now reads, "...event, the
undeveloped nature of the project..." Similar changes were made
on pp. V-90 and V-94.
O 7- /} Chapter VI
Incorporate the changes identified for the State permitting
section in Chapter I.
ADF&G and DEC permit descriptions were added to pp. VI-4 & 5,
and VI-9 & 10 to match the changes that were made on pp. 1-10
& 11.
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Appendix - NPDES Draft Permit AK0038652
NPDES Public Notice, item la, last sentence.
The last sentence should read "the treated wastewater
discharges resulting from the proposed facility will be
discharged into Red Dog Creek." The last part of this
sentence indicates DEC is reclassifying Red Dog Creek. The
Department has not received a request from Cominco for
reclassification and is currently not reclassifying Red Dog
Creek.
Comment noted. However, the NPDES Public Notice is not sched-
uled to be reissued.
00
P. 3 of 19; Item I.A.I. Monitoring.
A weekly sampling for the "daily maximum" is scheduled. How
does one guarantee the daily standard is met with a weekly
sampling frequency?
P. 5 of 19; Item C.2.
Biomonitoring is typed incorrectly.
P. 11 of 19, item I.l.d.
A violation of a maximum daily discharge limitation must be
reported within 24 hours. How is this possible if the
The weekly sampling frequency is deemed adequate for a deter-
mination of compliance with the effluent limitations.
This typo has been corrected.
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applicant is required to sample on a weekly basis? See
comment for p. 3 of 19.
Fact Sheet, p. 4, item G.
Pertaining to the sampling program, same comment as for p. 3
of 19. How does one achieve a daily maximum with weekly
sampling?
Fact Sheet, p. 6, item f.
Ikalukrok is also used for overwintering.
dc84051002dma
The NPDES permit does not contain a list of pollutants that must
be reported within 24 hours if discharge limitations are exceeded.
Therefore, this section of the permit does not technically apply to
the Red Dog discharge.
Comments noted.
reissued.
However, the Fact Sheet is not scheduled to be
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1T198+
ENVIRONMENTAL EVALUATION
BRANCH
National Audubon Society
ALASKA REGIONAL OFFICE
308 C STREET, SUITE219, ANCHORAGE, AK99501 (907) 276-7034
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May 11, 1984
William M. Riley
EIS Project Officer
Environmental Evaluation Branch M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Bi11 :
These comments are in response to the "Draft Environmental
Impact Statement" (DEIS) for the Red Dog Mine Project, Northwest
Alaska dated March 16, 1984. We would like to commend the
Environmental Protection Agency (EPA), Cominco Alaska Inc. and
NANA Regional Native Corporation (NANA) for their fine efforts to
date in gathering essential scientific information on the impacts
of this mining project on the region's environment. Your public
participation process has also been a very meaningful one in our
judgment. We feel we have been provided ample opportunity to
express our concerns and recommendations as planning for this
proposed project progresses.
Although we feel that the DEIS is very well written and has
been developed in an exemplary manner, it is important to
recognize that Audubon is vitally concerned with the irreversible
changes that will occur as a result of industrial intrusion into a
formally pristine region of the state. There will be permanent
altara;ion of fish and wildlife habitats, disturbance to wildlife,
loss of scenic and wilderness values, and impacts on the Cape
Krusenstern National Monument, not to mecion changes to cultural
values. Ideally, a DEIS should examine the cumulative impacts of
projects such as che proposed mine along with che projects that
are sure to follow in order to more effectively mitigate these and
ocher irreversible changes in the North.
Our specific concerns or conditions are as follows:
ACCESS THROUGH CAPE XRUSENSTERN NATIONAL MONUMENT
The land exchange currently proposed in association with
the Red Dog Mine operation, is a major federal action affecting
the human environment. It is very important, therefore, that this
DEIS or a separate DEIS deal with the land exchange in a thorough
Thank you. Comment noted.
AMERICANS COMMITTED TO CONSERVATION
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(IQ~A~) manner. For example, we are concerned with what happens to native
selected lands if Title XI is used instead of the land exchange.
The fact that the land exchange is not thoroughly addressed is the
most serious deficiency of the DEIS. (Please see attached
statement addressing Audubon's recommendations on land exchange
policy. )
fl&-p) RAILROAD
In comparing environmental impacts from both ths road and
railroad transportation modes, 1t appears that the railroad option
is best 1n many respects. Not only would adverse environmental
impacts associated with frequent truck traffic and dust be avoided
w1 :ti a railroad, but energy efficiency in transportation of ore
would be much greater. Although we realize that the road Is to be
built in such a manner as to permit eventual construction of a
railroad, there should be thorough discussion of why the railroad
cannot be be built Initially. If there are legitimate reasons,
they should be Included in the DEIS.
Qg-QCQST OF TRANSPORTATION ROUTE
Whether a road and/or railroad are eventually construcced
between the Red Dog Mine and a coastal port, it is vitally
important that preferred funding sources be identified and che
consequences explained. For example, does NANA and/or Cominco
Intend to seek public funds to finance the road/railroad? If so,
what will be the long term consequences to the regional
1 environment? Who will manage and maintain the road? Who will be
n allowed to use the road 1n addition to COMINCO? Will it b'e open to
» the public? The DEIS should deal with such questions in a thorough
manner.
r/g-P)FUEL 'AHD CONCENTRATE STORAGE
The preferred alternative recommends storing fuel and
concentrates offshore using a ballasted tanker. In the absence of
detailed engineering design and practical experience in
application of the ballasted tanker concept, considerable caution
1s called for. The DEIS (V-60) states that, "Little experience
exists with similar facilities so it is Impossible to
statistically evaluate the probability of various risks
associated with the ballasted tanker". The DEIS (V-61) goes on to
scare thai, "Impacts of fuel or oil spills could be heavy on local
area aquatic life" and "during adverse weather conditions, oil
spills could Impact beaches anywhere in the area from Cape
Krusenstern to Point Hope." For these reasons, we strongly urge
that a heavily reinforced tanker placed offshore for a period of
at least one year. This would provide opportunity to test its
capability to withstand the forces of pac* ice prior to loading
with fuel and concentrate. •
Evaluation of the proposed land exchange between the NPS and
NANA is not within the scope of this EIS. It is the responsibility
of the NPS to thoroughly evaluate whether the land exchange
would be in the public's best interest. Specific information con-
cerning the land exchange, as well as notice of the availability of
decision documents prepared by the NPS, is located in the Federal
Register (Vol. 49, No. 66, Wed. April 4, 1984, pp. 13437-13439).
The proper use of dust suppressants and the restriction of public
access should maintain road impacts at acceptable levels. The need
to transport large modules necessary for mill construction and the
relatively small tonnage of concentrates that would be produced
during the first five years of operations preclude initial construc-
tion of a railroad. However, a railroad could be more efficient in
the long-term. See the response to Comment 19-C and pp. V-47
and V-50 of the EIS.
Cominco is discussing with the State a loan for construction of the
port site facilities and road transportation system. If the State
agrees to help finance the Red Dog project, it is possible that the
State could assume partial or complete ownership of the port or
road. However, the extent of the state financing is unknown at
this time. See the response to Comment 13-A for a discussion of
regional use of the port and road.
According to the development schedule discussed on pp. 11-33 &
35, the offshore tanker would probably be ballasted in position
during the 1987 shipping season. The first movements of concen-
trates to market would probably occur during the 1988 shipping
season, although this development schedule is subject to change.
As such, this statement should not be construed as a commitment
by Cominco to balast the tanker one year prior to project start-up.
See the response to Comment 17-F for a discussion of expected ice
forces the tanker would be designed to withstand.
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HONITORING
We are generally pleased with the description of monitoring
programs designed to measure the effects of this proposed project
on fish and wildlife and thsir habitats. The DEIS should be more
specific, however, in terms of who the monitors will be working
for and who will pay their salaries. Since the project is a"
private commercial venture impacting public resources, we feel
that all monitors should be employed by appropriate public
agencies with Coninco required to share in the costs. It would
also be advisable to assign a fish and wildlife habitat biologist
to oversee the entire project from beginning to end. lie are
convinced that such a monitor would save all concerned parties
both time and money while helping minimize adverse impacts.
We appreciate your consideration of these comments and
recommendations.
Sincerely,
Specific details of the biological monitoring plan would be resolv
during the permitting phase of the protect. Various state a
federal agencies (including DNR, ADF&G and FWS) would revn
the monitoring plan, and provide suggestions as to who should
responsible for monitoring project activities and how moniton
would be conducted. If state funds were going to be used to p
for an on-site biological monitor, the position would have to
appropriated through the state legislature.
David R. Cline
Regional Vice President
Enclosure
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Russell Peterson, National Audubon Society
Richard Martyr, National Audubon Society
Anchorage Audubon Society
Arctic Audubon Society
Juneau Audubon Society
Kenai Peninsula Audubon Society
Kodiak Audubon Society
Alaska Coalition
- 3 -
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Sierra Club
MAY 22 1984
ENVIRONMENTAL EVALUATION'
BRANCH
Alaska Field Office
241 E. Fifth Avenue, Suite 205, Anchorage, Alaska 99501, (907) 276-4048
LT
oo
May 21, 1984
REC. VIC-
«r. William H. Rlley
EIS Project Officer y;r,V f.'.' YrJ'i
Environmental Evaluation Branch M/S 443
Environmental Protection Agency , .., -v ^ - .''lEf',. !'•'-
2300 Sixth Avenue cl '""'
Seattle, Wa 98101
Re: Sierra Club Comments on DEIS/Title 11-Red Dog Project
Dear Mr. Riley:
Our comments focus on the economic feasibility and environmental
analyses for the alternative transportation systems.
)ii4is ii
Section 1103 of Title 11 requires the Secretary of the Interior
to recommend to the President that permits for a transportation
system within s national park or wilderness system unit b'e
granted if the Secretary determines that the transportation
system would be compatible with the purposes for which the unit
was established and there is no economically feasible and prudent
alternative route for the system.
The DEIS finds that the road/vabm 2S port site of the preferred
alternative is the least costly of the alternatives and hence, by
implication, the most economically feasible route. This conclu-
sion, however, cannot be sustained on the basis of Information
presented in the draft. Two fundamental methodological errors in
the analysis must be corrected before any conclusion on economic
feasibility can be reached.
The first is that the draft uncritically acccepts Cominco's
ballpark cost estimates for the five alternative transportation
routes evaluated. It also accepts Cominco's alignments for four
of the five routes, and General Crude Oil's alignment for the
fifth or northern corridor. This acceptance means that Cominco
is allowed to determine the total distance of the corridors, as
well as the number of stream crossings and bridge lengths, and
hence the comparative costs.
Compare the draft's method with what Congress directed in Title
11 of ANILCA:
An independent evaluation of the transportation corridor alterna-
tives would be conducted by DOT/PF prior to submission of the
Title XI package to the President of the United States. The NPS
has requested additional economic information from Cominco regard-
ing the transportation corridors. This information is included in
the final Title XI application which is located in Appendix 6.
-Trtnlitl on Recycled Pap«_
1
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the head of each federal agency...shall consider and make
detailed findings supported bv^ substantial evidence, with
respect to (A) the need for, and economic feasibility of,
the transportation or utility system (and! (B) alternative
routes and modes of access, including a determination with
respect to whether there is any economically feasible and
prudent alternative to the routing of the system through or
within a conservation system unit...
(Section 1104(9)(2), emphasis added)
The authors of the draft meekly accept Cominco's cost guess-
timates because Cominco has failed to submit the detailed
engineering and cost data that is required under Title 11 for the
federal agencies' analyses.
The National Park Service has made at least three requests for
the information. On February 10, 19S4, the Service again
requested the following data:
Jtem 15. We note the continuing request Indicated in our
January 6 letter for additional Information and appropriate
documentation as follows:
a) Detailed cost figures for the proposed construction,
operation, and maintenance, including the economic
feasibility of the proposed transportation system.
b> The cost of the alternatives to routing the system
through Cape Krusenstern National Monument, including the
economic feasibility of these alternatives.
c) The cost of alternatives locating no borrow sites within
Cape Krusenstern National Monument, including the
economic feasibility of these alternatives.
d) Any expected impact on the national security interests of
the United States that may result from approval or denial
of the application.
(DEIS Vol. 2, Attachment F)
Until the independent study can be made by the Departments of
Interior and Transportation as required under Title 11,
conclusions on economic feasibility should be held in abeyance.
When the study is undertaken, the alignment of the alternative
routes should not be left to Cominco and GCO. Using information
on subsistence use areas and fish and wildlife resources.
including the data gathered by Cominco's consultants, the
Interior/Transportation analysis should independently locate
alternative route alignments that meet the tests of technical
feasibility and the avoidance to the maximum extent possible of
sensitive wildlife populations, habitats, and subsistence use
areas.
The second serious methodological error in the draft's treatment
of economic feasibility is that feasibility is implicitly defined
to mean the least cost for Cominco in moving its ore to the
An independent evaluation of the transportation corridor alterna-
tives would be conducted by DOT/PF prior to submission of the
Title XI package to the President of the United States. The NPS
has requested additional economic information from Cominco regard-
ing the transportation corridors. This information is included in
the final Title XI application which is located in Appendix 6.
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coast. But as the draft makes clear, the Red Dog access system
is intended by the State of Alaska to serve as the beginnings of
a regional transportation system for northwest Alaska. Cominco,
in fact, is asking the State to fund the road. Thus the question
of economic feasibility applies not just to Comlnco's
transportation needs for Red Dog, but to the overall regional
transportation system designed to serve the De Long Mountains
mineral district and other areas. The real issue is which
transportation system designed to serve Red Dog is also the
most economically feasible and prudent as part of an overall
regional system for the future.
The DEIS'a treatment of "regional impacts" (pp. V-86 to O9> ia
useful as far as it goes. Filling out the picture somewhat are
the attached excerpts from the Department of Commerce and
Economic Development's report on potential Alaska mineral
development.
Just as with the discussion of economic feasibility, the craft's
environmental impact analysis has a fundamental flaw in
methodology that yields conclusions of little or no utility for
Title 11 decision-making purposes. The draft takes as given the
five alternative routes it evaluates: GCO, Asikpak, Western,
Omikviorok, and Kruz. the last four of which were identified by
Cominco. The authors of the draft then evaluate the routes using
available resource information, including environmental baseline
data gathered by Cominco's consultants. In so doing, the authors
have the appropriate sequence exactly backwards. They become
intellectual captives of Cominco, and are led to pre-determined
conclusions.
An example of the ki
authors is their con
industry route alter
and AslkpaK corridor
on arctic char, a k
alternatives. Comin
studies of the two n
the Western, Kruz, A
between the routes i
areas in close proxi
nd of pitfall encountered by the draft's
elusion on the relative impacts of the
natives on fish resources. They find the GCO
s to have relatively higher potential impacts
y subsistence resource, than the southern
co's summer 1983 supplementary environmental
orthern routes revealed that, in comparing
sikpak, and GCO routes, "the major difference
s the greater number of major char spawning
mity to crossings on both northern routes."
But as the author of the freshwater studies observes, "minor
realignments in the actual route could change the character and
number of stream crossings from those tabulated. However, minor
realignments would be unlikely to significantly change the number
of important fish streams on any of the routes." (Johnathan P.
Houghton, "Freshwater Studies along the Northern Access Route
Alternatives," in Suoglement to Environmental Baseline Studies;;
35^ Dog Project^. Cominco, December 1983, Freshwater Habitats
section, emphasis added.)
Thus, instead of accepting the Cominco-GCO routes as given, the
The reader assumes incorrectly that routes were selected prior to
conducting baseline studies. A review of Chapter IV, in particu-
lar Figures IV-2 through IV-6, IV-9, IV-12, IV-15 and IV-16
clarifies that the approach used to select routes was an intrinsic
suitability analysis (McHarg, 1969). Sensitive resources located
primarily in the Wulik River drainage area would be best avoided
by routes to the north or south. Northern routes, however,
would cross several major rivers flowing southwesterly from the De
Long Mountains, all of which contain important subsistence fish-
eries. The southern routes would cross one major fisheries river,
the Omikviorok. Although the southern routes would all cross
Cape Krusenstern National Monument, there would be fewer actual
unavoidable resource impacts.
Minor realignments of the northern routes could perhaps avoid
major Arctic char spawning areas. However, these areas are not
constant from year to year, nor would avoiding the spawning areas
significantly lessen potential impacts to the fisheries. Major
impacts would still result from improved human access, increased
sedimentation, possible spills and the possibility of a structural
failure.
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Ul
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EPA, NPS, and DOT should, using the available information
the Railroad Option
In the screening process for the alternative tran
sytems, the authors find that the rail option has
impact than a year-round road for nine of the thi
or "disciplines," including the most important on
wildlife, subsistence, and Krusenatern impact . Nevertheless, the authors of the draft sere
option altogether becauae "the road was finally
bases of greater regional use flexibility, substa
capital cost, and the fact that the transportat lo
be initially laid out to meet the more restnctlv
constraints, thus keeping open the option for con
railroad wj.thln the same right-of-way at a later
35). In other words, despite the superiority of
on environmental grounds, it is rejected for pure
reasons, primarily on Cominco's estimate of a S20
higher cost than its preferred road.
:sportatlon
less potential
rteen variables
IBS: fish,
.bles III-6E and
in out the rail
Delected on the
intially less
m corridor would
e railroad grade
struction of a
time" (p. III-
the rail option
ly economic
-5O million
In the same screening process, the railroad is found lass
desirable than a road because a railroad "cannot transport large
mine area facilities modules," while a road can transport such
modules.
An explanation of the importance of this "transport" factor, so
far as Cominco is concerned, is found in the Anchorage limes of
February 27, 1983.
He CCominco exploration mana
a road would be required mi
modules and mill equipment n
to be carried on railroad ca
however, a railroad probably
means of transporting zinc a
seaport for shipment to Outs
company planners. Because o
railroad conversion, the rou
on a 1 - 1 1/2 percent grada
Class.'" Anchorage Times, Fe
ger Jerry Booth] explained that
tially because the building
eeded at ths site are too wide
rs. Over the long term,
would be the most economic
nd lead concentrates to a
ide smelters, according to
f that potential road-to-
tes being studied are laid out
C"Zinc Mine May 3e 'World
bruary 27. 1983)
The final EIS should explain why these facilities modules cannot
ae pre-fabricated for shipment by rail and assembly on site.
It is also obvious that a railroad is ultimately planned for
whatever right-of-way is chosen. All five alternative road
routes are constructed to railroad grades. Accordingly, the
final EIS should examine the economic feasibility of constructing
EPA and NPS are satisfied that the routes examined in the EIS
represent all reasonable alternatives. The preferred alternative,
to the maximum extent possible, would avoid conflict with subsis-
tence use areas, sensitive wildlife populations and habitats and
other important resources. Furthermore, the route options
examined include all those raised during the scoping process.
The railroad option has not been "rejected". Maintaining a road
grade suitable for a railroad leaves that option open for future
implementation. As explained on p 111-16, the option for each
component which showed the fewest level of potential impact was
selected unless another option for that component "addressed one
or more of the 12 issues in a significantly more favorable manner "
In this case, the road, built to railroad grade specifications,
addressed the regional use criterion much more favorably by pro-
viding the flexibility to haul oversized equipment or structures
(e.g., the large modules) necessary for mineral developments in
the Noatak Mining District. The road also addressed economic
feasibility much more favorably. While it is true that a railroad
could deliver concentrates more efficiently, the "threshold level"
for achieving an economic return for the Red Dog project is much
higher than 362,800 Mg (400,000 tons) per year. A study pre-
pared for the state DOT/PF specifically addressed transportation
infrastructure for mineral development in the Noatak Mining Dis-
trict and found that 702,900 Mg (775,000 tons) per year was the
economic margin for a railroad system serving that area (Louis
Berger & Associates, 1981). Furthermore, the proper use of dust
suppressants and the restriction of public access should maintain
the adverse impacts of a road at acceptable levels.
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a railroad Initially versus the road-then-later-railroad sequence
preferred by Cominco. Cominco'a initial annual production of
479.OOO tons of concentrates exceeds the "threshold level" of
4OO,OOO tons per year for railroads.
In addition, because a future railroad is provided for as part of
the State's "infrastructure" for northwest Alaska mineral
development, the EIS must, for each of the major alternative"
corridors, address the environmental consequences of a railroad
as well as the cumulative impact of the road followed later by
the construction and operation of a railroad along the same
corridor. For example. Congress will want an assessment of
whether a road followed by a railroad is compatible with the
purposes for which it established Cape Krusenstern National
Monument.
Similarly, the DEIS'a treatment of the Noatak corridor option la
exceedingly superficial. In the context of a regional transpor-
tation network, a Noatak corridor railroad from Red Dog to a
Hotham Inlet port that could also serve a railroad from the
Ambler mining district deserves more than the desultory
discussion in the DEIS. For the State of Alaska, which is being
asked to foot the bill for all the transportation "infra-
structure," the Noatak corridor merits evaluation in terms of
environmental impact and economic feasibility.
In discussing the regional impacts of the Red Dog, the DEIS notes
the Red Dog port site as a possible destination for coal that may
be mined (and undoubtedly shipped by rail) in the Point Lay
area. This discussion should be amplified and updated in the
final EIS, using, if available, BLM's EIS findings on the
potential coal developments.
) InY-iSSG^ntal C.onseguencesi Qaribou
In "An evaluation of the Effects on Subsistence of a Proposed
Land Trade in Cape Krusenstern National Monument" (February
1384), authors Stephen R. Braund and David C. Burnham provide
this description of the Mulgrave Hills:
The Mulgrave Hills are often uaed by wintering caribou
because strong winds keep the ridge tops clear of snow
allowing access to forage. During exceptionally heavy snow
years when the spring migration north is slowed down, some
animals calve prior to reaching the major calving grounds on
the North Slope. In the past, the Mulgrave Hills have been
used as calving grounds by caribou.
The fact that the Mulgrave Hills have in the past been used as
calving grounds is a very significant finding that does not
appear in the DEIS, even though it does appear in the baseline
environmental studies for the Red Dog project. As historic caribou
calving grounds, and thus potential calving grounds at any tine
in the future, the Mulgrave Hills take on added importance in
terms of the purposes for which Cape Krusenstern National
The major impact of constructing a railroad after the road was
built would involve realigning the approaches to any major
bridges. Approach realignment could cause a temporary increase
in stream sedimentation as discussed on pages V-47 and V-50 & 51
of the EIS, but no other environmental impacts would be expected.
The text on p. III-37 has been modified to provide more technical
information on the Noatak Corridor and to further explain the
decision to eliminate the corridor from review.
A discussion of the Red Dog project's possible impacts on the
development of coal resources in northwest Alaska is found on p.
V-89.
Although winter use of the Mulgrave Hills by caribou is not exten-
sive, it does occur. A discussion has been added to p. IV-15 (tf1
& 2) that addresses the occurrence and occasional calving by
caribou in the Mulgrave Hills.
-------
en
oo
Monument was established, and hence for the compatibility
analysis required by Title 11. The final EIS should
incorporate this vital information in its analysis of the
environmental impacts of alternative one on caribou.
Compatibility Test
(fl-6)3ection 1105 of Title 11 requires a determination by the
Secretary that a proposed transportation system inside a park or
wilderness system unit "...would be compatible with the purposes
for which the unit was established..." The draft's preferred
alternative, which crosses Cape Krusenstern National Monument,
was only found to be preferable relative to the other
alternatives selected by industry; the preferred alternative
could nonetheless be incompatible with the monument's purposes.
The Secretary of the Interior has until four months following the
final EIS to make a compatibility determination. The final EIS
should discuss the relationship between the EIS process and the
Secretary's compatibility report.
§E§9ifiS Comments Ke^ed to Pages in the Text
LE9nSi5Bi§£§- An explanation of how the Title 11 process relates I
to the DEIS would be useful. For example, what requirements of L
Title 11 is the DEIS intended to satisfy? _j
iii. Si and J;4. The discussion of the Title 11 application
needs to be brought up to date. The revision should acknowledge
the fact that Cominco has yet to submit a legally acceptable
application, and explain why the DEIS's Title 11 discussion
purports to be consistent with the Title 11 process.
discussions with the Interior Department and National Park
Service began ,-nuch earlier than June 1983. By May 1983, the
terms of the exchange closely resembled the exchange that has
recently been announced.
Mow that the exchange announcement has occurred, a map and
description of it should be included in the final EIS, in order
that the reader can better understand how the exchange makes, as
the DEIS says, "a Title XI permit unnecessary."
and
This
off
circ
whet
with
the
Maxi
NPS.
prom
SS J;4. "If the preferred alternative was developed with a
exchange, the environmental impacts would be similar."
assertion is obviously wrong: 64.0OO acres are to be chopeed
the northwest corner of the monument in a blatant attempt to
umvent Title 11. It clearly makes a great deal of difference
her a right-of-way is within or outside the monument. If
in, the UPS controls the use of the right-of-way, as well as
uses of the monument lands to either side of the road.
mum protection of monument wildlife would be ensured by the
Reclamation would be assured, not, as in the DEIS, vaguely
ised .
Because trie anviranmental impacts ara so fundamentally diiVarant
As part of the Title XI review process, DOI would make a deter-
mination as to whether the proposed transportation corridor would
be compatible with the purposes for which the Monument was estab-
lished. This compatibility determination will be outlined in DOI's
Record of Decision (ROD).
The final Title XI application is printed as part of the EIS. The
front piece is rewritten for the EIS. The discussion of the Title
XI process on p. 1-1 (114) has been expanded.
The final Title XI application is printed as part of the EIS.
Discussion on pages iii, x, and 1-5 concerning the Title XI appli-
cation is up to date. It is beyond the scope of the EIS to include
a map and description of the proposed land exchange between
NANA and NPS.
Evaluation of the proposed land exchange between the NPS and
NANA is not within the scope of this EIS. It is the responsibility
of the NPS to thoroughly evaluate whether the land exchange
would be in the public's best interest. Specific information con-
cerning the land exchange, as well as notice of the availability of
decision documents prepared by the NPS, is located in the Federal
Register (Vol. 49, No. 66, Wed. April 4, 1984, pp. 13437-13439).
-------
under the Intended land exchange, the final EIS must thoroughly
examine the preferred alternative under the assumption of a land
exchange.
And inasmuch as the land exchange was virtually complete in late
1983, the DEIS--for which the co-lead" is the agency (NFS) also
aaking the exchange--could easily have incorporated a full
analysis of the preferred alternative given the exchange. B'ut by
waiting until after the February publication of the DEIS to
announce the trade, the political appointees of the Interior
Deportment hoped to evade a full discussion of the environmental
impact of the trade on the monument. They succeeded in evading
it in the DEIS, but the final EIS must deal with the
environmental consequences of Interior's (and Cominco'sJ attempt
to sidestep Title 11.
)vi. In noting that caribou use, among other drainages, the
Omlkviorok River for winter range, and that a muskox herd winters
in the Rabbit Creek valley south of the Mulgrave Hills, the final
EIS should also acknowledge that these drainages are within Cape
Krusenstern National Monument.
Incidentally, NPS. Cominco, NANA, and conservation organizations'
representatives observed the monument's muskox herd, numbering
approximately a dozen animals, in the Rabbit Creek area in early
Kay of 1933. This suggests that the herd may also use the
monument in the spring and perhaps summer as well.
)jzi- the description of Title 11 can be improved. In addition
to the National Park Service, the heads of every federal agency
with jurisdiction over aspects of the proposed transportation
system participate in the Title 11 process. For example, DOT
^l« required to take a leading role in the analysis of economic
'faasioility.
2. Reference 13 made to 18,000 mining clalaia staked "in the
area to tna west and southwest of the Sed Dog prospect." In the
final EIS. a sap showing the location, extent, and ownership of
these, tne LiH and Su claim blocks, and any other major claim
blocks in the Da Long Mountains/Red Dog zinc belt would be
useful.
)l-$- CaPe Kruaenacern impacts. ANILCA (Title 11) also requires
that access through tha monument cannot be permitted if the
system is found incompatible with tha purposes for wnich the
monument was established.
yll;i- According to the draft. Red Dog ore contains 5.0 percent
lead, 17.1 percent zinc, 2.4 02./ton silver, and measuraole
levels of barite. The final EIS should indicate anticipated
markets and approximate dollar value of this "world class"
deposit, including estimated profits over the expected life of
the project.
Figure IV-5 (p. IV-16) shows that the Omikviorok River and
Rabbit Creek drainages fall within the boundaries of Cape Krusen-
stern National Monument. Winter conditions still exist in early May
in the study area. Therefore, the presence of muskoxen in the
Mulgrave Hills in May does not mean that the herd also uses the
Monument in the spring and summer.
Discussion of the Title XI process on p. 1-1 (H4) has been ex-
panded.
A map showing other mining claims in the Red Dog study area has
been added to Chapter I following Figure 1-1. The figure that
shows the Red Dog development schedule is now Figure 1-3.
Discussion of "Issue 10" on p. 1-9 has been expanded to include a
short statement of the need for a compatibility determination.
The text on p. 11-1 (111) has been modified to indicate anticipated
markets for the Red Dog ore. As part of the consolidated Title XI
application, the NFS has required that the applicant provide suf-
ficient economic information to allow a determination of whether
there is an economically feasible and prudent alternative to the
proposed system.
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11-15,16. In the discussion of the two northern corridors, it is
noted that "the route would provide access to these fisheries streams.
Certainly the road could cross those streams, but whether access
to the streams and the fish therein was provided would depend on
whether the road wa^fepen to recreational and subsistence fishermen
and, if the road wasopen, whether the State's fish and game regu-
lations could adequately control the potential adverse effects
of fishing. Subsistence and recreational char fishing already
exists in the Wulik River, which has the most extensive char
spawning and wintering habitat. (See figure IV-9 and IV-6) .
At numerous other places in the DEIS this potential access
to char streams is stressed. In view of the existing access via
riverboat, (V-101) the final EIS should refrain from exaggerating
the importance nf the stream crossings from the point of view of
access.
11-19. "Preliminary borrow site information is not available for
the northern corridor," according to the DEIS. The final EIS should
explain why even this "preliminary" information is unavailable,
inasmuch as the availability and location of gravel and _
a key factor in any assessment of the economic feasibility^^ road
and subsequent railroad.
III-7. III-ll, and 111-37. The discussion of the Noatak Corridor
is inadequate. According to the draft, the corridor was eliminated
-^ in the screening process because of "significant potential problems
X with both the route and the port." The alternative of a road or
, railroad to tidewater is dismissed out of hand. Not 'helpful is
the observation that "whether the overland corridor ended at the
O Noatak River or continued directly to some point on Hotham Inlet
O or Kotzebue Sound, either a barge to bulk carrier or port transfer
f-acility would still have to be constructed." All alternatives
require one or the other such facility.
In the final EIS, a more detailed discussion of the "significant
potential problems' should be included. Other transportation studies
have indicated that the lower Noatak River valley does not pose
insuperable engineering difficutlies for the construction of a road or
railroad. As noted above, the option of a railroad down the Noatak
corridor from the Red Dog area should be considered in the context
of a. northwest Alaska regional transportation system. _
(/*)-S) 111-15, Options screening criteria.
Disturbance to monument wildlife populations and habitat is a
major criterion that should be used for the "Krusenstern Impact",
because protection of wildlife is also one of the basic purposes for
which the unit was established.
^/7-^)lII-50. In the discussion of the identification of the preferred
alternatives, it is revealed that "...individual evaluation criteria
were not weighed equally." However, the balance of the discussion
indicates that the choice of the preferred alternative was in
fact based on equal weighting following a "broad review."
Despite the best of intentions to restrict access at stream cross-
ings, the remoteness of this area would make enforcement of such
restrictions very difficult. A greater number of stream crossings
would only compound this problem.
Preliminary information on the location of borrow sites along the
northern corridor, and the approximate amount of material avail-
able from these sites, has been added to Table 11-4 and Figure
11-8. This informtion is also located in the final Title XI applica-
tion (Appendix 6). Also see the response to comment 19-A.
Table III-3 (p. 111-11) and the text on p. III-37 summarize the
maior reasons the Noatak Corridor was eliminated during the initial
options review. The text on p. III-37 has been modified to pro-
vide more technical information on the Noatak Corridor and to fui—
ther explain the decision to eliminate the corridor from review.
Disturbance
life impacts
criteria.
to wildlife is implicit in the "access" criterion. Wild-
are also covered by the "wildlife" and "subsistence"
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,f/'9-
X
I
cr>
R) This methodological oonfusion should be cleared up in the final
EIS. Why was the unequal weighting—which is methodologically
appropriate in the context of Title 11's directives—discarded
when it came in time to select a preferred alternative?
Based on the compatibility and economic feasibility standards
of Title 11, the most important criteria are fish and wildlife
populations and habitats, subsistence, Cape Krusenstern values and
purposes, and technical complexity/cost. _
r) IV- 50,51. Visual Resources. ~
National Park Service standards, as well as the purposes for
Cape Krusenstern set forth in ANILCA mandate that the entire
Monument be classified in the visual "preservation" category.
The DEIS's "partial retention" classification of the northwest
part of the monument assumes that the preferred alternative will
be selected. _
7"\IV-38. In the discussion of the impact of the road on drainage
patterns whithin the monument it is noted that "change, more than
loss of vegetation would be expected in response to changes in
soil type, moisture regime, and topographic setting caused by
the road." This statement begs the question. A national monument
is established to preserve existing natural vegetation and the only
changes allowed are the ones that occur naturally. Changes in
vegetation caused by the pRoposed road represent losses of existing
natural vegetation and habitat.
Even with 187 stream crossings, the proposed road will probably
act as a major barrier to water flowing off the northwest slopes of
the Mulgrave Hills through wetleands to the Omikviorok and Wulik
River wetlands. A more detailed analysis should be made of the potent
vegetational changes, perhaps using experience with other similar
roads (e.g., the wetlands stretch of the Copper River Highway),
and the analysis related to the purposes for which the monument
was established.
For example, the Mulgrave Hills and the entire northwest
option of the Nomument serve as caribou winter range, and in the
past have been used as calving grounds. If the road's disruption
of the "diffuse" drainage patterns invovled caused long-term
losses of caribou habitat, not only would the caribou herd suffer,
but one of the major purposes of the monument—the protection of
wildlife and habitats—will have been compromised.
The DEIS notes that "loss of sedge grass tundra wetlands
would be small. Loss of tussock tundra, tussock tundra-low shrub
complex and open low shrub and complex wetland communities
would be much larger." How large, and what wildlife habitats are
involved?
Another question is begged by the authors when they assert
that the losses quoted above are not "regionally significant, as
al
The reviewer possibly misunderstood the "balance of the discus-
sion" on pp. 111-50 to 111-52. The preferred alternative was sel-
ected through a logical sequence of analysis that was based on
specific evaluation criteria. As stated in the first paragraph under
Identification of Preferred Alternative (p. 111-50 & 51), these
evaluation criteria were not considered equally important. We con-
cur with the reviewer that the most important evaluation criteria
were water quality, fish and wildlife populations and habitats,
subsistence activities and Cape Krusenstern National Monument
values. The text on pp. 111-42, 111-44 and 111-50 has been
modified to further clarify this issue.
As discussed on pp. IV-50 & 51, visual resources of the project
area were evaluated using the well-established U.S. Forest Service
Visual Resources Management (VRM) Program. Based on this sys-
tematic analysis, a portion of Cape Krusenstern National Monument
was classified with a partial retention visual quality objective,
while the remainder (the Mulgrave Hills area) was classified with a
retention level visual quality objective. This classification system
is largely based on the inherent visual quality of the land, includ-
ing visual variety, as well as the visual sensitivity of the land.
The system does not take into consideration the legal land status
or land ownership of any evaluated unit.
Discussion on pp. V-36 to V-40 states the potential impacts to
vegetation. On p. V-38 (114), the text states that the road
"...might impede local drainage. In general this impact could be
minimized by proper bridge and culvert construction, ..." The
reviewer possibly misinterpreted this to suggest that "the proposed
road will probably act as a major barrier to water flowing off the
northwest slopes of the Mulgrave Hills..." This statement miscon-
strues the analysis in the EIS. Loss of communities stated on p.
V-39 (1f1) need not be more specific because impacts would not be
significant (also see the response to Comment 19-Q). The Title XI
review process, as well as the state's right-of-way permit review
process would carefully review road design and evaluate the need
for additional mitigative measures.
-------
the loss of these vegetation types would be small relative to overall
occurence in the project area." Because the losses would occur
within Cape Ktusenstern National Monument they are by definition
nationally significant. Cape Krusenstern National Monument
contains the only fully protected example of the northwest Alaska
coastal landscape north of the Arctic Circle.
V-40. Terrestrial Wildlife.
,
CT1
Throughout the discussion there are refereances to impacts
on certain species as not being "regionally significant1' or "not
significant on a greater than local basis." Because of the
existence of Cape Krusenstern National Monument, adverse impacts
on monument wildlife populations automatically take on national
significance, especially in connection with endangered species such
as peregrine falcons, and species not well represented outside
Alaska such as caribou, musk oxen, wolves, and brown/grizzly
bears. The national importance of these species should be acknowledgec
in the final EIS.
*) On page V-42, there is an inadequate discussion of the impacts
of the road on bear movements "between thelowlands of the Wulik
and Kivalina Rivers and the Mulgrave hills. From the above,
it can be inferred that the bears are probably moving back and
forth from grazing and foraging in the Mulgrave Hills to critically
important (feeding) habitat — the fish runs in the Wulik and Kivalina
River systems. Accordingly, the final EIS should analyze more
closely the impacts of construction and operation of the road and
subsequent railroad on the welfare of these animals," and hence
on key values of Cape Krusenstern N.M.
(11- M/)V-47,49. Stream Crossings
As noted above, conclusions on the comparative environmental
advantages and disadvantages of the northern and southern corridors
cannot be drawn in the absence of the independent analysis of
corridor sitings by federal agencies, as required under Title 11.
(If- Xj)v~52. Access to fish streams
It is assumed by the authors of the DEIS that "the increase
in access available to local residents or mine employees would
adversely impact fish resources in streams that are crossed by the
[northern or Asilapak] corridor." In the final EIS it should be
acknowledged that whether the "fishing and associated disturbance"
occurs depends upon whether NANA-Cominco permits local residents
and mine employees to use the road for recreatioanal fishing and
other non-project purposes; whether ADFSG permits char fishing
during the late summer char spawning season; and on the degree of
enforcement of road restrictions and fish and game regulations. See
the discussion on mitigation—subsistence on page V-81.
10
It is the mandate of the NPS to preserve land units as they occur
naturally and to maintain natural and healthy populations of wild-
life. As discussed on p. IV-72, one of the purposes for which
Cape Krusenstern National Monument was established was to "pro-
tect habitat for, and populations of, caribou herds and other wild-
life, and fish resources." Wildlife populations and habitats that
occur within the boundaries of the Monument are under different
management constraints, but they have no greater significance
than populations and habitats outside the Monument's boundaries.
On p. V-92 specifically, and on pp. V-41 & 42 in general, the text
evaluates impacts to wildlife in the Monument.
Construction or operation of the road would not significantly affect
bear populations. As stated on p. V-42 (H2), "No known areas of
specific importance for denning or salmon feeding would be
affected." No further analysis is deemed necessary.
An independent evaluation of the transportation corridor alterna-
tives would be conducted by DOT/PF prior to submission of the
Title XI package to the President of the United States The NPS
has requested additional economic information from Cominco regard-
ing the transportation corridors. This information is included in
the final Title XI application which is located in Appendix 6.
The EIS does not "exaggerate" the importance of stream crossings
in terms of access. On p 11-16 (HI & 2) the text states that the
route would provide access to fisheries streams. As stated on
p. V-52, increased access available to local residents and mine
employees could impact fish resources, although the State has
indicated the road would not be open to the public (p. V-75).
Also see discussion on p. V-91 (fll). This issue would be further
clarified in the State's right-of-way permit.
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-y)V-66 and V-91. Air Quality
On page V-91, it is stated that "road dust could have effect
on vegetation to a distance of approximately 300 ra(984 feet) from
the road." On what is this estimate based? The discussion on page
66 of dust problems along the North Slope Haul Road indicates that
the zones of dust accumulation were wider than that assumed
for the Kruz (southern) corridor. Given the toxicity of dust' to
"many species of mosses and lichen," what are the implications
for caribou and other species that depend on the tundra involved
for food and nesting purposes?
67 Visual Resources
X
I
CT)
CO
In the discussion of adverse visual impacts of the preferred
alternative on the monument, the present low level of visitation should
not be used to discount the aesthetic scarring; the monument,
after all, is less than four years old. Aesthetic damage is
to be avoided regardless of visitor levels.
Although the port site would be the most visible, the
ore trucks and attendant dust clouds (if control measures are
absent) would be closer and more obtrusive to most monument
visitors.
Are the "mitigating design features" for the port, which
the authors find "would be necessary and appropriate," actually
planned? _
69 Sound
The DEIS's discussion of noise impacts is superficial. The
final EIS should include a more detailed analysis of the potential
impacts of project noise levels on wildlife, especially wilderness-
dependent species. If womument visitors would be disturbed by
noise within 5 miles of the road corridor, what is the likely
effect on Atonument wildlife?
The DEIS recognizes that helicopter and airplane traffic
associated with the project "should" abide by certain restrictions
designed to avoid disturbance to wildlife. Are these restrictions
planned? Would they be possible if the land exhange is made?
75 Regional Use
A reference is made to an "appropriate entity" that might be
reimbursed for the cost of building and maintaining the road.
This "entity" is, of course, the State of Alaska. The final EIS
should include a discussion of the proposed state financial role
in the construction of the road and any other "infrastructure."
>V-76 Technical Feasibility
No conclusions on technical feasibility can be drawn in the
absence of an independent evaluation of alternative corridors
and transporation methods by the federal agencies as required under
11
Dust impacts on vegetation are discussed on p. V-38 (H3). Data
come from Brown & Berg (1980). The discussion on p. V-66 may
have been misinterpreted by the reviewer. Measured accumulations
of dust were detected by Brown & Berg at 1,000 m (3,280 ft) from
the road, but impacts would be detected within 300 m (984 ft) of
the road. Vegetation loss as a result of dust accumulation would
be minimized through road watering and the use of dust stabil-
izers. Any losses would not be significant to caribou as the route
is on the fringe of their primary winter range.
Mitigating measures for road dust control, and mitigating design
measures for the port site would be formulated by the State's
right-of-way and tidelands use permits, as well as by EPA's Pre-
vention of Significant Deterioration air quality permit. See the
expanded discussion of dust control on p. V-66.
Potential impacts of noise on wildlife populations are discussed in
general on pp. V-40 to V-45 and specifically on pp. V-69 & 70.
Wildlife within 610 m (2,000 ft) of the transportation route would
be disturbed for short periods of time by the intermittent vehic-
ular traffic. However, studies have shown that caribou in par-
ticular are not displaced for long periods of time by intermittent
vehicular traffic (Bergerud et ai., 1984), and no significant noise
impacts to wildlife would be expected. Air traffic restrictions de-
signed to minimize disturbance of wildlife (particularly caribou)
would be formalized in the State's right-of-way permit, as well as
incorporated into the caribou monitoring plan.
Cominco is discussing with the State a loan for construction of the
port site facilities and road transportation system. If the State
agrees to help finance the Red Dog project, it is possible that the
State could assume partial or complete ownership of the port or
road. However, the extent of the state financing is unknown at
this time. See the answer to Comment 13-A for a discussion of
regional use of the port and road.
An independent evaluation of the transportation corridor alterna-
tives would be conducted by DOT/PF prior to submission of the
Title XI package to the President of the United States. The NPS
-------
Title 11.
Thank you for the opportunity to comment on the DEIS.
Sincerely yours,
Jack Hession
Alaska Representative
12
has requested additional economic information from Cominco regard-
ing the transportation corridors. This information is included in
the final Title XI application which is located in Appendix 6.
-------
MAY
ENVIRONMENTAL EVAUIATM
May 14, 1984 QKANCH
X
I
o»
Mr. William M. Riley
EIS Project Officer
Environmental Evaluation Br. M/S 443
Environmental Protection Agency
1200 6th Avenue
Seattle, WA 98101
Dear Mr. Riley:
These are the comments of the National Parks and Conservation
Association on the Draft Environmental Impact Statement, Red Dog
Mine Project, dated March 16, 1984. We appreciate the opportunity
to comment prior to the issuance of the final, EIS. As the only
national conservation organization focusing primarily on the pro-
tection of the national park system, we are very concerned about
the preservation of the natural and cultural features in Cape
Krusenstern National Monument.
As stated in the Alaska National Interest Lands Conservation
Act (Sec. 201 (3)), Cape Krusenstern was established "to protect
...ar series of archeological sites depicting every known cultural
period in arctic Alaska;... to protect habitat for and populations
of, birds, and other wildlife, and fish resources....
Procedurally , NPCA objects to the planned administrative land
exchange proposed between NFS and NANA Corporation, as it currently
appears to be constituted. Any such land exchange involving park
system lands should only be undertaken with the express consent of
the Congress. Such a process will more fully assure that the national
interest in protecting the unique resources of Cape Krusenstern will be
carefully and completely considered before approval. Furthermore,
such Congressional review will provide the best test of the all important
question of equal value to be derived by both parties in such an
exchange. At this point, based on our understanding of the lands
involved in the proposed exchange, it does not appear to NPCA that the
NPS would be receiving equal value in lands for those traded to the
NASA Corporation.
Substantively, the preferred transportation alternative proposed
in the DEIS would appear to have the least environmental impact of
the transportation routes studied. We recommend that if the southern
route through the monument is selected, then the following points
should be adhered to:
and Wetlands
Thank you. Comment noted.
The southern corridor should avoid impacts on vegetation to the
greatest extent possible. Wetlands, waterfowl habitat, and other
National Parks & Conservation Association. 17O1 Bghteenth Street. N.W., Washington. O.C. 20OQ9
-------
-2-
0-fi)sensitive areas should be avoided at all costs. Road dust should
be carefully monitored as this may prove to be detrimental to
adjacent vegetative communities. The FEIS should address how these
impacts "onitored and what steps will be taken to
7-g) Terrestrial Wildlife
Impact on caribou migrations should be very carefully
of tL road°d^ erferS Wlth the Patter" of their movements!
of the road during major caribou movements should be halted
we reel that- anv imnar-t-c A\ *•<*,-.*. «_ j_jj ,_ _ . <-*-"j-ny.
1
j
muskoxen' a™* waterfowl, while not receiving
'
sutler impacts from long-term, increased human access.
"-
«"••>• -Mi-
fa? -^Transportation
its solefuse should^^ ^"v"1 transportation route is constructed
analysis of each transportation mode needs to be done to assess its
-0 ™
Borrow Sites
concern
constructed the selection of borrow sites is of
Prposes for wh-H he monument would b« « blaient disregard for the
Assessment ^h £ * /3S astabli3hed. A separate Environmental
Assessment should be done for borrow site selection.
The southern corridor was designed to avoid wetland habitats to
the greatest extent possible and represents the best road alterna-
tive m terms of avoidance of wetlands. Road dust impacts are ad-
dressed on pp. V-19 and V-66. Dust generation would be minimized
by road watering and the use of dust stabilizers. Monitoring
would be stipulated in the state and federal right-of-way permits.
Cominco has initiated a caribou monitoring program in conjunction
with ADF&G. Beginning the spring of 1984, caribou movements
will be charted and population densities estimated four times a
year. Visual surveys will be concentrated at the mine site and
along the transportation corridor. As discussed on p. V-95,
NANA intends to curtail use of the road if traffic might interfere
with the normal passage of caribou through the vicinity.
Potential impacts to raptors are discussed on p. V-3, p. V-41 and
in the Endangered Species Biological Assessment (Appendix 3). In
addition, provisions to minimize impacts to raptors are listed in the
Biological Assessment and will be incorporated into any right-of-
way permits issued.
Specific details of the biological monitoring plan would be resolved
during the permitting phase of the project. Various state and
federal agencies (including DNR, ADF&G and FWS) would review
the monitoring plan, and provide suggestions as to who should be
responsible for monitoring project activities and how monitoring
would be conducted. If state funds were going to be used to pay
for an on-site biological monitor, the position would have to be
appropriated through the state legislature.
The proper use of dust suppressants and the restriction of public
access should reduce road impacts to acceptable levels. The need
to transport large modules necessary for mill construction and the
relatively small tonnage of concentrates that would be produced
during the first five years of operations preclude initial construc-
tion of a railroad. However, a railroad could be more efficient in
the long-term. See the response to Comment 19-C and pp. V-47
and V-50 of the EIS.
The issue of whether borrow sites would be located within the
boundaries of Cape Krusenstern National Monument would be
addressed by Congress when it reviewed the Title XI application.
The EIS discusses the impacts of borrow sites within the Monu-
ment, as well as impacts if the sites were only outside the Monu-
ment boundaries (see the response to Comment 15-G).
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-3-
North/South Corridor ""
During the ANILCA deliberations Congress decided to exclude from
National Interest Lands status certain lands within the corridor
located between the Noatak Preserve on the east and Cape Krusenstern
on the west. This corridor was set aside for transportation purposes
for the Red Dog Mine activity as well as a transportation corridor
for other potential resource developments in the Western Brooks Range
and the National Petroleum Reserve. The Noatak corridor and portsite
option "was eliminated during the initial options review because of
significant potential problems with both the route and port." (111-37)
In addition, "The corridor would cross many lowlands with substantial
permafrost and wetlands problems, and the many stream crossings would
have impacts upon water quality and fish. If the terminus of the over-
land corridor was at the Noatak River, the limited barging season would
require significant dredging of the Noatak River and substantial weather
and low water problems would still exist. Whether the overland corridor
ended at the Noatak River or continued directly to some point on Hotham
.. Inlet or Kotzebue Sound, either a barge to bulk carrier or a port
^ transfer facility would still have to be constructed." (111-37). We
, feel that in .light of the problems with a transportation route in the
Noatak corridor, and the intended construction of a transportation
^ route through' the northern portion of Cape Krusenstern National Monument,
^ the need for a road in the Noatak corridor would be eliminated. It is
then appropriate for these sensitive lands to be included as part of the
national monument or as part of the national preserve.
f*£, -£,*}Cultural Resources -
Cape Krusenstern is remarkable archeologically because, within its
gravels, in chronological order, lie artifacts from every known Eskimo
occupation of North America. One of the main reasons Cape Krusenstern
was established was "to protect and interpret" these archeological sites.
While not being directly impacted by development of the southern
transportation route the sites may suffer from indirect impacts. We
support the DEIS statement that "provisions would be made for recovery
operations under ACHP guidelines at sites discovered during construction."
(V-93). We also see the need for intensive preconstruction surveys that
might make the likelihood of site discovery during construction unlikely
The EIS should also address the need for preconstruction surveys of
borrow sites.
f^_o -/^Subsistence
Impacts on native subsistence use may occur from development of this
corridor. According to the Final Environmental Statement for Cape
Krusenstern, "In the event conflicts occur among uses or in cases where
a resource cannot support all demands for use, subsistence needs will
be given priority over other demands on natural resources, such as demands
imposed on sport hunting. The "DEIS indicates that use of the trans-
portation corridor area would eventually increase and that if this
occurance enabled substantial numbers of hunters and fishermen to use
the area, competition for subsistence resources could occur. Subsistence
use should not be interrupted. Traditional harvesting of plant life,
fish and terrestrial wildlife has been occurring for thousands of years.
This has contributed to the richness of the local native culture and is
This comment has been noted. Any decision to include the Noatak
corridor in conservation unit lands would have to be made by
Congress.
Impacts to known cultural resources and the mitigation of impacts
are discussed on pp. V-71 & 72. Cominco has agreed to conduct
an additional intensive preconstruction survey of cultural re-
sources. If a site could be avoided by a reasonable construction
redesign, it would be. If a site were impossible to avoid through
redesign, scientific data would be gathered from the site in a man-
ner consistent with Advisory Council (ACHP) recommendations for
archeological data recovery. In addition, the Secretary of Inter-
ior's Standards and Guidelines for Archeology and Historic Pres-
ervation would be followed during the data recovery operations.
Avoidance of sites and data recovery from unavoidable sites would
result in no significant adverse impacts to cultural resources.
The Section 810, Summary Evaluation and Findings (p. V-97 to
V-104) thoroughly discusses project impacts on subsistence.
-------
-4-
part of the cultural ambience so critical to the Cape Krusenstern area.
We feel that a special study of project impacts on subsistence and
increased use impacts on subsistence is essential.
(•2.o-_T) Water Quality
Every effort should be made to insure that the Omikviorok river
bridge and other river crossings be constructed in such a manner as not
to interfere with fish populations and other aquatic life. Water
quality degradation should be carefully monitored for increased sed-
imentation. We support the need for spillage control plans and recognize
that rapid response to any oil or chemical spill, is of the utmost
importance.
Specific design details of stream crossings and mitigating measures
would be reviewed through the State's right-of-way permit and
ADF&G's Title 16 permits. The preferred alternative represents
the best route in terms of number and size of streams that would
have to be crossed.
X
I
O)
00
In conclusion, NPCA reiterates our opposition to the procedures
being employed (i.e. land exchange by administrative decision) to grant
approval for the transportation corridor. Decision of such magnitude
should have the full review and approval of the Congress. The
transportation corridor chosen, however, does seem to be the best
environmentally, for purposes of developing the Red Dog Mine. Every
effort must.be taken to assure that construction and operational impacts
are held to an absolute minimum, and that NPS and other professional
personnel are employed in a continuing monitoring program throughout
the life of the mine project.
Thank you. Comment noted.
T. Destry Jarvia...,
Vice-president ''
-------
BILL SHEFFIELD, GOVERNOR
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF LAND AND WATER MANAGEMENT
NORTHCENTRAL DISTRICT
4420 AIRPORT WAY
FAIRBANKS, ALASKA 99701-3896
(907)479-2243
June 20, 1984
Mr. William M. Riley
EIS Project Officer
U.S. Environmental Protection Agency
1200 Sixth Avenue/ N/S 443
Seattle, WA 98101
JUN25
ENVIRONMENTAL EVALUATION
BRANCH
Dear Mr. Riley:
As a follow-up to
providing you with
portation facilities.
our phone conversation of June 14, 1984 I am
a written position regarding the Red Dog trans-
In short, our position remains as it was described in Commissioner
Wunnicke's March 9, 1983 letter to Cominco and GCO, as follows:
1. The State of Alaska will authorize the development of a
single transportation corridor. The route will be public
and available to multiple use by other future resource
developments in the region. As a public route, reciprocal
right-of-way agreements must be acquired wherever private or
corporate ownership is encountered.
2. Tideland (and associated upland) port development will also
be available to support multiple users such as oil and gas,
coal exploration, or support services development.
3. Local concerns, particularly subsistence use must be accom-
modated to the maximum extent possible.
4. One EIS should be produced that considers all potential
options. To this end, the research data collected by both
companies should be available to all participating
agencies.
Let me add that to keep environmental impact to a minimum all
parties should support the concept of a single, public use road.
Certainly whatever environmental impact is experienced, it will be
doubled upon construction of a second road.
X-69
-------
Mr. William H. Riley
June 20, 1984
Page 2
Over the past few months this office has prepared a list of state
concerns to be included in a reciprocal use agreement with NANA
Regional Corporation, the port site landowner. This work is nearing
completion and we will soon begin negotiations with NANA to work out
the necessary agreement. One of our concerns is to restrict the
road to "industrial" users, rather than open to the public.
No decision has been made as yet on what, if any, financial partici-
pation the state may make in the project. It would seem apparent,
though, that as our involvement grew, so too would our insistence on
public facilities.
If you have any question please give me a call.
strict
toSS-
Manager
Michael E. Vediner
Natural Resource Officer
Retained Lands Section
X-70
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Chapter X
References
-------
-------
XI. REFERENCES CITED
REFERENCES
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Grundy, Habitat Division, January 6, 1983.
. 1983b. Alaska Department of Fish & Game internal memo to Al
Townsend, Habitat Division, November 1, 1983.
. 1983c. Pers. Comm. Fisheries Biologist, Alaska Department of
Fish & Game, Fairbanks, AK.
Balding, G. O. 1976. Water availability, quality, and use in Alaska. U.S.
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Univ. of Washington Publications in Oceanography, Vol. 3, No. 2, pp.
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Bear Creek Mining Company. 1983. Testimony of Bear Creek Mining Com-
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Bendock, T. N. and K. T. Alt. 1981. Sport fish investigations of Alaska
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XI - 1
-------
Benoit, D. A., E. N., Leonard, G. M., Christensen, and J. T. Fiandt.
1976. Toxic effects of cadmium on three generations of brook trout
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Braham, H. W. and B. D. Krogman. 1977. Population biology of the bow-
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, M. A. Fraker, and B. D. Krogman. 1980. Spring migration of
the western Arctic population of bowhead whales. Marine Fishery Re-
view 42(9-10):36-46.
Braund & Associates. 1983. Kivalina and Noatak subsistence use patterns.
Ch. 7. Environmental baseline studies, Red Dog Project. Prepared for
Cominco Alaska, Inc.
Brower, W. A. et al. 1977. Climatic atlas of the outer continental shelf
waters and coastal regions of Alaska. Vol. III. Chukchi-Beaufort Sea.
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Brown, J. and R. Berg (eds.). 1980. Environmental engineering and eco-
logical baseline investigations along the Yukon River-Prudhoe Bay haul
road. CRREL Report No. 80-19. 187 pp.
, P. C. Miller, L. L. Tieszen, and F. Bunnell. 1980. An Arctic
ecosystem. Stroudsburg, PA: Dowden, Hutchingon & Ross. 571 pp.
Burns, J. J. 1983. Pers. Comm. Marine Mammal Research Supervisor,
Alaska Department of Fish & Game, Fairbanks, AK.
Burns, J. J. and T. J. Eley. 1978. The natural history and ecology of
bearded seal (Erignathus barbatus) and ringed seal (Phasa hispids).
J_n: Environmental Assessment of the Alaska Continental Shelf, Vol. 1.
OCSEAP, NOAA/BLM, Boulder, CO.
, and S. J. Harbo, Jr. 1972. An aerial census of ringed seals,
northern coast of Alaska. Arctic 25(4).
, L. H. Shapiro, and F. H. Fay. 1981. Ice as marine mammal
habitat in the Bering Sea. pp. 781-797. J_n: D. W. Hood and J.
Calder (eds.). The eastern Bering Sea shelf. Inst. Mar. Sci., Fair-
banks.
Childers, J. M. and D. R. Kernodle. 1981. Hydrologic reconnaissance of
the Noatak River basin, Alaska, 1978. U.S. Geological Survey Water
Resources Investigations Open-File Report 81-1005. 38 pp.
XI - 2
-------
, and R. M. Loeffler. 1979. Hydrologic reconnaissance of
western Arctic Alaska, 1976 and 1977. U.S. Geological Survey Open-
File Report 79-699. 70 pp.
Clarke, R. McV. 1974. The effects of effluents from metal mines on aquatic
ecosystems in Canada. A literature review. Environment Canada,
Fisheries and Marine Service, Technical Report No. 488.
Coady, J. 1983. Alaska Department of Fish & Game internal memo to Al Ott,
Habitat Division.
Cominco Alaska, Inc. 1983a. Red Dog Mine, Project Overview. January
1983.
. 1983b. Draft recreation report, Red Dog Project. July 1983.
. 1983c. Draft, Analysis of options, Red Dog Project. July 1983.
Cominco Engineering Services, Ltd. 1983a. Application of the HDS process
in the treatment of Red Dog tailings pond water. January 1983.
1983b. Wastewater collection and management, Red Dog Project.
May 1983.
Cowles, C. J. 1981. Biological assessment for endangered whales of the
Arctic Region with respect to proposed offshore oil and gas exploration.
Bureau of Land Management, Alaska OCS office. 42 pp.
Dames & Moore. 1982a. Vegetation - wetland communities, Red Dog Project.
Prepared for Cominco Alaska, Inc. 31 pp.
1982b. Final report. Port site preliminary studies for Cominco
Alaska, Inc. 5438-055-20, October 8, 1982.
. I983a. Environmental baseline studies, Red Dog Project. Pre-
pared for Cominco Alaska, Inc., Anchorage, AK.
. 1983b. Supplement to environmental baseline studies, Red Dog
Project. Prepared for Cominco Alaska, Inc., Anchorage, AK.
. 1983c. Air quality impact analysis, Red Dog Project. Prepared
for Cominco Alaska, Inc., Anchorage, AK.
De Cicco, A. 1982. Inventory and cataloging of sport fish and sport fish
waters of western Alaska. Part A: Arctic char life history study.
In: Alaska Department of Fish & Game, Sport Fish Investigations, Vol.
23, Study G-I-P-A.
1983. Pers. Comm. Fisheries Biologist, Alaska Department of
Fish & Game, Fairbanks, AK.
. (In press). Inventory and cataloging of sport fish and sport
fish waters of western Alaska. In: Alaska Department of Fish & Game,
Sport Fish Investigations, Vol. 24, Study G-I-P.
XI - 3
-------
E.V.S. Consultants Ltd. 1983. Toxicological, biophysical and chemical
assessment of Red Dog Creek, De Long Mountains, Alaska, 1982. Pre-
pared for Alaska Department of Environmental Conservation, Juneau,
AK. 245 pp.
Feulner, A. J., J. M. Childers, and V. W. Norman. 1971. Water resources
of Alaska. U.S. Geological Survey Open-File Report. 60 pp.
Fleming, R. H. and D. Heggarty. 1966. Oceanography of the southeastern
Chukchi Sea. pp. 697-754. ]_n: N. J. Wilimovsky and J. N. Wolfe
(eds.). Environment of the Cape Thompson region, Alaska. U.S.
Atomic Energy Commission, Oak Ridge, TN, Pub. PNE-481.
Frost, C. 1983. Pers. Comm. Marine Mammal Research Biologist, Alaska
Department of Fish & Game, Fairbanks, AK.
Giddings, J. L.
Knopf.
1967. Ancient men of the Arctic. New York: Alfred A.
and D. D. Anderson. In press. Prehistory of northwest Alaskan
Eskimo settlements and culture: Beach ridge archaeology of Cape
Krusenstern and other sites around Kotzebue Sound.
Gregory, L. 1974. The effect of effluent components from chlor-alkali
plants on aquatic organisms. A literature review. Fisheries Research
Board of Canada. Technical Report No. 228.
Hall, E. S., Jr. 1982a. A cultural resource site reconnaissance performed
in conjunction with development of the Red Dog mine, northwestern
Alaska. Report to Cominco Alaska, Inc. Edwin S. Hall and Associates,
Technical Memorandum #1.
. 1982b. Project specific cultural resource site inventory: The
Red Dog project. Report to the Bureau of Land Management. Edwin
Hall and Associates, Technical Memorandum #3.
. 1983a. Preliminary supplement: A cultural resource site recon-
naissance performance in conjunction with development of Red Dog mine,
northwestern Alaska. Report to Cominco Alaska, Inc. Edwin Hall and
Associates, Technical Memorandum #5.
1983b. Pers. Comm. Edwin S. Hall and Associates.
Hawley, J. R. 1972. Use, characteristics and toxicity of mine-mill reagents
in Ontario. Ontario Ministry of the Environment.
Hopkins, D. M. 1977. Coastal processes and coastal erosional hazards to
the Cape Krusenstern archeological site. U. S. Geological Survey
Open-File Report 77-32. 17 pp.
Houghton, J. 1983.
Seattle, WA.
Pers. Comm. Fisheries Biologist, Dames & Moore,
XI - 4
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Jansons, U. and R. G. Bottge. 1977. Economic mining feasibility studies of
selected mineral deposit types in the western Brooks Range, Alaska.
U.S. Bureau of Mines Open-File Report 128-77.
John Muir Institute, 1983. The regional socioeconomics of Norton Sound
(draft), prepared for Minerals Management Service, Alaska OCS Office.
Johnson, A. W., L. A. Viereck, R. E. Johnson, and H. Melchior. 1966.
Vegetation and flora. In: N. J. Wilimovsky and J. N. Wolfe (eds.).
Environment of the Cape Thompson region, Alaska. U.S. Atomic
Energy Commission, Oak Ridge, TN, Pub. PNE-481.
Johnson, C. 1983. Pers. Comm. Marine Mammal Biologist, National Marine
Fisheries Service, Anchorage, AK.
Kevin Waring Associates. 1983. Socioeconomic forecasts for the NANA
Region. Unpub. data.
LGL Ecological Research Associates, Inc. 1980. Baseline aquatic investiga-
tions of fish and heavy metal concentrations in the Kivalina and Wulik
Rivers, 1978-1979. Prepared for GCO Minerals Co.
Louis Berger & Associates. 1981. Western and Arctic Alaska transportation
study. Prepared for State of Alaska, Department of Transportation and
Public Facilities.
Marquette, W. M. and H. W. Braham. 1982. Grey whale distribution and
catch by Alaska Eskimos: A replacement for the bowhead whale?
Arctic 35(3).
Mauneluk Association. 1974. The NANA region; its resource and develop-
ment potential. Prepared for U.S. Economic Development Authority and
the U.S. Bureau of Indian Affairs, Juneau, AK.
. 1979. Subsistence. A summary of available information about
the NANA Region.
McHarg, I. 1969. Design with nature. Garden City, New York: Doubleday.
McVey, R. W. 1983. Pers. Comm. Director, Alaska Region, National Marine
Fisheries Service, Juneau, AK.
Moore, G. W. 1966. Arctic beach sedimentation, pp. 587-608. jjn: N. J.
Wilimovsky and J. N. Wolfe (eds.). Environment of the Cape Thompson
region, Alaska. U.S. Atomic Energy Commission, Oak Ridge, TN, Pub.
PNE-481.
Muller, S. W. 1947. Permafrost or permanently frozen ground and related
engineering problems. Military Intelligence Division, Chief Engineer,
U.S. Army office, Special Report, Strategic Engineering Study 62.
231 pp.
XI - 5
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Murray, D. F. 1980. Threatened and endangered plants of Alaska.
U.S.D.A. and U.S.D.I. Coop. Forest Service and Bureau of Land
Management Report, Contr. No. 53-0109-9-00014. 59 pp.
Noah, H. 1983. Pers. Comm.
Inc., Anchorage, AK.
Environmental Coordinator, Cominco Alaska,
. 1984. Cominco Alaska letter to Mr. Keith Kelton, Director,
Alaska Department of Environmental Conservation, June 26, 1984.
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fish, wildlife and their habitats - Arctic tundra and alpine meadows.
FWS/OBS 80/40.8. U.S. Department of the Interior, Washington, D. C.
70 pp.
Rae, J. A. 1983. Pers. Comm. Red Dog Project Manager, Cominco, Ltd.,
Trail, B.C., Canada.
Reeder, S. W., A. Demayo and M. C. Taylor. 1979. Guidelines for surface
water quality. Vol. 1. Inorganic Substances, Cadmium. Environment
Canada, Inland Waters Directorate, Ottawa. 19 pp.
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Cape Lisburne, Alaska. Mar. Fish. Rev. 42:46-51.
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Kivalina. In: N. J. Wilimovsky and J. N. Wolfe (eds.). Environment
of the Cape Thompson region, Alaska. U.S. Atomic Energy Commission,
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Sellmann, P.V., J. Brown, R. I. Lewellen, H. McKin, and C. Merry. 1975.
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Shaver, M. 1983. Pers. Comm. Superintendent, Cape Krusenstern National
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XI - 6
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Sprague, J. B., P. F. Elson, and R. L. Saunders. 1965. Sublethal copper-
zinc pollution in a salmon river -- a field and laboratory study. Int.
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. 1982. Population and trophies studies of seabirds in the
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liminary classification system for vegetation of Alaska. U.S.D.A.,
Forest Service General Technical Report PNW-106. 64 pp.
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Commissioner letter to W. H. Tonking, GCO Minerals and H. M.
Giegerich, Cominco Alaska, March 9, 1983.
XI - 7
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Chapter XII
Glossary
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XII. GLOSSARY OF TECHNICAL TERMS, ACRONYMS AND
ABBREVIATIONS AND MEASUREMENT EQUIVALENTS
DEFINITION OF TERMS
Technical Term
Definition
alluvium
anadromous
aufeis
borrow site
chelation
diachronic
epibenthic
epifauna
euryhaline
halophytic
hydric
hydrophyte
igneous
infauna
lighter
Material deposited by moving water.
Fish which go up rivers from the sea to spawn.
Icings formed from pressurized flows of streams or
groundwater.
Site from which road construction materials (gravel) would
be extracted.
Reaction which causes central atom (usually a metal ion)
to attach to neighboring atoms to form a ring structure.
Through time.
Existing on the surface of bottom material.
Community of organisms which live on or just beneath the
surface of bottom material.
Capable of withstanding wide variations in salinity.
Adapted to grow in salty or alkaline soil.
Characterized by an abundance of moisture.
Plant growing only in water or very wet earth.
Formed by volcanic action or intense heat.
Community of organisms which live within bottom material.
Open barge used for transporting goods between ships
and shore in shallow water.
XII - 1
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Technical Term
(Continued)
lightering
mafic
mesic
moraine
natal stream
oligochaeta
orographic
polynya
project area
Definition
rolligon
scree
sealift
seismic
solifluction
tailings
tailings pond
thaw bulb
Using open barges in loading and unloading of larger
ships where shallow waters prevent normal docking.
Pertaining to igneous rocks rich in magnesium and iron,
and relatively low in silica.
Moist, or requiring moderate amounts of moisture.
Mass of rocks, gravel, sand, clay, etc., carried and then
deposited by a glacier along its sides, at its terminus, or
underneath the ice.
Stream in which a fish is born.
Class of segmented worms; found chiefly in moist soils
and fresh water.
Pertaining to mountains.
Semi-permanent open lead in sea ice.
Refers to the entire area encompassed by proposed
project components. Generally bounded by the Singoalik
Lagoon port site, the GCO transportation corridor, Red
Dog Valley, the Mulgrave Hills, VABM 28 and an undeter-
mined distance out to sea.
Cushion-wheeled vehicle used for crossing tundra with
minimal damage. •
A heap of rock waste at the base of a cliff or a sheet of
coarse, loose debris lying on a mountain slope.
Large seasonal movement of cargo by ships from distant
points to the project area.
Related to, or caused by, earthquakes or man-made earth
tremors.
The process of slow downslope movement of water-
saturated earth.
The waste products of the milling process that are dis-
posed of in the tailings pond.
The area created by a dam to hold the mill tailings.
Unfrozen zone in permafrost area, usually around lake,
stream, or man-made structure.
XII - 2
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Technical Term Definition
(Continued)
thermocline Layer of water between warmer surface zone and colder,
deeper waters in which temperature decreases rapidly
with depth.
Title XI The part of the Alaska National Interest Lands Conserva-
tion Act (ANILCA) that provides a mechanism for the
Secretary of the Interior to grant access through certain
reserved lands in Alaska (e.g., Cape Krusenstern
National Monument).
trophic Related to nutrition.
ungulate A hoofed mammal.
xeric Related to, or having dry or desert-like conditions.
xerophytic Adapted to growing under very dry or desert-like (xeric)
conditions.
AGENCY ACRONYMS AND ABBREVIATIONS
Federal Agencies
ACHP Advisory Council on Historic Preservation
BLM Bureau of Land Management
CEQ Council on Environmental Quality
Corps Army Corps of Engineers
DA Department of the Army
DO I Department of Interior
EPA Environmental Protection Agency
FWS Fish and Wildlife Service
MSHA Mining Safety and Health Administration
NMFS National Marine Fisheries Service
NOAA National Oceanographic and Atmospheric Administration
NPS National Park Service
NWS National Weather Service
USGS United States Geological Survey
XII - 3
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State of Alaska Agencies
ADF&G
AEIDC
DEC
DGGS
DNR
Alaska Department of Fish and Game
University of Alaska, Arctic Environmental Information & Data Center
Department of Environmental Conservation
Division of Geological and Geophysical Survey
Department of Natural Resources
DOT/PF Department of Transportation and Public Facilities
SHPO State Historic Preservation Office
Other
ANCSA Alaska Native Claims Settlement Act of 1971
ANILCA Alaska National Interest Lands Conservation Act of 1980
BACT Best Available Control Technology
HDS High Density Sludge
IRA Indian Reorganization Act
NAAQS National Ambient Air Quality Standards
NANA NANA Regional Corporation
(originally: Northwest Alaska Native Association)
NEPA National Environmental Policy Act
NPDES National Pollutant Discharge Elimination System
NSB North Slope Borough
NSPS New Source Performance Standards
ORV Off-road Vehicles
PSD Prevention of Significant Deterioration
ROD Record of Decision
SPCC Spill Prevention, Control and Countermeasure Plan
VLCC Very Large Crude Carrier
VQO Visual Quality Objective
VRM Visual Resources Management
XII - 4
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METRIC/ENGLISH MEASUREMENT, ABBREVIATIONS AND EQUIVALENTS
Metric Unit (Abbrev.)
centimeter (cm)
meter (m)
kilometer (km)
hectare (ha)
square kilometer (km2)
liter (£)
cubic meter (m3)
cubic meter (m3)
cubic dekameter (dam3)
cubic meter
per second (m3/s)
kilogram (kg)
megagram (Mg)
meter per second (m/s)
meter per second (m/s)
miligram per liter (mg/£)
degrees Celsius (°C)
barrels (bbls)
Equivalent
2.54 cm = 1 in
0.3048 m = 1 ft
1.6093 km = 1 mi
0.4047 ha = 1 ac
2.590 km2 = 1 mi2
3.7854 £ = 1 gal
0.0283 m3 = 1 ft3
0.7646 m3 = 1 yd3
1.2335 dam3 = 1 ac-ft
0.0283 m3/s = 1 ft3/s
0.4536 kg = 1 Ib
0.9072 Mg = 1 ton
0.5144 m/s = 1 knots
0.3048 m/s = 1 ft/s
1.0 mg/£ = 1 ppm
(1.8x°C)+ 32= °F
English Unit (Abbrev.)
inch (in)
foot (ft)
mile (mi)
acre (ac)
square mile (mi2)
gallon (gal)
cubic feet (ft3)
cubic yard (yd3)
acre-foot (ac-ft)
cubic feet
per second (ft3/s)
pound (Ib)
short ton (2,000 Ib)
knot (knot)
feet per second (ft/s)
part per million (ppm)
degrees Fahrenheit (°F)
barrels (bbls)
XII - 5
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Chapter XIII
Index
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XIII. INDEX
Active layer: IV-8
ADF&G: (see Alaska Department of Fish & Game)
Advisory Council on Historic Preservation (ACHP): 1-10, V-25, V-71, V-81,
V-93, VI-8
Air quality: IV-49, V-17, V-66, V-81, V-83, V-92, VI-8
Aircraft flights: V-69
Airstrip: 11-13, V-85
Alaska Department of Environmental Conservation (DEC): 1-10, V-82, VI-9
Alaska Department of Fish & Game (ADF&G): 1-10, V-42, V-46, V-80, V-90,
VI-9
Alaska Department of Natural Resources (DNR): I-5, 1-11, V-75, VI-10
Alaska National Interest Lands Conservation Act (ANILCA): 1-1, III-36,
III-40, IV-1, V-93, V-97
Alaska Native Claims Settlement Act (ANCSA): I-2, IV-1
Alluvial deposits: IV-5, IV-7
Alternatives 1, 2 and 3: III-40, III-43, V-36
Ambler District: V-88
Anadromous fish: (see Fish)
Appendix 1, Reclamation Plan: V-83
Appendix 2, Spill Prevention, Control and Countermeasure (SPCC) Plan:
V-5, V-13, V-46, V-47, V-51, V-54, V-64, V-80, V-92
Appendix 3, Endangered Species Biological Assessment: IV-12, IV-19, IV-43,
VI-8
Appendix 4, Proposed NPDES Permit: VI-1
Appendix 5, Department of Army Public Notice and Section 404(b)(1)
Evaluation: VI-7
Appendix 6, ANILCA Title XI Right-of-Way Application: VI-7
Appendix 7, Protection of Cultural Resources: VI-8, VI-10
Archeological resources: VI-8, VI-10
Archeological sites: IV-53, V-25, V-90
Arctic char: (see Fish)
Arctic Circle: I-2
Asikpak Lagoon: IV-12, V-51
Asikpak River: 11-13, III-6, IV-12, IV-19, V-39, V-45, V-49, V-51
Asikpak route: III-6, 111-16, III-35, III-38
Atigun Pass: V-38, V-66
Ballasted tanker: (see Transfer facility)
Baqhalik Creek: IV-33
Barite: 11-1, II-8, IV-8
Barium sulfate: II-8, V-63
Bear Creek Mining Company: V-88
Beaufort Sea: I V-42, V-60
XIII - 1
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Belukha whale: (see Marine mammals)
Benthic invertebrates: IV-30, V-13, V-49
Bering Sea: IV-42
Bering Strait: IV-43
Best Available Control Technology (BACT): V-17, V-20
Big Diomede Island: IV-43
Bioaccumulation: IV-37, V-2, V-14
BLM: (see U.S. Bureau of Land Management)
Boating: IV-71, V-74
Bons Creek: II-6, III-3, 111-16, IV-25, V-16
Bons Creek water supply reservoir: 11-13, V-13, V-17, V-85
Borrow sites: 11-16, II-34, V-37, V-39, V-46, V-51, V-67, V-68, V-86
Bowhead whale: (see Marine mammals; c.f. Appendix 3)
Bridge: (see Road transportation system)
Brooks Range: I-2, IV-8, IV-17, V-88
Brown bear: (see Terrestrial wildlife)
Buddy Creek: III-3, IV-25
Cadmium: IV-23, IV-25, IV-26, IV-36, V-5
Campsite: III-3, V-27
Cape Krusenstern: IV-46, IV-53, V-53, V-57, V-61, V-64, V-94
Cape Krusenstern Archeological District: III-48, IV-53
Cape Krusenstern National Monument: 1-1, 1-5, 1-9, 11-18, III-7, III-48,
III-49, IV-2, IV-50, IV-53, IV-72, V-23, V-71, V-74, V-88, V-90,
V-97, VI-7
Cape Lisburne: I-2
Cape Seppings: V-74
Cape Thompson: IV-15, IV-42, IV-48
Caribou: (see Terrestrial wildlife)
Char overwintering habitat: (see Fish)
Chemical spills: V-2, V-5, V-38, V-45, V-47, V-54, V-61 (c.f. Appendix 2)
Chromium: IV-26, IV-30
Chukchi Sea: I-2, 11-13, IV-42, IV-46
Coal: III-3, V-89
Coastal geologic processes: I-8, III-46, IV-46, V-57, V-94
Coastal Zone Management: VI-11 (c.f. Appendix 8)
Cominco Alaska, Inc.: I-2, I-7
Community facilities: IV-69, V-34
Component: 11-1, 111-16, III-39, V-1
Concentrate spills: V-2, V-38, V-54, V-61 (c.f. Appendix 2)
Concentrate storage building: II-30, II-35, V-39, V-68
Concentrates (lead, zinc, barite): 11-1, II-8, V-63
Copper: IV-26, IV-37
Copper sulfate: 11-10, V-62
Corps: (see U. S. Department of Army Corps of Engineers)
Council on Environmental Quality (CEQ): 1-1
Cultural resources: I-8, III-48, I V-51, V-25, V-71, V-81, V-83, V-93,
VI-8, VI-10
De Long Mountains: I-2, IV-4, IV-15, V-75
Deadlock Mountain: I-2, IV-4
DEC: (see Alaska Department of Environmental Conservation)
Department of the Army (DA): IV-10, VI-1, VI-7
Development schedule: 11-34
Diachronic model: IV-53
XIII - 2
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Diesel fuel: 11-13, III-3
Discharge standards: 11-12, V-7, V-9
Diversion ditch: II-4, V-4, V-5, V-80, V-82
Division of Geological and Geophysical Survey (DGGS): V-89
DNR: (see Alaska Department of Natural Resources)
DOI: (see U.S. Department of the Interior)
Domestic wastewater: 11-18, V-8, V-80
Dredging: II-30, V-52, V-53, V-59
Dudd Creek: 11-13, III-3, IV-25, IV-37
Dust: V-2, V-17, V-19, V-38, V-66, V-81, V-91
Economy: I-9, III-48, IV-65
Emissions: V-17, V-21, V-66
Employment: IV-66, V-26
Endangered species: IV-11, IV-17, IV-43, VI-8 (c.f. Appendix 3)
EPA: (see U.S. Environmental Protection Agency)
EPA Significant Emission Rates: V-17, V-21
Erosion: V-14, V-38, V-46, V-59
Eschscholtz Bay: IV-42
Evaingiknuk Creek: III-7
Evaporation: IV-48, V-8
Fish: I-8, 11-13, 11-16, III-44, V-14, V-50, V-72, V-82, V-100
Anadromous fish: IV-32, IV-40, V-46, V-52, V-55, V-101
Arctic char: IV-36, IV-40, IV-54, IV-59, IV-72, V-14, V-25, V-73, V-101
Arctic grayling: IV-32, IV-36, IV-40, IV-72, V-14, V-51
Char overwintering habitat: 11-13, IV-32, V-51
Char rearing habitat: V-51, V-52
Char spawning habitat: IV-32, V-51, V-52
Chum salmon: IV-33, IV-40, IV-54, IV-59, IV-72
Coho salmon: IV-33
King salmon: IV-33
Migration: IV-37, V-50, V-52, V-55
Pink salmon: IV-33, IV-40
Salmon: IV-36, V-14, V-51
Sockeye salmon: IV-33
Tissue: IV-37, V-15
Fishing: IV-71, V-16, V-52, V-74, V-90, V-100, V-102
Fivefingered Creek: IV-33
Floodplains: IV-7
Fuel: 11-18, II-32, V-61
Fuel spills: V-2, V-5, V-38, V-45, V-47, V-54, V-61 (c.f. Appendix 2)
FWS: (see U.S. Fish and Wildlife Service)
Garbage collection: V-4, V-80
GCO Minerals Company: I-2, III-3, V-88
GCO route: III-3, 111-16, III-35, III-38
Glacial moraine: IV-4
Golden eagle: (see Terrestrial wildlife)
Gray whale: (see Marine Mammals; c.f. Appendix 3)
Grayling Creek: 11-16, IV-33, V-49
Groundwater: IV-19, IV-26, V-4, V-45, V-80, V-82
High Density Sludge (HDS) process: 11-12, V-9
Hotham Inlet: III-8, III-37
Hovercraft: III-7
Hunting: IV-71, V-26, V-36, V-74, V-81, V-90, V-100
XIII - 3
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Hydrology: IV-19, V-5, V-46, V-80, V-82, VI-9
Hydropower: IM-3
Ice: IV-47, V-60
Ice-wedge polygons: IV-5
Icings: IV-7, IV-19, V-49, V-82
Ikalukrok Creek: 11-13, IV-20, IV-25, IV-26, V-47, V-82
Imikruk Creek: IV-12
Imikruk Lagoon: IV-12
Income: IV-66, V-27, V-30
Inupiat Eskimos: IV-55, IV-62
Ipiavik Lagoon: IV-12, IV-20, IV-42, V-50, V-59
Iron: IV-23, IV-26
Kavrorak Lagoon: IV-42, V-51
Kivalina: I-2, 11-13, III-6, IV-2, IV-19, IV-54, V-25, V-98
Kivalina Lagoon: IV-12
Kivalina River: 11-13, III-6, IV-7, IV-12, IV-19, IV-23, IV-32, V-39, V-48,
V-73, V-101
Kobuk National Monument: V-88
Kotlik Lagoon: IV-37
Kotzebue: I-2, 11-1, IV-2, IV-54, IV-62, IV-70, V-33, V-81, V-99
Kotzebue Sound: III-8, III-37, IV-42
Kruz route: III-7, 111-16, III-35, III-38, V-99
Lagoon breaching: II-30, II-32, II-33, V-39, V-43, V-52, V-59
Land exchange: I-5
Land status: IV-2
Lead: 11-1, II-8, IV-8, IV-23, IV-25, IV-29, V-5
Lead sulfide: 11-13
Lighter barges: 11-30, 11-32
Lik prospect: I-5, III-3, III-49, V-76
Lime: 11-11
Manganese: IV-26
Mapsorak Lagoon: IV-37
Marine biology: I-8, III-46, IV-37, V-52
Marine birds: IV-42, V-55, V-57
Marine fish: IV-40, V-53, V-55
Marine invertebrates: IV-38, V-52
Marine mammals: IV-42, V-25, V-55, V-57, V-70, V-72, V-100, V-103
Bearded seal: IV-42, IV-54, V-73
Belukha whale: IV-42, IV-54, V-70, V-73
Bowhead whale: IV-42, V-56, V-70, V-73, VI-8 (c.f. Appendix 3)
Gray whale: IV-43, V-56, V-70, VI-8 (c.f. Appendix 3)
Harbor porpoise: IV-42
Polar bear: IV-43
Ringed seal: IV-42, IV-54, V-55
Spotted seal: IV-42, IV-54
Walrus: IV-43, V-73
Whale migration: IV-43, V-56, V-81
Marine water quality: IV-46, V-59, V-65, V-82
Mauneluk (Maniilaq) Association: V-72
Mercury: IV-26, IV-30
Meteorology: I V-47
Methylisobutyl carbinol: 11-11
Mill: 11-1, II-4, II-6, 111-1, V-85
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Mine: 11-1, II-2, 111-1, V-22, V-25, V-83
Mining Safety and Health Administration (MSHA): 11-12
Mitigation: V-78
Monitoring: V-81, VI-1
Moose: (see Terrestrial wildlife)
Morgan Coal Company: V-89
Mulgrave Hills: 11-13, IV-59, V-72, V-102
Muskoxen: (see Terrestrial wildlife)
NANA region: IV-62, IV-65, IV-70, V-99, VI-10
NANA Regional Corporation: I-2, 11-1, III-40, IV-2, V-27, V-75, V-78,
V-83
NANA/Cominco agreement: I-7, V-27, V-31, V-35, V-41, V-72, V-102
Natal streams: IV-32
National Ambient Air Quality Standards (NAAQS): V-17, V-20, V-66
National Climatic Center: IV-48
National Environmental Policy Act of 1969 (NEPA): 1-1
National Marine Fisheries Service (NMFS): 1-10, IV-43, VI-8
National Petroleum Reserve: III-36
National Pollutant Discharge Elimination System (NPDES) Permit: 1-1, I-9,
11-18, V-8, V-82
National Register of Historic Places: III-48, IV-53, V-25, V-71
Natural gas: III-3, V-87
New Heart Creek: V-50, V-72
Nickel: IV-26
NMFS: (see National Marine Fisheries Service)
No Action Alternative: III-40, V-1, V-77
Noatak: I-2, III-7, III-37, IV-2, IV-54, IV-62, V-25, V-98
Noatak corridor: HI-7, III-37
Noatak National Preserve: III-36, I V-71, V-88
Noatak River: 11-16, III-7, III-37, IV-7, IV-19, IV-33, IV-71, V-37
North Fork Red Dog Creek: III-3, IV-22, I V-25, V-14
North Slope Haul Road: V-38, V-66
North Slope Borough: 1-11, IV-2, IV-70, V-35, V-86
Northern corridor: 11-13, III-3, III-38, IV-53, V-85
NPS: (see U.S. National Park Service)
Ocean currents: IV-44
Off-road vehicles (ORVs): V-90
Ogotoruk Beach: IV-46
Ogotoruk Creek: IV-20
Ogotoruk Valley: IV-48
Oil: V-87
Omikviorok River: 11-16, III-7, IV-12, IV-20, V-37, V-49, V-50, V-101
Omikviorok route: III-7, 111-16, III-38
Option: 11-1, 111-1
Options screening criteria: III-9
Options screening process: III-8, 111-16, III-39
Ore: I-2, 11-1
Ore body: II-4, IV-26, IV-36, V-5
Orographic shading: IV-48
Ott Water Engineers, Inc.: I-5
Overburden: 11-4, V-84
Peregrine falcon: (see Terrestrial wildlife; c.f. Appendix 3)
Permafrost: 11-16, IV-5, IV-8, IV-19, V-46
XIII - 5
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pH: IV-23, IV-25, IV-26, IV-29, IV-36, V-10
Physical and chemical oceanography: IV-44, V-57
Physiography: IV-5
Pingos: IV-7
Point Hope: IV-43, IV-46, IV-47, IV-62, V-53, V-61
Point Lay: V-89
Polyacrylamide flocculant: 11-11
Polynya: IV-42, V-55, V-56
Population (human): IV-62, V-32
Port site: 11-1, 11-18, II-36, III-8, 111-16, III-35, VI-1
Power generation: 11-6, 11-13, III-3
Power plant: 11-1
Precipitation: IV-20, IV-48, V-8
Preferred alternative: III-50, V-95
Prevention of Significant Deterioration (PSD): V-17, V-20, VI-9
Project components: 111-1
Prudhoe Bay: V-38, V-66
Public access: V-75, V-89
Rabbit Creek: IV-17, IV-33, V-42, V-45, V-73
Railroad: 11-13, III-7, III-35
Raptors: IV-12, V-42
Reagents: II-8, V-9, V-63
Reclamation: V-15, V-83, V-86, VI-1 (c.f. Appendix 1)
Recreation: IV-70, V-36, V-74, V-83, V-93
Red Dog Creek: I-2, II-2, IV-19, IV-23, IV-26, V-11, V-14, V-82
Red Dog Valley: I-2, II-36, III-3
Regional use: I-9, III-48, V-75
Revegetation: V-13, V-19, V-47, V-66, V-86 (c.f. Appendix 1)
Right-of-way: 11-18, VI-7, VI-10
Road transportation system: 11-16, 11-36, III-7, III-35
Bridge: 11-13, 11-16, V-38, V-46, V-76, V-85
Construction: V-41, V-43, V-46, V-50, V-67, V-80
Culvert: 11-13, 11-16, V-38, V-46, V-49, V-82, V-85
Drainage: V-38, V-47
Stream crossing: III-44, V-46, V-49, V-51, V-82, V-85
Rolligons: V-47
Runoff: IV-20, V-7
Salinity: IV-46
Salmon: (see Fish)
Scoping issues: I-7
Scoping process: I-5, 111-1, III-8, III-42
Scour: V-60
Sealift: I-7, 11-18, II-34
Section 10 (River and Harbors Act of 1899): I-2, VI-7
Section 404 (Clean Water Act of 1972): I-2, VI-1, VI-7
Section 7 (Endangered Species Act of 1973): VI-8
Section 810 (ANILCA): V-97, VI-7
Sediment loading: V-15, V-50
Sediment transport: IV-46, V-57, V-82
Sedimentation ponds: V-13, V-46, V-59, V-62, V-80, V-82
Seepage containment: II-6, V-5, V-13
Seismology: IV-5
Selective flotation milling process: 11-8
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Siaktak Hills: IV-17, V-44
Silicate: II-8
Silver: 11-1, II-8, IV-8, IV-25, IV-26
Singoalik Lagoon: IM-6, III-8, III-35, III-38, IV-12
Singoalik River: III-6, IV-12, V-45
Slurry pipeline: III-7
Snowfall: IV-48
Social impacts: I-9, III-48
Socioeconomics: IV-62, V-27, V-81, V-83
Sodium cetylsulfonate: 11-11
Sodium cyanide: 11-10, V-62
Sodium isopropyl xanthate: 11-11
Soils: IV-8, IV-19
Sound: IV-51, V-23, V-68, V-81, V-93
South Fork Red Dog Creek: III-3, 111-16, IV-23, IV-26, V-5, V-14
Southern corridor: 11-16, III-3, III-7, 111-16, III-35, III-38, IV-53, V-85, V-101
Sphagnum: IV-8
St. Lawrence Island: IV-43
State Historic Preservation Officer (SHPO): 1-11, V-25, V-71, V-81, VI-10
Storm events: IV-20, V-8, V-80
Storm surges: I V-44
Subsistence: I-8, III-47, IV-54, IV-65, V-25, V-72, V-81, V-83, V-91,
V-93, V-97, VI-7
Sulfides: 11-1, II-8, V-63
Sulfuric acid: 11-11, V-62
Tailings: II-2, V-8
Tailings pond: 11-1, II-6, III-3, 111-16, V-7, V-8, V-80, V-84, VI-1
Tailings pond dam: II-4, II-6
Tailings pond overflows: V-12, V-16
Tailings slurry: II-6, II-8
Tasaychek Lagoon: V-88
Terrestrial wildlife: I-8, III-45, V-3, V-40, V-79, V-82, V-92, V-100
Brown bear: IV-17, V-3, V-42, V-44
Caribou: IV-12, IV-54, IV-72, V-3, V-25, V-41, V-44, V-72, V-101
Dall sheep: IV-17, V-4, V-42
Golden eagle: IV-12, V-3
Gyrfalcon: IV-12
Moose: IV-15, IV-54, IV-72, V-4, V-42, V-45, V-72, V-73, V-101
Muskoxen: IV-15, V-4, V-42, V-45
Peregrine falcon: IV-12, IV-17, V-41, V-44, VI-8 (c.f. Appendix 3)
Red fox: IV-17, V-3, V-44
Rough-legged hawk: IV-12
Shorebirds: IV-12
Small mammals: V-3, V-40, V-42, V-44, V-101
Song birds: V-3, V-40, V-42, V-44
Waterfowl: IV-12, IV-54, IV-59, V-4, V-42, V-45, V-72, V-101
Wolverine: IV-17, V-3, V-44
Wolves: IV-17, V-3, V-44
Thaw bulb: IV-7
Thaw lake: IV-5
Thermocline: IV-47
Tides: I V-44
Title XI (ANILCA): 1-1, I-5, 111-16, III-37, III-40, V-75, V-91, V-97, VI-7
XIII - 7
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Title 16 (Alaska Statutes): V-47, VI-9
Total suspended solids (TSS): V-11
Townsite: III-3, V-27, V-34
Transfer facility: II-30, III-8, III-35
Ballasted tanker: II-30, V-53, V-59, V-68, V-86
Bulk carrier: II-30, V-65
Buried pipeline: II-32, V-56, V-61
Causeway/dock: 11-30, III-8, III-35, V-53, V-56, V-58
Short causeway/lightering: II-30, II-32, III-8, III-35
Short causeway/offshore island: 11-30, Hl-8, III-35
Transportation corridor: 11-1, 11-13, III-3, III-35
Transportation system: 11-1, III-7, III-35
Trapping: V-26, V-36, V-74, V-90
Tugak Lagoon port site: 11-1, 11-13, III-6, III-8, HI-35, IV-12, IV-54,
V-55, V-73
Tutak Creek: IV-33, IV-37, V-41
U.S. Department of Army Corps of Engineers (Corps): 1-2, 1-10, VI-7
U.S. Bureau of Land Management (BLM): I-5, IV-1, V-89
U.S. Department of the Interior (DOI): 1-1
U.S. Environmental Protection Agency (EPA): 1-1, I-9, VI-1
U.S. Fish and Wildlife Service (FWS): 1-10, VI-8
U.S. Forest Service: IV-50
U.S. National Park Service (NPS): 1-1, I-4, 1-10, IV-2, V-75, V-99, VI-7
VABM 17: III-7, III-39
VABM 28 port site: 11-1, 11-13, 11-16, tll-7, 111-16, III-39, V-72
Vegetation: IV-8, V-2, V-36, V-39, V-79, V-82, V-91
Herbaceous: IV-10
Hydrophytes: IV-11
Mat and cushion tundra: IV-9
Shrubland: IV-9
Tussock tundra: IV-10, V-39
Very Large Crude Carrier (VLCC): II-30 (c.f. Ballasted tanker)
Visual resources: IV-50, V-22, V-67, V-92
Volcano Creek: III-3
Volcano Mountain: V-25
Waste heat: II-6, II-8, II-13
Wastewater treatment plant: 11-6, 11-12
Water balance: V-5
Water quality: I-7, III-44, IV-22, IV-36, V-5, V-11, V-46, V-80, V-82,
V-84, VI-9
Water recirculation: 11-6, 11-8
Water supply: 11-12, III-3
Waves: IV-44
Western and Arctic Alaska Transportation Study (WAATS): III-6, V-88
Western route: III-7, 111-16, III-38
Wetlands: IV-10, V-2, V-38, V-40, V-79, V-82, V-91, VI-7
Wind: IV-44, IV-49
Wolves: (see Terrestrial wildlife)
Worker housing: 11-1, II-6, 11-12, II-35, 111-1, III-3, V-85
Wulik Peaks: IV-19
Wulik River: 11-13, III-6, IV-7, IV-12, IV-19, IV-23, V-37, V-39, V-47,
V-51, V-73, V-101
Zinc: 11-1, II-8, IV-8, IV-23, IV-29, IV-36, V-5, V-11
Zinc sulfate: 11-10
Zinc sulfide: 11-13
XIII - 8
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XIV. LIST OF APPENDICES
1. Reclamation Plan
2. Spill Prevention, Control and Countermeasure (SPCC) Plan
3. Endangered Species Biological Assessment
4. Proposed NPDES Permits
5. Department of Army Public Notice and Section 404(b)(1) Evaluation
6. ANILCA Title XI Right-of-Way Application
7. Protection of Cultural Resources
All appendices are bound together in a separate volume.
XIV-1
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