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.
                                    IX

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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

-------
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

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                         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

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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

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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

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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

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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

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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

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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

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FIGURE 11-4 MILL SITE FACILITIES

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                                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

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 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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 BALLASTED TANKER
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-------
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

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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

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         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.

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                                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

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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

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OVOLCAN.
MOUNTAI
EL. 2127
                FIGURE 111-1  RED DOG VALLEY MAP
                SHOWING TAILINGS POND OPTIONSj

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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

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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

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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

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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

-------
                                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

-------
                                 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

-------
                                 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.

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                                                                                                      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.

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                                                                             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.

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                                                                              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.

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                                                                              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

-------
                                          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

-------
                                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

-------
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

-------
                               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

-------
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

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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

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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

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                      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

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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

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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

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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

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     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

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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

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     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

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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

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     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

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                                                                                                                        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

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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

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                                                        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

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                                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

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                                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

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                                                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

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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

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                                                                             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

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                                                                             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

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                                                                             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

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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

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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

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 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

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                               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

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                                                               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,

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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

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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

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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

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                              .
                        UJ
                        o
                        UJ
                          (9
FIGURE IV-10 MARINE BENTHIC INFAUNA
            SAMPLING STATIONS

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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

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                                             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

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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

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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

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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

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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

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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

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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

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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

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                  FIGURE IV-11
                  VISUAL QUALITY
OBJECTIVE ZONES IN PROJECT AREA

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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

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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

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                               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

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                                            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^/

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•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

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          ANNUAL SUBSISTENCE ACTIVITY CYCLE OF NOATAK
                                                                                ANNUAL  SUBSISTENCE ACTIVITY CYCLE OF KIVALINA
    23
    O
    c
    JJ
    m
 OZ
 >z
 HC
 7s 00
 
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                                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

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                                                         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

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                                                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

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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

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                          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

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                                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

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                                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

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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

-------
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.

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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.
                                V - 64

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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,


                                V - 65

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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


                                V  -  66

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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

                                V - 67

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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.

                                 V - 68

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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:

                                V - 69

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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.


                                V  - 70

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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-
                                 V - 71

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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-
                                V  -  72

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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
                                V  - 73

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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
                                 V - 74

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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-


                                V - 75

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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.
                                 V  - 76

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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
                                V -  77

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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
                                V - 78

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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.
                                V -  79

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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.
                                V  -  81

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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


                                V - 82

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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

                                V  -  83

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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.
                                 V - 90

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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.
                                V - 91

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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.
                                V -  95

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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;
                                V  - 97

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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:

                                V  - 98

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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.
                                V - 99

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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


                                 V -  100

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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.
                                 V - 102

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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

                                 VI  -  8

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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.
                                 VI  -  9

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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).
                                 VI  - 10

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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

-------
    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
£
U
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3

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                                                                                               Summary
Comments
35
1
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16
17
21
12
7
12
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8
6
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Sources
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3
                                           VII  -  3

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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

-------
               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

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                       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

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                       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

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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.

-------
                                                           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.

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        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

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                                                           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

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             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

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                                                                    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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                                                                                 -2-
X
 I
                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
00

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                    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
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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
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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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>)         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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CO

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NORTH SLOPE BOROUGH

OFFICE OF THE MAYOR
P.O. Box 69
Barrow, Alaska 99723
Phone:907-852-2611
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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.

-------
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
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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
00
o

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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

-------
   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...

-------
                                                -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

-------
                                   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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X
 I
-u
tO
      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
X
 I
en
o
                                                      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
X
 i
en
r\>
     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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en
     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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Ui
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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
CT>
         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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X
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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.

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    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).

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 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.

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 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

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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.

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                                                                    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.

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                                              -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   ''

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                                                     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

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                         XI.   REFERENCES CITED
REFERENCES

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Alt,  K.  T.   1978.    Inventory  of cataloging  of sport fish  and  sport  fish
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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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Benoit,  D.  A.,  E.  N.,  Leonard,  G.  M., Christensen,  and J.  T.  Fiandt.
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                                  XI - 2

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	,  and  R.  M.  Loeffler.   1979.   Hydrologic reconnaissance of
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            1983b.   Wastewater collection and  management,  Red Dog  Project.
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     Arctic Region with respect to proposed  offshore oil and  gas exploration.
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                                  XI - 3

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                                  XI - 4

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                                  XI  -  5

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     The  classification   and geomorphic  implications  of thaw  lakes  on  the
     Arctic  coastal  plain,   Alaska.   Research   Report  344,  Cold  Regions
     Research and  Engineering Laboratory,  Hanover,  NH.  21 pp.

Shaver, M.  1983.   Pers.  Comm.  Superintendent, Cape  Krusenstern  National
     Monument,  National Park Service,  Kotzebue,  AK.

Smith, H.  L.  1982.   Archaeological  investigations  in the DeLong  Mountains,
     northwest  Alaska,  1979-1980.   Bureau  of Land Management,  Fairbanks,
     AK.

Social  Research  Institute.   1982.  NANA coastal resource service area coastal
     management plan:   The people.

Specht, W.  L.   1973.   The effect  of heavy  metals  upon the  diversity and
     abundance  of benthic  macroinvertebrates.   M.S.  Thesis,  Penn.  St.
     Univ.  58 pp.
                                  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.
     J.  Air,  Water Pollut.  9:531-543.

Springer,  A. M.  and  D.  G.  Roseneau.  1977.  A  comparative  sea-cliff bird
     inventory of the  Cape Thompson  vicinity,  Alaska.   pp.  206-262.  In:
     Environmental  assessment of  the  Alaska Continental   Shelf.   Annual
     reports  of  principal investigators  for the year ending March  1977.  Vol.
     5.   Receptors-birds.   Nat.  Oceanic and  Atmos.  Admin.,  U.S. Dept. of
     Commerce.

	.  1982.    Population and  trophies  studies  of  seabirds  in the
     northern Bering and  Chukchi Seas, 1981.  In: Environmental assessment
     of  the Alaskan  continental shelf.  Annual  reports of  principal investiga-
     tors  for the year ending March  1982.  Nat. Oceanic and Atmos. Admin.,
     U.S.  Dept. of Commerce.

Tailleur,  D.  L.   1970.   Lead-,  zinc-,  and  barite-bearing  samples from the
     western  Brooks   Range,  Alaska.   U.S.  Geological  Survey Open-File
     Report 70-319.

Tsytovich,  N. A.  1975.   The  mechanics  of frozen  ground.   New  York:
     McGraw Hill  Book  Co.

U.  S.  Department  of Commerce,  Bureau   of  Economic  Analysis.   1982.
     Personal income and employment by major source,  1967 to 1981.

U.  S.  Environmental  Protection Agency.   1983.  Responsiveness summary for
     scoping  meetings,  February 14 through April  1, 1983 on  Red  Dog Mining
     Project  EIS.

Viereck, L. A., C.  T.  Dyrness, and A. R. Batten.  1981.   Revision of pre-
     liminary  classification  system  for  vegetation  of Alaska.   U.S.D.A.,
     Forest Service General Technical Report PNW-106.  64 pp.

WGM, Inc.   1978.  Mineral studies  of  the  western  Brooks Range.  Vol.  I  &
     II.  U.S.  Bureau of Mines, Contract  No.  J0155089.

Winslow, P.  C.   1968.   Notes  on  biology  of Wulik River char (unpublished).
     Alaska  Department of  Fish  &  Game,  Division of Sport  Fish, Juneau,
     AK.

Woodward-Clyde Consultants.  1983.   Coastal sedimentations:   Cape Thomp-
     son to Cape Krusenstern.

Wunnicke,  E.  C.   1983.   Department  of  Natural  Resources,  Office  of the
     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
                                 XIII  -  4

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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
                                  XIII  -  6

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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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