v>EPA

  DOI
United States
Environmental Protection
Agency
Region 10
1200 Sixth Avenue
Seattle WA 98101
EPA 910/9-84-122b


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
            Volume II—Appendices

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                           RED DOG MINE PROJECT
                        DRAFT ENVIRONMENTAL IMPACT
                                 STATEMENT

                          Volume II;  Appendices

1.  Reclamation Plan
2.  Spill, Prevention, Control and Countermeasure Plan
3.  Endangered Species Biological Assessment
4.  Proposed NPDES Permits
5.  Department of the Army Public Notice and Section 404(b)(l) Evaluation
6.  ANILCA Title XI Right-of-Way Application
7.  Cultural Resources Protection
8.  Coastal Zone Management Consistency

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	Appendix 1
Reclamation Plan

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                RECLAMATION PLAN

                 RED DOG PROJECT

                    JUNE  1983
PREPARED BY COMINCO ENGINEERING SERVICES  LTD,
               FILE NO,  RD0.012
                                                FEB 10 1984


                                            ENVIRONMENTAL EVALUATION
                                                   BRANCH

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                           TABLE OF CONTENTS
                                                                       Page
1.  Summary                                                              1
2.  Introduction                                                         2
3.  Project Description                                                  4
4.  Environmental  Setting                                                9
    4.1  Water Quality                                                   10
    4.2  Aquatic Biology                                                 11
    4.3  Terrestrial Biology                                             13
    4.4  Marine Biology                                                  18
5.  Reclamation Plan                                                     20
    5.1  Introduction                                                    20
    5.2  Reclamation Guidelines                                          21
    5.3  Reclamation Concepts for the Mine Site                          23
                                                                         9d
         5.3,1  Open Pit Mine
                                                                         OQ
         5.3.2  Mine Waste Dumps
                                                                         32
         5.3.3  Tailings Impoundment
                                                                         38
         5.3.4  Water Supply Reservoir
         5.3.5  Mill, Accommodation, Service Areas, Airstrip,            40
                Roads
    5.4  Reclamation Concepts for the Transportation Corridor            42
    5.5  Reclamation Concepts for the Port-Shipping Facility             47
    5.6  Reclamation Research Proposals                                  49
6.  References                                                           51

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                        LIST OF TABLES
Table


 3.1        Nature and Extent of Land Disturbance
            Associated with Red Dog Mine Project

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                       LIST OF FIGURES
Figure                                                     Page

 2.1          Red Dog Location Map                           3
 3.1          Red Dog Mine Site                              7
 5.1          Mine Pit Layout                               26
 5.2          South Fork Tailing Impoundment                33
 5.3          Water Storage Pond                            39
 5.4          Mill  Site Plan                                41
 5.5          Land Transport                                43
 5.6          Transportation Corridors                       45

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                                                                  - 1 -
1.   Summary
    Cominco Alaska Inc.  is exploring the development of substantial
    deposits of lead/zinc/silver ore adjacent Red Dog Creek in NW
    Alaska, 90 air miles north of Kotzebue.   The project will
    consist of an open pit mine and concentrator together with
    associated transportation and shipping facilities.   The project
    has a potential life of 50 years.   Development of the project
    according to preferred siting options will  ultimately disturb
    2,070 acres of land including 1,500 acres over the 50 year
    period at the mine site, 520 acres along the transportation
    corridor and 50 acres at the coastal shipping facility.  In
    accordance with an agreement with  the NANA Regional Corporation,
    Cominco Alaska will  reclaim all land disturbed as a result of
    the operation.

    A conceptual plan for the reclamation of land affected by
    various components of the Red Dog  project is presented.  The
    plan provides for the reclamation  of all disturbed lands in
    accordance with guidelines established by the NANA-Cominco
    Alaska agreement.  While it is recognized as desirable to
    initiate reclamation as early as possible following disturbance,
    the main project components of the mine  site, the transportation
    corridor and the shipping facility will  be active for the
    duration of the project life.  Reclamation of these components

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                                                                  -  2  -
   must, therefore, be delayed until late in the operating life of
   the mine and following abandonment.

   Due to  the  site specific nature of factors affecting revege-
   tation  potential of mined-land disturbances and  to  limited
   revegetation technology specific  for conditions  prevailing
   at the  site, detailed plans for revegetating waste  disposal
   sites are not  presented in the conceptual plan.  A  research
   program will be implemented early in the operating  period
   of the  project to  develop the technology necessary  to
   achieve revegetation objectives.

   A reclamation  and  post-production accrual fund  to cover
   reclamation and all other post-production expenditures
   will  be established.  Cominco Alaska will maintain  a  per-
   formance  bond  underwriting the reclamation  as required by
   the  agreement  with NANA.

2.  Introduction
    Cominco Alaska Inc.  is  exploring  the development of sub-
    stantial  deposits  of  lead/zinc/silver  ore adjacent  Red
    Dog  Creek near Deadlock Mountain  in  NW Alaska  (Figure 2.1).
    The  project will  consist  of  an  open  pit mine and concen-
    trator 90 air miles north  of Kotzebue, together with
    associated transportation  and shipping facilities.

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                                    - 3 -
   PACIFIC  OCEAN
FIG 2.1   RED  DOG   LOCATION   MAP

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                                                                  - 4 -
    The NANA Regional  Corporation obtained selection rights to the
    Red Dog area with  the passage of ANILCA in 1980.  After dis-
    cussing the project with a number of mining companies,  the
    Regional Corporation selected Cominco Alaska Inc.  to act as
    the developer of the deposit.  In the spring of 1982 a  letter
    of agreement was signed which outlined the relationship between
    Cominco Alaska and NANA.  That agreement calls for Cominco
    Alaska to lease the property from NANA and to act as the
    operator for the project.   In accordance with the agreement,
    all land disturbed as a result of the operation shall  be
    reclaimed by the Operator in accordance with a reclamation
    plan prepared by the Operator prior to commencement of
    operations.

    The following sections of this document describe the proposed
    mining project and relevant information on the environmental
    setting within the project area.  Based on the nature of the
    project, its physical and biological setting and data
    available, a conceptual plan for the protection and
    reclamation of land and water resources is described.
    Studies identified as necessary for development of site
    specific reclamation technology are summarized.

3.  Project Description
    The project is located 55 miles from the Chukchi Sea, east-
    northeast of Kivalina.  There are no roads in the area  and

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                                                              -  5  -
the nearest village to the deposit is Noatak, some 47 miles to
the south.   The ore is in the form of metal  sulphides in a
Mississippian chert formation in the drainage area of two
forks of Red Dog Creek.  Although the deposit is not yet
fully defined by geologists, the potential  mine contains
approximately 85 million tons of mineralization.  The project
will have a potential life of 50 years with the possibility
of extension if new ore is found.

Development of the Red Dog mine will require establishment
of the entire infrastructure necessary to mine the ore,
concentrate the minerals and transport the concentrate to
salt water for shipment.  Mine site facilities will include
the mine pit and waste dumps; a mill and tailings impound-
ment; a water supply reservoir for process and human use;
sediment retention and water treatment facilities for the
mine area facilities; accommodation for workers; a power
supply system and transportation system to the coast.  An
airstrip was constructed in 1982.  A port facility would
be located along the Chukchi Sea coast.  Facilities
required in the coastal zone include a dock with ship-
loading facilities, concentrate and fuel storage and
handling facilities, equipment storage and maintenance
facilities, housing and a power plant.

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                                                              - 6 -
A concise description of project history, land status, mining,
milling and transportation options as well  as siting options
for each component of the Red Dog project is provided in the
"Red Dog Mine Project Overview" released by Cominco Alaska
Inc. in January, 1983 (1).  Cominco Alaska has completed a
preliminary evaluation of these options and has identified
what seem to be the most feasible options from an environmental,
economic and engineering viewpoint.  The preferred options
include open pit mining with waste stockpiled above the pre-
ferred tailings impoundment site on the south fork of Red
Dog Creek (Figure 3.1).  The mill will be located on a known
bedrock outcrop within the impoundment catchment area that
allows gravity flow of tailings slurry from the concentrator.
A water storage reservoir, required for year round operation
of the mill as well as domestic water supply will be created
by constructing a dam on Bons Creek at the south end of the
Red Dog valley with a pipeline following the road system to
the mill.  The preferred option for land transportation
utilizes the southern corridor through Krusenstern National
Monument to the coast with concentrate storage and shipping
facilities at VABM 28 on  the coast.   Development of  the
project according to preferred siting options will
ultimately disturb 2,070  acres of  land  including 1,500
acres  over a 50 year period  at the mine  site,  520  acres
along  the  transportation  corridor  and 50 acres at  the
coastal  shipping  facility (Table  3.1).

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                                                                            -  8  -
Table 3.1:  Nature and Extent of Land Disturbance Associated with Red Dog Mine Project1
            Type of Disturbance
1.  Mine Site

    Mine, waste dumps,  access road
    Tailing pond, access road
    Water supply pond,  access road
    Mill incl.  residence area & access road
    Airstrip, service corridors
      Mine site sub-total
 Land
 Area

(acres)
    580
    730
     95
     65
  	30

  1,500
   Vegetation Type*
II-C1, II-B1
II-B1, III-C1, IIC1
II-C1
III-C1
II-C1, III-C1, II-B3
2.  Transportation Corridor

    Southern corridor
    Borrow pits incl. access roads
     Transportation corridor sub-total
    435
     85

    520
III-C2, II-B1, II-B3, II-B2
Sites unknown
3.  Port
    Port facility

     Total  land disturbance
     50     III-A4,  III-C3
  2,070
    Footnote:

    1.   Source:   Faxcom from D.F.  Vinish,  CESL Trail  to H.A.  Noah,  Cominco Alaska,
                 October 26, 1982.

    2.   Erikson,  D.E.  & L.R. Hettinger.  Terrestrial  Biology.   In Environmental
                 Baseline Studies  Red  Dog  Project,  Dames and  Moore, January,  1983.

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                                                                  - 9 -
4.  Environmental  Setting
    The Red Dog project is situated in the Wulik River drainage of
    the DeLong Mountains.  The ore deposit is located in the
    drainage area of the main fork of Red Dog Creek.   This creek
    is a tributary to Ikalukrok Creek, itself a major tributary
    of the Wulik River.  The Wulik River empties into the
    Kivalina Lagoon, which opens into the Chukchi  Sea near the
    village of Kivalina.

    Local  topography at the mine site consists of moderately
    sloping hills  with elevation ranging from 800 to  1,500 feet.
    Surrounding the deposit to the north and east are the rugged
    ridges of the  DeLong Mountains.  In the west and  southwest,
    the fringing hills of the DeLong Mountains drop off sharply
    to a gentle coastal upland.

    Terrestrial, aquatic and marine biology and water quality data
    were developed during 1981 and 1982 for the project area to
    provide a data base upon which to base project impact analyses
    and to provide information on natural  resources that could be
    used as input  in optimizing  mine facilities from  both the
    engineering and environmental  standpoints.  Information
    pertinent to development of  an environmental  protection and
    reclamation plan for the project are summarized.   Full  details
    of the methodology used and  the findings in the on-site
    investigations can be found  in the report, "Environmental

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                                                              -  10 -
Baseline Studies - Red Dog Project"  which was  prepared  by Dames
and Moore in January,  1983 (2).

4.1  Water Quality
     Water in the Wulik River displays  quality characteristics
     typical of unpolluted fresh water  in the  Arctic.   These
     are clear water streams having  low levels of colour,
     suspended solids, turbidity and nutrients.   The water is
     highly oxygenated, moderately hard to hard,  and of the
     calcium bicarbonate type.   The  pH  is essentially neutral
     and levels of most trace elements  fall  within ranges
     acceptable for fresh water  aquatic life.   Water in
     Ikalukrok Creek exhibits characteristics  similar to the
     Wulik River with  one exception. The concentrations of
     some metals increase as one approaches  the confluence
     with Red Dog Creek.

     Red Dog Creek presents a contrast  in water quality.
     The upper portion of the mainstem, most of the South
     Fork, and the North Fork exhibit high water quality.
     Water in the mainstem beginning adjacent  to the highly
     mineralized showing area becomes degraded and remains
     in this condition downstream to the confluence with
     the South Fork.  The middle portion of this section
     of creek manifests the lowest water quality.  Cadmium,

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                                                             - 11 -
     lead,  zinc and iron  concentrations  can  be  particularly  high
     in this  section of the mainstem.   Dissolved  oxygen  levels
     decrease,  alkalinity levels  decrease  to or near  zero, and
     pH is  slightly acidic.  The  water type  changes from calcium
     bicarbonate to calcium and magnesium  bicarbonate or to
     magnesium  and sodium sulphate depending on flow.  The water
     is soft  to moderately hard.   Turbidity, suspended solids,
     and sulphate levels  are generally high  in  this area.
     Recovery begins at the confluence of  the mainstem and the
     South  Fork, but it is not particularly  significant  until
     flow from  the North  Fork dilutes  the  mainstem.   Red Dog
     Creek  adversely affects  the quality  of Ikalukrok Creek
     below  their confluence.  This effect, at least in terms
     of zinc  concentrations, extends several miles downstream
     in Ikalukrok Creek.

4.2  Aquatic  Biology
     The Wulik  River system is an important  overwintering area
     for Arctic char.  Chum and pink salmon  also  spawn in the
     system.   Primary utilization of Wulik fish is  in the
     subsistence harvest  of char  by Kivalina and  Noatak
     natives.  Arctic grayling are found throughout the
     system but are not widely utilized.

     Ikalukrok  Creek has  several  documented  char  spawning
     areas  from seven to  19 miles downstream of the mouth

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                                                         -  12 -
of Red Dog Creek and some possible char overwintering areas
about nine miles downstream of the mouth of the Red Dog but
no specific spawning areas have been located in this reach
or upstream.  Rearing of char fry and yearlings is common-
place upstream to above the mouth of Red Dog Creek.  Growth
of juvenile char in the Wulik system is excellent compared
to that in other Arctic Alaska populations.  Dud Creek,
which enters the Ikalukrok about eight miles below the
mouth of Red Dog Creek, has a small char spawning population
and is an important rearing stream.

The Red Dog mineralization has been shown to have a profound
effect on the water quality and hence the aquatic ecology
of not only Red Dog Creek itself, but also Ikalukrok Creek
for some distance downstream.  Within much of the mainstem
of the Red Dog this influence is graphically demonstrated
by the absence or near absence of periphyton, macrophytes,
insects and fish.

A spawning population of grayling in the North Fork of
Red Dog Creek reaches this clean water tributary by
migrating upstream through the mainstem during spring
runoff when metal levels are relatively low.  Char and
grayling juveniles entering Red Dog Creek from Ikalukrok
Creek or from the North Fork (grayling only) suffer
heavy mortalities from exposure to metals.  Living

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                                                              - 13 -

     grayling fry in lower Red Dog Creek displayed abnormal escape
     reactions and were apparently near death.  No fish have been
     found in Red Dog Creek above the mouth of the North Fork.

     In Ikalukrok Creek, Red Dog Creek's influence can be seen
     Jn effects on periphyton, benthic macroflora (mosses) and
     insects to at least 0.3 miles downstream of the confluence.
     Fish in this same reach are exposed to, and survive in,
     levels of metals (especially cadmium and zinc)  near or
     above EPA recommended criteria for the protection of
     aquatic life.  One result of this exposure is the
     increased level of various metals seen in the tissues of
     fish, primarily grayling, in upper reaches of Ikalukrok
     Creek.  Maximum levels in both char and grayling were
     usually from fish with greatest potential exposure to
     Red Dog Creek.   While increases in tissue levels of
     certain metals  appeared significant, they were  all within
     established guidelines for edible fish.

4.3  Terrestrial  Biology
     Twelve vegetation types were delineated for the study
     area, and encompassed tall  shrub, low shrub and herbaceous
     lifeforms.   Tussock tundra was by far the most  abundant
     type, but low shrub tundra, open low shrub and  complexes
     of these vegetation categories were also common.   Wet-
     land  vegetation occurs on about five percent of the area

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                                                        - 14 -
crossed by the proposed transportation corridors.   Except
for wetlands, no known critical  plant habitats occur
along the corridors and no candidate threatened or
endangered species are known to  occur in the area.

The avifauna of the study area is primarily composed
of water-oriented birds.  One hundred and four species
were identified in ten different ecological  formations.
The lake, pond and lagoon habitats were the most heavily
used of the aquatic formations and the tall and low shrub
formations along streams or lakes were the most heavily
used terrestrial habitats.

During spring migration, the most important staging areas
are located in lagoons at the mouth of major river systems,
especially those having large areas of the delta habitat.
One of the major staging areas is located in Ipiavik
Lagoon, just north of the proposed southern port site.
The delta habitats are even more important during  the
fall migration when they are heavily utilized by
shorebirds, swans, geese, and ducks.  On a regional
basis, however, numbars of birds using the lagoon  systems
within the study area are relatively low compared  to
nearby areas in Kotzebue Sound.   The gravel ocean
beaches had very low utilization in summer and fall.
Glaucous gulls and arctic terns  are characteristic of
birds found in this habitat, the latter using this
habitat for nesting.

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                                                        - 15 -
The endangered peregrine falcon is the only threatened
or endangered bird species known to occur in the project
area.  A total of seven sites were documented as having
peregrine falcon activity.  One of these sites was
questionable.  These sites require certain restrictions
regarding development or disturbance activities.  Both
transportation corridors pass an equal number of sites
but present alignments are outside of the two mile
minimum buffer restrictions.  Golden eagles, protected
under the Bald Eagle Act, occur along both corridors
but the restrictions protecting golden eagles are not
as stringent as those for endangered species.  No
falcon or golden eagle nests were located near either
the northern or southern port sites.

In recent years, caribou have used the Wulik and
Kivalina drainages for winter range.  Within these
drainages actual distribution during the winter months
is probably dependent on local weather conditions
(i.e. snow depth).  In spring, the caribou leave
the winter range and make their way north through
the DeLong Mountains to their traditional calving
grounds on the Arctic Slope.  Only a few stragglers
remain in the study area during late spring and early
summer and none of these animals were found to calve
in this area.  By mid-June, caribou (mostly bulls and

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                                                        - 16 -
yearlings) were abundant in the southern foothills of
the Belong Mountains, distributed in small  bands.  Shrub
habitats were utilized most frequently.   The largest
movement of caribou occurred in early July when 10's
of thousands of animals, in post-calving aggregations,
passed through the upper drainage of the Kivalina
River from the Spiny Ridge area and moved through the
mountain drainages to the east in the traditional
counter-clockwise fashion.  These aggregations consist
of all segments of the herd.  Most of the animals
return to the Arctic Slope to spend the summer.  The
number of caribou residing in the study area in the
late summer season appeared to be low.  Caribou
return to the wintering areas in the Wulik and Kivalina
drainages in late fall primarily from the northwest but
some may come into the area from the Noatak region.
The number of animals using the study area from year
to year is highly variable.

A herd of eight muskox were sighted several times during
the field season.  The herd appears to have established
its winter range in the Rabbit Creek drainage over the
last several years.  During the summer months, these
animals were found to range extensively in the study
area and move in an apparent clockwise fashion through-
out the season.

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                                                        - 17 -
Moose are not abundant and are generally restricted in
winter to the tall willow habitat along the Wulik River
and Ikalukrok Creek.  These same tall  shrub areas are
used in the summer but there is also a dispersal of
moose to upland mountainous areas and throughout smaller
drainages that are not used in the winter.

Grizzly/brown bear were found throughout the study area
during the 1982 field season.  The distribution of these
wide-ranging animals appears to vary seasonally.  Upper
mountainous areas are favoured in the spring while
coastal areas are favoured in the summer and fall.
Bears were concentrated along spawning streams when
fish were present.  Concentrations" were observed along
the Wulik River, Ikalukrok Creek and Asikpak River.
Only one area was located in the Sivak Mountain area
of the Asikpak River drainage where extensive denning
was observed (several dens).

Small mammals were scarce in the study area in 1982.
Typically one would expect to find two species of shrews
(the arctic and masked shrew), three species of voles
(the red-backed, the tundra vole and the singing vole),
and two species of lemmings (the collard and brown
lemming).  These animals are of major importance mainly
as prey for other mammals and birds.  Other small mammals
found to occur in the study area are the ermine, porcupine,

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                                                             - 18 -
     arctic ground squirrel ,  muskrat, river otter and snowshoe
     hare.

     Some larger predatory animals found in the study area are
     the wolverine, wolf, red fox and the arctic fox.  These
     furbearers are important to the local  economy.

4.4  Marine Biology
     The nearshore coastal  region and open  lagoons in the
     vicinity of alternative  port sites are used by  migrating
     anadromous fish,  such as Arctic char and salmon, as a
     transportation corridor  between spawning rivers and the
     Chukchi  Sea.   Both outmigrating fish and those  returning
     to spawn are  present at  different times of the  year.
     Precise  migration routes and timing in the vicinity of
     possible port sites has  not been established.

     Numerous resident marine fish are abundant in the
     relatively shallow waters nearshore.  These include
     flounders such as yellow-fin sole and  Alaska plaice
     as well  as saffron cod.   These fish are important
     components of the diet of marine mammals such as seals.
     Densities of  these fish  appear to be similar at all
     locations studied, both  within and away from the
     project  vicinity.  Large numbers of Pacific herring
     spawn  along the coast between Kivalina and Mapsorak
     Lagoon.

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                                                        -  19 -
Significant populations of invertebrate species that are
important prey items for fish are found in the region.
These include infauna, such as clams and polychaete
worms, and epifauna, such as shrimp, crab, brittle
stars, and other, smaller crustaceans.

Seabirds (murres, puffins, kittiwakes)  from the Cape
Thompson colonies did not appear to use the nearshore
areas to any significant degree and were usually ob-
served in waters beyond the 40 foot isobath.  No major
foraging areas were located in the nearshore waters.

Several species of waterfowl (primarily eiders) use
the area seaward of the landfast ice as a spring migra-
tion corridor to the northwest and around Point Hope.
These birds number in the tens of thousands.

Ringed seals are the most abundant marine mammal using
the shorefast ice with the highest densities associated
with heavily fractured ice at the southern port area
in late May.  Bearded seals occur in low densities
throughout the fast ice.  Both species leave during the
open-water period.

The belukha and endangered bowhead whales migrate
through the open leads off Kivalina during late April-
early May.  Whales tentatively identified as bowheads

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                                                                 -  20  -

         were observed  as  late  as  the  last  week  in  June.   During  the
         fall on  their  southward migration  to  the wintering  grounds,
         they are thought  to pass  through the  western  Chukchi,  but
         no observations were reported in the  study area.

         Endangered gray whales were seen on several  occasions
         during July and August along  the coast  from Cape  Krusenstern
         to Point Hope  usually  in  shallow water  close  to the beach.
         Since gray whales feed in shallow  water, the  likelihood
         of them encountering port structures  would be greater
         than for other whale species.
5.   Reclamation Plan
    5.1  Introduction
         A conceptual  plan for the protection and reclamation of
         land and water resources affected by various components
         of the Red Dog project is presented.  The plan provides
         for the reclamation of all  disturbed lands in accordance
         with guidelines established by the NANA-Cominco Alaska
         agreement and any laws or regulations applicable to such
         reclamation activities.   Features of the mine design
         which protect water quality and aquatic resources and
         minimize the extent and severity of disturbance to
         terrestrial resources are described.  Due to the site
         specific nature of factors affecting revegetation potential
         of mined-land disturbances and to limited revegetation

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                                                             - 21 -
     technology specific for conditions  prevailing at the site,
     detailed plans for revegetating  waste disposal  sites are
     not presented in the conceptual  plan.  A research program
     will  be implemented early in the production period of the
     mine to develop the technology necessary to achieve
     revegetation objectives.

5.2  Reclamation Guidelines
     According to the NANA-Cominco Alaska agreement,  the
     "Reclamation Plan"  shall  provide for reclamation within
     the following guidelines:
     a)  the parties recognize  that reclamation of disturbed
        land is desirable,
     b)  the parties recognize  that land  disturbances  related
        to surface mining and  the deposition  of tailings and
        waste rock are inevitable and complete return of all
        of the disturbed land  to its  undisturbed condition
        is not possible,
     c)  reclamation shall  be generally designed to mitigate-
          (i)  potential long  term danger to  human life or
               the subsistence needs  of  the natives of the
               NANA Region,
         (ii)  any adverse  visual or  unaesthetic conditions,
               and
        (iii)  to the extent reasonably  practicable,  to
               restore the  land to a  condition compatible
               with surrounding land,

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                                                        - 22 -
d) disturbed land shall  be restored to natural  looking
   contours compatible with the surrounding terrain (it
   being recognized that the area of the mine excavation
   will not be refilled),
e) where available in appropriate quantities, topsoil
   shall be separately removed and stockpiled for further
   application after reshaping of disturbed areas have
   been completed; provided that the parties recognize
   that permafrost conditions could cause long-term
   stockpiling of topsoil  to be impractical,
f) appropriate measures shall be taken to control or
   reduce erosion, landslides and water runoff to the
   extent practicable,
g) fisheries and wildlife  habitats shall be rehabilitated
   to the extent practicable,
h) to the extent practicable, disturbed areas shall,
   through seeding, fertilizing and other appropriate
   means, be revegetated with a diverse vegetative cover
   of species native to the area and similar to that
   on adjoining areas.

A reclamation and post-production accrual fund to cover
reclamation and all other post-production expenditures
will be established.  Cominco Alaska will maintain a
performance bond underwriting the reclamation as
required by the agreement with NANA.

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                                                             - 23 -
     While it is desirable to initiate reclamation as  early as
     possible following disturbance,  the main project  components
     of the mine site, the transportation corridor and the
     shipping facility will  be active for the duration of the
     project life.   Reclamation of these components must,
     therefore, be delayed until  late in the operating life
     of the mine and following abandonment.   It is also
     conceivable that certain project components,  notably
     the transportation and  port  systems, can be utilized
     by the region beyond the operating life of the mine and
     reclamation of these major services may not be required.


     Reclamation concepts for the main project components
     at the mine site, the transportation corridor and the
     shipping facility are presented  in the  following  sections
     of this document.


5.3  Reclamation Concepts for the Mine Site
     Land disturbance at the mine site totals 1,500 acres
     and includes the following components (3):

     Open pit,  waste dumps,  access roads         580 ac.
     Tailings pond, access roads                  730 ac.
     Water supply reservoir, access roads         95 ac.
     Mill  including residence, access road        65 ac.
     Airstrip,  service corridors                   30 ac.

     A reclamation  concept for each mine site component is
     discussed.

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                                                               - 24 -

5.3.1  Open Pit Mine
       The Red Dog deposit is exposed between 950 feet and 1,200
       feet elevation on a northeast facing slope within the
       drainage of the main fork of Red Dog Creek.   The deposit
       is located within an area mapped as  dwarf shrub, mat and
       cushion tundra vegetation type (2).   Dwarf shrub vegetation
       is primarily associated with upland  ridges and bedrock
       outcroppings above 800 feet elevation.  The tundra
       vegetation is alpine in appearance with the richness of
       the vegetation dependent largely on  moisture.   Drier sites
       typically are characterized by lichen encrusted rock with
       only scattered prostrate shrubs.  White mountain avens
       (Dryas octapetala) in association with a number of co-
       dominant species form a number of different plant
       communities recognized within the mat and cushion tundra
       category.  No critical plant habitats and no threatened
       or endangered plant species are known to occur in the
       area.

       Soils of the mat and cushion tundra  typically contain stony
       parent material near the surface.  Profiles are therefore
       shallow and mineral in nature except for a thin (0.8" to 2")
       organic horizon at the surface (2).   Shallow soil samples
       within the mine area were variably elevated in metals zinc,
       lead, copper and iron.   Potential for conserving soil
       suitable for reclamation appears minimal.

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                                                        - 25 -

The Red Dog mineralization has had a profound effect on water
quality and aquatic resources within the mainstem of Red Dog
Creek (2).  Water is highly mineralized, exhibits low pH
levels and relatively 'high suspended solids, turbidity,
sulphate and metal concentrations.  Periphyton, macrophytes,
insects and fish are absent or near absent.

The outcropping orebody and its geological configuration
dictate open pit mining as the most feasible mining method
(Figure 5.1).  The pit will be developed in two stages:
preproduction followed by production mining.  During pre-
production overburden is removed from the pit; access roads
to the pit, pit ramps and initial benches are established.
Unmineralized waste will be used for road and tailing dam
construction.  Mineralized waste will  be stockpiled in a
catchment area above the tailings impoundment.  Production
mining will involve the annual extraction of 1,057,000 tons
ore.

The open pit will  be designed to optimize ore recovery with
due consideration of the Red Dog Creek adjacent to the pit
area (1).   Pit slopes are designed at 35° (1^:1) and will
be confirmed by rock mechanics design.   Benches are 25 feet
high.   The final  pit could be 2,800 ft.  x 1,000 ft.  in plan
area (64 ac.) and contain up to 28 benches to the 500 ft.
elevation.   A ditch/dyke system will  be designed to capture

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                                                            - 26 -
                LATITUDE
1300
1250
                             ORIGINAL GROUND
                                                        PROPOSED
                                                        OITCH/BERM
 750 -
                              1 ULTIMATE
                            FIG. 5.1     MINE  PIT  LAYOUT

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                                                        - 27 -

runoff from the pit working area and divert it to the tailing
impoundment resulting in an improvement in the quality of
Red Dog Creek during the production period.

After 20 years the creek course will have to be diverted to
allow continued mining of the deposit.  It is planned to
design a wide bench at creek level  on which a diversion ditch
will be constructed to route the creek around the perimeter
of the pit.  Design and function of both the ditch/dyke and
the bench diversion ditch are described in "Wastewater
Collection and Management, Red Dog  Project", issued in May,
1983(4).

Reclamation of the pit poses unusual problems because of
the proximity of the orebody to the mainstem of Red Dog
Creek, the landform created by the  open pit mining
technique and the consolidated nature of bedrock exposed
by mining.  The pit will ultimately cross the present creek
location and its depth will be substantially below creek
level.  Backfilling the pit, resloping pit walls to
natural contours compatible with surrounding terrain
and restoring the Red Dog Creek course are not practical.
Any requirement to implement any of these measures would
destroy the economics of the project.

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                                                        - 28 -
Upon completion of mining Red Dog Creek will be diverted
back along its original course flowing into the pit,
eventually raising the water level in the pit to
approximately 900 feet, the elevation of Red Dog Creek
at the downstream extremity of the pit.  A reservoir
will be created within the Red Dog drainage system with
water ranging up to 400 ft. deep with steep, rock cliffs
along the shoreline.  Abandoned pit access ramps will
provide access to the water.  Pit walls will rise up
to 300 feet above the reservoir on the west side and
up to 260 feet on the east side.  Exposed sections of
the pit wall will consist of up to 12 benches, 25 feet
high and 35 feet wide, in  consolidated unmineralized and,
to a much lesser extent, mineralized rock.  Surface
drainage from the pit walls will be retained within
the pit area.  Due to the consolidated nature of the
rock vegetation establishment on the benches may not be
possible.

Since the mining plan calls for the recovery of all
ore with a high metal sulphide content, the contribution
of soluble metals to Red Dog Creek from the mine area
will be minimal after operations cease.  The pit will
thereafter function as a reservoir in the watershed
system with substantially  improved quality over that
under present conditions.

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                                                               - 29 -

5.3.2  Mine Waste Dumps
       Mineralized and unmineralized  waste  material  which  is  not
       suitable for mill  processing will  be stockpiled  on  the
       east side of the South  Fork Red  Dog  Creek  drainage  area
       above the proposed tailing  impoundment  site  (Figure 5.2).
       Mine waste stockpiles will  be  constructed  on  stable ground
       on a 10% west facing  slope  between 950  feet  and  1,200  feet
       elevation.  The extent  of slide  areas identified on the
       slope will be clarified by  geotechnical  investigation  and
       unstable areas will  be  avoided.

       Two vegetation types were mapped on  the  west  facing slope
       of the South Fork  drainage; dwarf shrub  mat  and  cushion
       tundra and low shrub tundra (2).   Well-drained upland
       knolls and slightly more mesic habitats  of mat and
       cushion tundra are characterized by  white  mountain  avens
       in association with  skeletonleaf willow  (Salix phlebophylla)
       and netleaf willow (S.  reticulata).   Dwarf arctic birch
       (Betula nana) and  narrow!eaf Labrador-tea  (Ledum decumbens)
       form a dwarf shrub community on  the  more mesic sites such
       as swales and areas of  thicker mineral  soil.  Low shrub
       tundra vegetation  of dwarf  arctic  birch, crowberry  (Empetrum
       nigrum) and bog blueberry (Vaccinium uliginosum)  is quite
       common on upland rolling hills.   Diamondleaf  willow also
       appears as a co-dominant with  dwarf  arctic birch, narrow-
       leaf Labrador-tea  and Vaccinium  species  in some  areas  of

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                                                        - 30 -

silty soils on rolling terrain.   No wetlands,  critical  plant
habitats or endangered plant species are known to occur in
the area.

Soils typical  of mat and cushion tundra were described  in
section 5.3.1.  Soils of low shrub tundra are  mineral,
generally silty, and usually well  to moderately well
drained (2).  The drainage is a  reflection of  the upland
landscape position and relatively steep slopes.  The
active layer is variable,but usually less than 28 inches.
The silty soil material  is potentially suitable as a  plant
growth medium for waste dump revegetation.  Conservation
of the active silt layer during  preparation of waste
dump sites, if located on soils  similar to those described
for the low shrub vegetation type, will be investigated.

Water quality and aquatic ecology of the South Fork of  Red
Dog Creek have also been affected by the Red Dog minerali-
zation.  While the South Fork is described as  a clear
water stream having low suspended solids and turbidity
with high dissolved oxygen levels; the water is soft  to
moderately hard, has low pH with moderate to high cadmium
and high zinc concentrations.  The major source of Cd and
Zn is a tributary draining a portion of the slope east  of
the creek.  No fish are known to exist in the  South Fork
of Red Dog Creek.

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                                                        - 31 -
Separate waste dumps will  be constructed with capacity for
stockpiling 29 million tons of unmineralized waste and 11
million tons of Teachable mineralized waste.  Most of the
unmineralized waste removed during pit development and
the initial five years of mining will be used for road
and tailing dam construction.  Waste dumps will  be
constructed on the 10% natural slope by dumping  and
spreading waste in 10 to 20  foot thick lifts to a maximum
dump height of 120 feet (4).  Toes of the waste  dump will
be keyed to competent load bearing material to prevent
failure.  The planned dumping technique is designed to
increase dump stability, accelerate freezing of  the dump
and prevent leaching.  The resultant dump will  have a flat
central area with the same slope as the underlying natural
terrain but with steep perimeter slopes averaging 35°.

Surface drainage and seepage during the initial  phases
of dump construction will  be directed downslope  into the
tailing impoundment.  However, as completed dumps
stabilize hydraulic permeability will diminish and
reduce the extent of leaching.  Compaction of lift
surfaces by vehicular traffic will  inhibit infiltration
of precipitation and diffusion of air, thereby restrict-
ing oxidation of sulphides.  With development of perma-
frost conditions in the dump interior following  completion
of dump construction, leaching from waste dumps  will cease.

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                                                               -  32  -
       Surface  drainage  contamination will  be  eliminated  following
       revegetation  of the waste  dump surface.

       The surface of the waste dumps will  be  reclaimed to  an
       appearance compatible  with the surrounding  terrain.   Waste
       dumps  will be recontoured  as  required to  achieve permanent
       slope  stability and facilitate revegetation.   Waste  dumps
       present  a harsh environment for  establishing  vegetation.
       Effective reclamation  will  be dependent upon  development
       of practical  site preparation techniques  which improve
       conditions sufficiently such  that  self-sustaining
       vegetation indigenous  to the  region  can be  established
       successfully. Exposure to severe  climatic  conditions,
       steep  perimeter slopes, a  compacted  rocky growth medium
       with a low content of  fines and  essential plant nutrients
       plus,  in the  case of mineralized waste, low pH and elevated
       concentrations of metals  (6), are  severe  constraints to
       waste  dump reclamation. Techniques  will  be developed,  as
       needed,  to mitigate  site specific  reclamation constraints
       during the projects  operating period.
5.3.3  Tailings Impoundment
       Finely ground rock tailing, a waste  produced  during
       concentration of  minerals  in  the ore, will  be impounded
       in the drainage of the South  Fork  of Red  Dog  Creek
       behind an  impervious  earth fill  dam  (Figure 5.2).   The
       site meets all of the  planning  criteria with  particular

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                                                          - 33 -
ACCOMMODATION
            SEEPAGE/CONTINGENCY •»•
     DIVERSION DITCH
SEEPAGE CONTINGENCY
 0AM
                    YEAR 5
                                       HAUL ROAD
                                            LINER
-EL 950
-EL 870
                                               HAUL ROAD

                                                   	EL 800
                     TAILING  DAM  SECTION
       FIG. 5.2   SOUTH FORK TAILING IMPOUNDMENT

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                                                        - 34 -

emphasis on a dam structure location that can  be  placed on
bedrock.  Preliminary design concepts for the  tailing im-
poundment are described in "Tailings Impoundment  Preliminary
Design, Red Dog Project", issued in March, 1983 (5).

The tailing will  cover an extensive area of land  currently
sustaining three vegetation types including dwarf shrub mat
and cushion tundra and low shrub tundra, both  of  which were
described in section 5.3.2 and the third, a herbaceous
vegetation type identified as sedge-grass tundra  (2).
Sedge-grass tundra characteristically occurs in lake  basins
or in filled back water areas along streams.  The sites
are usually poorly drained but water inundation of the
soil profile may occur for only part of the growing
season.  There is usually less than 12 inches  of  peat and
no surface water.

A number of similar plant communities are formed  by various
combinations of cottongrass (Eriophorum vaginatum, E. angusti-
folium and sedge (Carex aquatilis aquatilis).   Entire leaf
mountain-avens and grayleaf willow may be important in some
communities especially if better drained microsites are
present.  Certain communities of sedge grass tundra that
occur in infilled drainage channels can be considered wetlands.
Vegetation of these types are dominated by obligate hydrophytes
including Carex aquatilis, Arctophila fulva, Huppurus vulgaris,

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                                                        - 35 -

and Friophorum angustifolium.  Except for some possible wet-
lands, no critical plant habitats and no threatened or
endangered plant species are known to occur in the tailing
impoundment site.

Soils typical of mat and cushion tundra and low shrub tundra
vegetation types were described in sections 5.3.1 and 5.3.2.
Typical soils of the sedge-grass tundra are organic, usually
of sedge peat with an active layer depth of about 60 cm.
Silty mineral inclusions, when present, are gleyed or mottled
indicating frequent water inundation.  Both the organic soils
typical of sedge-grass tundra and the silty mineral soils
typical of low shrub tundra have potential as suitable
plant growth media.  Conservation of these important soil
resources may be critical to effective reclamation of waste
rock and tailing disposal areas.

An earth-fill dam, with a base elevation of 800 feet, will
be constructed in stages as described in the document "Tailings
Impoundment Preliminary Design, Red Dog Project" (5).  Prior
to full production, the dam would be constructed to suffi-
ciently contain five years of production tailing.  The dam
will then be raised to its final elevation of 950 feet.  The
top of the dam will be used as a haulage road to haul ore
from the pit to the mill complex.  A spillway, constructed
at 944 feet elevation, will maintain structural competence
in the event of an overflow.  A downstream seepage contingency

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                                                        -  36 -

structure will  collect any seepage and return it to the
impoundment area.

The thickened tailings slurry will be discharged into the
impoundment area from a pipeline originating from the mill.
The slurry will contain about 60% solids by weight, with
the liquid portion consisting of excess process water,
dissolved minerals and residual  reagents.  Tributaries of
the South Fork with known heavy metal content will  continue
to drain into the impoundment while uncontaminated  streams
will be diverted into adjacent watersheds.  Surface drainage
from the mine, from mine waste dumps and the mill site will
also be collected in the tailing impoundment.  Water
entering the impoundment will be processed through  a water
treatment plant to remove any metals prior to discharge to
the presently contaminated Red Dog Creek.  Details  of the
water treatment plant and process are described in  "Waste-
water Collection and Managament, Red Dog Project" issued
in May, 1983 (4).

A reclamation scheme is proposed for the tailing impoundment
which assumes relief from E.P.A. regulations restricting
discharge to Red Dog Creek of any water associated  with the
disposal of tailing.  When operation of  the  tailing  impoundment

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                                                           - 37 -
is terminated, it is proposed that all  free standing  super-
natant water will be treated and discharged to Red Dog
Creek, exposing an extensive flat landform composed of
tailings.  Lined channels in the tailings and dam breaches
with stabilized spillways will  be constructed to  prevent
collection of surface drainage within the impoundment area
and to channel flow of the South Fork of Red Dog  Creek  and
its tributaries into Red Dog Creek.   The tailings mass  is
expected to freeze becoming part of the underlying perma-
frost.  If practical, the surface of the dam and  tailings
impoundment will be restored to an appearance resembling
that of the surrounding terrain.

As is the case with mine waste, tailing present a harsh
environment for vegetation establishment and practical,
site specific reclamation techniques require development.
Preliminary tailing incubation test results suggest exposure
of tailings to atmospheric conditions will cause  a decrease
in pH to within the strongly acid range (pH < 4.5) with a
concomitant increase in metal solubility particularly zinc
(6).  Restoring a near neutral  tailings reaction  by liming
or covering tailing with a more suitable plant growth medium
may be necessary for satisfactory vegetation establishment.

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                                                               - 38 -
5.3.4  Hater Supply Reservoir
       A water storage reservoir will  be required  to ensure an
       uninterrupted supply of water for year round operation of
       the mill, the major consumer of water for the Red Dog
       project, and for domestic use.   The preferred site for the
       reservoir is on Bons Creek at the south end of the Red
       Dog Valley (Figure 5.3).   A dam structure will be required
       and the reservoir location situates a dam on a bedrock
       foundation.  The natural  geographic features of the site
       minimizes the disturbed surface area for the required
       storage volume.

       The site presently sustains dwarf shrub mat and cushion tundra
       vegetation (2).  Bons Creek water quality is typical of
       unpolluted arctic surface waters and is acceptable for
       domestic use.  There are no known critical  plant or animal
       habitat on the site.

       Current options for abandonment of the water storage
       reservoir and dam are to either breach the structure to
       prevent subsequent storage or allow it to continue dis-
       charging by a permanent spillway.  An evaluation of
       hydro!ogical and dam stability conditions which prevail
       at the  time of property closure is required to determine
       the most satisfactory option.

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                                              - 39 -
       ORMAL WATER SURFACE
      ELEV 845*
      MAX 848'
   FEET
SECTION
DA M
     FIG.  5.3   WATER  STORAGE  POND

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                                                               - 40 -
5.3.5  Mill. Accommodation,  Service Areas,  Airstrip and Roads
       Proximity to the mine and tailing impoundment were determining
       criteria with regard  to siting the mill  and associated  ser-
       vices (1) (Figure 5.4).   Availability of bedrock for foundation con-
       struction was also a  consideration.   An  accommodation complex,
       providing hotel-type  accommodation to service a rotational
       work force, will be constructed on a similar site near  the
       mill complex.  An airstrip was constructed in 1982 south
       of the proposed tailing impoundment  site and directly east
       of the Bons Creek water storage reservoir.  Service corri-
       dors, access roads connecting the main  mine site components
       and the haul road will be appropriately situated.

       Mine site facilities  will be located primarily on sites
       mapped as sedge-grass tundra and dwarf shrub mat and
       cushion tundra vegetation types (2).  The airstrip
       intersects  a small area of open, low shrub shrubland.

       All necessary precautions will be taken during construction
       and operation of the project to minimize disturbance of
       land and water courses.  Clean, unmineralized mine rock
       will be used to construct roads, service corridors and
       service areas.  Culverts and stream crossings will be
       appropriately sized and  installed in a manner which
       minimizes stream sedimentation.  Surface runoff from
       the mill site will be collected in the tailings impoundment

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                       - 41 -
FIG 5.4   MILL SITE  PLAN

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                                                             -  42  -
     and  treated  prior  to  discharge  to  Red  Dog  Creek.

     At completion  of the  operating  life  of the mine,  the
     facilities will be removed  and  the site will  be  rehabili-
     tated.   All  equipment,  buildings and other surface
     structures will be dismantled and  removed  from the site.
     Where  the remaining concrete  foundations would be sig-
     nificant surface obstacles, these  will  be  removed to
     ground  level.   The airstrip,  service areas and corridors
     and  roads will  be  scarified to  relieve compaction and
     recontoured, if necessary,  to restore  natural  contours.
     Culverts and bridges  will  be  removed and open drainage
     channels will  be restored.  Water  bars will be constructed,
     if necessary,  to control  erosion.   Vegetation indigenous
     to the  region  will be established  on disturbed sites  by
     applying revegetation techniques developed during the
     operating period of the project.

5.4  Reclamation  Concepts  for the  Transportation Corridor
     Three  options  for  transporting  concentrate from  the mine
     to the  sea coast  are  being evaluated including slurry
     pipeline, railroad and road haulage (Figure 5.5).  All
     three  options  are  land based  requiring a corridor of
     land for routing,  a substantial sub-base to prevent
     permafrost degradation and structures  for  stream and
     river  crossings along the route.

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                                                      - 43 -
                    30
                     FILL
                    ORIGINAL GROLlfJO"
            TYPICAL ROAD SECTION
                  /  ORIGINAL. GROUND
             RAILROAD SECTION
SLURRY LINE)

FILTBJATE
RETURN
                        Q ft O U N Q
-------
                                                        - 44  -

Siting of the corridor to the sea coast is constrained by
two factors; firstly, the position of the orebody is fixed,
and secondly, the wetlands formed by the deltas of the
Kivalina and Wulik Rivers create a triangular area of
undrained, frozen, polygonical  ground which should be
avoided on both economic and environmental grounds.  The
potential corridor siting will  be from the mine site
either north or south around the wetlands area (Figure 5.6).

The preferred option for siting the transportation corridor
is a southern route through Cape Krusenstern National
Monument.  While the political  implications of land status
for a route traversing Cape Krusenstern National Monument
necessitates consideration of alternative routes, the direct
route through the National Monument is most advantageous
both economically and environmentally.  Costs are minimized
due to advantages of length, avoidance of major river and
stream crossings, passage through areas not prone to
solifluction and accessibility to gravel and borrow materials.
Avoidance of Kivalina wetlands minimizes extent of wetland
vegetation to about 5% of the area crossed by the corridor
(2).  Except for wetlands, no known critical plant habitats
occur along the corridor and no endangered species are known
to occur  in the area.  The habitat patterns of most game
animals  flank the corridor as opposed to being intersected
by the corridor.  Known peregrine falcon nesting sites

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                  - 45 -
FIG.5.6  ROUTE

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                                                        - 46 -

adjacent to the corridor are outside of the two mile minimum
buffer restriction based on present alignment.  Avoidance of
major river and stream crossings minimizes effects on water
quality, fish habitat and riparian habitat.

The preferred corridor to a southern port is 55 miles long
and crosses six major and 41 minor streams (3).  Construction
of a gravel road with a 30 foot wide top surface will require
a corridor 65 feed in width resulting in a disturbed land
area of 435 acres.  Borrow and gravel pits for subgrade and
surface construction materials are estimated to disturb an
additional 85 acres increasing land disturbance associated
with the transportation corridor to a total of 520 acres
(Table 3.1).

It is conceivable that the transportation corridor will be
used by the region beyond the operating life of the mine
and reclamation will not be required.  However, if the road
system is not to be used following mine abandonment it will
be reclaimed.  All bridges and stream crossing structures
will be removed and drainage courses will be restored.
The road surface will be scarified to relieve compaction
apd, where necessary, recontoured to restore natural
looking contours.  Water bars and other surface runoff
diversions will be constructed, as necessary, to control
erosion and prevent sedimentation of streams.  Self-
sustaining vegetation indigenous to the region will be

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                                                             -  47  -

     established on all  disturbed  surfaces.   Borrow pits  will
     be reclaimed immediately after their usefulness has
     terminated.  If available,  soils  suitable  for reclamation
     will  be stockpiled  and replaced on  the  abandoned pit surface
     prior to revegetation with  native plants.   Where practical,
     slopes will be recontoured  to an  appearance compatible with
     the surrounding terrain. Precautions will  be taken, as
     necessary,  to control  surface runoff, both  during the time
     the pits are active and following abandonment, to protect
     stream habitats from excessive sedimentation.

5.5  Reclamation Concepts for the  Port-Shipping  Facility
     A port facility with concentrate  storage to allow for
     year round  receipt  of concentrates  shipped  from the  mine
     and suited  for seasonal ocean shipping  of  concentrates
     to world markets will  be constructed on the sea coast (1).
     The coastline is unsheltered  and  therefore  exposed to sea
     and ice action.  Lagoons along the  coast could offer
     protection, but either support active marine habitats,
     or are very shallow.  Near-shore  waters are generally
     shallow and are a determining factor in the method of
     ocean transport.  Important environmental  aspects to be
     considered  are the  migration  of waterfowl,  anadromous fish
     and marine  mammals, sediment  transport  and  the perception
     by the people of an industrial facility on  the coast.

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                                                        -  48  -
Security in the methods for the storage and movement of
concentrates and supplies must also be considered.

Siting of the port facility and alignment of the
transportation corridor from the mine are co-determining.
Shortest distance to deep water, the most economic  land
based transportation corridor and environmental  concerns
are important criteria for determining the preferred
siting option.  The logical terminus of the southern
route through Krusenstern is at VABM 28 where the
Mulgrave Hills intersect the Chukchi Sea (Figure 5.6).
However, selection of VABM 28 for the port site depends
upon resolution of land status issues arising from the
proposed construction of the transportation corridor
through Krusenstern National Monument.

The port facility will incorporate a deep water dock
and shiploading facility with concentrate receiving,
storage and handling facilities.  Fuel storage and ware-
housing for supplies necessary to the operation of the
mine are also an important function of the port.  Assess-
ment of optional facilities for docking, concentrate
storage and handling and fuel storage has not been
completed.  It is assumed that on-shore facilities will
be constructed on crushed rock and will disturb
approximately 50 acres of land.

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                                                             - 49 -

     It is conceivable that the port system will  be used by the
     region beyond the operating life of the mine and reclamation
     will  not be required.   In the event the facility is abandoned
     all  buildings, equipment and other surface structures will
     be dismantled and removed from the site.  Where the remaining
     concrete foundations would be significant surface obstacles,
     these will  be removed  to ground level.  Crushed rock pads
     will  be scarified to relieve compaction and  perimeter slopes
     will  be recontoured.  Shoreline features will  be restored
     following removal of the dock.  Vegetation indigenous to
     the site will be established on the disturbed  areas.

5.6  Reclamation Research Proposals
     Effective reclamation  of land disturbed by the Red Dog
     project will  depend on application of site preparation
     and revegetation techniques capable of ameliorating
     conditions  limiting establishment and growth of plant
     species native to the  region.  During the past decade
     considerable  information useful for planning revegetation
     of Alaskan  tundra disturbance has been developed in
     conjunction with other resource development  in northern
     Alaska.  While it is generally recognized that factors
     influencing vegetation establishment and growth vary
     with  geographic setting of the mine, the nature of the
     ore deposit and the type of land disturbance,  develop-
     ment  of revegetation techniques for the various kinds

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                                                        - 50 -

of land disturbance at the Red Dog project will  be based on
currently available revegetation technology developed in
Alaska and on reclamation experience at other Cominco mines
in North America.  During the operating period of the project
revegetation techniques will  be assessed and refined on sites
representative of the major kinds of land disturbance.  Prior
to initiation of insitu investigations laboratory and growth
room studies will be conducted on waste rock and tailing
to identify plant growth limiting factors and to assess tech-
niques for modifying mine and mill wastes to improve plant
growth potential.  Techniques investigated will depend on
the nature and severity of factors identified as limiting
growth on the various waste materials.  Establishment of
diverse, self-sustaining communities of native plant species
will require development of effective propagation and
planting techniques.  Development of practical methods for
conserving surficial soil material for use in reclamation
of waste rock, tailing and borrow pits may also be necessary.
Early  during the operating period of the  project, surficial
soils  within land  areas selected  for mine and mill waste
disposal will be mapped and characterized to determine
availability and suitability  of  natural  soil materials  for
covering waste disposal dumps.

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                                                                 - 51 -
6 .  References
    1.  Cominco Alaska Inc., Red Dog Mine Project Overview.
         Prepared by Cominco Alaska Inc., January, 1983.

    2.  Dames and Moore et al.   Environmental  Baseline Studies,
         Red Dog Project,  Cominco Alaska Inc., January, 1983.

    3.  Faxcom from D.F.  Vinish, CESL Trail  to H.A.  Noah,
         Cominco Alaska Inc.,  October 26, 1982.

    4.  Cominco Engineering Services Ltd.,  Wastewater Collection
         and Management,  Red Dog Project, May, 1983.

    5.  Cominco Engineering Services Ltd.,  Tailing Impoundment
         Preliminary Design, Red Dog Project,  March,  1983.

    6.  Ball, D.L.,  Application  of the HDS  Process in the
         Treatment of Red  Dog Tailings Pond  Water.  A study
         conducted by Chemical Process Research  Group,
         Technical  Research Centre,  Cominco  Ltd.,  Trail, B.C.

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                   Appendix 2
Spill Prevention, Control and
Countermeasure (SPCC) Plan

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PRELIMINARY SPILL PREVENTION, CONTROL

       AND COUNTERMEASURES PLAN
           RED DOG PROJECT
             Prepared By:
            COMINCO  ALASKA

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                           TABLE  OF CONTENTS
                                                                       Page
1.    INTRODUCTION  	     1
     1.1   Purpose  	     1
     1 .2   Statement  of Policy  	     2

2.    MATERIALS QUANTITIES AND PROPERTIES  	     2
     2.1   Concentrator  Reagents  	      2
     2.2   Reagent Shipping Containers  	      5
     2.3   Concentrates	 .     6
     2.4   Fuel  Requirements  	     8

3.    MATERIALS TRANSPORTATION AND DEPORTMENT  	     8
     3.1   Port   	     9
          3.1.1   Concentrator  Reagent Handling  	   12
          3.1.2   Concentrate Shipment  	    12
          3.1.3   Fuel Storage  	    13
     3.2   Transporation   	   13
          3.2.1   Reagents Transport  	    16
          3.2.2   Concentrates  Transport  	    17
          3.2.3   Fuel Transport   	   17
     3.3   Mill Site Materials  	    17
          3.3.1   Reagents Utilization  	    19
          3.3.2   Concentrates  Production & Storage  	    19
          3.3.3   Fuel Storage and  Distribution  	    20

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                            TABLE OF CONTENTS
                                 (Continued)
4.   ADMINISTRATIVE SPILL  PREVENTION AND CONTROL
       PROCEDURES  	   20
     4.1   Materials Management  	   21
     4.2   Documentation and  Notification   	   22

5.   COUNTERMEASURES  EQUIPMENT AND MATERIALS   	   23
     5.1   Mobile Equipment  	   23
     5.2   Aircraft   	   25
     5.3   Communications   	   25
          5.3.1    Port Site  	   25
          5.3.2    Mine Site   	   25
     5.4   Chemical Spills Control  	   26
     5.5   Concentrate Spills Control  	   27
     5.6   Oil  Spills  Control   	   27

6.   SPILLS  RISK AND CONTROL   	   28
     6.1   Port Site   	   28
          6.1.1    Reagents  	   28
          6.1.2    Concentrates  	   30
          6.1.3    Fuel  	   31
     6.2   Materials Transportation  	   32
          6.2.1    Reagents  	   33
          6.2.2    Concentrates  	   34
          6.2.3    Fuel  	   34
     6.3   Mill Site   	   35
          6.3.1    Reagents  	   35
          6.3.2    Concentrates  	   35
          6.3.3    Fuel  	   36

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                                   PREFACE
This  report  is  preliminary  in nature.   It  is based  on the level  of conceptual
engineering  design detail  necessary to  establish capital  and  operating  costs
only  for  financial  feasibility.   Operatin  details are based on  concepts devel-
oped  from experience at other Cominco operations.

Final  design details  will develop more  optimum  solutions to some of the prob-
lems  discussed  herein.   The actual mine operating  personnel assigned during
the final  detail  design of the project will be charged with the responsibility of
developing an  operating management practices  manual which  may alter some of
the details of this  SPCC plan.

The general philosphy  and commitment by  Cominco as a  responsible coperate
citizen to ensure a minimal  disruption to  the environment will not change  upon
finalizatio of this SPCC  plan.
                                      HI

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                             1.  INTRODUCTION
The  proposed  Red Dog mining project will produce lead, zinc and  barite con-
centrates  from mined  ore  and   consume  various  chemicals  as mill  process
reagents.   In  addition,  substantial  volumes  of fuel will be  used  for electric
and  mature  power generation.   The  port  facility  will  receive  and trans-ship
fuel  on  behalf  of  the  Nana Region  villages.  Handling  and storage facilities
will  be designed  to  prevent  accidents  and  spills.   However,  spills  of all of
these  commodities, although remote,  can cause detrimental  environmental im-
pacts  which in, the  case  of  certain chemical  reagents, may be acute.   The
issue of personal  safety is  of paramount importance in  all operations involving
these materials.

Notwithstanding  Federal and  State  requirements,   it  is incumbent upon the
project to  plan and implement procedures which will minimize  the risk of spills
and  to prepare practicable and  effective countermeasures.   Such  planning
must  necessarily  integrate  both  the resources and liabilities  in  the  project
components in  terms  of personnel,  equipment  and the environmental setting.
It  is  a basic  principle that these objectives are  consistent with  good engi-
neering and operating  practices.
1.1  Purpose

     This  report  presents Cominco Alaska's plan at  the feasibility  level for
     the prevention and  control  of chemical, oil  and  concentrate  spills  which
     may emanate  from components  of the Red  Dog operations.  It  is important
     to  recognize  that the comprehensive specification of materials  management
     and spills control procedures  can only be completed when  detailed engi-
     neering is  substantially complete and materials  procurement is underway.
     It  is  proposed  that  the final  selection of  specific countermeasures re-
     sources be  made in  consultation with the appropriate  State  and Federal
     agencies.

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     The  planning documented  herein is  based on  the  project alternatives
     which include the  offshore island (ballasted tanker) as £ part of the  port
     facility).
1 .2  Statement of  Policy

     The following  are  key elements  of  Cominco Alaska's  policy with respect to
     spills  prevention  and  control  and environmental  protection  in  general:

         0   To comply  with all existing  State and Federal regulations.

         0   To  provide  additional   environmental  protection  measures  where
            warranted  that  are technically  feasible  and economically viable.

         0   To  encourage,  support  and conduct research  to  establish  high
            standards  of  performance  and  to improve  methods for  environ-
            mental  control.

         0   To  anticipate future pollution  control  requirements and  to make
            provision for them in long range planning.

         0   To  keep  employees,  agency  personnel and the general  public fully
            informed  concerning  all   environmental aspects of company  opera-
            tions.

         0   In all  emergency situations,  in order of priorities  are:   personal
            safety, environment,  property and production.
                                  - 2 -

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               2.  MATERIALS QUANTITIES AND PROPERTIES
2.1  Concentrator Reagents

     The  chemical  reagent requirements  for  Red  Dog  have been  established
     from a  comprehensive  program of metallurgical testwork.  There are no
     feasible alternatives to these materials  which may  be applied  without in-
     curring losses  of  the  valuable minerals to tailing,  or inferior  concentrate
     grades.   All are  in safe use  in  similar  base metal concentrators around
     the world  and there  is  ample  experience upon which  to base  effective
     management procedures and  facilities design.

     Table 2.1  provides the  quantities  of  reagents to be  used in the initial
     production period  and  an estimate of the  requirements when  concentrate
     production will be expanded in about year six of the operation.

                                  Table  2.1
                       Red Dog  Concentrator Reagents
Zinc sulfate (ZnSO4'
Copper sulfate (CuSO )
Sodium  cyanide  (NaCN)
Methyl isobutyl  carbinol (MIBC)
Sodium  isopropyl xanthate (NalPX)
Sodium  cetyl sulfonate (EC-111)
Sulfuric acid, 93% (H2SC>4)
Hydrated  lime ((CaOH)2)*
Polyacrylamide flocculant (Percol 730)*
Initial
Production
tons/year
529
529
106
53
529
79
1,057
4,182
6
Initial
Production
tons/year
982
982
197
98
982
79
1,962
6,553
6
    *NOTE: Part  of the  lime  and  all  of  the flocculant  will  be  used in tue
            wastewater treatment process.
                                  -  3 -

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 In  zinc and  copper sulfates  are slightly  acid,  water soluble salts  which
 will  be used  as  conditioners in flotation.  These materials will be  shipped
 in bulk,  2,000 Ib. capacity,  reinforced plastic  bags  and can be  compat-
 ibly sorted together.

 Sodium  cyanide  is  a  water  soluble  and   toxic  reagent  which  must  be
 stored  and  handled in  isolation  from other chemicals,  particularly those
 which   are  acidic  in nature.    It is commonly supplied  in lump form  and
 will  be shipped  in  2,000  Ib.  capacity  plastic  bags.   This  reagent  has
 been proven  to  be essential  to the metallurgical process  as  a depressant
 of iron minerals  and cannot be substituted  by potential alternatives such
 as sodium sulfite.

 Methyl  isobutyl  carbinol is a  flammable alphatic liquid  alcohol  which is
 lighter than  and  has  only a  modest solubility   in  water.  This  material
 will  be shipped  in 400 Ib.  capacity steel  drums  and can be safely stored
 with the other chemicals.  It will  be used  as a frothing agent  in  flota-
 tion .

 The  sodium  isopropyl  xanthate is an  essential sulfide mineral collector in
 the  flotation  process.   It will be shipped  as pellets  in 2,000 Ib.  capacity
 plastic  bags  which  are  preferably  stored  apart  from  acidic materials.

 Sodium  cetyl  sulfonate   is  a  paste-like surface  active agent  used  for
 barite   flotation  that has only  a  moderate  solubility  in  water.   It is  es-
 sentially  non-toxic and  has been approved  for  use  in  food  applications.
 It will  be shipped in 400 Ib. capacity  steel drums.

Sulfuric acid will be  shipped  and   stored  in  bulk tanks.   Although  the
concentrated  93%  acid  form does not attack  mild  steel in normal  condi-
tions,  it  should  be generally regarded as  being  corrosive and  great care
is required  in  materials  selection.   It is  necessary  in  the process to
ensure  that  the  zinc concentrate has a  sufficiently  low  silica concentra-
tion  to  be marketable.
                              - 4 -

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     Lime  will  be  used  as  a pH modifier in  flotation  and as  a neutralizing
     agent in the wastewater treatment plant.   It  is  moderately water soluble
     and only  toxic in concentrations which  result  in  high alkalinity.   In  the
     hydrated  form,  it is  relatively  safe  to  manage  and  will  be  shipped  in
     2,000 Ib.  capacity plastic bags.

     The  flocculant  (Percol  730)  is  a slowly  water  soluble,  high  molecular
     weight,  acrylamide-based  polymer  that  will be used  as  a  solids settling
     aid  in the  wastewater treatment plant.    This  material is relatively non-
     toxic.   It  will be shipped  in 50 Ib.  sacks on pallets and  must be pro-
     tected from temperature extremes in storage.
2.2  Reagent  Shipping Containers

     With the exception of the liquids,  it is  planned that all reagents be sup-
     plied  and handled  in  the semi-bulk plastic bag containers.  This  form of
     packaging  is  becoming  very widely used instead of the more  traditional
     forms including fibre  and steel drums and  polylined sacks.  The advan-
     tages offered  by the large bag containers are:

         0  more  reliable   protection and control of  the contained  materials,

         0  improved  economy in  both  purchase costs  and  handling opera-
            tions,

         0  elimination of  disposal  problems  (containers are  re-used  up  to
            about 100 times),

         0  storage areas  are minimized.

     The bags  are completely integral  units  and come  equipped with  fittings
     for bottom discharge  into system  hoppers and  reinforced  rigging  acces-
     sories  for  loading  and transport  by cranes and  forklifts.  Typical prop-
     erties  of a  suitable  reagent  bag  material are  provided  in  Table  2.2.
                                   - 5  -

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                                  Table 2.2
                   Properties of Reagent Container Material
    Material
    Thickness
    Weight
    Breaking strength, 3 cm.  strip
    Ultimate elongation
    Hydrostatic  resistance, 3 min.
    Flexure resistance (Scott type test)
    Low temperature
    Thermal resistance
    Chemical resistance
PVC Coated Polyester Fabric
1 .00 ± .05 mm
1,130 ± 100 g/sq. m.
Warp  150  Kg,  Fill 150 Kg
Warp  25%,  Fill 30%
+3,000 g/sq. cm.
Fine 1 Kg  1,000 times
Satisfactory handling to -40°C
No  damage to  70°C
Excellent  with both  10%  NaOH
  and  10%  H2S04
2.3  Concentrates

     The  lead  and  zinc  concentrates  to be produced at Red Dog  are essen-
     tially the  sulfides of the respective metals  accompanied by minor  amounts
     of other metal  sulfides and  gangue impurities.   For example,  the zinc
     concentrate will typically assay 59.0% Zn,  3.7% Fe  and 2.2% Pb while the
     lead  concentrate will contain 62.5%  Pb,  7.4% Fe and 8.0% Zn.  The mois-
     ture contents  will  be  about  7-8% and the  various  flotation  reagents  will
     be present in the form of surface  complexes bound  to  the  solids.  The
     individual  particles  have a high  specific gravity (Pbs 7.5, ZnS  4.1)  and
     they will virtually all be less than 400 mesh in  size.

     !n terms of basic chemical  properties, the  concentrates  are  relatively in-
     active  in comparison to the corresponding  metal  sulfates.   Being largely
     inert,  they are not immediately a threat to biological organism  in  situa-
     tions where discharge  to the environment may  occur.  Strong supporting
     evidence for this  fact  is provided by experience in  concentrators  where
     the  biological  monitoring of workers exposed to airborne metal sulfides  is
                                  - 6 -

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     conducted.   Blood  lead  values  are low in these situations  and no health
     problems  are encountered.   Apparently,  the stability of  metal  sulfides
     can permit their intake  and clearance from organisms  without  appreciable
     biological  accumulation.

     The barite to be produced  is essentially water insoluble  and is  regarded
     by chemists  as  being chemically  inert.   In  fact,  as a  mitigative  measure
     in  dealing with  spills  of  the  soluble  barium salts,   conversion to the
     barite  form  (BaSO.)  is  a recommended technique.   The Red Dog material
     will be about 90%  BaSO.,  containing  silica  (SiC"  ) and minor  concentra-
     tions of heavy metals as impurities.   It will  be dried  in the concentrator
     to  essentially zero moisture content before  shipment.  The concentrate
     production capacities  are given in Table 2.3 as follows:
                                  Table 2.3
                 Red Dog Concentrate Production,  tons/year
                         Lead Concentrate     Zinc Concentrate     Barite
Initial Production               79,000               350,000          50,000
Expanded Production          119,000               585,000          50,000
     It  should  be noted that the barite production capacity is  as  noted above,
     and the  actual  quantities  produced in any given year may  be substan-
     tially  less, and vary with  market demand.

     All  handling and  shipping  operations  of  the  lead  and zinc  concentrates
     will be  in the bulk form.   Barite  will be  packaged  in  the  recycleable,
     plastic bag-type containers identical to those used for reagents.
                                  - 7 -

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2.4   Fuel  Requirements

      Red Dog  operations  will annually require about 5.5 million gallons of  No.
      1  grade diesel  fuel  for electric power generation.   This quantity will in-
      crease to an excess  of 7.0 million gallons when production  is expanded in
      about year  six.   In addition  to  diesel,  a relatively small supply  of jet
      fuel  and  aviation  gasoline will  be maintained at the mine  site,  primarily
      for emergency purposes.

      Typical specifications of the "Arctic  Diesel" fuel to be  used are given in
      Table 2.4.

                                  Table  2.4
                          Typical Fuel Specifications
            Gravity °API                         -    40.0
            Flash Point,  °C                      -       48
            Viscosity  @ 40%C, cSt                -1.4
            Pour  Point, °C                       -       50
            Cloud Point,  °C                      -       46
            Sulfur,  mass %                       -     0.11
            Sediment  and  water, Volume  %       -      .05
            Ash,  mass %                         -      .01
            Cetane number                       -       45
            Btu per gallon                       -   134,700
            Distillation end point, C              -      282
            3.  MATERIALS TRANSPORTATIN AND DEPORTMENT
This  section  considers the  transport and  storage logistics of  chemical  rea-
gents,  concentrates and  fuel as  a  basis  for subsequently  evaluating  spill
prevention and  control.   The three elements within the overall system are the
                                   - 8  -

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port, road  and mill  site.   Within the port and  mill  there are,  naturally, sub-
elements  which consist of discrete  handling  and/or  comsumption  operations.
3.1  Port

     The  receiving of  general  supplies,  oil and  chemical reagents  and  the
     shipment  of concentrates  will  be during  the open  water  season which
     normally runs  from early July to the end of October.  These operations,
     as well  as the major storage  of  all  materials  will  be at the port complex
     illustrated in Figure 3.1.  The  three  major  facilities in  the complex  are
     the deep  water dock,  the shallow water dock and  storage  area and  the
     concentrate storage building  located 2.5 miles  inland.

     The  deep  water  dock  will be a  modified  ice-strengthened  250,000 DWT
     tanker  permanently ballasted in  35  feet of  water about 4,000  feet from
     the shoreline.   Figure  3.2  illustrates  the general  configuration of  the
     vessel  and  its material  handling system.   It  will have  the capacity  for
     storing  up  to three  months of  concentrate  production and 9.4 million
     gallons  of  fuel  (initial  requirement  5.5  million  gallons).    A 1,000  ton
     capacity lightering  barge will  transport supplies  and  concentrates  to or
     from the shore during  the open water season.

     The  shallow  water dock  is a  reinforced earth-fill  causeway  some 400 feet
     in length  having  a sheet pile face.   This facility also includes  chemical
     reagents  and supplies storage,  a fuel transfer  facility,  a  small accom-
     modation complex and  ancillary support facilities.

     The  main  concentrate storage capacity for 8.5 months production will  be
     in a long  building  2.5  miles from  the coast.  Trucks will either  dump
     (from the  mill) or load (to  the dock)  within  the  building  and a  tracked
     loader will be used for pile construction or reclaim.
                                  - 9 -

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                                         f
                               Figure  3.1
TCH3B
                               RDO4A322
0

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3.1.1  Concentrator Reagent Handling

       All  chemicals,  with  the exception of sulfuric acid,  will be shipped
       to the  port in  normal  ocean  freight carriers and off-loaded  by
       crane  into  the  lighter for transport to  the  dock.   Forklift/truck
       combinations will then  place  the containers  in  a  secure  storage
       area on the side of  the wide  road between the shallow water dock
       and  its service area.  The small reagent lots of  about 100  tons or
       less  each  will  be directly  transported  to the mill  site.  Materials
       will  be  segregated according  to  the requirements outlined  in Sec-
       tion  2.1 and protected from vehicular movements.

       The  annual supply of sulfuric acid will  be  provided  in on ocean-
       going barge or ship.  An  1,800 ft. long,  6  in.  dia.  pipeline will
       then convey the acid into a 30 ft.  high  by 30 ft. dia.  heat traced
       and  insulated  mild   steel  storage tank.   An acid  resistant  lined
       berm of 110% tank  capacity  will  provide contingency  containment
       around  this vessel.

3.1.2  Concentrate Shipment

       Lead  and  Zinc  concentrates   will  normally be reclaimed  from the
       storage building  and  transported  to an enclosed area  near the
       shallow water dock face in a tractor drawn unit consisting  of 2-75
       ton  capacity side dump  boxes.   A  portable  shuttle conveyor will
       load  the concentrates from  there into the lighter  barge.

       This vessel  will discharge its  cargoe  to the deep water dock as
       illustrated  in  Figure  3.2 at a  location which  is actually within the
       bow  of the ballasted tanker.   Concentrates  will be  conveyed to
       the  storage  holds or directly  to  the shiploaders which are fitted
       with "elephant  trunks" for discharge  deep  into the  holds of the
       concentrate  carriers.   All  exposed  conveyor  systems   will  be
       covered  to protect   against  wind  transport  of  concentrate  par-
       ticles.
                             - 12 -

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     3.1.3  Fuel Storage
            Two center tanks of the  deep water dock,  protected by reinforced
            wing  tanks, will  receive the annual  fuel  supply  from an ocean-
            going  tanker.   Fire protection  for this storage will  be provided
            and  the  status  of  the  tanks will be monitored by instrumentation.

            Fuel will  be pumped to a shore-based  50,000  gallon transfer week
            at an  average  rate of  approximately  100,000 gallons per  week.
            The  undersea  fuel  line  will consist  of a  4  in.  dia.  Schedule 40
            steel  line set inside a  6  in.  dia. Schedule  40  line which will  be  in
            a  backfilled trench  in the  sea bottom.   The  entire  shore-based
            fuel  facility, with  the  exception  of dispensing lines will  be set  in
            a  lined berm  of 110% tank  capacity and  protected  by  appropriate
            security  and fire suppression measures.
3.2  Transportation

     An  overall perspective of all  material movements required for the opera-
     tion  is  provided  in  Figure 3.3.  The haulage of mine  waste and ore  is
     included in the figure but this issue is outside the scope of this report.
     It  gives an effective summary of the transportation schedules and  vehicle
     types used between the mill and the  port site,  with the  latter assumed  to
     be at  VABM  28.   The  road  considered is  that along the shortest route
     (56.7 miles)  passing  through the Cape Krusenstern N.M.  This alignment
     is  illustrated in Figure 3.4.

     The  road  will  be gravel  surfaced,  of  30 ft. nominal  width and  con-
     structed almost entirely  of fill.   Passing  places of 50  ft. width  will be
     provided  every two  miles  and  the  maximum grade  is 4%.   Five bridges
     are required  varying in  length  from 50 to  160 feet.   Culverts  will be
     constructed in  122  stream and watercourse crossings with  an additional
     60  installed to  handle spring  runoff.
                                  - 13 -

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                                                Figure  3.4

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 All transport  vehicles using  the  road will be  in radio communication with
 a  dispatcher at the mill  site and  with  each other.  This service will  be
 utilized  for schedule monitoring,  the constant monitoring of road condi-
 tions  and  for  controlling the passing  of vehicles travelling  in  opposite
 directions.

 3.2.1  Reagents Transport

       The smaller reagent lots  indicated in Table 2.1 including cyanide,
       MIBC,  EC-111  and  flocculant,  will  likely be immediately trans-
       ported  to  the mill site as they are received in the annual  sea lift.
       The  remainder will  be  transported  along  with  general  supplies
       throughout  the   year  according  to  vehicle  availability and  the
       minimum requirement of maintaining a three week  operating supply
       at the mill.

       Any reagent  containers which are determined  by  inspection to be
       damaged  in  shipment  or  storage  will be  placed  in spare contain-
       ment bags  and immediately  hauled to the mill  for contents utiliza-
       tion.

       Reagents will be  transported to  the mill  utilizing  the backhaul of
       the  concentrate transport  units.   Bags will be placed  directly in
       the  trailers  and  up to 10  trips  per  day are  potentially available
       for  reagents,  but the normal frequency will be  substantially less
       as general supplies must also be  moved.

       Sulfuric acid  will  be transported  approximately  once  every  10
       days in  the dedicated  tanker unit of highway acid specifications.
       The  tanker  capacity  will  be 6,400  gallons  which is equivalent to
       about 49 tons.

3.2.2  Concentrates Transport

       Lead  and zinc concentrates  will be shipped to the port in 75 ton
       capacity trailers  which y'H  be covered.   Two  trailers and a trac-

                              - 16  -

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            tor will  make up one unit and  10  trips  per day  will normally be
            necessary  during the initial  production  period.

            Barite shipments in  bags will  be  on  flat  bed  trailers  or  in  the
            concentrate  trailers  depending  on  the  availability  of  the  latter.
            The  frequency  will  be  2-6  shipments  per week  depending  on
            market   conditions   which  are  evident  when   the  operation   is
            started.

     3.2.3  Fuel Transport

            Fuel  will  be  shipped to  the mill  site  in  units  consisting of two
            10,500 gallon capacity trailers.  Supply maintenance will  normally
            require one round trip per day.
3.3  Mill Site Materials

     The  major handling of all  reagents, concentrates  and fuel  will  center  in
     and around the mill complex  illustrated  in Figure 3.5.
     3.3.1   Reagents  Utilization

            All  storage of chemicals  at  the site will  be  in  the concentrator
            building  in accordance  with the previously  outlined  requirements
            for  segregation,  particularly  as  they  apply  to  sodium  cyanide.
            The method of handling solid reagents will be  initial dissolution  in
            solution  preparation  tanks,  followed by  transfer to stock  tanks
            from which the  solutions are  dispensed  to  various points in the
            process in clearly  identified  lines.    Cyanide handling will  be  done
            in  a secure enclosed  area within  the wastewater  treatment build-
            ing, that  is isolated from  all  other  reagents.
                                  - 17 -

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-H--
               'ISO



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       MiBC will  be directly  applied  from drums by  metering pumps and
       sulfuric  acid will  be  used  directly  from  a  bulk  storage  tank of
       about  7,000 gallons  capacity.   This vessel will  be protected in a
       similar manner to the larger storage  tank at  the port.

       The basement of  the  general  reagents  preparation  area will  be
       confined separately  from that  serving  the process section of the
       concentrator.  Solution spills will  be collected  in  a  sump  and re-
       turned to the appropriate stock tank.

3.3.2  Concentrates Production and Storage

       Lead and zinc concentrates  recovered in slurry form from flotation
       cells will be  pumped  to their respective  thickeners which are ex-
       ternal  to the main concentrator  building.   Large sumps will collect
       minor  spills and  be used to contain  the entire content of these
       vessels  in  the  event  they  have  to be  emptied for  maintenance.
       Concentrates collected  in these sumps and  process  spills within
       the  concentrator  building  will   be   returned  to  the  process.
       Thickened   concentrates  will be  pressure  filtered  and  dried to a
       moisture  content  of  7-8%  and  conveyed  to  concentrate  storage
       buildings which  have  a design  capacity of six weeks  production.
       Transports  will therein be  loaded  and the trailers covered with a
       heavy  roll-up tarpaulin  before being  dispatched to  the  storage
       facility at the coast.

       Barite  will  be processed in a similar  manner  with the exceptions
       that it  will  be  dried  to  essentially  a   zero  moisture  level  and
       bagged,  with  up  to  six  weeks  production  being  stored  beneath
       the dewatering section of the  plant.

3.3.3  Fuel Storage and  Distribution

       A  200,000  gallon  tank  near  the  mill  will provide the  main fuel
       storage for the power  plant and mobile equipment  at the site.  In
                              -  19  -

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            addition,  there  will  be a  50,000  gallon  emergency  supply  tank
            located  adjacent to the  accommodation  complex.  A 15,000 gallon
            tank  will  be  located  at  the  airstrip  to  store jet  fuel,  but  the
            actual  volume  maintained will be determined  by experience during
            the initial period of operation.  A  small  supply of  aviation gaso-
            line  in  drums for  the  emergency  refueling  of light  aircraft  will
            also  be stored  in  this location.   All tanks and ancillary  pumping
            facilities will  be protected  by  lined  berms  providing a  containment
            volume equalling 110% of tank capacity.

            All  external  fuel distribution  lines will be  located  in above ground
            utilidors.   Those which  are  in  the mill  complex  will  be  isolated
            from all other  process  and  service lines.
   4.  ADMINISTRATIVE  SPILL PREVENTION AND CONTROL  PROCEDURES
Comprehensive  and  detailed  programs  to  prevent spills  and  minimize their
environmental impacts  will  be implemented before the start of operations and,
specifically,  during  the detailed design  of the project  facilities.   In addition
to ensuring  the implementation  of  sound  technical and  engineering practices,
these will  include  the  establishment  of administrative procedures  for materials
management  and  spills control.   It  is  obvious  that  these must  address  the
regulatory requirements of the  U.S.  Environmental Protection  Agency, U.S.
Coast  Guard  and  the  Alaska Department  of  Environmental Conservation.   In
addition,  however, the security of operations and  personal  safety  are  issues
of particular importance in view of the realities  of  location  and  climate.
4.1  Materials Management

     Responsibility for this  function will  be charged to a Materials Management
     Committee  under  the  direction of  the  Manager  or his assistant.   Key
     personnel will  include  the Mill Superintendent (reagents,  concentrates),
                                  - 20 -

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Maintenance Superintendent (fuel,  transportation), Chief Storekeeper and
the  Fire Chief  who  will  be in charge of security and  safety.   Other
personnel  with specific  responsibilities  such as the  Environmental  Tech-
nician and  the Training Officer will be  called  upon to support this  group
from  time to time.

Important taks of this Committee shall include:

Inventory Control  -  The maintenance and  review of accurate records of
the  department, and consumption  or production  of  all  chemicals.   Con-
centrates  and  fuel-loss  detection  and  response planning  are  specific
objectives.

Security -  The provision of effective devices and procedures to protect
materials in storage  and to ensure  access to these  by only authorized
and  trained personnel  is  essential to  spill prevention.   The  Committee
will  also review housekeeping issues and implement appropriate  inspection
schedules.

Training  -  Training  manuals  will be  prepared and  programs of instruc-
tion  conducted.   These will  focus  on  the  hazards of  various  materials
and  procedures for their safe handling and  use.   Particular attention will
be given to mill reagent operators and  those  responsible for transporta-
tion  and the various handling operations.

Emergency  Response Procedures  -  The   Committee will  regularly  review
emergency  response  procedures in  the  light of  operating experience and
changine risks.  These will  be  optimized and  countermeasures equipment
changed  as  required.   An additional duty will  be  the  investigation of
spills or  near spills  which involve a  threat to  the environment or per-
sonal  safety.

Appropriate  response teams  will be delegated and trained  in accordance
with  the potential  location  of  a  spill  and the material  involved.  All spill
                             - 21 -

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     response  co-ordination  will  be  done  by the  Fire  Chief.   The  logistical
     aspects of the operations dictate more than just a central  response team.
4.2  Documentation and  Notification

     It  will be  the policy of  Cominco Alaska  to document all  material  spills
     whether  or not they  result in external discharge  and environmental  im-
     pairment.  These  will be  filed with the Manager for  regularly scheduled
     revies by  the  Materials  Management  Committee.    Information  to  be
     promptly compiled in the event of a  spill  shall include:

         0  Specific location of spill.
         0  Date and time of spill.
         0  Ambient conditions at  location.
         0  Specific material  and estimated  quantity.
         0  Apparent cause.
         0  Nature and extent  of environmental contamination.
         0  Proportions of  material  contained and lost.
         0  Hazards to personnel, injuries.
         0  Specific countermeasures employed.
         0  Disposition of spilled material.
         0  Clean-up procedures implemented and date of completion.

     Notification  of  spills with at  least the potential for environmental impact
     will  be  promptly  made to EPA,  ADEC and the Coast Guard (river or
     marine situations).   If, in the judgement of the Manager, major  impacts
     are  possible or  external  assistance  with  countermeasures is required,
     these notifications will be  done immediately.   The  village  of Kivalina and
     the  Nana headquarters  will also  be immediately advised  and  briefed  in
     the  event  of a  major  spill  at  the port  or  one  which  might severely
     threaten  the Wulik  River.

     The  agencies  will  be  notified  in  advance of any planned  changes in  the
     nature or  quantities  of  the  materials  utilized  or produced at Red  Dog.
                                  - 22 -

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     This will  also apply to the systems  required  for the handling and storage
     of material.
            5.  COUNTERMEASURES EQUIPMENT AND  MATERIALS
The detailed  specification of  resources  which will be available  solely for spills
control is not possible at this time, but will be  done in  the  procurement phase
of the  project.   However, a  preliminary indication as to the nature and scope
of the  proposed capabilities can  be given.   It is planned that EPA, ADEC and
the  Coast Guard be  consulted  to ensure  that  the  resources  finally selected
conform with  regulatory requirements and  optimum  technology  which  is avail-
able at the  time.
5.1  Mobile Equipment

     A  detailed list of mobile equipment to be available  at  the  mine and  port
     sites  is presented  in  Table 5.1.   This  equipment will  be used  for spills
     control  according to the order  of priorities stated in Section 2.1.
5.2  Aircraft

     No  aircraft will permanently be maintained  at  the  site but  light aircraft
     and  helicopters will  be  available  from  Kotzebue which is less  than one
     hour flying time away.   A 5,000 ft.  long runway at the mine  and a heli-
     port at the port site will be  available for emergency transportation pur-
     poses.   Large  cargo loads of countermeasures  equipment  can  be brought
     in  by  Hercules  or  similar aircraft  from Anchorage  or  other  points  in the
     south.
                                  - 23 -

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                                 Table 5.1

                Mobile Equipment Available for Spills Control
           Mine Site
       Size
     Typical  Unit
3 Front End Loaders
1 Front End Loader
2 Tracked Dozers
2 Tracked Dozers
1 Wheeled Dozer
3 Road Graders
1 Hiab Truck
a Water/Gravel/Sand Truck
1 Lowboy Tractor/Trailer
1 Snowblower
1 Snowplow  Truck
1 Crane
2 Buses
8 Pick-up Trucks
1 Fire Truck
3 Forklifts
1 Service Truck
4 Haul Trucks
	Port Site
1 Forklift
1 Crane
1 Front End Loader
1 Front End Loader
1 Tracked  Dozer
1 Tracked  Loader
2 Pickups
3 Fuel Oil  Trailers
1 Acid Trailer
8 Flat Bed Trailers
1 Load Lugger
4 Tractors
1 Crane
1 Container Forklift
7 cu. yd.
1/2 cu.  yd.
410 HP
200 HP
310 HP
180 HP
3 ton
5 ton
15 ton
20 ton
82 passenger
1/2 & 3/4 ton
1,000 gallon
4,000 lb/6,000 Ib
3 ton
150 tons
	Size
6,000 Ib.
20 ton
7 cu. yd.
4 cu. yd.
200 HP
3 1/4 cu. yd.
3/4 ton
10,500 gallon
6,400 gallon
40 ft.
50 ton
20 ton
Cat 988B
Low Profile
Komateu D355A
Cat D7
Cat 824C
Cat 146

Kenworth
V-blade Kenworth
Mobile-Rought Terrain
Bluebird
4 Wheel Drive
4 Wheel Drive
Diesel

Kenworth  Truck &
2 Trailers

	Typical  Unit	
4 Wheel Drive
Mobile-Rough Terrain
Cat 988B
Cat 966B
Cat D7
Cat 977C
4 Wheel Drive
Fruehauf
Fruehauf
Fruehauf
Mobile-Rough Terrain
Taylor TY 520M
                                 - 24 -

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5.3  Communications
     5.3.1   Port Site
            Radio - Air-to-ground  and marine  VHP  radio  systems to maintain
            communications with inbound  and outbound ships and aircraft.   A
            small  "seaport  services"  system  for  operational  personnel and
            vehicles at the port.

            Telephone - a  small PABX (8 lines) system to provide public net-
            work access to key locations  at the port.

            Status  Monitoring  - a 12  channel telemetry system for  monitoring
            the  status of major storage tanks from the mine site.
     5.3.2  Mine Site
            Seaport Mine Link - A UHF radio link  to  provide a multi-channel
            facility to support telephone and  analog telemetry systems.

            Transportation  System - A VHP  radio repeater system  to  provide
            reliable communications to  haulage vehicles  from the mill  complex
            and seaport.

            Mine/Mill System  -  A  VHP  radio  repeater  system to provide com-
            munications  between the operating offices,  mobile units and  mine/
            mill and service personnel  using protable  radios.

            HF Marine  - HF radio  including antenna  and  towers system  to
            provide  communications  to ships  associated  with  the  seaport.

            Deadlock Mountain Site -  A  site  facility  to  support the  various
            radio systems associated  with Red Dog operations.
                                  -  25 -

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5.4  Chemical Spills  Control

     The  on-site equipment  available  would be  essentially  that on the  mobile
     equipment  list supplemented with various  hand tools and  portable  pumps
     for  reclaiming  spilled  suifuric  acid.   Spare  reagent  containers will  be
     maintained for repackaging  those  damaged  in shipment  or handling.

     Lime  is  available,  both  as a  countermeasure  and  restorative agent,  for
     dealing with  acid  spills.    The bag containers will be  fitted for  bottom
     discharge  and  the  material can  be  readily dispensed  from either  cranes
     or helicopters.   The  use  of  available  suifuric  acid  to  neutralize  lime
     spills  will   not  be  conducted  as  this  countermeasure would  pose  risks
     greater than those associated  with the lime  spill.

     A  supply  of  either  calcium hypochlorite or  sodium hypochlorite will be
     maintained at both the port and  mill sites to combat the  effects of sodium
     cyanide  spills.   No  decision   has  yet  been  made on  which  material to
     select.   The  calcium salt  has a  long shelf life  but  it is in a granular
     form that  is difficult to apply.  The sodium salt is in  a  solution form  but
     has  a  shorter shelf life and  requires a greater weight  over the calcium
     salt  for the equivalent cyanide oxidizing capacity.
5.5  Concentrates Spill  Control

     The  on-site  equipment  available  for  cleaning  up  spilled  concentrates
     would  be that on  the  mobile  equipment  list.   In the unlikely event  of  a
     vessel  sinking (i.e.  lighter barge),  special slurry  reclaim pumps suitable
     for marine  applications  are  available from another Cominco operation.
5.6  Oil  Spills Control

     As  indicated previously  in this report, the selection of equipment specif-
     ically for oil spills  control  will be  made later in the project development
                                   -  26 -

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     and  with agency consultation.   However, it is recognized  that  oil  spill
     control  equipment  will be essential  in  an effective countermeasures plan,
     this  information will  be  presented in the Final SPCC  Plan.
                       6.   SPILLS  RISK AND  CONTROL
6.1  Port Site

     An  obvious risk factor which could  contribute  to  spills  of all  material at
     the port  during handling  operations is  the  weather.  In order to mini-
     mize this  risk  it  is  essential that  the  operation  take  advantage of  all
     possible  aids  in obtaining accurate  forecasts of weather and  sea  condi-
     tions in order to schedule loading and  unloading  activities.   A clear set
     of   directives  governing the  curtailment of  operations  during  difficult
     weather is also  vital.

     6.1.1   Reagents

            Container security  discussed  in  Section 2.2  will  be  an effective
            preventive measure in preventing the  spills  of  chemicals.   Car-
            goes will be  inspected prior  to  unloading  from  supply ships  to
            ensure that  damaged   containers  are  repackaged prior to being
            transferred  to  lighters.  Secure rigging and crane operation prac-
            tices will prevent  the  accidential  discharge of containers  to  the
            sea.

            If  discharged  to the  sea,  several  of the  chemicals  have bulk
            densities   less  than  that  of  water and  these containers  will float.
            Divers  would  be brought  in to assist in the underwater recovery
            of sunken containers.   Since the  containers  are  waterproof,  either
            situation  should  not result  in marine  contamination  provided  that
            they remain  intact.  There  are  no feasible  containment  or recov-
            ery  procedures which  may  be applied  if reagents  are  in  direct
            contact with seawater.
                                  - 27 -

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       In  the  unlikely  event  of  a reagent  spill in the sea,  short-lived
       impacts  on  marine life  in the  immediate vicinity  will occur  but
       should dissipate  quickly.

       The prevention  of spills on  shore will  be  effected  by the imple-
       mentation  of  careful  security  in storage and safety  with  vehicle
       movements.   The materials in  segregated storage will be inspected
       at  regular intervals  and  damaged  containers  immediately trans-
       ported to  the mill for the use of the contents.   Under no circum-
       stances  will  the handling  of  reagent  containers  be  permitted  if
       ambient  temperatures  are  less than the  safe level specified by the
       manufacturer.

       Acid will be  directly  unloaded at  the  shallow water dock  from an
       ocean-going   barge.    Spills  prevention  will  originate in  careful
       materials selection and  continue  with the regular  inspection of all
       storage  and handling systems.  A check-list  system will be imple-
       mented  to  protect against  the improper operation  of  pumps  and
       valves.    The status  of the acid  storage tank  will be monitored
       from the mill  by  telemetry  and any major  spill  from this source
       will  be  contained by  a berm lined with acid  resistant  material.

       There are no mitigative procedures which can be  applied if acid  is
       spilled to the sea.   Short term  toxic  impacts by virture of  pH
       depression  may  be evident in the immediate  vicinity of the spill.
       Small land  spills  at the  port will  be neutralized with  lime and the
       contaminated  soil excavated and  transported to  the mill  for dis-
       posal in  the tailings pond.
6.1.2  Concentrates
       Potential  origins  of  concentrate spills  at  the port are  conveyor,
       shiploading,  lighter  and truck  operations.   Short of  a  major acci-
                              -  28 -

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        dent  such  as  the  sinking  of  a  loaded  lighter,  most  potential
        causes of spills would  be relatively minor  and of a poor operating
        or  housekeeping nature.

        Trucks will  be covered  and if rear dumps are used  for  haulage,
        tailgates  will be  tightly  secured.  All  exposed  conveyors will  be
        covered  to  prevent  the wind transport of concentrate  particles
        and return  belts  will be  cleaned to remove  sticking material  which
        could  potentially fall  in the sea.  Conveyor transfer points will  be
        enclosed  housings  which will be  regularly cleaned out and systems
        will  be interlocked.   Shiploaders  will be  equipped  with  elephant
        trunks to direct  concentrates deep  into ships  hold  and prevent
        spillage on decks.

        Minor  losses  to the  sea are expected to be rapidly dispersed  by
        the  dynamic  sea  conditions  at  the  VABM  28 site and  to have
        negligible marine  impacts.  Spillage  will  result in  some release  of
        surface adsorbed  flotation reagents and  heavy metals but the sul-
        fides  will remain  chemically  intact  and be  inundated  by normal
        marine sediments.

        If major spills,  such  as those from a vessel  sinking, are localized,
        every   effort would   be  made to  recover  the materials  using  a
        slurry  pump  system.   This utilizes a pump fitted with an agitator
        assembly  that fluidizes consolidated  material to a  pumpable  form.
6.1.3  Fuel
       An essential  feature of fuel  spill  prevention is the integrity of  the
       deep water  dock itself in the  light of sea and  ice  conditions  ex-
       pected at the port.   Storage will be  in  center  compartments pro-
       tected  from the sea by two  layers of steel.   Prior  to being per-
       manently  ballasted  in  a  prepared  bottom location,  the  outer  hull
       will be  ice strengthened  by  the  addition of about 600 tons of new
       steel plate and  about 200 tons of steel  will be  provided for addi-


                              - 29 -

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            tional bulkheads in the tanks.   Approximately 95,000 cubic yards
            of gravel ballast  will be  used to permanently  stabilize  the  vessel
            on the sea bottom.

            Corrosion protection measures will be  provided on  the  outer hull
            and  an  ice  load  monitoring  system will be  installed.  Status  moni-
            toring of the fuel  in  storage  will  continually  be conducted by
            instrumentation  and  the bilges  between hull compartments will be
            routinely  inspected.

            Fuel  transfers  to  the  berm-protected  shore facility  using  the
            undersea  double  line  will be closely  monitored.    Flow  detectors
            will  be  incorporated to  warn  of smooth transfer disruptions and
            leak detectors will be  installed  to  sense fuel  leakage in the  space
            between the  inner  4-inch  and outer 6-inch  line.

            If spills to the sea  are detected,  containment and  clean-up mea-
            sures would  be  initiated using equipment available at the port.  It
            is recognized that sea  conditions  could be such that containment
            is not  practicable  since  boom   effectiveness  is  limited.   By  the
            nature of the viscosity  of diesel  fuel, it is not expected that sub-
            stantial  long  lasting  beach accumulations would occur during  high
            shoreward  winds.  Therefore, it is not proposed that the removal
            of contaminated beach  material be  a  standard  feature of clean-up
            measures.   It is  quite  possible that  this practice would  cause
            more  physical damage to beach systems than would  result from the
            spilled oil itself.
6.2  Materials Transportation

     The  significant cause of  potential spills during transportation  are  common
     to all materials  handled.   Driver error or carelessness  is the predominant
     factor  in major  transportation  accidents  throughout  North America and
     every  effort must  be made  to  eliminate this as an  element of  risk at Red
                                  - 30 -

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 Dog.  Comprehensive  training and safety rules are essential and must  be
 backed  by  strong  management  policies  with  respect  to  infractions and
 driver performance.

 The road  will  generally  be constructed according  to  standards employed
 on  the  North  Slope.   Impact engineered guard rail  systems will  be in-
 stalled  on bridges and the berming  of approaches  will  be employed  on a
 site specific basis if  these do not constitute a greater safety hazard  by
 trapping snow.  Reflectors will  be installed  as  road side markers.

 Maintenance  is  a  vital protective measure as  it applies to both road and
 vehicle  conditions.   Base  inspections  and prompt surface repair will  be
 conducted during the  warmer months  and will  be particularly emphasized
 during  the break-up  period in  the spring.   Snow  removal  will  be routine
 during   winter,  coupled  with improvement  programs  to control drifting
 and troublesome locations.  All  haulage vehicles will be on fixed preven-
 tive maintenance  schedules and their  safety systems  shall be  inspected
 daily.

 Vehicle  collisions are  a  potential cause  of  material  spills which  can  be
 eliminated  by  effective communications between drivers and  dispatchers.
 Frequent contacts  between  drivers proceeding in opposite directions will
 permit scheduled  vehicle passing at  the prepared  passing locations.   At
 all  times,  trucks  hauling  reagents from the  port will  have the right-of-
 way over  concentrate  trucks  from the mill.  Frequent radio contacts will
 also serve to  alert  drivers  during  periods  of  rapidly  changing  road
 conditions  and  losses  of  contact will result  in  the dispatch of assistance
 followed  by the deployment of appropriate spill countermeasures.

 Once the road  alignment is fixed and detailed  design  is underway  recon-
 naissance of sensitive  locations and stream crossings will be conducted  to
assist  in  the  tactical  planning  of  spill  countermeasures  appropriate  to
 specific  sites.   For  example, it would be impossible to contain a fuel  spill
at the  point  of a stream crossing, but  there  may be downstream locations
                             - 31 -

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of  opportunity  at  which  containment  could  be  effected.   These site
assessments  will  also  include  planning  for  access  vehicle types and
routes.

6.2.1  Reagents

       Under most circumstances  in  which accidents occur during trans-
       portation  it  is  expected  that the reagent  containers  will  be  of
       sufficient  strength to  remain intact  or,  at  worst,  suffer  only
       minor  ruptures with small  losses.   Where  possible, the  spill  area
       will  be isolated  and the  materials  reclaimed for immediate  use  in
       the concentrator.  Highly  contaminated soils and muskeg or snow
       will  be removed  and disposed of  in  the  tailings pond,  and the site
       later  revegetated.  Areas  where sodium  cyanide  spills  result  in
       ground contamination  will  be treated  with hypochlorite.   Sulfuric
       acid   spills  will   be  reclaimed where  possible  and  the  impacted
       ground area neutralized with  lime.   Reagent  spills  to watercourses
       will  be dealt  with  by  procedures to  be developed  in  the site
       specific tactical  planning.   These  will  always involve  the dispatch
       of the  Environmental  Technician  and  assistants  with field analyt-
       ical  kits to establish the advance and  extent of  stream contamina-
       tion.   Consultation with  the Alaska Department  of Fish  and Game
       will  be immediately initiated  if there appears to  be a  potential for
       impact on fish resources.   Field data  from watercourses  and spill
       magnitude  estimates  will then be  used to decide  on appropriate
       countermeasures  which could involve outside  support  such as heli-
       copters.

       Since containment of  water soluble reagent  spills  in stream flows
       is  not  normally  possible,  specific  countermeasures might include
       the  broadcast  application  of  lime  from helicopters for  mitigating
       acid  impacts, or  a similar use of  hypochlorite for cyanide  destruc-
       tion.   Such in-situ actions  require effective field  monitoring sup-
       port,  and  careful  control and  would  be  initiated  with agency
       approval.
                             - 32 -

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6.2.2  Concentrates

       There is the potential for a spill of up to 150 tons of concentrates
       in a  single  event.   Lost materials would  be  reclaimed by mobile
       equipment  appropriate  to the  site  and  either  transported  onto
       storage at the  port  or  sent  back  to the concentrator for retreat-
       ment  if the  material is  contaminated.   Impacted  soils and  muskeg
       would  be  stripped  and  handled in a manner  similar  to that  with
       reagent spills.

       Since the  concentrate  particles  have a high  specific gravity and
       the chemical availability of the  metal  sulfides  is  low, significant
       detrimental impacts  of  spills  on  watercourses are  not expected.
       Particles would  rapidly  settle out  and appreciable  accumulations
       could  later  be recovered  by  dredging  with  backhoes  or other
       appropriate equipment.

6.2.3  Fuel

       Fuel   spills on  land  would  initially  be contained  by appropriate
       ditches  or  berms and  reclaimed into  portable tanks  by pumping
       and  residues  would  be  cleaned-up by the  application of  a  loose
       sorbent such  as peat moss.   Contaminated soils and muskeg would
       be stripped  and the contained  fuel  incinerated  at the mill  site.

       The  prior  tactical  planning would be  most effective  in managing
       fuel spills  to watercourses.   Appropriate countermeasures  includ-
       ing booms, sorbents and  ancillaries  would  be deployed  at  pre-
       selected  downstream  locations  to  intercept  and  recover  spills.
                             - 33 -

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6.3  Mill Site
     The environment  is most  protected  from material spills at this  location by
     the integral  nature of the  operations.   Through long established design
     and operating  practices, concentrators contain internal facilities  for spills
     management  and  materials  recovery.   Sirrpiy  put, there  is  no  physical
     possibility of spills being  discharged from  the concentrator building.  A
     final  line of  defence is the tailings  pond which would  serve  to trap all
     materials  and  contaminated  runoff  emanating  from the  entire  mill area.

     6.3.1  Reagents

            The  facilities  to process  reagents  and  contain  spills  have  been
            previously  discussed.  Appreciable  concentrations  of  these mate-
            rials  will  not  occur  in  tailings  pond  water  since,  by  virture  of
            their  chemical properties,  there is  a vital  requirement  for care-
            fully  managed application  in the  process.   They normally report
            almost completely  to the concentrates  with  the  balance  remaining
            bound to  residual  sulfides  in  tailings.   Overdoses  in  the process
            would  be  immediately  reflected   by  upset  conditions   and, since
            about  85%  water recycle from  the tailings thickener will  be prac-
            ticed,  continual optimum control  will  be essential.

     6.3.2  Concentrates

            Concentrator  spills will  be  reclaimed  by  internal systems and the
            housing  of storage  areas and conveyor galleries will  prevent the
            wind   borne  transport   of  these  materials.   Tailing  will  contain
            residual metal  sulfide  values but unacceptable  losses  to tailing
            could  not  be  tolerated  for  economic  as we!! as environnentai  rea-
            sons.
                                   - 34 -

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6.3.3  Fuel
       Fuel spills  from  storage  tanks  will  be contained  by  protective
       berms and  the material consumed in  the  power plant.   Distribution
       lines will  be regularly inspected and minor leakages corrected im-
       mediately.

       Fuel would  be  an  unacceptable contaminant  in  the  wastewater
       treatment plant but  any  present in the tailings  pond  water will
       normally report as a  scum on the surface  of  the  treatment clari-
       fier.  Any fuel present as a  visible sheen will  be recovered  and
       disposed of by standard procedures  for  water  borne spills.
                             - 35 -

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                     Appendix 3
Endangered Species Biological
                 Assessment

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                          BIOLOGICAL ASSESSMENT
                                 of the
               Red Dog Mining Project's  Potential  Effects
                         on Endangered Species

                          Prepared Pursuant to
                 Section 7 of the Endangered Species  Act
                          of 1973 (as amended)
Introduction
This Biological Assessment has been prepared in partial  fulfillment of
responsibilities under Section 7 of the Endangered Species  Act.   It is
meant to complement the Red Dog Mine Project Environmental  Impact
Statement which provides a detailed project description  (Chapter II) and
description of the affected environment (Chapter IV).   Information on
threatened and endangered species is included in Chapter IV and  in
Chapter V, Environmental Consequences.   The reader will  find specific
page references for each species addressed in this Biological  Assessment
in the EIS index (Chapter XIII).

Terrestrial Species

Based on information supplied by the U.S.  Fish and Wildlife Service, the
arctic peregrine falcon (Falco peregrinus  tundrius) is  the  only  listed
endangered terrestrial species present  in  the study area.   Additionally,
several rare Alaska plants that are considered candidates for possible
future listing as threatened or endangered have potential to occur in the
area.

Threatened and Endangered Plant Species

According to Murray (1980), three candidate species have potential to
occur in the area.  The Kobuk locoweed  (Oxytropis kobukensis), which is
under consideration for endangered status, occurs along  a  25-mile stretch
of the Kobuk River on sand dunes.  The  kokrines oxytrope (Oxytropis
kokrinensis) occurs in the western Brooks  Range on dry  alpine slopes,
ridge crests, and fellfields.  Erigeron muirii has been  located  on dry
slopes northwest of the project area near  Cape Thompson. Both of these
species are under consideration for threatened status.   Walpole  poppy
(Papaver walpolei), considered previously  to be threatened, is no longer
under consideration for protected status (U.S. Fish and  Wildlife Service
1980).  This species occurs on coarse,  well-drained soil in the  lower
Noatak and middle Kobuk Rivers.

Of these plant species, the kokrines oxytrope has the most  potential to
occur near the proposed mine area.  The kobuk locoweed  has  potential to
occur along proposed corridors, primarily  near rivers  between the mine

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area and coast,  and perhaps on coastal  sand dunes.   None  of  the  species
of concern have  been located to date by field searches  conducted from
1981 to 1983 by  Dames & Moore (1983a,b).   Thus,  it  appears unlikely that
candidate threatened or endangered,  or  rare plant species are  present in
areas proposed for development by the Red Dog Mine  project.
Plant collections (Dames & Moore 1983a,b) strongly  indicate  that the
limited distribution of many species desginated  as  "rare" is in  fact due
to inaccessibility.  For example, the Dames & Moore studies  indicated
that ranges of Alii urn schoenoprasum   var. sibiricum,  Angelica  lucida, and
Seneciq pseudoarnica are apparently  more  widespread than  previously
indicated by Hulten (1968).  Similarly, Taraxacum phymatocarpum, although
rarely collected, is well-represented along the  coast,  both  south and
north of Kivalina.

Peregrine Falcons

Although the project area is located within 150  miles of  one of  the
largest concentrations of peregrines in North America,  the Colvilie River
drainage (Kessel and Cade 1958, Cade 1960), the  southern  slopes  of the
Brooks Range are not noted for high  peregrine density.  The  Noatak
drainage to the  east supported a few peregrines  in  the  past  (Hines 1963,
Haugh and Potter 1975).  The Cape Thompson region,  northwest of  the
survey area, has historically supported a couple pair of  peregrines
(Swartz 1966).  Located east and northeast of the project area,  the
Kuparuk and Ipewik River drainages have had peregrines  in the  past (Hines
and Williamson,  quoted in White and  Boyce 1977). More  specific  to the
project area,  both the Kivalina and  Wulik Rivers were surveyed by fixed
wing aircraft by White and Boyce (1977) but no peregrines were found.
According to those investigators, overall habitat along the  Kivalina and
Wulik Rivers was considered of lesser importance compared to other rivers
in the region because of the lack of and quality of cliff structures.
Raptor surveys (Douglas and Bente 1980) conducted in  1978 and  1979 by LGL
for GCO's proposed mine located proximate to the Cominco  Red Dog Mine
located no peregrine nests in the study area.

Dames & Moore 1982 field studies of  the Wulik and Kivalina River
drainages located seven active peregrine eyries  in  the  vicinity of
proposed northern and southern transportation corridors for  the Red Dog
Mine (Dames & Moore 1983a).  An additional 11 peregrines  were  observed
away from nests.  The sites identified  as peregrine nests were not
located along the major rivers but were found along the cliffs and bluffs
in less obvious  areas (i.e., small streams and tributaries)  not generally
covered during previous peregrine surveys.

Between June 15-23 and on July 31, 1983,  followup field studies (Dames &
Moore 1983c) were conducted to determine if the  peregrine nests located
in 1982 were again occupied by the birds and to  survey  the Singoalik
River drainage.   A check of each nest site where peregrines  were located
on the 1982 survey failed to yield a single active  peregrine nest.  A
total of four sites were completely  inactive, one site  was occupied by
                                  - 2 -

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rough-legged hawks (Buteo lagopus),  and  three  of  the cliffs  were  occupied
by gray-phase gyrfalcons (Fa I co rusti col us).   No  active  raptor nests were
located along the remainder of the Singoalik  River drainage.

Peregrines present in the project area would  be most vulnerable to human
disturbance during nesting.  Possible  effects  could be loss  of birds and
reduced reproductive success.   The current  alignments of transportation
corridors proposed for the project are located greater than  2 miles from
any peregrine nest located during Dames  & Moore's 1982 studies.  If a
2-mile buffer around these sites or any  others located prior to
construction is honored, essentially no  impact should occur  to peregrines
nesting in the area.   Any migrating peregrines would avoid  areas where
potentially disturbing activity occurs.

In addition to providing a 2-mile buffer around the nests, steps  would be
taken to avoid disturbance to peregrines from aircraft and helicopters.
Operators would be provided maps and be  required  to travel corridors and
at altitudes which would avoid disturbing known peregrine falcon  nests.

There would be no significant impact on  prey  species.  Shorebirds and
waterfowl generally comprise a major portion  of the peregrine's diet.
However, the location of project components  avoids the major shorebird
and waterfowl nesting and staging areas  (see  Figure IV-3, page IV-13, of
the DEIS).  Upland habitat losses along  the  preferred road corridor would
be locally insignificant in view of the  abundance of this type of habitat
in the project area.  Thus any upland  species  which may comprise  a
portion of the peregrine's prey base would  not be significantly
affected.  However, peregrine feeding  activity may be modified due to
construction of the road.  No herbicides or  pesticides are proposed to be
used.  Potential disturbance of peregrine nests due to increased  access
to the area should not be a problem since the access road would not be
available for general public use.

Conclusions

No candidate threatened or endangered plant  species have been located at
the mine site, along proposed transportation  corridors,  or at proposed
port sites.  Ranges of "rare" species are apparently more widespread than
previously indicated.

If 2-mile buffer zones around peregrine  nesting sites are honored and
aircraft avoid known nesting sites, minimal  or no impact to  this  species
should occur as a result of the Red Dog  project.
                                  - 3 -

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                                  REFERENCES
Cade, T.G., 1960.   Ecology of the peregrine and gyrfalcon populations in
    Alaska.  Univ.  of Calif.  Publ.  Zool.  63.

Dames & Moore,  1983a.  Environmental  baseline studies,  Red Dog Project.
    Prepared for Cominco Alaska,  Inc.

Dames & Moore,  1983b.  Vegetation mapping of the Omikviorok River corridor
    and threatened-endangered plant species search (Draft).  Prepared for
    Cominco Alaska,  Inc.

Dames & Moore,  1983c.  1983 raptor surveys (Draft).   Prepared for Cominco
    Alaska, Inc.

Douglas, R.J. and  P.J. Bente, 1980.  Baseline studies of raptors in a
    proposed mineral development  area in  the DeLong  Mountains during 1978 and
    1979.  Prepared by LGL for 6CO Minerals.

Haugh, J.R., J.P.  Potter, 1975.  Evaluation of raptor populations; Tuxedni
    Bay, Iliamna Lake, Noatak River Valley and Fortymile River Valley of
    Alaska.  Report to USDI,  BLM  and  USFWS.

Hines, J.Q., 1963.   Birds of the  Noatak River, Alaska Condor 65:410-425.

Hulten, E., 1968.   Flora of Alaska and neighboring territories; a manual of
    the vascular plants.  Stanford University Press, Stanford, California.

Kessel, B., T.J. Cade, 1958.   Birds of the Colville  River, northern Alaska.
    Biological  Papers of the University of Alaska No. 2. 83 pp.

Murray, D.F., 1980.  Threatened and endangered plants of Alaska.  U.S. Dept.
    Agriculture, Forest Service,  and U.S. Dept. Interior, Bureau of Land
    Management.

Swartz, 1966.  Seacliff birds.  ln_ Wilimovsky, J.N., and N.J., Wolfe, eds.
    Environment of the Cape Thompson Region, Alaska.  U.S. Atomic Energy
    Commission.  Div. of Tech.  Info.  PNE-481.

U.S. Fish and Wildlife Service, 1980.  Endangered and threatened wildlife and
    plants; Review of plant taxa for listing as endangered or threatened
    species.  Federal Register (45-242),  pp. 82480-82569.

White, C.M., and D.A. Boyce,  1977.  A profile of various rivers and their
    raptor populations in western Alaska in  1977.  Tech. Rept. No. 01
    USDE-BLM, Anchorage, AK.
                                   -  4  -

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Marine Mammals

Based on comments received from the National  Marine Fisheries Service,
bowhead and gray whales are endangered species present in the study
area.  The bowhead whales (Balaena mysticetus) and the gray whale
(Eschrichtius robustus) are listed as endangered under the Endangered
Species Act of 1973 as amended.  Both species migrate into or through the
Chukchi Sea near the study area.

Bowhead Whales

The most recent estimate of the number of bowhead whales in waters
adjacent to Alaska is 3,857 individuals.  The western Arctic population
winters in the western and central Bering Sea (Braham et al., 1980).  The
northward migration is collated with the timing of ice breakup usually
beginning in early April.  As they move through the Chukchi Sea,  the
bowhead whales follow ice leads occurring seaward of the landfast ice.
These  leads usually bring them across outer Kotzebue Sound in a
northeasterly direction to the vicinity of Cape Thompson.  Some whales
move through a persistent polynya that forms between Kivalina and Point
Hope (Braham et al., 1980).  Most of these animals then move from the
Chukchi Sea into the Beaufort Sea and on the summering areas near Banks
Island in Arctic Canada.  After summering in Canadian waters, the fall
migration takes the bowhead whales past Point Barrow and on westward
toward Hereld and Wrangell Islands and on to the western portion of the
Chukchi Sea (Braham and Krogman, 1977; and Cowles, 1981).

Dames & Moore (1983) conducted field surveys to locate all marine mammals
in the project area.  No bowhead whales were observed during their
traditional migration period in late April and early May.  However, a cow
and calf were observed on June 25, 1982, a few hundred yards offshore of
Kivalina Village heading north.  During subsequent flights both north and
south  of Kivalina helicopter pilots reported seeing large black whales
approximately 6 times during the following week.  The whales were
swimming north generally within one mile of the shore.  Groups size
ranged from four to six.  The last sighting occurred around July 1, 1982.

Gray Whales

The National Marine Fisheries Service assumes that essentially the entire
population of California Gray Whales, estimated at 15,000 to 17,000
individuals, migrates north from their wintering grounds and into the
Bering Sea in April and May.  By June many move through the Bering Strait
and enter the Chukchi Sea.  During the summer, most of the population
concentrates in shallow waters around St. Lawrence Island and northward
to the Chukchi Sea where the gray whale distribution coincides with high
densities of the benthic gammarid amphipods, on which they forage.
Between July and September, low numbers of gray whales regularly move as
far east as Point Barrow (Marguette and Braham, 1982).  A smaller number
of gray whales may occassionally move as far east as the northwest
territories in Canada (Maher, 1960; Johnson et al., 1980; and Rugh and
Fraker, 1981).
                                   -  5  -

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During Dames & Moore's marine mammal  surveys,  gray whales  were  sighted on
three different occasions between July and August 1982.  The  first
observation occurred on July 18,  when a lone animal  was  observed  feeding
off Kavorak Lagoon in very shallow water.   The second sighting  was on
July 22, 1982, when another gray  whale was seen off Imikruk Lagoon as it
passed under the boat of the diving crew in very shallow water.   The last
observation occurred on August 2, 1982, during an annual bird survey when
a lone animal was seen swimming southward  off Ipiavik Lagoon.  The latter
animal appeared to have a very noticeable  lateral curvature of  the lower
spine just above the tail.  This  feature could possibly  help  to identify
this individual in other parts of its range.

Conclusions

Bowhead whales in the project area would be most vulnerable to  human
disturbance during the migration  period.  Based on potential  impacts
identified during research in other parts  of Alaska, possible effects
would include disturbance from boats or low-flying aircraft.   However,
the disturbance of these animals  during spring migration is tied  to
open-leads in the ice pack and little disturbance would  be anticipated
from shoreside activities related to the mineral concentrate storage and
transfer facilities because the area of landfast ice is  usually 1 mile or
more in width.

Vessel traffic for movement of concentrate away from Alaska or supplies
or materials to Alaska would occur after the ice has gone, which  usually
occurs around July 1st.  As a result, the bowhead migration would pass
through the Kivalina area before  the annual shipping season begins,
resulting in no disturbance to migrating bowhead whales.

Gray whales within the project area would be most vulnerable to human
disturbance during the summer shipping period since they migrate  and feed
in very shallow nearshore waters in July and August.  However,  gray
whales are uncommon in the Kivalina area and marine mammal specialist
John Burns (Alaska Department of Fish & Game) said that  he anticipates
essentially no impact from gray whales encountering causeway/dock
structures approximately 400 feet or less in length.    However, vessel
traffic during lightering operations between the dock structure and an
offshore island system may have to be interrupted for short periods if
gray whales should begin feeding within the port area.  It is assumed
that any migrating whales would avoid the areas where potentially
disturbing activity was occurring.

In order to avoid any potential for harassment of endangered whales in
the project area, the following guidelines would be adhered to:

         (l)(a) Vessels and aircraft would  avoid concentrations of groups
         of whales.  Operators would, at all times, conduct their
         activities at a maximum distance from such concentrations of
         whales.  Under no circumstances, other  than an emergency, would
         aircraft be operated at an altitude lower than 1,000 feet when
         within 500 lateral yards of groups of whales.  Helicopters would
         not  hover or circle above such areas or within 500  lateral yards
         of such areas.
                                   -  6  -

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  (b) When weather conditions do not allow a 1,000 foot flying
altitude, such as during severe storms or when cloud cover is
low, aircraft would be operated below the 1,000 foot altitude
stipulated above.  However,  when aircraft are operated at
altitudes below 1,000 feet because of weather conditions, the
operator would avoid known whale concentration areas and would
take precautions to avoid flying directly over or within 500
yards of groups of whales.

(2) When a vessel is operated near a concentration of whales the
operator would take every precaution to avoid harassment of
these animals.  Vessels would reduce speed when within 300 yards
of whales and those vessels capable of steering around such
groups would do so.  Vessels would not be operated in such a way
as to separate members of a group of whales from other members
of the group.

(3) Vessel operators would avoid multiple changes in direction
and speed when within 300 yards of whales.  In addition,
operators would check the waters immediately adjacent to a
vessel to ensure that no whales would be injured when the
vessel's propellers [or screws] are engaged.

(4) Small boats would not be operated at such a speed as to make
collisions with whales likely.  When weather conditions require,
such as when visibility drops, vessels would adjust speed
accordingly to avoid the likelihood of injury to whales.
                         - 7 -

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                                  REFERENCES


Braham, H.W.,  Fraker,  M.A.,  and Krogman,  B.D.,  1980.   Spring migration of
    the western Arctic population of bowhead whales,  Mar.  Fish.  Rev.
    42(9-10):36-46.

Braham, H.W.,  and Krogman,  B.D., 1977.   Population Biology of the Bowhead
    (Balaena mysticetus) and Beluga (Delphinapterus leucas) Whale in  the
    Bering, Chukchi and Beaufort Seas.   National  Marine Fisheries Service,
    National Marine Mammal  Laboratory,  Northwest  and Alaska Fisheries Center.
    Processed Report.  28 pp.

Cowles, C.J.,  1981.  Biological Assessment for Endangered Whales of the Arctic
    Region with Respect to Proposed Offshore Oil  and Gas Exploration.  Bureau
    of Land Management, Alaska OCS Office.  42 pp.

Dames & Moore, 1983.  Environmental Baseline Studies, Red Dog Project.
    Prepared for Cominco Alaska, Inc.,  Anchorage, Alaska.

Johnson, J.H., Braham, H.W., Krogman, B.D., Marquette, W.M., Sonntag, R.M.  and
    Rugh, D.J., 1980.   Research conducted on bowhead whales, June 1979 to June
    1980:  preliminary results:  Int. Whal. Comm., 32nd annual meeting,
    Cambridge, England.  Document SC/32/PS-10.  50 pp.

Maher, W.J., 1960.  Recent records of the California gray whale (Eschrichtius
    glaucus) along the north coast of Alaska.  Arctic 13:257-265.

Marquette, W.M., and Braham, H.W., 1982.  Gray Whale distribution and catch
    by Alaskan eskimos:  a replacement for the bowhead whale?  Arctic 35(3):
    386-394.

Rugh,  D.J., and Cubbage, J.C.,  1980.  Migration of bowhead whales past Cape
    Lisburne, Alaska.  Mar. Fish. Rev. 42(9-10):46-51.

Rugh,  D.J., and Fraker, M.A.,  1981.  Gray Whale  (Eschrichtius robustus)
    sightings in eastern Beaufort Sea.  Arctic 34(2):186-187.
                                   - 8 -

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                   United States Department of the Interior       AUG is 1933
                               FISH AND WILDLIFE SERVICE
REPLY REFER TO:                        101 1 E. TUDOR RD.
                                ANCHORAGE, ALASKA 99503
       cc                             (907)276-3800
                                                                     ti 5  AUG J9fl?
       William M. Riley, EIS Project Officer
       U. S. Environmental  Protection Agency
       1200 Sixth Avenue
       Seattle, Washington   98101

       Dear Mr. Riley:

       This responds to your July  19, 1983 request for  a  list  of threatened  or
       endangered species in the vicinity  of the  Red  Dog  Mine  project.  As
       described in your request,  the project includes  a  triangular  area bounded
       by Cape Thompson on  the northwest,  the Red Dog deposit  on the northeast
       (T.31N, R.I8V/),  Cape Krusenstern to the south  and  the Chukchi Sea to  the
       southv/est.

       Based on the best information currently available  to us,  the  Arctic
       Peregrine Falcon (Falco peregrinus  tundrius) is  the only  listed
       endangered species present  in the project  area.  The endangered  Eskimo
       curlew (Numenius boreal is)  may have historically nested in this  region.
       Now nearly extinct,  the Eskimo curlew has  not  been recorded in Alaska
       since the late 1880's and need not  be considered further  in this
       consultation.  Additionally,  the Service maintains a list of  rare Alaska
       plants which are considered candidates for possible future listing  as
       threatened or endangered.  Although none of the  plants  are known to occur
       in the project area, the January 1983 Baseline Study prepared by Dames
       and Moore, points out that  no vegetation studies have been conducted  in
       the transportation corridors.  If candidate threatened  or endangered
       plants are found within the project area,  they and their  habitats should
       be considered in the environmental  planning process.

       As previously stated in our March 7,  1983  correspondence, Section 7(c) of
       the Endangered Species Act  of 1973, as amended,  requires  Federal agencies
       to prepare a biological assessment  when threatened or endangered species
       have been identified in the vicinity  of a  proposed construction  project
       that is a major  Federal action significantly affecting  the quality  of the
       human environment.   Since the Baseline Study (pages 5-71, 72)
       acknowledges that a  small but significant  number of endangered Peregrine
       Falcons occur in the vicinity of the  transportation corridor, a
       biological assessment for the Red Dog project  is required.  The
       assessment should be completed in conjunction  with the  National
       Environmental Policy Act process and  can be a  section within  the
       environmental impact statement that closely examines the  potential
       effects of all  three components of  the action  on the peregrine.  In
       general, a biological  assessment should include  the following:

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                                                                Page 2


a.  An onsite  inspection  of the  area  affected  by  the  proposed project.

b.  Interviews with recognized experts  on  the  species at issue.

c.  A literature  review to determine  the species  distribution,  habitat
    needs,  and other biological  requirements.

d.  An analysis of possible impacts to  the species, including cumulative
    effects.

e.  An analysis of measures to minimize impacts.

Biological  assessments  may be prepared  by  a designated non-Federal
entity.   If, as a result  of the  assessment, it is concluded that the
proposed activity may affect the Peregrine Falcon,  then a request for
formal consultation should be submitted with a copy of the assessment to
the Regional Office of  the Fish  and Wildlife Service.

We appreciate  your concern for endangered  wildlife.   Questions  or
requests for further assistance  can be  directed to our Endangered Species
Division (907) 786-3435.
                                       Sincerely,
                                     £ Regional  Director
cc:   NAES
     LWRDP

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                                  UNITED STATES DEPARTMENT OF COMMERCE
                                  National Oceanic and Atmospheric Administration
                                  National Marine Fisheries Service
                                  P.O. Box 2668
                                  Juneau, Alaska  99802
September 28, 1983
Mr. William M. Riley
Environmental Evaluation Branch (M/S 443)
Environmental Protection Agency
1200 Sixth Avenue                                   \
Seattle, Washington  98101                          \

Dear Mr. Riley:

This letter is in response to your September 2, 1983,  request for
information concerning rare, threatened, or endangered species under the
jurisdiction of the National Marine Fisheries Service  (NMFS) which occur
in the Chukchi Sea between Cape Thompson and Cape Krusenstern.  NMFS
bears responsibility for two species of endangered whales which frequent
the Chukchi Sea in the area under consideration by the Red Dog Mining
project Environmental Impact Statement (EIS): the bowhead whale (Balaena
mysticetus) and the gray whale (Eschrichtius robustus).

General description of endangered whales occurrence in the Chukchi Sea;

Bowhead whale: The most recent estimate of the number of bowhead whales
in waters adjacent to Alaska is 3857 individuals.  The western Arctic
population of bowhead whales winters in the western and central Bering
Sea (Braham et al., 1980).  The northward (spring) migration is
correlated with the timing of ice breakup, usually beginning in early
April.  Most of the whales move through the Straif Anadyr, passing west
of St. Lawrence Island, when they leave the Bering Sea.   From there,
they generally pass through the Bering Strait west of Big Diomede
Island.  However, the availability of open water determines the bow-
head's migratory path and the whales could possibly use the east side of
the Strait in some years (Braham et al.,1980; Cowles,  1981). Once in the
Chukchi Sea, the bowhead whales follow ice-leads occurring seaward of
the landfast ice.  These leads usually bring them across outer Kotzebue
Sound in a north-easterly direction to the vicinity of Cape Thompson.
Some whales move through a persistent polynya that forms between
Kivalina and Point Hope (Braham et al., 1980).  Open leads are again
followed past Cape Thompson and Point Hope to Cape Lisburne.  In the
vicinity of Cape Lisburne, the population begins to follow the leads
adjacent to the landfast ice on its way to Point Barrow (Braham et al.,
1980; Rugh and Cubbage, 1980).

From Point Barrow, the bowheads travel north-east toward Banks Island in
Canada.  The majority of the whales enter the Canadian Beaufort Sea by

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mid-June, where they spend the summer.  The fall  migration, after
passing Point Barrow, travels west toward Herald and Wrangell  Islands
prior to heading south.  The migration toward the Bering Strait is
believed to occur in the western Chukchi Sea (Braham and Krogman, 1977;
Cowles, 1981).

Gray Whale:  Virtually the entire stock of California gray whales,
estimated at 15,000 to 17,000 individuals, migrates north from their
wintering grounds and enter the Bering Sea in April or May.  By June,
mai.y move through the Bering Strait and enter the Chukchi Sea.  During
the summer, most of the population concentrates in shallow waters around
St. Lawrence Island north to the Chukchi Sea where the grey whale
distribution coincides with high densities of the benthic gammarid
amphipods, en which they forage.  Between July and September,  low
numbers of gray whales regularly move as far east as Point Barrow
(Marquette and Braham, 1982).  A smaller number of gray whales may
occasionally move as far east as the Northwest Territories in  Canada
(Maher, 1960; Johnson et aj_., 1980; Rugh and Fraker, 1981).

If we can be of further assistance, or if additional details on these
endangered whales are needed, please do not hesitate to consult further
with us.

Sincerely,
  bbert W. McVey
Director, Alaska Region

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Literature Cited

Braham, H.W., Fraker, M.A., and Krogman, B.D., 1980.  Spring migration
of the western Arctic population of bowhead whales., Mar. Fish. Rev.
42(9-10):36-46.

Braham, H.W. and Krogman, B.D., 1977.  Population Biology of the Bowhead
(Balena mysticetus) and Beluga (Delphinapterus leucas) Whale in the
Bering, Cnukchi and Beaufort Seas.  National Marine Fisheries Service,
National Marine Mammal Laboratory, Northwest and Alaska Fisheries
Center.  Processed Report.  28 pp.

Cowles, C.J., 1981.  Biological Assessment for Endangered Whales of the
Arctic Region with Respect to Proposed Offshore Oil and Gas Exploration.
Bureau of Land Management, Alaska OCS Office.  42 pp.

Johnson, J.H., Braham, H.W., Krogman, B.D., Marquette, W.M., Sonntag,
R.M. and Rugh, D.J., 1980.  Research conducted on bowhead whales, June
1979 to June 1980: preliminary results: Int. Whal. Comm., 32nd annual
meeting, Cambridge, England.  Document SC/32/PS-10.  50 pp.

Maher, W.J., 1960.  Recent records of the California gray whale
(Eschrichtius glaucus) along the north coast of Alaska.  Arctic
13:257-265.

Marquette, W.M. and Braham, H.W., 1982.  Gray whale distribution and
catch by Alaskan eskimos: a replacement for the bowhead whale?  Arctic
35(3):  386-394.

Rugh, D.J. and Cubbage, J.C., 1980.  Migration of bowhead whales past
Cape Lisburne, Alaska.  Mar. Fish. Rev. 42(9-10):46-51.

Rugh, D.J. and Fraker, M.A., 1981.    ay whale (Eschrichtius robustus)
sightings in eastern Beaufort Sea.  Arctic 34(2):186-187.

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                     United States Department of the Interior
                                 FISH AND WILDLIFE SERVICE
IN REPLY REFER TO:                        101 1 E. TUDOR RD.
                                  ANCHORAGE, ALASKA 99503
         SE                              (907) 276-3800

         William M. Riley, EIS Project Officer                       ^      ,  ,GC^
         U.  S. Environmental Protection Agency                       '^ k* J " '
         1200  Sixth Avenue
         Seattle, Washington  98101

         Dear  Mr. Riley:

         This  responds to your request for comments on EPA's Biological Assessment
         (BA)  for the Red Dog Mine Project.  The BA was initiated as a result of
         our August 15, 1983, letter to you indicating the occurrence of the
         endangered Arctic peregrine falcon within the proposed project area.

         Section 7(c) of the Endangered Species Act of 1973, as amended, requires
         Federal agencies to prepare a BA when threatened or endangered species
         occur in the vicinity of a proposed construction project that is a major
         Federal action significantly affecting the quality of the human
         environment.  The August 15 letter further identified what a BA should
         entail.  Specifically:

            a.   An onsite inspection of the area affected by the proposed
                 project.

            b.   Interviews with recognizea experts on the species at issue.

            c.   A literature review to determine the species distribution,
                 habitat needs, and other biological requirements.

            d.   An analysis of possible impacts to the species, including
                 cumulative effects.

            e.   An analysis of measures to minimize impacts.

         The BA, as written, satisfies items a, b, and c above.  It is deficient,
         however, relative to d and e.

         Prerequisite to an analysis of possible impacts (d) is a project
         description.  This could be accomplished by including a description of
         the various components of the project in the BA or by referring to the
         appropriate sections of the Environmental Impact Statement (EIS).  A map
         of  the project area would also be useful.  Perhaps this too could be
         accomplished by reference to the EIS.
                                                                        FEB
                                                                   ENVIRONMENTAL EVALUATION
                                                                           BRANCM

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Each project component which may directly or indirectly affect the Arctic
peregrine on either a short or long-term basis should be addressed and
the specific area of conflict identified.  Examples of potential impacts
include: greater frequency of low-flying aircraft,  increased recreational
use of the area as a result of improved access, changes in the prey base
brought on by alteration of vegetation, and use of  chemical insecticides.

Once potential conflicts have been identified, means of avoiding or
minimizing the impacts (e) should be discussed.  At this point in time,
we do not believe your analysis is thorough enough  to support your
conclusion that the Red Dog Mine project, with its  associated
transportation corridors and other developments, will not affect the
endangered Arctic peregrine falcon.

If measures are taken to avoid all conflicts,  the project will obviously
have no effect on endangered species and formal consultation will not be
required.  If conflicts remain, however, endangered species may be
affected and formal consultation will be necessary.

Questions regarding these comments may be directed  to our Endangered
Species Division at (907) 786-3435.  Thank you for  the opportunity to
review the BA and for your cooperation in protecting endangered wildlife.
                                       Sincerely,

-------
         U. S.  ENVIRONMENTAL  PROTECTION  AGENCY

                               R E G I O N   X

       TJ                   1200SIXTHAVENUE

        |              SEATTLE, WASHINGTON  98101
REPLY TO
ATTN OF:     M/j 443


   CEB 14 i924

  Robert E. Putz
  Director, Alaska Region
  U.S. Fish and Wildlife Service
  1011 E. Tudor Road
  Anchorage, Alaska  99503

  Dear Mr. Putz:

  Thank you for your January 30, 1984, comments on the Biological  Assessment
  prepared for the Red Dog Mine Project.  The Assessment has been  modified
  to reflect your concerns related principally to potential  indirect project
  impacts on the peregrine falcon.

  As the Biological Assessment now references appropriate sections of the
  project EIS, I trust that having the Draft EIS in hand will help clarify
  the small potential for disturbance to peregrine falcons.   The Draft EIS
  will be distributed in early March 1984.  We will be happy to work with
  you to provide any additional information you feel should  be included in
  the Biological Assessment.

  Sincerely,
  William M. Riley
  EIS Project Officer

  cc:  Dennis Money, USFWS w/attachment
       Robin West, USFWS w/attachment
       Harry Noah, Cominco w/attachment

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        	Appendix 4
Proposed NPDES Permits

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       PROPOSED FINAL



      NPDES PERMIT FOR



DISCHARGES FROM THE TAILINGS



   IMPOUNDMENT WASTEWATER



     TREATMENT FACILITY

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                                                Permit  No.:  AK-003865-2
                                                Application No.:  AK-003865-2
                    AUTHORIZATION  TO  DISCHARGE UNDER THE
              NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
     In compliance with the provisions  of the Federal Water  Pollution Control
Act,  as amended,  (33 U.S.C. Section 1251 et seq; the "Act"),
                        COMINCO ALASKA INCORPORATED
is authorized  to  discharge from a facility located 82 miles  north of Kotzebue,
Alaska to  receiving waters named Red Dog Creek in accordance with the
discharge  point,  effluent limitations,  monitoring requirements  and other
conditions set forth herein.
     This  permit  shall become effective
     This  permit  and the authorization to discharge shall expire  at midnight,
         (five years from the effective date).
Signed this        day of
                                                   DRAFT
                                          Director, Water Division,  Region 10
                                          U.S.  Environmental  Protection Agency

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                                                  Page 2 of 19
                                                  Permit No.:  AK-003865-2


                              TABLE OF CONTENTS

Cover Sheet--Issuance and Expiration Dates

I.    Effluent Limitations and Monitoring Requirements

     A.  Specific Limitations and Monitoring Requirements
     B.  Receiving Water Monitoring Program
     C.  Biomonitoring Program
     D.  Precipitation and Evaporation Monitoring Program
     E.  Best Management Practices
     F.  Definitions

II.   Monitoring, Recording and Reporting Requirements

     A.  Representative Sampling
     B.  Monitoring Procedures
     C.  Penalties for Tampering
     D.  Reporting of Monitoring Results
     E.  Compliance Schedules
     F.  Additional Monitoring by the Permittee
     G.  Records Contents
     H.  Retention of Records
     I.  Twenty-four Hour Notice of Noncompliance Reporting
     0.  Other Noncompliance Reporting
     K.  Inspection and Entry

III.  Compliance Responsibilities

     A.  Duty to Comply
     B.  Penalties for Violations of Permit Conditions
     C.  Need to Halt or Reduce not a Defense
     D.  Duty to Mitigate
     E.  Proper Operation and Maintenance
     F.  Removed Substances
     G.  Bypass of Treatment Facilities
     H.  Upset Conditions
     I.  Toxic Pollutants

IV.   General  Requirements

     A.  Changes 1n Discharge of Toxic Substances
     B.  PIanned Changes
     C.  Permit Actions
     D.  Duty to Reapply
     E.  Duty to Provide Information
     F.  Other Information
     G.  Signatory Requirements
     H.  Penalties for Falsification of Reports
     I.  Availability of Reports
     J.  Oil  and Hazardous Substance Liability
     K.  Property Rights                                   r\f^ A f*V
     L.  Severability                                      IJK£&£* G
         Mf    r-                                            mM&r m mw  w~*  w
         Transfers

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                                                 Page 3 of 19
                                                 Permit No.:   AK-003865-2
I.    Effluent  Limitations  and Monitoring Requirements

     A.   Specific  Limitations and Monitoring Requirements

         1.   The following effluent  limitations and monitoring requirements
shall apply  to all  discharges from the  tailings impoundment wastewater
treatment facility (outfall  001):
       Effluent
   Characteristics
Effluent Limitations
    Flow (mgd)
    Copper (mg/1)
    Zinc (mg/1)
    Lead (mg/1)
    Cadmium  (mg/1)
    Mercury  (mg/1)
    Total Suspended
      Solids  (mg/1)
    PH
    Temperature
                          Daily
                         Maximum
   7.1
   0.3
   1.5
   0.6
   0.10
   0.002
             30 Day
             Average
5.4
0.15
0.75
0.3
0.05
0.001
             Mom'toring Reguirements

             Frequency    Sample, Type
                (During Discharge)
   30.0        20.0
(see  paragraph 4. below)
    N/A        N/A
Continuous
Weekly
Weekly
Weekly
Weekly
Weekly

Weekly
Daily
Daily
Recorded
Grab
Grab
Grab
Grab
Grab
24 hr.
Composite
Grab
Grab
          2.   Discharges are only permitted during the months of May through
          October.

          3.   There  shall  be no discharge of floating solids or oily wastes
          which  produce  a  sheen on the surface of the receiving water.

          4.   The  pH shall  not be less than 6.0 standard units nor greater
          than 10.5  standard units.

          5.   All  discharges shall comply with Alaska Water Quality Standards
          (18 AAC10).

      B.  Receiving  Water, Monitoring  Program

          1.    Ambient water quality  monitoring shall be performed at two (2)
 stations on Ikalukrok Creek.   Data collection shall  occur  seasonally from
 break-up (mid May)  to freeze  up  (mid October).   The  initial three years_of
 monitoring prior to discharge beginning the  effective  date .of  this permit will
 be used to expand the existing  baseline data.  Subsequent  monitoring following
 the initiation of discharge from the tailings  impoundment  wastewater treatment
 facility will be used to characterize impacts of the operation  on the Wulik
 River  drainage.

               Station identification codes correspond  to those identified in
 the Dames and Moore  "Environmental  Baseline Studies  -  Red  Dog  Project"  as
 •f o 11 ows:

          Site  9:   Ikalukrok Creek above confluence  with Red  Dog Creek
          Site 73:   Ikalukrok Creek downstream of confluence with Red Dog Creek
                                                          DRAFT

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                                                 Page 4 of 19
                                                 Permit No.:  AK-003865-2
    The following  table identifies parameters  and  frequency of collection  for
both receiving  water  and b'iomonitoring programs:
    Flow
    Conductivity
    Suspended Solids
    Turbidity
    Cadmium (total)
    Iron
    Lead
    Zinc
    Aluminum
    Hardness
    Temperature
    Dissolved Oxygen
    PH

    Frequency Codes:
     Site 73        Site 9

      b              a
      b              b
      b              b
      b              b
      b              b
      b              b
      b              b
      b              b
      b              b
      b              b
      b              b
      b              b
      b              b

a)  continuous
b)  weekly  (grab)
c)  daily  (grab)
                                                         Flow-thru
                                                     Biomonitoring Facility
a
a
c
c
a
a
a
a
a
a
a
c
c
         2.   A quality assurance plan shall be developed,  the primary purpose
              of which shall  be to assist in explaining data  anomalies, if and
              when they occur.  The quality assurance plan  shall also provide
              information on  sampling and laboratory analytical techniques.
              The plan shall  include activities such as replicates on ten
              percent of samples, analyses of sample blanks to identify
              contaminated sampling equipment and spiked samples for metals
              analysis.
                                                      DRAFT

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                                                 Page 5 of 19
                                                 Permit No.:  AK-003865-2
     C.   Biomonitoring  Program
    To provide  an  early warning  system  as  a  part of the water treatment plant
process control,  the permittee will  be  required to develop, subject to State
approval,  a continuous  flow-thru biomonitoring facility which meets the
following  criteria:

         1.   The  biomonitoring  facility  shall provide for the maintenance of
cold-water fish specie(s).   Control  and test organisms shall be continuously
subjected  to water which is a dilution  of  the effluent with local surface
waters.  Effluent  to surface water dilution  ratios shall  produce a surrogate
of the effluent's  ultimate  dilution  in  the Ikalukrok, except that the dilution
shall be 10% more  concentrated than  would  be expected as  a safety margin.
This will  be accomplished using  realtime  flow data from the Ikalukrok above
the confluence of  Red Dog Creek  and  realtime flow data from the plant
effluent.   The surrogate solution shall be monitored for  pH, conductivity,
temperature and divalent cations.

         2.   The test organisms shall  be  continuously or frequently observed
for symptoms of distress and mortality.  TYPE I  and  TYPE  II warning levels are
recommended.  The TYPE I warning level  is  defined as symptoms of distress
related to engineering failure of the biomonitoring  facility.  A TYPE  II
warning level is defined as an effluent caused  distress  incident.
Observations of distress (either TYPE I or TYPE  II)  will  result in necessary
actions being taken by personnel to prevent distress  in  the monitored
organisms.

         3.   Notification of ADEC within 24 hours  from  the time of occurrence
of  a  TYPE  II warning level  will  be required, including  information on  pH,
conductivity, temperature and divalent cations  at  the  time of the  incident.
Any remedial actions taken to mitigate the TYPE II  incident will  also  be
communicated.

         4.   Fish which have exhibited symptoms of distress, whether  TYPE  I
or  TYPE II,  shall be replaced with fresh  equivalent stock, maintained  for that
purpose.

         5.   This  biomonitoring facility shall  be  tested,  verified  and
operational  when discharge commences from the tailings  impoundment water
treatment  facility.

      D.  Precipitation  and Evaporation Monitoring Program

          1.   The permittee  shall establish monitoring stations  at  the mine
site for determining the annual  precipitation and annual  evaporation  rates.
This monitoring program  shall begin on the  effective date of  this  permit  and
end on the expiration  date.

          2.    The permittee  shall submit  to  EPA the monitoring  results
 annually.   The  first report  is  due one year  from the effective  date  of this
•permit.
                                                        DRAFT

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                                            Page  6 of 19
                                            Permit No.:  AK-003865-2
E.   Best Management  Practices

    1.    The  permittee shall develop a Best Management Practices (BMP)
         program  in  accordance with good engineering  practices and the
         following conditions:

         a.   The  BMP program shall:

              (1) Be documented in narrative form,  and shall  include any
              necessary plot plans, drawings or maps;

              (2) Establish specific objectives for the  control of toxic
              and hazardous pollutants.

                   (i)    Each facility component or system  shall be
                   examined for its potential for causing a release of
                   toxic  or hazardous pollutants to waters  of the United
                   States due to equipment failure, improper operation,
                   natural phenomena such as rain or snowfall, etc.

                   (ii)   Where experience indicates a reasonable
                   potential for equipment failure (e.g. a  tank overflow
                   or leakage), natural condition (e.g.  precipitation),
                   or other circumstances to result in significant
                   amounts  of toxic or  hazardous pollutants reaching
                   surface  waters,  the  program should include a
                   prediction of the direction, rate of  flow and  total
                   quantity of toxic or hazardous pollutants which  could
                   be discharged from  the facility as a  result of each
                   condition  or circumstance;

               (3) Establish specific best management practices to meet
               the objectives  identified under  paragraph a.(2) of  this
               section, addressing  each  component or system capable  of
               causing a release of toxic or  hazardous pollutants  to the
               waters of the United States.
                                                        DRAFT

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                                       Page 7 of 19
                                       Permit No.:  AK-003865-2
         (4) The BMP program:
              (i)   May reflect  requirements for Spill Prevention
              Control  and Countermeasure  (SPCC Plan) under Section
              311 of the Act and 40  CFR Part 112, and may
              incorporate any part of such plans into the BMP
              program by reference;

              (ii)  Shall assure the proper management of solid and
              hazardous waste in accordance with regulations
              promulgated under  the  Solid Waste Disposal Act, as
              amended by the Resource Conservation and Recovery Act
              of 1976 (RCRA)(40  U.S.C.  6901 et seq).  Management
              practices required under  RCRA regulations shall be
              expressly incorporated into the BMP program; and

              (iii) Shall address the following points for the
              ancillary activities:

                    (A) Statement of Policy;
                    (B) Spill Control  Committee;
                    (C) Material Inventory;
                    (D) Material Compatibility;
                    (E)  Employee Training;
                      F)  Reporting and Notification  Procedures;
                      G)  Visual  Inspections;
                    (H)  Preventive Maintenance;
                    (I)  Housekeeping; and
                    (J)  Security.

          [Ancillary activities  include but are  not  limited  to:
          Materials  storage  areas; in-plant transfer,  process and
          material  handling  areas; loading and unloading  operations;
          plant  site runoff;  and  sludge and waste  disposal  areas.]

2.   The permittee shall  submit  this BMP  program to  both  EPA and ADEC
     for approval  within  eight months of  the effective date  of this
     permit.

3.   The BMP  program shall  be fully  implemented- as soon as possible
     but no later than one  year  after the effective  date  of  this
     permit or upon commencement of  facility construction activities,
     whichever occurs  first.

4.   The permittee shall  amend the BMP program whenever there is a
     change in the facility design,  construction,  operations, or
     maintenance which materially affects the facility's  potential
     for discharge of  significant amounts of hazardous or toxic
     pollutants into the waters  of the United States.
                                                    DRAFT

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                                            Page 8 of 19
                                            Permit No.:  AK-003865-2
     5.   If  the BMP  program proves to be ineffective in achieving the
         general  objective of preventing the release of significant
         amounts  of  toxic or hazardous pollutants to those waters and the
         specific objectives and  requirements under paragraph l.a. of
         this  section,  the permit and/or the BMP program shall be
         subjected to modification to incorporate the revised BMP
         requirements.

    6.    Upon  approval,  the terms and conditions of the BMP program shall
         become  part of this permit.

    7.    The permittee  shall maintain a description of the BMP program  at
         the facility and shall make the description available to the
         Director upon  request.

F.  Definitions

    1.    "30 Day Average" shall mean  the total  units discharged  during  a
         monitoring month divided by  the number of  days in that  period
         that the production  or commercial  facility was operating.  Where
         less than daily sampling is  required  by this  permit,  this
         average shall  be  determined  by  the summation  of  the  measured
         daily discharges  divided by  the number of  days during  the
         monitoring month  when the  measurements were made.

    2.   "Daily Maximum" shall mean the  maximum value  attained on any  day
         in a given monitoring month.

    3.   "Monitoring Month" shall mean the period consisting of the
         calendar weeks which end in a given calendar  month.

    4.   A  "24 hour composite" ("24 hr.  Comp.") sample shall  mean a
         flow-proportioned mixture of not less than 4 discrete aliquots.
         Each aliquot  shall be a grab sample of not less  than 100 ml  and
         shall be collected and stored in'accordance with procedures
         prescribed in  the most recent edition of Standard Methods for
         the  Examination £f Water and Wastewater.

     5.   A  "Grab"  sample is a single sample or measurement taken at a
         specific time or over as short a period of time as  is feasible.

     6.   "Upset" means an exceptional incident  in which there is
         unintentional  and temporary noncompliance with technology-based
         permit  effluent limitations because of factors beyond the
          reasonable control of the permittee.   An  upset does not include
         noncompliance to the extent caused by operational error,
          improperly designed  treatment facilities, inadequate treatment
          facilities,  lack of  preventive maintenance, or careless or
          improper operation.

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                                                 Page  9 of  19
                                                 Permit No.:  AK-003865-2
        7.    "Bypass" means the intentional  diversion  of waste  streams from
              any portion of a treatment facility.

        8.    "Severe property damage" means  substantial  physical damage to
              property, damage to the treatment facilities  which  causes them
              to become inoperable, or substantial  and  permanent  loss of
              natural resources which can reasonably be expected  to occur in
              the absence of a bypass.  Severe property damage does not mean
              economic loss caused by delays  in production.

II.   Monitoring, Recording and Reporting Requirements

     A.   Representative Sampling

         Samples taken in compliance with the monitoring requirements
         established  under  Part  I. A. shall be collected from the effluent
         stream prior to discharge into the receiving waters.  Samples  and
         measurements shall be representative of the volume and  nature  of the
         monitored  discharge.

     B.   Monitoring Procedures

         Monitoring must be conducted according to test procedures  approved
         under 40  CFR Part  136,  unless other test procedures have been
         specified  in this  permit.

     C.   Penalties  for  Tampering

         The Clean Water Act  provides that any person who falsifies,  tampers
         with or  knowingly  renders inaccurate, any monitoring device or method
         required  to be maintained under  this  permit shall,  upon conviction,
         be punished by  a fine  of not more than $10,000 per  violation,  or by
         imprisonment for  not more than  6 months per violation,  or by both.

     D.   Reporting of Monitoring Results

         Monitoring results shall be summarized each month on Discharge
         Monitoring Report  (DMR) form (EPA No.  3320-1).  The reports shall  be
         submitted monthly and  are to be  postmarked  by  the 10th day of the
         following month.   Legible copies of  these,  and all  other reports,
         shall be  signed and certified  in accordance with  the requirements of
         Part  IV.-G. Signatory  Requirements,  and submitted to the Director,
         Water Division and the State agency  at the  following addresses:

         original  to:      United States  Environmental  Protection Agency
                           Region 10
                           1200 Sixth Avenue
                           Seattle, "Washington 98101
                           Attn:  Water Compliance Section,  Mail  Stop 513

                                                             DRAFT

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                                             Page  10 of  19
                                             Remit No.:  AK-003865-2
    copy to:           Alaska  Department  of  Environmental  Conservation
                      Northern  Regional  Office
                      675  7th  Avenue
                      P.O.  Box  1601
                      Fairbanks,  Alaska   99707
E.   Compliance Schedules
    Reports of compliance or noncompliance with,  or any progress  reports
    on interim and final requirements  contained in any Compliance
    Schedule of this permit (Part I.  A.) shall  be submitted no later than
    10 days following each schedule date.
F.   Additional Monitoring by the Permittee
    If the permittee monitors any pollutant more frequently than  required
    by this permit, using test procedures approved under 40 CFR 136 or as
    specified in this permit, the results of this monitoring shall be
    included in the calculation and reporting of the data submitted in
    the DMR.  Such increased frequency shall also be indicated.
6.   Records Contents
    Records of monitoring information shall include:
    1.  The date, exact place, and time of sampling or measurements;
    2.  The individual(s) who performed the sampling or measurements;
    3.  The date(s) analyses were performed;
    4.  The individual(s) who performed the analyses;
    5.  The analytical  techniques or methods used; and
    6.  The results of  such  analyses.

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                                            Page 11  of  19
                                            Permit No.:  AK-003865-2
H.   Retention  of  Records

    The permittee shall retain records of all monitoring information,
    including  all  calibration and maintenance records and all  original
    strip chart  recordings for continuous monitoring instrumentation,
    copies of  all  reports required by this permit, and records of  all
    data used  to  complete the application for this permit,  for a period
    of at least  3 years from the date of the sample, measurement,  report
    or application.   This period may be extended by request of the
    Director at  any  time.

I.   Twenty-four  Hour Notice of Noncompliance Reporting

    1.  The following occurrences of noncompliance shall be reported by
    telephone  within 24 hours from the time the permittee becomes aware
    of the circumstances:

         a.  Any noncompliance which may endanger health or the
         environment.

         b.  Any unanticipated bypass which exceeds any effluent
         limitations in the permit.   (See  Part  III. G. Bypass of
         Treatment Facilities.)

         c.  Any upset which  exceeds  any effluent limitation  in the
         pertni t.  (See Part  III.  H.  Upset  Conditions.)

         d.  Violation of a maximum  daily  discharge  limitation  for any of
         the pollutants  listed  in  the permit to be  reported within 24
         hours.

    2.   A written submission  shall  also  be provided within 5  days of the
    time that the permittee  becomes  aware  of the  circumstances.   The
    written description shall  contain:

          a.  A description of the noncompliance and  its  cause;

          b.  The  period of noncompliance,  including  exact  dates and times;

          c.  The  estimated time noncompliance  is  expected  to  continue if
          it has  not  been corrected;  and

          d.  Steps taken or planned to  reduce,  eliminate,  and prevent
          reoccurrence of the noncompliance.

     3.   The  Director may waive the written report  on a case-by-case
          basis if the oral report has been received within 24 hours by
          the Water  Compliance Section in Seattle, Washington  by phone,
          (206) 442-1213.
                                                          DRAFT

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                                                 Page 12 of 19
                                                 Permit No.:  AK-003865-2
        4.   Reports shall be submitted to the addresses in Part II. D.
             Reporting of Monitoring Results.

    J.  Other Noncompliance Reporting

        Instances of noncompliance not required to be reported within 24
        hours shall be reported at the time that monitoring reports for
        Part II. D. are submitted.  The reports shall contain the information
        listed in Part II. I. 2.

    K.  Inspection and Entry

        The permittee shall allow the Director, or an authorized
        representative, upon presentation of credentials and other documents
        as may be required by law, to:

        1.   Enter upon the permittee's premises where  a regulated facility
             or  activity  is located or conducted, or where records must be
             kept under the conditions of this permit.

        2.   Have access  to and copy, at reasonable times, any records that
             must be kept under the conditions of this  permit;

        3.   Inspect at reasonable times any facilities; equipment  (including
             monitoring and control equipment), practices, or operations
             regulated or required under this permit, and

        4.   Sample or monitor  at reasonable times, for the purpose of
             assuring  permit compliance or  as otherwise authorized  by  the
             Clean  Water  Act, any substances or parameters at any  location.


III.  Compliance  Responsibilities

     A.   Duty to  Comply

         The  permittee  must  comply with  all  conditions of  this permit.   Any
         permit  noncompliance  constitutes  a  violation  of the  Clean  Water  Act
         and is  grounds for  enforcement  action;  for  permit  termination,
         revocation  and reissuance,  or modification;  or  for denial  of  a permit
         renewal  application.   The  permittee shall  give  advance  notice  to the
         Director of any planned changes  in  the  permitted  facility  or  activity
         which  may result in noncompliance  with  permit  requirements.

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                                            Page 13 of 19
                                            Permit No.:  AK-003865-2
B.  Penalties for Violations of  Permit Conditions

    The Clean Water Act  provides that any person who violates a permit
    condition implementing  sections 301, 302, 306, 307, 308, 318, or 405
    of the Clean Water Act  is  subject to a civil penalty not to exceed
    $10,000 per day of such violation.  Any person who willfully or
    negligently violates permit  conditions implementing sections 301,
    302, 306, 307,  or 308 of the Clean Water Act is subject to a fine of
    not less than $2,500, nor  more than $25,000 per day of violation, or
    by imprisonment for  not more than 1-year, or both.  Except as
    provided in permit conditions on Part III.  G. Bypass of Treatment
    Facilities and  Part  III.   H. Upset Conditions, nothing in this permit
    shall be construed to relieve the permittee of the civil or criminal
    penalties for noncompliance.

C.  Need to Halt or Reduce  not a Defense

    It shall not be a defense  for a permittee in an enforcement action
    that it would have been necessary to halt or reduce the permitted*
    activity in order to maintain compliance with the conditions of this
    permit.

D.  Duty to Mitigate

    The permittee shall  take  all reasonable  steps to minimize or prevent
    any discharge in violation of this permit which has a likelihood of
    adversely affecting  human  health or the  environment.

E.  Proper Operation and Maintenance

    The permittee shall  at  all times properly operate and maintain  all
    facilities and systems  of  treatment and  control  (and related
    appurtenances)  which are  installed or used  by the permittee to
    achieve compliance with the  conditions of this permit.   Proper
    operation and maintenance  includes effective  performance, adequate
    funding, adequate operator staffing and  training, and adequate
    laboratory and process  controls,  including  appropriate  quality
    assurance procedures.  This  provision requires the operation of
    backup or auxiliary facilities  or  similar systems only  when necessary
    to  achieve compliance with the  conditions of  the  permit.

F.  Removed  Substances

    Solids,  sludges, filter backwash,  or other  pollutants removed  in  the
    course of treatment or  control  of  wastewaters  shall be  disposed  of  in
    a  manner such  as to prevent  any pollutant from such material from
    entering navigable waters.
                                                     DRAFT

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                                            Page 14 of  19
                                            Permit No.:  AK-003865-2
G.   Bypass of Treatment  Facilities:

    1.    Bypass not  exceeding  limitations; the permittee may allow  any
         bypass to occur which does not cause effluent limitations  to be
         exceeded, but only  if it  also is for essential  maintenance to
         assure efficient operation.  These bypasses are not subject to
         the provisions  of paragraphs 2. and 3. of this  section.

    2.   Notice:

         a.  Anticipated bypass; if the permittee knows  in advance  of the
         need for a  bypass,  it shall submit prior notice, if possible at
         least 10 days before  the  date of the bypass.

         b.  Unanticipated bypass; the permittee shall submit notice of
         an unanticipated bypass as required under Part  II. I.
         Twenty-Four Hour Reporting.

    3.    Prohibition of  bypass:

         a.  Bypass  is  prohibited  and the Director may take enforcement
         action against  a permittee for a bypass, unless:

               (1) The bypass was unavoidable to prevent loss of life,
              personal  injury,  or  severe  property damage;

               (2) There  were no  feasible  alternatives to the bypass, such
               as the use of  auxiliary treatment facilities, retention of
               untreated wastes,  or maintenance during normal periods of
               equipment downtime.   This condition is  not satisfied if the
               permittee could have installed  adequate backup equipment to
               prevent a bypass which occurred  during  normal periods of
               equipment downtime or  preventive maintenance; and

               (3) The permittee submitted notices as  required under
               paragraph 2.  of this section.

          b.   The Director may approve  an  anticipated  bypass,  after
          considering its adverse effects,  if  the  Director  determines that
          it  will meet the three conditions  listed above  in paragraph 3.a.
          of  this section.
                                                    DRAFT

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                                                Page 15 of 19
                                                Permit No.:   AK-003865-2
    H.   Upset Conditions:
        1.    Effect of an upset;  an upset constitutes an affirmative defense
             to an action brought for noncompliance with such
             technology-based  permit effluent limitations if the requirements
             of paragraph 2. of this section are met.  No determination made
             during administrative review of claims that noncompliance was
             caused by upset,  and before an action for noncompliance, is
             final administrative action subject to judicial review.

        2.    Conditions necessary for a demonstration of upset; a permittee
             who wishes to establish the affirmative defense of upset shall
             demonstrate, through properly signed, contemporaneous operating
             logs, or other relevant evidence that:

             a.  An upset occurred and that the permittee can identify the
             specific cause(s) of the upset;

             b.  The permitted facility was at the time being properly
             operated; and

             c.  The permittee submitted notice of the upset as required
             under Part II. I. Twenty-Four  Hour Notice of Noncompliance
             Reporting.

             d.  The permittee complied with  any  remedial measures  required
             under Part  III. D.  Duty to Mitigate.

        3.   Burden of proof;  in any enforcement  proceeding, the  permittee
             seeking to establish the  occurrence  of  an  upset has  the  burden
             of proof.

     I.  Toxic  Pollutants

        The  permittee  shall comply with  effluent  standards  or  prohibitions
        established under  Section 307(a)  of the  Clean Water Act for toxic
        pollutants within  the time provided in  the  regulations  that establish
        those  standards  or prohibitions,  even if  the permit has not yet been
        modified  to incorporate the requirement.

IV.   GENERAL  REQUIREMENTS

     A.   Changes  in  Discharge  of Toxic Substances

         Notification  shall be provided to the Director  as  soon as the
        permittee  knows  of, or has reason to believe:

         1.   That  any  activity has occurred or will  occur which would result
         in  the discharge of any toxic pollutant which is not limited in the
         permit,  if that  discharge will exceed the highest of the  following
         "notification levels":
                                                       DRAFT

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                                            Page  16 of  19
                                            Remit No.:  AK-003865-2
         a.  One hundred micrograms per liter (100  ug/1);

         b.  Two hundred micrograms per liter (200  ug/1) for  acrolein and
         acrylonitrile; five hundred micrograms  per liter  (500 ug/1) for
         2,  4-dinitrophenol and for 2-methyl-4,  6-dinitrophenol; and one
         milligram per liter (1 mg/1) for antimony;

         c.  Five  (5) times the maximum concentration  value reported for
         that  pollutant in the permit application;

    2.    That  the  permittee has begun or expects to begin  to  use or
         manufacture as an intermediate or final product or byproduct any
         toxic pollutant which was not reported  in  the permit application.

B.  Planned  Changes

    The permittee  shall give notice to the Director, as soon  as  possible,
    of any planned physical alterations or additions to the permitted
    facility.   The permittee shall also give advance notice of any
    planned  changes  in the permitted facility or activity  which  may
    result in  noncompliance with  permit requirements.

C.  Permit Actions

    This permit may be modified,  revoked  and reissued, or  terminated for
    cause.  The filing of  a request  by the permittee for a permit
    modification,  revocation  and  reissuance, or termination,  or a
    notification of planned changes  or anticipated noncompliance,  does
    not  stay  any permit  condition.

D.  Duty to Reapply

    If the permittee wishes to continue  an activity regulated by this
    permit after the expiration date of  this permit,  the permittee must
    apply for and obtain a new permit.    The application should be
    submitted at least 180 days before the expiration  date of this permit.

 E.  Duty to Provide Information

    The  permittee shall  furnish to the Director, within a reasonable
    time, any information which the Director may request to  determine
    whether cause exists for modifying,  revoking and  reissuing, or
    terminating this permit,  or to determine compliance with this
    permit.   The  permittee shall also furnish to the  Director, upon
    request,  copies of records required to  be kept by this permit.
                                                    DRAFT

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                                            Page 17 of  19
                                            Permit No.:  AK-003865-2
F.   Other Information

    When the permittee  becomes aware that it failed to submit any
    relevant facts  in a permit application, or submitted incorrect
    information in  a permit  application or any report to the Director,  it
    shall promptly  submit  such facts or information.

G.   Signatory Requirements

    All applications, reports or  information submitted to the Director
    shall be signed and certified.

    1.  All permit applications shall  be  signed as follows:

         a.  For a corporation:   by a  responsible corporate officer;

         b.  For a partnership  or sole proprietorship:  by a general
         partner or the proprietor, respectively.

         c.  For a municipality,  State,  Federal, or  other public agency:
         by either a principal  executive  officer or  ranking elected
         official.

    2.   All reports required by  the permit  and other  information
         requested by the Director shall  be  signed  by  a person described
         above or by a duly authorized representative  only if:

         a.  The authorization  is made in writing  by a person described
         above and submitted to the Director.

         b.  The authorization  specified either an  individual or a
         position having  responsibility for  the overall operation of the
         regulated facility or  activity , such as  the  position of plant
         manager, operator of a well or a well field,  superintendent, or
         position of equivalent responsibility.   (A duly  authorized
         representative may thus be either a named individual or any
         individual occupying a named position.)

     3.   Changes to authorization.  If an authorization under paragraph
          IV.  G.  2.  is  no  longer accurate because  a different individual
         or position has  responsibility for the overall  operation of the
         facility,  a new  authorization satisfying  the requirements  of
          paragraph  IV.  G. 2. must  be submitted to  the Director  prior to
         or together with any reports, information, or applications to  be
          signed  by an  authorized representative.
                                                     DRAFT

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                                            Page 18 of 19
                                            Remit No.:   AK-003865-2
    4.    Certification.  Any person signing a document under this section
         shall make the following certification:

         "I  certify under penalty of law that this document and all
         attachments were prepared under my direction or supervision in
         accordance with a system designed to assure that qualified
         personnel properly gather and evaluate the information
         submitted.  Based on my inquiry of the person or persons who
         manage  the system, or those persons directly responsible for
         gathering the information, the information submitted is, to  the
         best of my knowledge and belief, true, accurate, and complete.
         I am aware that there- are significant penalties for submitting
         false information, including the possibility of fine and
         imprisonment for knowing violations."

H.  Penalties for Falsification of Reports

    The Clean Water Act  provides that any person who knowingly makes any
    false statement,  representation, or certification in any record or
    other document submitted  or required to  be maintained under  this
    permit, including monitoring reports of  compliance or noncompliance
    shall, upon conviction  be punished by  a  fine of not more than $10,000
    per violation, or  by imprisonment for  not more than 6 months per
    violation, or by  both.

I.  Availability of Reports

    Except for data determined  to  be  confidential  under  40  CFR  Part  2,
    all reports prepared in accordance with  the terms of this  permit
    shall be available for  public  inspection at the offices of  the  State
    water pollution control  agency and  the Director.  As required by the
    Act,  permit applications, permits  and  effluent  data  shall  not be
    considered confidential.

J.  Oil  and  Hazardous Substance Liability

    Nothing  in  this permit shall  be construed to  preclude  the  institution
    of  any  legal action or relieve the  permittee  from any  responsibilities,
    liabilities, or penalties to which  the permittee  is  or  may be  subject
    under Section 311 of the Act.

K.  Property Rights

    The issuance  of this permit does not convey any property rights of any
    sort, or any  exclusive privileges,  nor does it authorize any injury to
    private property or any  invasion of personal  rights, nor any
    infringement  of Federal, State or local laws or regulations.
                                                        1RAFT

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                                            Page 19 of 19
                                            Permit No.:  AK-003865-2
L.  Severability

    The provisions of this permit are severable, and if any provision of
    this permit,  or the application of any provision of this permit to
    any circumstance, is held invalid, the application of such provision
    to other circumstances, and the remainder  of this permit, shall not
    be affected thereby.

M.  Transfers

    This permit may be automatically transferred to a new permittee if:

    1.  The current permittee notifies the Director at least 30 days in
    advance of the proposed transfer date;

    2.  The notice includes a written agreement between the existing and
    new permittees containing a specific date  for transfer of permit
    responsibility, coverage, and liability between them; and

    3.  The Director  does  not notify the existing permittee and the
    proposed new  permittee of his or her intent to modify, or revoke and
    reissue the permit.   If this notice is not received, the transfer is
    effective on  the  date  specified in the agreement mentioned in
    paragraph 2.  above.
                                                    DRAFT

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  PROPOSED DRAFT



 NPDES PERMIT FOR



DISCHARGES FROM THE



   PORT FACILITY

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          U.S.  ENVIRONMENTAL  PROTECTION   AGENCY

^eosr^                        REGION  X

                            1200 SIXTH  AVENUE

                       SEATTLE,  WASHINGTON  98101
 "TWO*      Mail  Stop 521

   CERTIFIED MAIL - RETURN RECEIPT REQUESTED

     AUG 2 4  1984

   Doug Lowery,  Regional  Supervisor
   Northern Regional  Office
   Alaska  Department of Environmental  Conservation
   P. 0.  Box 1601
   Fairbanks, Alaska  99707

   Re:   NPDES Permit No.:   AK-004064-9
                           Cominco Alaska  (Port Facility)

   Dear Mr.  Lowery:

   Enclosed for  your use  in completing a certification action is a copy of
   the  National  Pollutant Discharge Elimination System (NPDES) permit which
   EPA  proposes  to  issue.

   Comments that were received  on  the  draft permit have been addressed and
   incorporated  into the  enclosed  permit.   Issuance of the final  permit will
   be contingent on  the completion of  the  statutory requirements of Title XI
   of the  Alaska Lands Conservation Act.   It is expected that the Final
   Environmental  Impact Statement  will  be  released for public review in
   September.

   Sincerely,
   Harold  E.  Geren,  Chief
   Water Permits  and Compliance  Branch

   Enclosure

   cc:  Alaska  Department  of  Environmental  Conservation,  Juneau
       Alaska  Ooerations  Office,  EPA (Anchorage  &  Juneau)
       Bill  mm*  H&&&. HJ$ 443

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               United States Environmental  Protection Agency
                                Region 10
                            1200 Sixth Avenue
                        Seattle, Washington  98101
                              (206) 442-1214

            NOTICE OF PROPOSED ISSUANCE OF  A NATIONAL POLLUTANT
              DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT TO
                DISCHARGE TO WATERS OF THE UNITED STATES,

                      NOTICE OF STATE CERTIFICATION

                                   and

           NOTICE OF STATE DETERMINATION OF CONSISTENCY  WITH THE
                  ALASKA COASTAL ZONE MANAGEMENT PROGRAM


Public Notice No.:  AK-004064-9

Public Notice Issuance  Date:       June 25, 1984
Public Notice Expiration Date:     July 25, 1984

1.   Applicant

     Cominco Al aska
     5660 B. Street
     Anchorage, Alaska   99502

Cominco proposes to operate a port facility for shipping lead and zinc
concentrates from their Red Dog Mine.  The port facility is located  17
miles southeast of Kivalina.  This facility is a new discharger.

Discharges from the port site will be to the Chukchi  Sea.   Chukchi Sea is
classified by the  Alaska Water Quality Standards as classes II
A(i)(ii)(iii), B(i)(ii), C and D for use in agriculture, seafood
processing and industrial water supply, water contact and secondary
recreation, growth and  propagation of fish, shellfish aquatic life and
wild life, and harvesting for consumption of raw mollusks or other raw
aquatic life.

2.   Tentative Determination

The Region 10 Office of the Environmental Protection Agency (EPA) has
tentatively determined  to issue a discharge permit to the above listed
applicant.  However, issuance of the final  permit by  EPA will  be
contingent upon completion of the statutory requirements of Title XI of
the Alaska National Interest Lands Conservation Act.   Accordingly, this
permit cannot be issued unless Cominco is authorized  by the Department of
the Interior, the  President and Congress to construct a mining road
through Cape Krusenstern National Monument to the port site.

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3.   State Certification

This Notice will  also serve as Public Notice of the Intent of the State of
Alaska, Department of Environmental Conservation to consider certifying
that the subject discharge will comply with the applicable provisions of
Sections 208(e),  301, 302, 303, 306 and 307 of the Clean  Water Act.  The
NPDES permit will not be Issued until the certification requirements of
Section 401 have been met.

4.   State Consistency Determination

This Notice will  also serve as Public Notice of the intent of the State of
Alaska, Office of Management and Budget, Division of Governmental
Coordination, to review this action for consistency with  the approved
Alaska Coastal Zone  Management Program.

5.   Public Comments

Persons wishing to comment on the tentative determinations contained in
the proposed permit  or wishing to request that a public hearing be held,
may do so in writing, within 30 days of the date of this  public notice.  A
request for a public hearing shall state the nature of the issues to be
raised as well as the requester's name, address and telephone number.
Comments must be received within this 30 day period to be considered in
the formulation of final determinations regarding the application.  All
comments should include the name, address and telephone number of the
commenter and a concise statement of the exact basis of any comment and
the relevant facts upon which it is based.

All written comments and requests should be submitted to  EPA at the above
address to the attention of the Director, Water Division  M/S 521.

Persons wishing to comment on State Certification should  submit written
comments within this 30 day period to the State of Alaska, Northern
Regional Office,  Alaska Department of Environmental Conservation (ADEC),
P. 0. Box 1601, Fairbanks, Alaska 99707.

Persons wishing to comment on the State Determination of  Consistency with
the Alaska Coastal Zone Management Program should submit  written comments
within this 30 day period, to the State of Alaska, Northern Regional
Office, Office of Management and Budget, Division of Governmental
Coordination, 675 7th Avenue, Station H, Fairbanks, Alaska 99701.
Comments should be addressed to the attention of Alaska Coastal Management
Program Consistency  Review.

6.   Administrative  Record

The proposed NPDES permit and other related documents are on file and may
be inspected and copies made in Room 110 at the above address any time
between 8:30 a.m. and 4:00 p.m., Monday through Friday.  Copies and other
information may be requested by writing to the EPA at the above address to

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the attention of the Water Permits Section  M/S 521, or by calling (206)
442-1214.   This material is also available  from the EPA Alaska Operations
Office,  Room E535, 701 C Street, Anchorage,  Alaska 99513 or EPA Alaska
Operations Office, 3200 Hospital Drive,  Suite 101, Juneau, Alaska 99801.
A copying  machine is available in the Seattle office for public use at a
charge of  20 cents per copy sheet.  There is no charge if the total cost
is less than 25 dollars.

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                               Fact Sheet

              United States Environmental  Protection Agency
                                Region 10
                            1200 Sixth Avenue
                        Seattle, Washington 98101
                             (206) 442-1214
Application No  :   AK-004064-9                          Date: June 25, 1984

PROPOSED ISSUANCE  OF  A NATIONAL POLLUTANT DISCHARGE ELIMINATION  SYSTEM
(NPDES) PERMIT TO  DISCHARGE POLLUTANTS PURSUANT TO THE PROVISIONS OF THE
CLEAN WATER ACT
                             Cominco Alaska
                            (Port Facilities)


has applied for issuance of a National Pollutant Discharge Elimination
System (NPDES)  permit to discharge pollutants pursuant to the provisions
of the Clean Water Act.  This fact sheet includes (a)  the tentative
determination of the Environmental Protection Agency (EPA) to issue  the
permit, (b) information on public comment, public hearing and appeal
procedures, (c) the description of the proposed discharges, (d)  a listing
of tentative effluent limitations and other conditions, and (e)  a sketch
or detailed description of the discharge location.  We call your special
attention to the technical material presented in the latter part of  this
document.

Persons wishing to comment on the tentative determinations contained in
the proposed permit issuance may do so by the expiration date of the
Public Notice.   All written comments should be submitted to EPA  as
described in the Public Comments Section of the attached Public  Notice.

After the expiration date of the Public Notice, the Director, Water
Division, will  make final determinations with respect to the permit
issuance.  The  tentative determinations contained in the draft permit will
become final conditions if no substantive comments are received  during the
Public Notice period.  However, issuance of the final  permit by  EPA  will
be contingent upon completion of the statutory requirements of Title XI of
the Alaska National Interest Lands Conservation Act.  Accordingly, this
permit cannot be issued unless Cominco is authorized by the Department of
the Interior, the President and Congress to construct a mining road
through Cape Krusenstern National Monument to the port site.

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                                   -2-

The pennit will  become effective 30 days after the final detenninations
are made, unless a  request for an evidentiary hearing  is submitted within
30 days after receipt of the final detenni nations.   An evidentiary hearing
will be granted only if it meets all the requirements  of 40 CFR 124.74.

The proposed NPDES  pennit and other related documents  are on file, may be
inspected, and copies made in Room 11D,  1200 Sixth Avenue, Seattle,
Washington 98101, at any time between 8:30 a.m.  and 4:00 p.m., Monday
through Friday.   Copies and other information may be requested by writing
to EPA at the above address to the attention of the Water Permits Section
M/S 521, or by calling (206) 442-1214.  This material  is also available
from the EPA Alaska Operations Office, Room E556, Federal Bldg., 701 C
Street, Anchorage,  Alaska   99513 or EPA Alaska Operations Office, 3200
Hospital Drive,  Suite 101, Juneau, Alaska 99801.   A copying machine is
available in the Seattle Office for public use at a charge of 20 cents per
copy sheet.  There  is no charge if the total cost is less than 25 dollars.

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                            Technical  Information

A.  Applicant;   Cominco Alaska
                Mailing Address:  5660 B. Street
                                Anchorage,  Alaska   99502

B.  Project Location:  West of Mulgrave Hills on the shore of Chukchi Sea
                      (Approximately 17 miles southeast of  Kivalina)
                      Northwest section of  Cape Krusenstern National Monument

C.  Background:

     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 (See Figure 1. )

EPA and the Department of the Interior (DOI), developed an environmental
impact statement (EIS) for the Red Dog Mine  project.  Figure 1 shows the mine
location,  the two transportation corridor alternatives (northern and
southern), and the port site for each corridor.   The preferred corridor is the
southern route.  Consequently, Cominco has submitted an application for this
port site.  The  subject of this Fact Sheet is the discharges from the
preferred port site.  The NPDES permit for the mine and mill discharge is
being permitted  in a  separate process and was published in the draft EIS.

D.  Project Description:

     The port facility will include a deep water dock and a  ship loading
facility with concentrate receiving, storage and handling facilities; fuel
storage and warehouse for supplies necessary for the operation of the mine;
and housing for  emergency ship loading crews.

     The mine and mill operations will operate year-round; however, the port
facility will only receive supplies and fuel during the summer sealift, and
ship concentrate from late June until early  October.

     All  of the  facilities, except the concentrate  storage building, are
located on the coastline.  The storage building is  located 2.5 miles east
(inland)  of the  port  facilities.

E.  Sources of Wastewater

     The applicant has applied for the discharge of domestic wastewater, and
surface runoff collected from the port area.  Domestic wastewater will be
treated with a package treatment plant.  Discharge  will only occur during the
shipping season.  The estimated discharge is 1500 gallons per day (gpd).

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                                      -4-

The stornwater runoff at the port facility will be collected and routed to a
settling poiwt for treatment.  The estimated average discharge from the pond is
5170 gpd. /This is based on a pond sized to contain the runoff from a 10
year-24 hour precipitation event.

F.  Receiving Waters

     Domestic waste and runoff discharges will be to the Chukchi Sea.  Chukchi
Sea is classified by the Alaska Water Quality Standards as classes II
A(i )(ii)(iii), B(i)(ii), C and D for use in agriculture, seafood processing
and industrial water supply, water contact and secondary recreation, growth
and propagation of fish, shellfish aquatic life and wild life, and harvesting
for consumption of raw mollusks or other raw aquatic life.

G.  Basis of Limitations and Monitoring Requirements

     EPA has not promulgated national guidelines for storm water runoff from
port facilities.  Therefore, the permit effluent limits are based on a best
professional judgement of applicable technology based limits.

     1.  Domestic Wastewater

         The package treatment plant should provide treatment to achieve
secondary treatment standards (40 CFR 133).  To ensure that the plant is
operating properly, the permittee will be required to sample for BOD and TSS
at least once per month during the shipping season (late June until early
October).

     2.  Runoff

         The pollutants of concern associated with runoff from the port are
solids, and oil and grease.  Runoff from the fuel storage area has been
limited to an oil and grease limit of 10 mg/1 and total suspended solids to 20
mg/1.   These limits are based on the use of a settling pond and an oil/water
separator.  Monitoring for flow and oil and grease will be required weekly.

         The fuel storage tanks will contain #1 grade diesel oil.  Diesel is
considered to be highly toxic to aquatic life.  However, leaks from the tanks
will  not result in a direct discharge to any receiving waters since the tanks
will  be within a bermed area.  The bermed area is sized to contain 110% of the
tanks  volume.   Consequently, if there was a major leak, the bermed area will
be able to contain all  the fuel.

         During routine operations, if a leak is detected the permittee will
be required to monitor for the presence of diesel oil in the stormwater
runoff.  Discharges of diesel oil are prohibited.

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                                   -5-

H.  State Certification
     If the permittee achieves the above limits,  State water quality
standards are not expected to be violated.
I.  Ocean Discharge Criteria Evaluation
    Section 403 of the Clean Water Act requires EPA to decide on the basis
of available infonnation whether the discharge will  cause unreasonable
degradation of the marine environment.
    The criteria to evaluate the discharge are listed  in 40 CFR Part 125,
Subpart M.  After consideration of these criteria,  it  appears evident that
if the permittee complies with the permit limits,  the  discharge will not
cause unreasonable degradation.
J.  Permit Term
    The permit will expire in five (5) years.

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                                                              SAOHAL7K C 
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                                 Permit No.:  AK-004064-9
                                 Application No.:  AK-004064-9
              United States Environmental  Protection Agency
                               Region 10
                           1200 Sixth Avenue
                        Seattle, Washington 98101
                  AUTHORIZATION TO DISCHARGE UNDER THE

             NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM


     In compliance with the provisions of the Federal Water Pollution
Control Act,  as amended, (33 U.S.C. §1251 et seq;  the "Act"),

                             Cominco Alaska

is authorized to discharge from a facility located 17 miles southeast of
Kivalina,  Alaska, to receiving waters named Chukchi Sea and an unnamed
tributary  to  the Cmikviorok River in accordance with discharge points,
effluent limitations, monitoring requirements and  other conditions set
forth herein.

     This  permit shall become effective

     This  permit and the authorization to discharge shall expire at
midnight,


Si gned thi s      day of



                                        DRAFT
                             Director, Water Division, Region 10
                             U.S. Environmental  Protection Agency

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                                                Page 2 of  14
                                                Permit No.:  AK-004064-9
                             TABLE OF CONTENTS

Cover Sheet—Issuance and Expiration Dates

I.    Effluent Limitations and Monitoring  Requirements

     A.    Sewage Treatment Plant
     B.    Port Site Sedimentation Pond
     C.    Concentrate Storage Facility Sedimentation Pond
     D.    Other Requirements
     E.    Definitions

II.   Monitoring, Recording and Reporting  Requirements

     A.    Representative Sampling
     B.    Monitoring Procedures
     C.    Penalties for Tampering
     D.    Reporting of Monitoring Results
     E.    Compliance Schedules
     F.    Additional Monitoring by the Permittee
     G.    Records Contents
     H.    Retention of Records
     I.    Twenty-four Hour Notice of Noncompl iance Reporting
     J.    Other Noncompl iance Reporting
     K.    Inspection and Entry

III.  Compliance Responsibilities

     A.    Duty to Comply
     B.    Penalties for Violations of Permit Conditions
     C.    Need to Halt or Reduce not a Defense
     D.    Duty to Mitigate
     E.    Proper Operation and Maintenance
     F.    Removed Substances
     G.    Bypass of Treatment Facilities
     H.    Upset Conditions
     I.    Toxic Pollutants

IV.   General Requirements

     A.    Changes in Discharge of Toxic Substances
     B.    Planned Changes
     C.    Permit Actions
     D.    Duty to Reap ply
     E.    Duty to Provide Information
     F.    Other Information
     G.    Signatory Requirements
     H.    Penalties for Falsification of  Reports
     I.    Availability of Reports
     J.    Oil and Hazardous Substance Liability
     K.    Property Rights
     L.    Severability
     M.    Transfers
                               DRAFT

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                                                 Page 3 of 14
                                                 Permit No.:   AK-004064-9

I.  Effluent Limitations and Monitoring Requirements

     A.  Sewage Treatment Plant (Outfall 001)

     During the period beginning on the effective date of this  permit and
lasting through the expiration date, the permittee is authorized to discharge
from Outfall 001  in accordance with the following:
EFFLUENT
CHARACTERISTICS

Flow

BOD5

Total
Suspended Solids

PH
  EFFLUENT LIMITATIONS
Daily Avg     Weekly Avg
  30 mg/1
45 mg/1
  30 mg/1      45 mg/1

  pH shall  not be  less than
  6.0 standard units, nor
  greater  than 9.0 standard
  units.
                MONITORING REQUIREMENTS
Frequency*
Weekly
Monthly
Monthly
Weekly
Sample Type
Measurement
Grab
Grab
Grab
*During months of discharge only.
     B.  Port Site  Sedimentation Pond (Outfall  002)

     1.  During  the period beginning on the effective date  of this permit and
lasting through  the expiration date, the permittee is authorized to discharge
from Outfall  002 in accordance with the following:
EFFLUENT
CHARACTERISTIC

Flow
Oil and Grease
Total
Suspended Solids
Total  Copper
Total  Z1nc
Total  Lead
Total  Mercury
Total  Cadmium

PH
  EFFLUENT LIMITATIONS
Daily Avg.    Monthly Max.
                MONITORING REQUIREMENTS
                Frequency*  Sample Type
....
10 mg/1
20 mg/1
0.15 mg/1
0.5 mg/1
0.3 mg/1
0.001 mg/1
0.05 mg/1
....
20 mg/1
30 mg/1
0.30 mg/1
1 .0 mg/1
0.6 mg/1
0.002 mg/1
0.1 mg/1
Weekly
Weekly
Weekly
Monthly
Monthly
Monthly
Monthly
Monthly
Measurement
Grab
Grab
Grab
Grab
Grab
Grab
Grab
  pH shall  not  be less
  than 6.0  standard units,
  nor greater than 9.0
  standard  units.
                Weekly
*During months  of  discharge only.

     2.  There  shall be no discharge of diesel  oil
                                   DRAFT
Grab

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                                                 Page 4 of  14
                                                 Pennit No.:  AK-004064-9
     C.   Other Requirements
     1.   There  shall  be  no discharge of floating solids or oily wastes which
produce a sheen  on  the surface of the receiving water.

     2.   The permittee is only required to submit monitoring results  for
those months that discharge(s) has occurred.

     3.   The sample  type, monitoring frequencies or monitoring program may  be
changed upon the review of the above monitoring results.  This may include the
addition of biomonitoring requirements.

     D.   Definitions

     1.   "Daily Average" ("Daily Avg.") shall mean the total units discharged
during a monitoring month divided by the number of days in that period that
the production or commercial facility was operating.  Where less than  daily
sampling is required  by this permit, this average shall be determined  by the
summation of the measured daily discharges divided by the number of days
during the monitoring month when the measurements were made.

     2.   "Weekly Average" is the arithmetic mean of samples collected during
a calendar week.

     3.   "Daily Maximum" ("Daily Max.")  shall mean the maximum value
attained on any  day in a  given monitoring month.

     4.   "Monitoring Month" shall mean the period consisting of the calendar
weeks which end  in  a  given calendar month.

     5.   A "24  hour  composite" ("24 hr. Comp.") sample shall mean a
flow-proportioned mixture of not less than 8 discrete aliquots.  Each  aliquot
shall be a grab  sample of not less than 100 ml and shall be collected  and
stored in accordance  with procedures prescribed in the most recent edition of
Standard Methods for  the  Examination erf Water and Wastewater.

     6.   A "Grab"  sample is a single sample or measurement taken at a
specific time or over as  short a period of time as is feasible.

     7.   "Upset" means an exceptional incident in which there is
unintentional and temporary noncompliance with technology-based permit
effluent limitations  because of factors beyond the reasonable control  of the
permittee.  An upset  does not include noncompliance to the extent caused by
operational error,  improperly designed treatment facilities, inadequate
treatment facilities,  lack of preventive maintenance, or careless or improper
operation.

     8.   "Bypass"  means  the intentional diversion of waste streams from any
portion of a treatment facility.
                               DRAFT

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                                                Page 5 of 14
                                                Permit No.:   AK-004064-9
     E.   Definitions
     1.   "Daily Average" ("Daily Avg.")  shall mean the total  units discharged
during a monitoring month divided by the  number of days in that period that
the production or commercial facility was operating.  Where less than daily
sampling is required by this permit, this average shall be determined by the
summation of the measured daily discharges divided by the number of days
during the monitoring month when the measurements were made.

     2.   "Weekly Average" is the arithmetic mean of samples collected during
a calendar week.

     3.   "Daily Maximum" ("Daily Max.")  shall mean the maximum value
attained on any day in a given monitoring month.

     4.   "Monitoring Month" shall mean the period consisting  of the calendar
weeks which end in a given calendar month.

     5.   A "24 hour composite" ("24 hr.  Comp.") sample shall  mean a
flow-proportioned mixture of not less than 8 discrete aliquots.   Each aliquot
shall be a grab sample of not less than 100 ml and shall be collected and
stored in accordance with procedures prescribed in the most recent edition of
Standard Methods for the Examination of_ Water and Wastewater.

     6.   A "Grab" sa
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                                                       Page  6 of  14
                                                       Permit No.:  AK-004064-9
II.   MONITORING, RECORDING AND REPORTING REQUIREMENTS
     A.   Representative Samplinq.   Samples  taken  in compliance with the
         monitoring requirements established  under Part  I shall be collected
         from the effluent stream prior to  discharge  into the receiving
         waters.  Samples and measurements  shall  be representative of the
         volume and pature of the monitored discharge.

     B.   Monitoring Procedures.  Monitoring must  be conducted according to
         test procedures approved under 40  CFR  Part 136, unless other test
         procedures have been specified in  this permit.

     C.   Penalties for Tampering.   The  Clean  Water Act provides that any
         person who falsifies, tampers  with,  or knowingly renders inaccurate,
         any monitoring device or method required to  be maintained under this
         permit shall, upon conviction, be  punished by a fine of not more than
         $10,000 per violation, or by imprisonment for not more than 6 months
         per violation, or by both.

     D.   Reporting of Monitoring Results.   Monitoring results shall be
         summarized each month on  Discharge Monitoring Report (DMR) form (EPA
         No. 3320-1).  The reports shall be submitted monthly and are to be
         postmarked by the 10th day of  the  following month.  Legible copies of
         these, and all other reports,  shall  be signed and certified in
         accordance with the requirements of  Part IV. G. Signatory
         Requirements, and submitted to the Director, Water Division and the
         State agency at the following  addresses:

         original to:  United States Environmental Protection Agency
                      Region 10
                      1200 Sixth  Avenue
                      Seattle, Washington  98101

                      Attn:  Water Compliance  Section, Mail Stop 513

         copy to:      State of Alaska
                      Department of Environmental  Conservation
                      Northern Regional Office
                      675 7th Avenue
                      P. 0. Box 1601
                      Fairbanks, Alaska  99707
                                DRAFT

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                                                   Page 7  of   14
                                                   Permit  No.:  AK-004064-9
E.   Compliance  Schedules.  Reports of compliance or noncompliance
     with,  or any progress reports on interim and final  requirements
     contained in any  Compliance Schedule of this permit (Part  IA)
     shall  be submitted no later than 10 days following  each  schedule
     date.

F.   Additional  Monitoring by the Permittee.  If the permittee
     monitors any pollutant more frequently than required by  this
     permit,  using test procedures approved under 40 CFR 136  or as
     specified in this permit, the results of this monitoring shall
     be included in the calculation and reporting of the data
     submitted in the  DMR.  Such increased frequency shall  also be
     indicated.

G.   Records  Contents.  Records of monitoring information shall
     include:

     a.   The date,  exact Mace, and time of sampling or measurements;

     b.   The individual(s) who performed the sampling or
          measurements;

     c.   The date(s)  analyses were performed;

     d.   The individual(s) who performed the analyses;

     e.   The analytical techniques or methods used; and

     f.   The results  of such analyses.

H.   Retention of Records.  The permittee shall retain records  of all
     monitoring  information, including all calibration and
     maintenance records and all original strip chart recordings for
     continuous  monitoring instrumentation, copies of all reports
     required by this  permit, and records of all data used to
     complete the application for this permit, for a period of  at
     least 3  years from the date of the sample, measurement,  report
     or application.   This period may be extended by request  of the
     Director at any time.

I.   Twenty-four Hour  Notice of Noncompliance Reporting.

     1.   The following occurrences of noncompliance shall  be
          reported by  telephone within 24 hours from the time the
          permittee becomes aware of the circumstances:

          a.   Any noncompliance which may endanger health or the
              environment.

          b.   Any unanticipated bypass which exceeds any effluent
               limitation in the permit.  (See Part III. G. Bypass  of
               Treatment Facilities.)
                             DRAFT

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                                                   Page 8  of 14
                                                   Permit No.:   AK-004064-9

          c.    Any upset which exceeds any effluent limitation in the
               permit.  (See Part III. H. Upset Conditions.)

          d.    Violation of a maximum daily discharge limitation for
               any of the  pollutants listed in the permit to be
               reported within 24 hours.

     2.   A written submission shall also be provided within 5 days
          of  the time that the permittee becomes aware of the
          circumstances.   The written description shall contain:

          a.    A description of the noncompliance and its cause;

          b.    The period  of noncompliance, including exact dates and
               times;

          c.    The estimated time noncompliance is expected to
               continue if it has not been corrected; and

          d.    Steps taken or planned to reduce, eliminate, and
               prevent reoccurrence of the noncompliance.

     3.   The Director may waive the written report on a case-by-case
          basis if the oral report has been received within 24 hours
          by  the Water Compliance Section in Seattle, Washington by
          phone,  (206) 442-1213.

     4.   Reports shall be submitted to the addresses in Part II.  D.
          Reporting of Monitoring Results.

J.   Other Noncompliance Reporting.  Instances of noncompliance  not
     required to be reported within 24 hours shall be reported at the
     time that monitoring  reports for Part II. D. are submitted.  The
     reports  shall  contain the information listed in Part II. 1.2.

K.   Inspection and Entry.  The permittee shall allow the Director,
     or an authorized representative, upon the presentation of
     credentials and other documents as may be required by law,  to:

     1.   Enter upon the permittee's premises where a regulated
          facility or activity is located or conducted, or where
          records must be  kept under the conditions of this permit;

     2.   Have access to and copy, at reasonable times, any records
          that must be kept under the conditions of this permit;

     3.   Inspect at reasonable times any facilities, equipment
          (including monitoring and control equipment), practices, or
          operations regulated or required under this permit, and

     4.   Sample or monitor at reasonable times, for the purpose of
          assuring permit  compliance or as otherwise authorized  by
          the Clean Water  Act, any substances or parameters at any
          location.
                             DRAFT

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                                                       Page  9  of  14
                                                       Permit No.:  AK-004064-9
III.  COMPLIANCE RESPONSIBILITIES
      A.   Duty to Comply.  The permittee must comply with  all  conditions
          of  this permit.  Any permit noncompliance  constitutes  a
          violation of the Clean Water Act and is grounds  for  enforcement
          action; for permit termination, revocation and reissuance, or
          modification; or for denial of a permit renewal  application.
          The permittee shall give advance notice to the Director of any
          planned changes in the permitted facility  or activity  which may
          result in noncompliance with permit requirements.

      B.   Penalties for Violations of Permit Conditions.   The  Clean Water
          Act provides that any person who violates  a permit condition
          implementing sections 301, 302, 306, 307,  308, 318,  or 405 of
          the Clean Water Act is subject to a civil  penalty not  to exceed
          $10,000 per day of such violation.  Any person who willfully or
          negligently violates permit conditions  implementing  sections
          301, 302, 306, 307, or 308 of the Clean Water Act is subject to
          a fine of not less than $2,500, nor more than $25,000  per day
          of  violation, or by imprisonment for not more than 1-year, or
          both.  Except as provided in permit conditions on Part III. G.
          Bypass of Treatment Facilities and Part III.  H.  Upset
          Conditions, nothing in this permit shall be construed  to
          relieve the permittee of the civil or criminal penalties for
          noncompliance.

      C.   Need to Halt or Reduce not a Defense.  It  shall  not  be a
          defense for a permittee in an enforcement  action that  it would
          have been necessary to halt or reduce the  permitted  activity in
          order to maintain compliance with the conditions of  this permit.

     D.   Duty to Mitigate.  The permittee shall take all reasonable steps to
         minimize or prevent any discharge in violation of this  permit which
         has  a reasonable likelihood of adversely affecting human health or
         the  environment.

     E.   Proper Operation and Maintenance.  The permittee  shall  at all times
         properly operate and maintain all facilities and  systems of treatment
         and  control (and related appurtenances)  which  are installed or used
         by the permittee to achieve compliance with the conditions of this
         permit.  Proper operation and maintenance includes effective
         performance, adequate funding, adequate  operator  staffing and
         training, and adequate laboratory and process  controls, including
         appropriate quality assurance procedures.  This provision requires
         the  operation of backup or auxiliary facilities or similar systems
         only when necessary to achieve compliance with the conditions of the
         permit.
                                  DRAFT

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                                                  Page  10 of  14
                                                  Permit No.:  AK-004064-9

F.  Removed  Substances.  Solids, sludges, filter backwash, or other
    pollutants  removed in the course of treatment or control of
    wastewaters shall be disposed of in a manner such as to  prevent any
    pollutant from  such materials from entering navigable waters.

6.  Bypass of Treatment Facilities:

    1.    Bypass not exceeding limitations.  The permittee may allow any
         bypass to  occur which does not cause effluent
         limitations to be exceeded, but only if it also is  for essential
         maintenance to assure efficient operation.  These bypasses are
         not subject to the provisions of paragraphs 2.  and  3. of this
         section.

    2.    Notice:

         a.   Anticipated bypass.  If the permittee knows in advance of
             the need for a bypass, it shall submit prior notice, if
             possible at least 10 days before the date  of the bypass.

         b.   Unanticipated bypass.  The permittee shall submit notice of
             an unanticipated bypass as required under  Part II. I.
             Twenty-Four Hour Reporting.

    3.    Prohibition of bypass.

         a.   Bypass is prohibited and the Director may  take
             enforcement action against a permittee for a bypass,
             unless:

             (1)   The bypass was unavoidable to prevent loss of
                   life, personal injury, or severe property damage;

             (2)   There were no feasible alternatives to the
                   bypass, such as the use of auxiliary  treatment
                   facilities, retention of untreated wastes, or
                   maintenance during normal periods of  equipment
                   downtime.  This condition is not satisfied  if the
                   permittee could have installed adequate backup
                   equipment to prevent a bypass which occurred
                   during normal periods of equipment downtime or
                   preventive maintenance; and

             (3)   The permittee submitted notices as required under
                   paragraph 2. of this section.

         b.   The Director may approve an anticipated bypass,  after
             considering its adverse effects, if the Director
             determines that it will meet the three conditions
             listed above in paragraph 3.a. of this section.
                             DRAFT

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                                                       Page 11 of 14
                                                       Permit No.:  AK-004064-9
    H.    Upset Conditions
         1.    Effect of an upset.  An upset constitutes an affirmative
              defense to an action brought for noncompliance with such
              technology-based permit effluent limitations if the
              requirements of paragraph 2. of this  section are met.  No
              determination made during administrative review of claims
              that noncompliance was caused by upset, and before an
              action for noncompliance, is final  administrative action
              subject to judicial review.

         2.    Conditions necessary for a demonstration of upset.  A
              permittee who wishes to establish the affirmative defense
              of upset shall demonstrate,  through properly signed,
              contemporaneous operating logs, or  other relevant evidence
              that:

              a.   An upset occurred and that the permittee can identify
                  the specific cause(s) of the upset;

              b.   The permitted facility was at  the time being properly
                  operated; and

              c.   The permittee submitted notice of the upset as
                  required under Part II. I. Twenty-Four Hour Notice
                  of Noncompliance ReportiHgT

              d.   The permittee complied  with any  remedial measures
                  required under Part III. D. Duty to Mitigate.

         3.    Burden of proof.  In any enforcement  proceeding, the
              permittee seeking to establish the  occurrence of an upset
              has the burden of proof.

    I.    Toxic Pollutants.  The permittee shall comply with effluent
         standards or prohibitions established under Section 307(a) of
         the Clean Water Act for toxic pollutants within the time
         provided in the regulations that  establish those standards or
         prohibitions, even if the permit  has not yet been modified to
         incorporate the requirement.

IV.  GENERAL REQUIREMENTS

    A.    Changes in Discharge of Toxic Substances.   Notification shall be
         provided to the Director as soon  as the  permittee knows of, or
         has reason to believe:

         1.    That any activity has occurred or will occur which would
              result in the discharge of any toxic  pollutant which is not
              limited in the permit, if that discharge will exceed the
              highest of the following "notification levels":
                                 DRAFT

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                                                   Page  12 of  14
                                                   Permit No.: AK-004064-9

          a.   One hundred  micrograms per liter (100 ug/1);

          b.   Two hundred  micrograms per liter (200 ug/1) for
               acrolein and acrylonitrile; five hundred micrograms
               per liter (500  ug/1) for 2,4-dinitrophenol and for
               2-methyl-4,  6-dinitrophenol; and one milligram per
               1-iter (1  mg/1)  for antimony;

          c.   Five (5)  times  the maximum concentration value
               reported for that pollutant in the permit application;

     2.   That the permittee has begun or expects to begin to use or
          manufacture as an intermediate or final product or
          byproduct any toxic  pollutant which was not reported
          in the permit application.

B.   Planned Changes.  The  permittee shall give notice to the
     Director, as soon as possible, of any planned physical
     alterations or additions  to the permitted facility.  The
     permittee shall  also give advance notice of any planned changes
     in the permitted facility or activity which may result in
     noncompliance with  permit requirements.

C.   Permit Actions.   This  permit may be modified, revoked and
     reissued, or terminated for cause.  The  filing of a request by
     the permittee for a permit modification, revocation and
     reissuance,  or termination, or a notification of planned changes
     or anticipated noncompliance, does not stay any permit condition.

D.   Duty to Reapply.  If the  permittee wishes to continue an
     activity regulated  by  this permit after  the expiration date of
     this permit, the permittee must apply for and obtain a new
     permit.  The application  should be submitted at least 180 days
     before the expiration  date of this permit.

E.   Duty to Provide  Information.  The permittee shall  furnish to the
     Director, within a  reasonable time, any  information which the
     Director may request to determine whether cause exists for
     modifying, revoking  and reissuing, or terminating this permit,
     or to determine  compliance with this permit.   The permittee
     shall also furnish  to  the Director, upon request,  copies of
     records required to  be  kept by this permit.

F.   Other Information.   When  the permittee becomes aware that it
     failed to submit any relevant facts in a permit application,  or
     submitted incorrect  information in a permit application or any
     report to the Director, it shall  promptly submit such facts or
     information.
                             DRAFT

-------
                                                   Page. 13 of 14
                                                   Permit No.: AK-004064-9

G.   Signatory Requirements.   All  applications, reports or infor-
     mation submitted to  the  Director shall be signed and certified.

     1.   All  permit applications  shall be signed as follows:

          a.    For a corporation:  by a responsible corporate officer;

          b.    For a partnership or sole proprietorship:  by a
               general  partner or  the proprietor, respectively.

          c.    For a municipality, State, Federal, or other public
               agency:  by  either  a principal executive officer or
               ranking  elected official.

     2.   All  reports required by  the permit and other information
          requested by  the  Director shall be signed by a person
          described above or  by a  duly authorized representative of
          that person.  A person is a duly authorized representative
          only if:

          a.    The authorization is made in writing by a person
               described  above and submitted to the Director.

          b.    The authorization specified either an individual or a
               position having responsibility for the overall
               operation  of the regulated facility or activity, such
               as  the position of  plant manager, operator of a well
               or  a well  field, superintendent, or position of
               equivalent responsibility.  (A duly authorized
               representative may  thus be either a named individual
               or  any individual occupying a named position.)

     3.   Changes  to authorization.  If an authorization under
          paragraph IV. G.  2. is no longer accurate because a
          different individual or  position has responsibility for the
          overall  operation of the facility, a new autho-
          rization satisfying the requirements of paragraph IV. G. 2.
          must be  submitted to the Director prior to or together with
          any  reports,  information, or applications to be signed by
          an  authorized representative.

     4.   Certification.  Any person signing a document under this
          section  shall make  the following certification:

               "I  certify under penalty of law that this
               document and all attachments were prepared under
               my  direction or supervision in accordance with a
               system designed to  assure that qualified
               personnel  properly gather and evaluate the
               information  submitted.  Based on my inquiry of
               the person or  persons who manage the system, or
               those persons  directly responsible for gathering
               the information, the information submitted is, to
               the best of  my knowledge and belief, true,
               accurate,  and  complete.  I am aware that there
               are significant penalties for submitting false
               information, including the possibility of fine
               and imprisonment for knowing violations."
                               DRAFT

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                                                   Page 14  of 14
                                                   Permit No.: AK-004064-9

H.   Penalties  for Falsification of Reports.  The Clean Water Act  provides
     that any person who  knowingly makes any false statement,
     representation, or certification in any record or other document
     submitted  or required to be maintained under this permit, including
     monitoring reports or reports of compliance or noncompliance  shall,
     upon conviction be punished by a fine of not more than $10,000 per
     violation, or by imprisonment for not more than 6 months per
     violation, or by both.

I.   Availability of Reports.  Except for data determined to be
     confidential  under 40 CFR Part 2, all reports prepared in accordance
     with the terms of this permit shall be available for public
     inspection at the offices of the State water pollution control agency
     and the Director.  As required by the Act, permit applications,
     permits and effluent data shall not be considered confidential.

J.   Oil and Hazardous Substance Liability.  Nothing in this permit shall
     be construed  to preclude the institution of any legal action  or
     relieve the permittee from any responsibilities, liabilities,  or
     penalties  to  which the permittee is or may be subject under Section
     311 of the Act.

K.   Property Rights.  The issuance of this permit does not convey any
     property rights of any sort, or any exclusive privileges, nor does it
     authorize  any injury to private property or any invasion of personal
     rights, nor any infringement of Federal, State or local laws  or
     regulations.

L.   Severability.   The provisions of this permit are severable, and if
     any provision of this permit, or the application of any provision of
     this permit to any circumstance, is held invalid, the application of
     such provision to other circumstances, and the remainder of this
     permit, shall  not be affected thereby.

M.   Transfers.  This permit may be automatically transferred to a new
     permittee  if:

     1.   The current permittee notifies the Director at least 30  days in
          advance  of the  proposed transfer date;

     2.   The notice includes a written agreement between the existing and
          new permittees  containing a specific date for transfer of permit
          responsibility, coverage, and liability between them; and

     3.   The Director does not notify the existing permittee and  the
          proposed new permittee of his or her intent to modify, or revoke
          and reissue the permit.  If this notice is not received,  the
          transfer is effective on the date specified in the agreement
          mentioned in paragraph 2. above.
                             DRAFT

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	Appendix 5
Department of the Army Public
    Notice and Section 404(b)(1)
                    Evaluation

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US Army Corps
of Engineers
Alaska District
 Regulatory Functions  Branch
 Pouch 898
 Anchorage, Alaska  99506
Public
of  App
                                  PUBLIC NOTICE  DATE:   March 16,

                                  REFERENCE  NUMBER:  071 -OYD-4-840012

                                  WATERWAY NUMBER:  Chukchi Sea 11
 Interested parties are hereby  notified that an application  has  been  received
 for  a Department of the  Army permit for certain work in  waters  of  the United
 States, as described below  and shown on the attached plan.

 APPLICANT:  Cominco Alaska, Incorporated

 LOCATION:  Red Dog Mine,  sec.  19, T. 13 N., R.  18 W., K.R.M.

 WORK :   1)   Tailing  Dam:   Place   approximately 2,800,000  cubic yards  of
 dredged  and  fill  material  in  the  south  fork  of Red Dog Creek and  adjacent
 wetlands  to construct a  tailing dam.   The dam will  be 150 feet high and 30
 feet  wide at  the  crest, with  an  embankment  approximately 2,400  feet  long.
 The  upstream  slope  will  be  2:1  with  downstream  side  slope  of  4:1.   A
 spillway will  be constructed to meet the 10-year, 24-hour rainfall  event.
 2)   Access  Road:   Place  approximately 177,408 cubic yards of  fill  material
 in  wetlands  to  construct  a  gravel access road connecting  the  mill   site,
 tailing dam,  and  mine.   The  2.1  mile  road will  be constructed 6 feet high
 and  60 feet wide at the  crown with 2:1  side slopes.

 PURPOSE:  The purpose of these activities  is to construct support  facilities
 for  the  efficient and environmentally  safe operation  of the Red Dog  Mine.
 All  activities will be located on private lands.

 ADDITIONAL  INFORMATION:    The  Environmental   Protection  Agency  (EPA)  is
 preparing  an  Environmental  Impact Statement  (EIS)  for  the  Red  Dog  Mine
 project.  The Alaska District  Corps of Engineers is a coorperating agency in
 the  EIS.  A permit  decision regarding  the road and tailing dam will not be
 made  until  after  the  Final  EIS   has  been prepared.    This  public notice
 reflects  the  applicant's  preferred  alternative.   Other  alternatives  are
 being considered  in  the  EIS  process and  a discussion of these alternatives
 can  be found in  Chapter  III of the EIS.

 AUTHORITY:   This   permit  will  be  issued  or  denied  under  the  following
 authorities:
 (X)  Discharge dredged or fill material  into waters of the United  States -
 Section 404, Clean  Water Act (33 U.S.C.  1344).

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WATER  QUALITY  CERTIFICATION:   A  permit for  the  described work  will  not be
issued  until  a certification  or  waiver of  certification  as  required under
Section  401  of the  Clean Water Act  (Public  Law 95-217),  has  been received
from the Alaska Department of Environmental Conservation.

PUBLIC  HEARING:   The  Corps  of  Engineers  and  the  Environmental  Protection
Agency  will  hold joint  public hearings  on  the  Draft  EIS.   The  dates  and
locations of these public hearings can be found in the Draft EIS.

CULTURAL  RESOURCES:   The  applicant's  perferred   alternative  may  affect
cultural resources  located  within  and  adjacent  to Cape Krusentstern National
Monument.   Formal   consultation  pursuant  to  Section  106 of   the  National
Historic Preservation Act (33 CFR 800) is required.

ENDANGERED SPECIES:   Preliminarily,  this  described activity will  not  affect
endangered  species,  or  their critical habitat  designated as  endangered or
threatened, under the Endangered Species Act  of  1973  (87 Stat.  844).  Formal
consultation under  Section  7  of  the Act  is  not required  for  the described
activity.

FLOOD  PLAIN  MANAGEMENT:   Evaluation  of  the described activity will  include
conformance  with   appropriate  State  or   local  flood   plain  standards;
consideration  of  alternative  sites  and  methods  of  accomplishment;  and
weighing  of  the   positive,   concentrated  and   dispersed,  and  short  and
long-term impacts on the flood plain.

EVALUATION:  The  decision  whether  to  issue  a  permit  will be based  on an
evaluation  of   the   probable   impact   including   cumulative impacts   of  the
proposed activity  on the public  interest.   That decision will  reflect  the
national   concern   for   both  protection  and   utilization   of  important
resources.   The benefit  which reasonably  may be  expected  to  accrue from the
proposals  must  be  balanced  against  its  reasonably  foreseeable detriments.
All  factors which   may   be   relevant  to  the  proposal  will   be  considered
including  the  cumulative  effects  thereof;   among  these   are  conservation,
economics,   aesthetics,   general  environmental  concerns,  wetlands,  cultural
values,  fish  and  wildlife  values,  flood  hazards,  flood  plain  values,   land
use, navigation,  shoreline  erosion  and accretion, recreation,  water  supply
and  conservation,   water quality,   energy needs,  safety,  food  and  fiber
production,  mineral  needs,  and,  in  general,  the needs  and  welfare  of  the
people.

Comments on the described work, with  the  reference  number, should reach  this
office  no   later  than   30  days  after the   publication   of  the  notice  of
availability of the  Final EIS to  become part  of the record and be considered
in the  permit  decision.   Copies of any comments  should  be sent  to  Mr.   Bill
Riley,   Environmental  Evaluation  Branch  (M/S  443),  Environmental  Protection
Agency,  1200   Sixth  Avenue,   Seattle,   Washington   98101.     If   further
information is desired concerning this  notice,  contact Mr. Joe Williamson at
(907) 552-4942  or 279-6713.
                                   -2-

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The  Notice  of   Application   for  State  Water  Quality  Certification  and
Certification  of Consistency  with  the  Alaska  Coastal   Management  Program,
will be public noticed by the State of Alaska at a later  date.
                                   District Engineer
                                   U.S. Army, Corps of Engineers
Attachments
                                     -3-

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MAP
AREA\5
                                                                                                          DEADLOCK
                                                                                                          MTN.
   Vicinity  Map
             LEGEND
                MONUMENT BOUNDARY

                TRANSPORTATION CORRIDOR
                             VABM 28
                             PORT SITE -
ENSTERN

ONUMENT
                                                                                                CHUKCHI  SEA 11
                                                                                                Cominco  A la s K a
                                                                                                RedDogProjecl

                                                                                                Sheet  1  of 4
LOCATION  MAP

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 CHUKCHI SEA 11
SITE PLAN
Cominco Alaska
Red Dog Project
Sheet 2 of 4   1/84J

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NOTE: MINE SITE ROADS TO REQUIRE 177,408
 CU. YDS. FILL. INITIAL PIT DEVELOPMENT
 SUPPLY SUITABLE WASTE ROCK FOR USE //
 AS FILL MATERIAL.                 //
                                                                       ROAD SECTION-TYPICAL
                                                                                                  Commco Alaska
                                                                                                  Red Doa Project
                                                                                                  Sheet $ ol 4  1/84

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             SEEPAGE/CONTINGENCY
                   /
                                                one
                                                BODY
ACCOMMODATION
                             TAl/iNG
                            IMPOUNDMENT
      DIVERSION DITCH
                          IMPOUNDMENT-PLAN
                                             HAUL ROAD
  SEEPAGE CONTINGENCY
  DAM
NOTE'
,
UPSTREAM a DOWNSTREAM SLOPES FOR —^
YEAR 1 ARE 2: 1
, 310
930
                                               EL 950


                                               EL 870
                                       HAUL ROAD

                                               EL 800
 FILL REQUIREMENTS ( cu. yds. )
   ( MINE WASTE MATERIAL )
                             DAM SECTION
                                 1"-200'
                                        CHUKCHI SEA 11
                                   TAILING IMPOUNDMENT
      YEAR 1

      YEAR 6
 255.000

2.800.000
Cominco Alaska
Red Dog Protect
Sheet 4 of 4  1/84

-------
 US Army Corps
 of Engineers
Public  Notice
of Application
for  Permit
Alaska District
Regulatory Functions  Branch
Pouch  898
Anchorage, Alaska  99506
                               PUBLIC NOTICE DATE:   March 16, 198^
                               REFERENCE NUMBER:  071-OYD-2-830359

                               WATERWAY NUMBER:  Chukchi Sea 9

Interested parties are hereby notified that  an application has  been received
for a Department of the Army permit for certain work  in waters  of the United
States, as described below and  shown on the attached plans.

APPLICANT:  Cominco Alaska, Incorporated

LOCATION:  Port Facility: sec.  10, T.  25 N., R. 24 W., K.R.M.

          Mine Site:  sec. 19,  T. 31 N., R. 18 W., K.R.M.

          A gravel road would be constructed from the port facility to  the
mine site along the route shown in the attached plans.

WORK:  The proposed work can be described  in two  parts:

       1.  Road:   Approximately 3,980,000 cubic  yards of fill  material will
be required to construct a gravel road,  including 28 turnouts,  in wetlands.
The 56.7 mile  road will  be constructed approximately  6 feet high and 30 feet
wide at the  crown,  with  2:1  side slopes.   The  dimensions  for  a typical
turnout  are 350 feet  x 20 feet x  6  feet, with  2:1  side  slopes.   The road
will have a total  of  175 culverted crossings and  2 bridge  crossings.  Gravel
material  for  the  road  and turnouts  will  be  obtained from several  borrow
sites.  These  borrow  sites will be permitted at a later date when the exact
locations are  known.  Possible borrow site locations have  been shown on  the
attached plans.

       2.   Port  Facility:  The  port will  consist  of  the  construction  of
concentrate transfer facility,  dock,  upland  port facility, and  a concentrate
storage  building.   The  concentrate  transfer  facility  will  consist   of
ballasting a large ship on the sea floor  approximately 4,000 feet offshore.
The ship  will  be ballasted in  35  feet of  water and will be used to transfer
lead and zinc concentrate from  the  dock  to  ocean  going  ships.   The .area
dredged  for such an  action would  be  1,000 feet  by 150 feet by 5 feet deep,
with the dredged material pumped into the  ship's  wing tanks to act as ballast
(total  of 25,000  cubic yards).   In  addition,  1,000  feet to the  north,  an
area 1,000  feet  by  200  feet  by  10 feet deep  will be  dredged  to supply
ballast  for the  tanker (total of  75,000 cubic  yards).   There would be  no
onshore  storage of dredged material.   The  dock  will be  400 feet  long  and
extend  to 12  feet of  water  offshore, with  3:1  side slopes.  Twenty-nine
thousand  (29,000)  cubic  yards  of  fill   would  be  needed for the  dock,
including armor rock  located  at  the  toe  of the structure.  The upland port

-------
site will be constructed  in  wetlands  adjacent to the Chukchi Sea and will be
used  as  a  staging  area  for  concentrate  shipping,  the  movement  of  mine
supplies, and  building  materials.   Tne Pad will  be  510 feet by 265 feet and
10  feet  deep.   The  total  fill  required  is  63,000  cubic  yards.   The
concentrate storage  building will  be located  on the  excavated  barrow site
approximately 2.5 miles from the shore side  facility.   The building will be
912  feet by  180 feet  by  80 feet  tall.  No  fill  will   be  required.   The
opening  of  the port lagoon  would  require the  dredging of  an  opening which
would be  60 feet by 370 feet by 12 feet.  A total  of  15,000 cubic yards of
material would  be moved.   This  would  be  done to allow  access  to  the  lagoon
for the  construction barge  to be used in the  initial development of the road
and port.

PURPOSE:   The  purpose   is   to  develop  a  road  and  port  facility for  the
construction  and operation  of  the  Red Dog  Mine.   The  road will  be  an
industrial  use  road  constructed  to  carry 150 ton  trucks which  will  move
lead/zinc concentrate from the mine to the  port.   The road would carry up to
12 truck  trips  per  day plus other  assorted mine related vehicle trips.  The
port would  function approximately  4 months  of the year  and would  act  as the
incoming and outgoing point for all material for the Red Dog Mine.

ADDITIONAL  INFORMATION:   The   Environmental   Protection   Agency   (EPA)  is
preparingan   Environmental  Impact  Statement  (EIS)  for  the  Red  Dog  Mine
project,  including  the  gravel road and  port  facility.   The Alaska District
Corps of  Engineers  is  a  coorperating agency  in  the  EIS.   A permit decision
regarding the road and  port  facility  will not be made  until after the Final
EIS  has  been   prepared.    This  public  notice  reflects  the  applicant's
preferred alternative.   Other alternatives are  being considered  in the EIS
process  and a  discussion of  these alternatives can  be found  in Chapter III
of the EIS.

AUTHORITY:   This  permit  will   be issued  or   denied   under  the  following
authorities:

(X)  Perform work in or affecting navigable waters of the United States
Section 10,  River and Harbor Act 1899  (33 U.S.C. 403).

(X)  Discharge dredged or fill material into waters of  the  United States
Section 404, Clean Water Act (33 U.S.C. 1344).

(X)  Title  XI,  Alaska National  Interest Lands Conservation  Act (PL 96-487;
94 Stat. 2371).

WATER QUALITY  CERTIFICATION:  A  permit  for  the  described  work will  not be
issueduntila  certification or waiver  of certification  as  required under
Section  401 of  the Clean  Water Act  (Public  Law 95-217),  has  been received
from the Alaska Department of Environmental Conservation.

COASTAL ZONE MANAGEMENT ALT  CERTIFICATION:  Section  307(c)(3)  of the Coastal
Zone Management  Act  of 1972, as amended by  16 U.S.C.  1456(c)(3),  requires
the applicant  to certify that the  described activity affecting land or water
uses  in  the   Coastal   Zone  complies with   the  Alaska Coastal  Management
Program.  A permit will  not be  issued  until  the  Office  of  Management and
Budget,  Division  of  Governmental   Coordination  has   concurred   with  the
applicant's  certification.

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PUBLIC  HEARING:   The  Corps of  Engineers  and  the  Environmental  Protection
Agency  will  hold joint  public  hearings  on  the  Draft  EIS.   The  dates  and
locations of these public hearings can be found in the Draft EIS.

CULTURAL  RESOURCES:   The  applicant's   perferred  alternative  may  affect
cultural resources  located  within  and  adjacent  to Cape Krusentstern National
Monument.   Formal   consultation  pursuant  to  Section  106 of  the  National
Historic Preservation Act ( 33 CFR 800) is required.

ENDANGERED SPECIES:   The proposed  action  may  affect threatened  or endangered
species or  their  critical  habitats.   Formal consultation  with  the U.S.  Fish
and Wildlife Service  and  National  Marine Fisheries  Service,  under Section 7
of the Endangered Species Act of 1973 (87 Stat. 844), is required.

FLOOD PLAIN  MANAGEMENT:   Evaluation of  the described activity  will  include
conformance  with   appropriate  State   or   local   flood   plain  standards;
consideration  of  alternative  sites  and  methods  of  accomplishment;  and
weighing  of  the   positive,   concentrated   and  dispersed,   and  short  and
long-term impacts on the flood plain.

EVALUATION:  The  decision  whether to  issue  a permit  will  be  based  on  an
evaluation  of   the   probable  impact   including  cumulative   impacts  of  the
proposed  activity  on the  public  interest.    That decision will  reflect  the
national   concern   for   both   protection   and  utilization   of  important
resources.  The benefit  which  reasonably may be  expected  to  accrue from the
proposals must be balanced against its reasonably foreseeable detriments.
All  factors  which   may  be relevant  to  the  proposal  will  be  considered
including  the   cumulative  effects  thereof;  among  these  are  conservation,
economics,  aesthetics,   general  environmental  concerns,  wetlands,  cultural
values,  fish  and wildlife  values, flood hazards,  flood  plain  values,  land
use,  navigation,  shoreline  erosion  and accretion,  recreation,  water supply
and  conservation,  water  quality,  energy   needs,   safety,   food  and  fiber
production,  mineral  needs,  and,   in  general,   the  needs and welfare  of  the
people.

Comments on the described  work,  with  the reference number, should reach this
office  no  later  than  30  days  after  the  publication  of  the  notice  of
availability of the  Final  EIS  to become part of the record and be considered
in  the  permit  decision.   Copies of any  comments  should be sent  to  Mr.  Bill
Riley,  Environmental  Evaluation  Branch  (M/S 443),  Environmental Protection
Agency,   1200   Sixth  Avenue,   Seattle,   Washington    98101.    If  further
information is  desired  concerning  this  notice,  contact Mr. Joe Williamson at
(907) 552-4942 or 279-6713.

The  Notice of  Application for  both  State  Water  Quality  Certification  and
Certification of  Consistency with  the  Alaska Coastal Zone Management Program
will be public noticed by the State of Alaska at  a  later date.


                                   District Engineer
                                   U.S. Army, Corps  of Engineers

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                                                                                                        DEADLOCK
                                                                                                        MTN
Vicinity Map
                  C,    KIVALINA
           LEGEND
              MONUMENT BOUNDARY

              TRANSPORTATION CORRIDOR
                             VABM 28
                             PORT SITE -
                                                          NATIONAL fvONUMENT
                                                                                              Cominco Alaska
                                                                                              Red Dog Project
                                                                                              Chukchi Sea 9
                                                                                              071-OYD-2-830359
                                                                                              Sheot 1  of 13
LOCATION  MAP

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     BALLAST FOR TANKER
    APPRQX. 75,000 CU, YpS.
             1000'
                                                                                               BARGE  DOCK
                                                             DOCK  OVER  SHEET PILES
                                                                 CONCRETE CAISSON
                                           HIGH TIDE LINE
                                           T-
                                              4" FUEL LINE (NTS

                                                           SEABED
                                                                                          SECTION ELEVATION
                                                           CASING ( NTS )
                                                                                     EARTH  FILL
                                                                                    29,000 cu  yds.
                                         DREDGE
                                           CUT   Dredging  &  backfill  of trench
                                         	involve 12.000  cu. yds, of  materia
                                                                 hor. 1"= 170'
                                                                 ver. 1"= 50'
o
o
o
     PLAN OF  PORT  FACILITIES
                                               1"  400'
                                                  uil. GENERAL SITE DEVELOPMENT
                                                  £•'•'-  63.000 cu yds.  FILL
     DEEP WATER  DOCK       BARGE
  •( BALLASTED TANKEP )
      ( See  sheet 10 for
        tanker section )
                  Approximate location
                  undersea fuel line
            1017'
             1000'

       of /     /

              f
                                                                                                                           POWER
                                                                                                                          GENERATION
[PORT.. LAGOON
                                      BREAK REPRESENTS 2750'
                  	L
                   AR£A.
                                     10'
    SECTION ELEVATION
hor.  1" = 400'
ver.  1" = 40'
                     NOTES:  Port facility location may be slightly
                             altered to reduce impact to cultural
                             resource site.
                                                                        200'       510'

                                                                      BREAhTREPRESENTS  500'
        SEAPORT FACILITIES
                 Cominco AI a s k a
                 Red Dog Project
                 Chukchi Sea 9
                 071-QYD-2-83035S
                 Sheet2of13   1/8

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     CHUKCHI  SEA
NOTE:
     DARK AREA REPRESENTS
     ACTUAL PIT AND WOULD SUPPLY
     ALL GRAVEL NEEDED

     EXPLORATION AREA IS THE
     TOTAL AREA WITHIN WHICH
     THE  PIT MAY BE LOCATED
                                                                                                                         «*
                                                                                                                         UJ
                     PORT SITE
                                                                                                        \
                                                                                                                 ) ;
                                                                                                                 v
                                                                                                     Comlnco Alaska
                                                                                             1 MILE   Red  Dog Project
                                                                                                     Chukchi Sea 8
                                                                                                     07 1 -OYD-2-830359
                                                                                                     Sheet 3 oJ 13  1/84

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gravel pit
                       Comlnco Alaska
              1 MILE    Red Dog Project
                       Chukchi Sea 9
                       071-OYD-2-830359
                       Sheet 4 of 13  1/84
piorattpn
   "

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        Comlnco Alaska
MILE    Red DOQ Projecl

-------
         Comlnco Alaska
1  MILE    Rad Dog Project
         Chukchi Sea f>
         0?1-QY0~2-e303S6
         Sheet § of tS  1/84

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Comlneo
Rod ooi
Chukchi
071-(
Sheet

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                                           ENTRAJE S^QQAGE BUILDING
                                                  LOCATION
,,-  • ->
                                        PORT SITE


                               LOCATION DETAIL
                           ACCESS        ROAD
                                     912'0"
                              SECTION ELEVATION
                                       1"=36'

                                                CONCENTRATE STORAGE
FACILITY BUILT ON  BEDROCK OF

FORMER BARROW SITE  AT PT. (?
Cominco Alaska
Red Dog Project
Chukchi Sea 9
07 1-OYD-2-830358
Sheet 8 of 13  1/84

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   PORT SITE
 ( See sheet 2, for detail )
 ORIGINAL GROUND

  15 -
-5
                         -12'
                    IO2    I 44 FEET
    SECTION  ELEVATION @
    hor. 1 "- 68'   ver.  1 "- 40'
                                                          PORT LAGOON
                                                             LAYOUT

                                                           1"-300' ( approx.)
   ORIGINAL GROUND-
                                    -12'
               SHORELINE         570 FEET


       SECTION ELEVATION  ®

       hor.  1" = 225'   ver. 1 " = 40'



                     168'0" -
  4-
                                       NA7URAL BREACH

                                        ,   DREDGE SPOILS, \
                                       ~f   15,000 CU. YDS. \

rr
0

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ir
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KITCHEN/DINER/REC










               BARGE LAYOUT

                     1" = 50'
                                             NOTE:
20'!
                  ELEVATION
                     1"=50'
                                            20     CONSTRUCTION FACILITIES
                                                               Cominco Alaska
                                                               Red Doc Project
                                                               Chukchi Sea 9
                                                               071-OYD-2-830359
                                                               Sheet 9 of 13   1/84

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                                           BULK CARRIER
                                                       <£
                                               /_	
                                       f   DRY GOODS
                                     7t-
                                      t;-:
                                      i^-:

                                    zi
                                     ;-J                t
                                     -.",,                (
                                        _^.  __,_,„„ ,j

                                       I   CONTAINERS  4
   190'
                         BALLAST
                     100,000 CU. YDS.
                                           1017'
                            PLAN
                           1" = 120'
                                  DELIVERY BARGE
[
r
L_T
•

L
                                                                           I
SEABED
                 AVAILABLE STORAGE DEPTH-42'
                                                                                 1000'
                                                    SECTION ELEVATION  ©

                                                            1"= 120'
 ( vertical
 exaggerated )
                                                    BALLAST
                                               SEABED
                                                              DREDGED  PAD TO PRODUCE
                                                              25,000 CU. YDS. MATERIAL
                                                              TO  BE USED AS  BALLAST
                                                              ( vertical  exaggerated )
                                                                     0"-
                                                                                 n
   BULK
' CARRIER
                 SECTION ELEVATION (A)

                       1"= 120'
                                                              /-
154'9"
                                                                                BULK
                                                                               CARRIER
                               SECTION ELEVATION

                                      1"= 120'
                             DEEP  WATER DOCK

                                   Cominco Alaska
                                   Red DOQ Project
                                   Chukchi Sea 9
                                   071-OYD-2-830359
                            	  Sheet 10 o! 13  1/84

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                   2% DRAINAGE DITCH
                                                                               SLOPE VARIABLE

                                                                             DEPENDENT ON MATERIAL
  TYPICAL CROSS SECTION of BORROW PIT
                       __
                                                                                NOTE:
                                                                                VOLUME  OF OVERBURDEN
                                                                                NOT AVAILABLE

                                                                                NO OVERBURDEN STOCKPILES
                                                                                SHOWN AT THIS TIME
                                                                               TYPICAL  BORROW PIT
                                                                             CROSS  SECTION&PLAN
TYPICAL PLAN of BORROW, PIT
              N.T.S.
Commco Alaska
Red Dog  Project
Chukchi Sea 9
071-OYD-2-830359
Sheet 11 of 13  1/84

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                                                               ,^w//://K
                                                               'V-S       ft^\JG. CROSSING 8000 cu.yds. Fill
                             TYPICAL  BRIDGE  CROSS  SECTION
                               SCALE :HOR. 1'=20'  VERT.1"=10'
                                    30
                         r
                                            -1
GRADED ROCK
PROTECTION  AROUND
CULVERTAS REQUIRED
                                                 TYPICAL SIDE SLOPE

                                                      2
      NATURAL STREAM SLOPE
                                 CORRUGATED STEEL CULVERT
TYPICAL ROAD CROSS SECTION  SHOWING  TYPICAL CULVERT
                               0          15   AVG. 1500  cu. yds. of fill
        EXPLANATION  of  ROAD

      •  56.7 MILES LONG,30' NOMINAL WIDTH
          W/GRAVELED SURFACE  & AVG
          6' SUBBASE of GRANULAR FILL
      •  TOTAL  FILL : 3,866,000 cu. yds.

      •  TOTAL  CULVERTS :  175

      •  TOTAL  TURNOUTS :  28
         - 4000 cu. yds. FILL
         -DIM.  50' WIDE X 350'LONG
          PER  TURNOUT

      •  MAJOR BRIDGES : ONE

      •  CROSSING of RIVERS & STREAMS  :
         -O'MIKVIOROK RIVER
                       Cominco Alaska
  BRIDGE&ROAD     Red DOQ projoct
CROSS SECTIONS   SJ^-V-8*30359
                       S h e e t 12 o f 13  1/84

-------
       \   \  \   \
                                                  SLOPE
                                                      350'-
                                                    ROAD
                                                                                                  30'
                                                    \  \  X
 /  /
SL
                                                            /  /  /   '   '
                                                  5LOPE


                                          TYPICAL PLAN OF TURNQUT
                                                   SCALE 1' 60'
                                                                                         NOTE:
                                                                                              REFER TO SHEET 2 of 1 3
GRADED ROCK PROTECTION

     AROUND CULVERT
                                      -20-
                                                                                        TYPICAL SIDE SLOPE
                                            NATURAL STREAM SLOPE

                             TYPICAL CROSS SECTION OF TURNOUT

                                                    N.T.S.
                                                  Cominc o Alaska
                                                  Red Dog Project
                                                  Chukchi Sea 9
                      CROSS SECTION & PLAN  071-0x0-2-03035
                      ______________________  Sheet13oM3   m
                                                                            TYPICAL TURNOUT

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                            APPENDIX 5

         EVALUATION OF THE DISCHARGE OF DREDGED AND FILL

      MATERIAL IN ACCORDANCE WITH SECTION 404(b)l  GUIDELINES


                    SUBPART A - ACCEPTABILITY

     Dredged and fill material  should  not be discharged into  the
aquatic ecosystem unless  it  can  be  demonstrated that such a dis-
charge  would  not   have  an  unacceptable  adverse  impact  either
individually or  in  combination with other  known  and/or probable
impacts of other activities affecting the ecosystem of concern.


                     SUBPART B - RESTRICTIONS
                                     (
     The proposed Red Dog Project woud involve a discharge  of fill
material  into  a special  aquatic site for  construction  of mine
site facilities, a road/railbed to the coast, and  port facilities.
A description  of  the proposed project and  alternatives evaluated
for impact  analysis is  found in  the Summary and  Chapters II  and
III of  the  draft EIS.  All  practicable  alternatives to the pro-
ject would  involve  a discharge into a special aquatic site.    As
discussed in  the Summary and  Chapter  III of  the draft EIS,  the
applicant's  proposed project  is  the  environmentally preferred
alternative and  will have  less  adverse impacts  than any of  the
other alternatives identified.

     The discharge  of fill  material  will have to be  certified  as
being  in  compliance with  State Water Quality  Standards  and  the
project cannot violate applicable Federal toxic effluent standards
pursuant to Section 307 of the CWA (40 CFR 219).

     As determined  in Subparts C  through G  of  this  evaluation  and
as discussed in  Chapter V of the draft EIS, the  proposed  project
or any  of the alternatives,  would  not contribute  to significant
degradation  of  waters  of  the  United  States  including  adverse
effects on human health,  life stages of organisms  dependent on  the
aquatic  ecosystem,   ecosystem  diversity,  productivity  and  sta-
bility, and recreational,  aesthetic, and economic  values.

     Appropriate  and practical  steps have  been  identified  in
Subpart H  which would minimize  potential  adverse impacts of  the
discharge on  the aquatic ecosystem.   These mitigating  measures
would be incorporated into the project design or would be  required
by permit conditions or other agreements.

            SUBPART C - PHYSICAL AND CHEMICAL IMPACTS

     Pertinent  information  about primary,  secondary,  and  cumula-
tive impacts of  the proposed project  and alternatives  related to
the  substrate;  turbidity/suspended  particulates;  physical   and

-------
chemical  changes to  the water  column;  current, circulation,  or
fluctuation; and  salinity  gradients  is contained in Chapter  V of
the draft EIS.

                  SUBPART D - BIOLOGICAL IMPACTS

     Pertinent  information  about primary, secondary,  and  cumula-
tive impacts of the  proposed project and alternatives  related to
threatened and endangered species, aquatic organisms, and wildlife
is contained in Chapter V of the draft EIS.

      SUBPART E - POTENTIAL IMPACTS ON SPECIAL AQUATIC SITES

     Special aquatic sites that would  be  affected by the proposed
project are wetlands, mud  flats,  and vegetated  shallows.   Depend-
ing on  the  exact alignment of  the road/railbed, riffle and  pool
complexes may also be affected.   Discussions  about  impacts  of the
proposed project and alternatives on values associated  with those
special aquatic sites are found in Chapter V of the  draft EIS.

        SUBPART F -  IMPACTS ON HUMAN USE CHARACTERISTICS

     Human use  characteristics that would be  affected  by  the  pro-
posed project  include  subsistence species,  recreational and  com-
mercial    fisheries,     water-related    recreation    activities,
aesthetics,  Cape Krusenstern National  Monument,  and archeological
sites.   As  discussed  in the draft EIS, the proposed project  will
have a low level of impact on each of these  characteristics.  Per-
tinent information about potential impacts of  the proposed project
and alternatives is found in the Summary and Chapters III and  V of
the draft EIS.

                  SUBPART G - EVALUATION AND TEST

     The source and type of discharge material  that  would  be  used
to develop  the  proposed project or  any of  the alternatives  is
described in chapter II of the draft EIS.  Based on  these evaluat-
ions and  discussions,  and the  locations  of  the potential  gravel
sites  described,  the   possibility  that  the   proposed  discharge
material is a carrier of contaminants  is  very unlikely.  Based on
this  evaluation,  there  is  little  likelihood  that   discharges
associated with the proposed project would result in contamination
of the  aquatic  ecosystem;   therefore,  no  testing  would   be  re-
quired.

          SUBPART H - ACTION TO MINIMIZE ADVERSE EFFECT

     Those practicable  actions  which are not part  of  the  appli-
cant's  current proposal but which could be taken to  minimize  sig-
nificant adverse effects of  the proposed discharge  are described
in Chapter V of the draft EIS.

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	Appendix 6
ANILCA Title XI Right-of-Way
                  Application

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CTAN£*. it) ro/.'M ««.. canal, pipeline, road);  (b) related  structures and f»cili
    U««;  
-------
   IJ».  Deicnbc other t««»on«ble «lt«rn«(.v« route* «odmod«. considered.


         SEE  ATTACHMENT "A"
     b.  ft"hy wer» theie • llemativei not selected?


         SEE ATTACHMENT "A"
    c. Give explanation •• to why it it neceaiary to crott Federal Undi.
   The  proposed  route represents  the  alternative which  would have  the  least environmental
    impact of  the  routes  considered.   Further,  the  route through  the  Monument represents  the
   best  engineering  alternative  for construction of  access  in  this  region.   Please  refer to the
   preliminary draft EIS for  a complete  review of  this  subject.

  14.   List authorizations and pcndlnc application*  filed for similar projects which may provide information to the authorizine  aeency. ('
       Ify number. Jate. coJe. or  name.)

        SEE ATTACHMENT "A"



  IS.   Provide statement of need  for project, inciudinc the economic feaaibility and itema such as:  (a) cost of proposal (construction.
       •lion, tiut maintenance): (b) estimated cost of next best alternative; and (c) expected public benefits.

        SEE ATTACHMENT "A"
  16.  Describe probable effects on the population in the area, inciudinc the social and economic aspects, and the rural lifestyles.

        SEE ATTACHMENT  "A"
 17.  Describe likely cavironmcnisi effects that the proposed project will have on: (a) air quality: (b) visual Impact: (c) surface and ft
      water quality mad quantity; (d) the control or structural chance on any stream or other body of water;  (c) existinc noise levels;
      (Q the surface of the land. Inciudinc vccctatlon. permafrost, soil, and soil stability.

       •SEE  ATTACHMENT  "A"


 18.  Describe the probable effects that the proposed project will have on: (a) populations of fish, plant, wildlife, and marine life, inclu
      threatened and endanccred species;, and (b) marine mammals, inciudinc huntinc. capturinc. collecting or kiltinc these animals.

       SEE  ATTACHMENT  "A"
 19.  Name all the Dcpaitmcnt(s)/Accttcy(ies) where this application is beinc filed.
       NATIONAL  PARK  SERVICE
       U.S.  CORPS OF  ENGINEERS
       ENVIRONMENTAL  PROTECTION  AGENCY


I HCRCBY CCRTirr. That I a« of legal ace and authorized to do business in the State and that I have personally examined the informa
contained In the application and beliey,c that the information submitted is correct to the best of my knowlcdcc.
~       1               -  /}
1- 1*
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                                    APPLICATION  FOR  TRANSPORTATION AND UTILITY  SrSTfcMS
                                                 AND  FACILITIES ON FEDERAL  LANDS
                                                                                                  «7
                     GENERAL INFORMATION
               ALASKA NATIONAL INTEREST LANDS

   'hi» «pplication will be  used when ipplyinq;  for  • riKht-of-w«y,
   crmit, license,  lease, or certificate for the use o( Federal land*
   >hich lie within  conservation system units  and National Recreation
   r Coniervation  Areas  as defined in the Alaska National Interest
   .ands Conservation  Act.  Conservation system units include the
   ;«tion«l Park System.  National  Wildlife Refuge  System.  National
   .'ild  and Scenic  Rivers  System.  National Trails  System.  National
   •'ilderness  Preservation System,  and National Forest Monuments.'

   'raniportation and utility  systems and facility uses for which the
   .pplication nay be used are:

   t.  Canals, ditches, flumes,  laterals,  pipes, pipelines,  tunnels,
   ad other systems for the transportation of water.

   2.  Pipelines and other systems for the transportation of liquids
   ther than  water, including oil,  natural gas, synthetic liquid and
   xxeous fuels, and any refined product produced  therefrom.

   3.  Pipelines,  slurry and emulsion systems, and  conveyor belts
  or transportation of solid materials.

   4.. Systems  for the transmission  and distribution  of  electric
   nerzy.

   5.  Systems  for transmission or reception  of  radio, television.
  elephone. telegraph,  and other electronic signals, and other  means
  •f communications.
                                         machines,   air  cushion
6.  Improved  rights-of-way  for   snow
chicles, and all-terrain vehicles.

7.  Roads,  highways,  railroads,  tunnels,  tramways,  airports,
       strips, docks, and other systems of general transportation.
 This application nun be filed  simultaneously  with  each Federal
  epartment  or  agency  requiring  authorization to  establish  arid
 •perate your proposal.
 r.  AUska.  the  following agencies  will help the applicant  file an
 ipplication and identify th* other  agencies the applicant should
 rontact and possibly-file with:

   Department of Agriculture
   Regional Forester, Forest Service (USFS)
      Federal  Office Building. P.O.  Bon 1628
      Juneau.  Alaska 99802
      Telephone: (907) 588-7247 for a local Forest Service  Office)
   Department of Interior
   Bureau of Indian Affairs (BIA)
     Juneau Area Office, P.O. Box 3—8000
     Juneau. Alaska 99802
     Telephone:  (907) S86-7209

   Bureau of Land Management (BLM)
     701 C Street. Box 13
     Anchorage. Alaska  99513 .
     Telephone:  (907) 271-5055 for a local BLM Office)

   National  Park Service  (NPS)
     Alaska Regional  Office. 540 West Sth Avenue. Room 202
     Anchorage. Alaska 99501
     Telephone:  (907) 271-4196

   U.S.  Fish At Wildlife Service (FWS)
   Office  of the Regional Director
     1011 East Tudor Road
     Anchorage. Alaska 99503
     Telephone:  (907) 276-3800
Xote-Fllings with any Interior acency m«y be filed with any office
toted above or with the:   Office  of the Secretary of the Interior.
Regional Environmental Officer. Box 120, 1675 C Street, Anchor*
ige,  Alaska 99513.
                                                                       D«poffm«flf of Tran • pof 1 ol i on                       	     	
                                                                       Federal Aviation Administration
                                                                         Al«ik* Region-AAL-4. P.O.  U
                                                                         Anchorage. Alaska  99513

                                                                    NOTE- The D. p.rtmcnt of Transportation has  established  the
                                                                    •bove central filing  point  for  agencies within that  Department.
                                                                    Affected  agencies are:   Federal  Aviation  Administration (FAA),
                                                                    Coast Guard (USCG).  Federal  Highway  Administration  (FK'.YA).
                                                                    Federal Railroad Administration (FRA).
                                                                        OTHER THAN ALASKA NATIONAL INTEREST LANDS
                                                                    Use of this form is not limited  to National Interest Conservation
                                                                    lands of Alaska.

                                                                    Individual  departments/agencies may  authorize  the  use  of this
                                                                    form  by  applicants   for transportation  and utility systems and
                                                                    facilities on  other Federal  lands outside those areas described
                                                                    above.

                                                                   •For proposals located outside of Alaska, applications will be fi! = -J
                                                                    at the local agency office or at a location specified by the  respon-
                                                                    sible Federal  agency.
                                                                                      SPECIFIC INSTRUCTIONS
                                                                                 (Items not listed are icl[~txptanatoryi


                                                                   Item
                                                                    7   Attach preliminary site and facility construction plan*.  The
                                                                        responsible agency will provide instructions whenever speci-
                                                                        fic plans are required.

                                                                    8   Generally,  the nap must  show the  section(s). township(s),
                                                                        and range(s) within which the project is to be  located.  Show
                                                                        the proposed location of the project on the map as  accurately
                                                                        as possible.  Some agencies require detailed survey maps.
                                                                        The responsible agency will provide additional instructions.

                                                                   9,  10, and  12 — The responsible agency will provide  additional
                                                                        instructions.

                                                                   13   Providing information on alternate routes  and modes  in  as
                                                                        much  detail  as  possible,  discussing why  certain  routes  or
                                                                        modes  were  rejected  and  why  it is  necessary  to cross
                                                                        Federal lands will assist the agency(ies) in processing your
                                                                        application  and reaching  a final  decision.    Include only
                                                                        reasonable  alternate routes and modes as related  to current
                                                                        technology  and economics.

                                                                   14   The responsible agency will provide instructions.

                                                                   IS   Generally, a  simple statement of the purpose of the proposal
                                                                        will  be  sufficient.   However,  major  proposals  located  in
                                                                        critical or sensitive areas may  require a full analysis with
                                                                        additional  specific  information.   The  responsible  agency
                                                                        will provide  additional instructions.

                                                                   16   through 18 — Providing this information in as much detail  as
                                                                        possible  will  assist the  Federal   agency(ies)  in processing
                                                                        the application and  reaching  a  decision.  When completing
                                                                        these  items,  you  should  use sound judgment in furnishing
                                                                        relevant information.  For example, if the project is  not near
                                                                        a stream or other body of water, do not address this  subject.
                                                                        The  responsible  agency will provide additional instructions.

                                                                        Application must be signed by  the applicant  or applicant's
                                                                        authorized representative.
                                                                  If additional  space is naea'ed to  complete any item,  pUaso  put t!i«
                                                                  information on • separate »h««« of paper end identify it as "Contin-
                                                                  uation «( Item".
~or supplemental,  see reverse)

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                                                        SUPPLEMENTAL
NOTE: The responsible «g«ncy(ie«) will provide additional instructions.
I _ PRIVATE CORPORATIONS
a. Article* ot Incorporation
b. Corporation Bylaws ,
A certification from th» State showing the corporation is in good standing and is entitled to operate within the
C- State.
d. Copy of resolution authorizing filing
e. The name and address of each shareholder owning 3 percent or more of the shares, together with the number
and percentage of any class of voting shares of the entity which such shareholder is authorized to vote and
the name and address of each affiliate of the entity together»with. in the case of an affiliate controlled by the
entity, the number of shares snd the percentage of any class of voting stock of that affiliate owned, directly
or indirectly, by that entity, and in the case of an affiliate which controls that entity, the number of shares
and the percentage of any claas of voting stock of that entity owned, directly or indirectly, by the affiliate.
( If application is for an oil or gas pipeline, describe any related right-of-way' or temporary use permit appli-
* • cations, and identify previoua applications.
g. If application is for an oil and gas pipeline, identify all Federal lands by agency impacted by proposal.
CHECK APPROPRIATE
BLOCK
ATTACHED
a
CD
a
CD
CD
CD
CD •
FILED •
g^
G3
ca
, 	 QJ
CD
a
. LTj
                                                     - PUBLIC CORPORATIONS
a. Copy of law forming corporation
b. Proof of organization
c. Copy of Bylaws
d. Copy of resolution authorizing filing
If application is for an oil or gas pipeline, provide information required
*• by Item "I-f" and "I-g" above.
CD
CD
LD 1
CD
CD
I CD
l_ CD
CD
CD
CD
                                      - PARTNERSHIP OR OTHER UNINCORPORATED ENTITY
a. Articles of association, if any
'b. If on* partner is authorized to sign, resolution authorizing action is
c. Name and address of each participant, partner, association, or other
. If application is for an oil or gas pipeline, provide information required
by Item "I-f" and "I-t" above.
CD
. CD
CD
LD
CD
CD
CD
a
• If the required information is already filed with the agency processing this application and is current, check block entitled "Filed.
Provide the fiie identifies tion information (e.g.. number, dale, coJe. name). If not on file or current, attach the requested information.
                            NOTICE

 The  Privacy  Act  of  1974  provides that you  be  furnished the
 following information  In connection with information required by
 this spplication for an authorization.
 AUTHORITY:  16 U.S.C. 310; 5 U.S.C. 301.
 PRINCIPLE PURPOSE:  The information is to b« used to process
 the application.
 ROUTINE USES:   (I) The processing of the applicant's request
 for an  authorization.   (2)  Documentation for public information.
 (3) Transfer to  appropriate Federal  agencies  when concurrence
 is required  prior to granting s right  in public lands  or resources.
'(4X5) Information from the record and/or the  record will be trans-
 ferred to appropriate  Federal,  Slate, local  or foreif(n  agencies,
 when relevant  to civil,  criminal or regulatory  investigations or
 prosecutions.
EFFECT OF NOT PROVIDING INFORMATION:  Disclosure of th
Information is voluntary.  If all the information is not provided, th
application may be rejected.
               DATA COLLECTION STATEMENT
The  Federal  agencies collect this Information from applicant
requesting right-of-way, permit, license, lease,  or certification fc
the use of Federal lands.
The  Federal  agencies
pllcant's proposal.
use  this information to evaluate the a;
The  public la obligated to respond to this informstion request  i
they wish to obtain permission (O use Federal lands.

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                               ATTACHMENT  A
 INTRODUCTION

 Due to the scope of the questions  asked in the Title 11 application, presented
 below  are responses to questions 7, 9,  12,  and 13 to 18 as outlined in Stan-
 dard  Form 299.
QUESTION 7:

The Project Description

The proposed  project  would  consist  of  constructing a  road  and  associated
facilities  through the  northwest corner  of Cape Krusenstern  National  Monu-
ment.   The   road  would  be  single  lane,  30  feet  wide  with  slightly  larger
section of the road (50 feet wide) developed  to  serve as  turnouts.   The road
fill would average approximately 6 feet in  depth with an average grade of 1 to
3  percent.   The associated facilities  will  entail borrow sites used to obtain  fill
material for the road and  a concentrate storage building located 2.5  miles from
the coast.

There  would  be approximately 6  potential  borrow  sites within  Cape  Krusen-
stern  National  Monument.   Table  1   gives the  details of  the  borrow  sites.

The specific  barrow site locations  are listed in Appendix C.

The concentrate storage building  would hold  the lead and zinc concentrate at
the coast  before  shipment.   The building  would be  912  feet by  180 feet  by
80  feet high.   The  building would  be located on  a  excavated  barrow  pit to
reduce the need  to  disturb additional  ground.   Please refer to  Appendix  C_
for additional information.

The purpose  of the road is to provide  access  to  the Red Dog  Mine.  The
development  of  the  associated  barrow permits is  essential  to the cost effective
construction  of  the  roadway.   Transporting borrow  from outside the Monument
would  substantially  increase the cost of  the southern corridor.   The  increase
in cost,  although cumulatively not greater than  the  cost of constructing the
northern  alternative,  would make the  southern corridor prohibitive to  build.

The purpose  of the concentrate  storage  building  is  to hold concentrate for
later  shipment.   The proposed location  offers the  best option  for placement
due to access to the  road, foundation conditions,  and  limiting the  amount of
disturbed  land  within the  Monument  (due  to  the placement of the building  on
an existing borrow site).

The total  right-of-way requested  is  250  feet  from  the centerline of the road.
The centerline  will  be set  after additional  engineering  design  is complete.

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                                                  Table  I

                               PRELIMINARY BORROW SITE  SPECIFICATIONS,
                                           SOUTHERN CORRIDOR
Borrow
Site
Number
1*
2
3
4
5
6
Average Access
Exploration Disturbed Approximate Excavation Road
Area Pit Area Volume Needed Depth Length
ha
85.5
49.2
57.0
98.4
77.7
163.2
ac ha ac m3 yd3 m ft km mi
211.2 19.4 48.0 305,853 400,043 2.1 7.0 0.19 0.12
121.6 9.5 23.4 289,144 378,188 3.0 10.0 0.39 0.24
140.8
243.2 5.2 12.8 190,189 248,760 4.9 16.0 1.29 0.80
192.0 13.9 34.4 590,100 771,826 4.3 14.0 1.08 0.67
403.2
Within 91 m
(100 yd)
of Stream
No
No
No
No
No
Yes
*  Will also serve as the coastal concentrate storage facility site after  borrow excavation.

-------
The  road would  serve  as  access to the Red  Dog Mine for the expected project
life  which  is  presently  estimated  at 50  years.   Use  of  the road  would be
year-round  with the possible exceptions  of  a period during  spring breakup
and  during  significant  caribou migration periods.

Construction  is  scheduled to begin  in  July  of 1985.   Road  construction will
require approximately  16  months with a majority  of initial construction in the
Monument to be completed between January through April of  1986.

The  movement of the mine's output of lead and zinc concentrate  will  require  a
total between  9 to 12 trips per day when the mine is operating.

Please refer to Appendix C_  for specific  details of turnout location, siting  of
the  road  corridor, specifics  on  the  concentrate storage  building and detail on
the borrow  pits.


QUESTION  9:

State or  Local  Approvals

There  are no  specific  state or local approvals which must be obtained  as part
of the  formal  Title  XI  process.   However,  there are  two State  of  Alaska
certificates  which must be  obtained  by  the  Corps  of  Engineers  and  one by
EPA  for  the federal process to move  forward.   The Corps of  Engineers (COE)
must obtain  a 401   Consistency Determination of the  404  Wetlands  permit.
Further,  the  COE  must  obtain  from  the state   a  Coastal  Zone  Management
Consistency  Determination  to  complete the Section 10/404  process.   Cominco
has  made application for the Coastal Zone Management Consistency Determina-
tion.   In addition  the  National  Park Service must  obtain  approval from the
State Historic  Preservation Officer  as to how  cultural resources will be main-
tained.

EPA  must  obtain  a 401  Water Quality  Consistency  Determination  from the
Alaska  Department  of  Environmental  Conservation to  complete  the   NPDES
process.    Cominco  is  not aware  of  any specific action  which the company
needs to take on the 401 state certifications.

Question 14 outlined all permits which need to be obtained  for  the  total Red
Dog  project.


QUESTION 12:

Review of Technical  and Financial Ability to  Construct  Such a Route

Cominco  Alaska is a  division of  Cominco American,  Incorporated  which  in turn
is  wholly-owned  by  Cominco  Ltd.  Cominco Ltd. is a public company and cur-
rently  has  outstanding approximately 5.8  million  preferred  shares  and  18.8
million common  shares  of stock.    Sales  of  products  and  services for the
worldwide  Cominco operation during  1982 amounted to  $1.24  billion,  and its
assets  were $2.09 billion  at  December 31,  1982.   Cominco Ltd.  in turn is  51
percent owned by Canadian Pacific  Enterprises Ltd.,  a wholly owned  subsid-
iary  of Canadian Pacific Railway.

                                     - 3 -

-------
Cominco  Ltd.  has been  in  the mining business for more than 75 years.  The
mining and integrated  metals  segment of its  business comprises mining,  pro-
cessing,   smelting  and   refining  of  lead,  zinc,   copper,   silver  and  gold.
Cominco  Ltd.  and its subsidiaries have substantial  experience in mining under
Arctic conditions.   Most recently,  its new Polaris  Mine on  Little  Cornwallis
Island in the  Canadian  High  Arctic became  the most  northerly mine  in  the
world.

Cominco  American, Incorporated  has been engaged in the conduct  of  a trade
or  business  within  the  United  States  since  June 6,  1929 and  is  currently
qualified to do business  in 30 states.   It  is a substantial  operating  company
that has mining  operations  in  Bixby, Missouri;  Garrison, Montana;  and  Lone
Pine,  California.   It  also  has  substantial  chemical  fertilizer  operations  in
Beatrice,  Nebraska  and  Borgey,  Texas  and  an electronic  materials operation
located in Spokane,  Washington.


QUESTION 13:

Identify Alternatives  to the  Proposed Project

A.   A  total  of  three  options and  five suboptions  were considered  for  the
     transportation route.   In  addition,  four options and two suboptions were
     considered for  the mode  or  system of transport.  See the following table
     for  a  complete listing of routes  and modes initially considered.
                TRANSPORTATION  OPTIONS & SUBOPTIONS

                           INITIALLY  CONSIDERED


     Transportation         	Option	          	Suboption

     0  Route              Northern                 GCO Route
                           Southern                 Western Route
                                                     Omikviorok  Route
                                                     Kruz Route

                           Noatak
     0   Mode               Slurry Pipeline
                           Hovercraft
                           Railroad
                           Road                     Winter only
                                                     "Year-Round"
                                    - 4 -

-------
     Transportation Route:

     Characteristics important in selecting  a route 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  archeological  sites,  impact  on Cape Krusen-
     stern National Monument,  and impacts on other  regional  uses.   See  the
     following table for the total distance traversed by each  route considered.
 DISTANCES FOR TRANSPORTATION CORRIDOR  OPTIONS AND SUBOPTIONS
Transportation Corridor
Option
Northern
Suboption
GCO
Asikpak
                                                    Total Distance
                                         Mine to Port Site    Within  Monument
                                              (Miles)

                                               83.5
                                               73.1
                   (Miles)
Southern   Western (VABM  17)

           Western (VABM  28)

           Omikviorok (VABM  17)

           Omikviorok (VABM  28)

           KRUZ (VABM 28)
59.9
65.5

55.4
61.0

56.2
 9.8
17.0

21.6
28.8
24.0
Noatak     To Noatak Village
           To Fish Hatchery
51.0
69.0
     Northern Corridor:

     The northern  corridor  has two suboptions.  The first would be the GCO
     route  originally suggested by General  Crude Oil (GCO) Minerals.  This
     route  would connect  GCO's Lik mineral  prospect 19  km (12 mi) northwest
     of  Red Dog Valley to the Chukchi  Sea port site at Singoalik Lagoon, 42
     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 and  have  eight  major  multi-span bridge
     crossings (greater than  30.5 m  [100  ft]).
                                    - 5 -

-------
The  second  northern  corridor  suboption would  be the  Asikpak route.
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 and have six major
multi-span bridge  crossings.

Southern  Corridor:

The  southern corridor  would  share a common alignment with the northern
corridor  for the  first  11.8  km  (7.4  mi).   At  that  point  the southern
corridor  continues  southwest along  the  flanks of  the  Mulgrave  Hills.

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.  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  within  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.  The leg to VABM 17 would cross no major streams.
The  leg  to VABM 28 would  have one  major multi-span bridge  crossing.
Termination of  the southern  corridor at VABM  17 versus  VABM 28 would
be determined  by selection  of  the  port  site based on relative environ-
mental  consequences.

The  Omikviorok route suboption  would also diverge  west from the common
alignment.   Beginning  just south of the northern boundary of the  Monu-
ment,  the route  would  parallel  the Omikviorok  River to VABM  17,  or
cross the Omikviorok  River  and  proceed  south to VABM  28.   The leg to
VABM  17  would cross  no major streams.   The leg  to VABM 28 would have
one major multi-span bridge  crossing.

The  Krusenstern  route suboption would  continue to VABM 28 from the
points  of  divergence from  the  other  suboptions.    It would cross the
Omikviorok  River  considerably further  upstream than the other two sub-
options.

Noatak Corridor:

The  Noatak corridor option  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  Eviangiknuk 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  approximately  28.8 km  (18  mi) downriver  from  Noatak
(total  corridor length  of  110.4  km  [69 mi])  to reach  deeper  water  for
barge transport.
                               - 6 -'

-------
     Transportation Mode

     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 availability of technology  and reliability.

     Screening Process

     To  determine  the best 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.   The table  below lists
     those options  eliminated during  the  initial review process.
                 TRANSPORTATION OPTIONS & SUBOPTIONS

               ELIMINATED DURING INITIAL  REVIEW PROCESS
     Transportation          	Option	         	Suboption

     0  Route                Noatak
     0  Mode                 Slurry Pipeline
                             Hovercraft
                             Road                     Winter
(See table "Major  Reasons for Elimination of Transportation Options and  Sub-
 options  During Initial Review Process".)
     In the second step, the remaining, options were individually evaluated in
     detail  from  the  perspective  of  each  resource  or  technical  discipline
     (e.g.,  water quality, wildlife,  subsistence,  technical  feasibility).   For
     each discipline, a specific  set of "options screening criteria" was used to
     identify potential  impacts  for  each option.  Then,  each options was com-
     pared  to  all  other related  options  to  identify the  best option  (i.e.,  the
     one  with  the least  potential impacts)  for both  the transportation  route
     and mode.
                                     -  7  -

-------
                                          COMPARISON TABLE
Component
Option Relat
Suboplion Low
Transportation Roule1
Northern Corridor
GCO Roule

C
O

M
p

A
R
_ Asikpak Roule Cultural Resources
Regional Use




Southern Corridor
Western Route Krusenslern Impact




C Omikviorok Route
O
M
P
A
R
E
0



ive Level of Potential Imoact'
Moderate


Subsistence
Regional Use






Water Quality
Vegetation
Freshwater Biology
Fish
Wildlife
Technical Feasibility

Water Quality
Freshwater Biology
Subsistence
Cultural Resources
Technical Feasibility
Water Quality
Vegetation
Wildlife
Subsistence
Cultural Resources
Krusenstern Impact
Technical Feasibility
Economic Feasibility
High


Water Quality
Vegetation
Freshwater Biology
Fish
Wildlife
Cultural Resources
Technical Feasibility
Economic Feasibility
Subsistence
Economic Feasibility





Vegetation
Fish
Wildlife
Economic Feasibility

Freshwater Biology
Fish









E
L
1
M
I
N
A
T
E
D






E
L
I
M
I
N
A
T
E
D


I
M
I
N
A
T
D

       Krur Route1
                                 Water Quality
                                 Vegetation
                                 Freshwater Biology
                                 Wildlife
                                 Subsistence
                                 Technical Feasibility
                                 Economic Feasibility
                                                          Fish
                                                  Cultural  Resouces
                                                  Krusenstern  Impact
 Transportation Mode

    Railroad
C
0
M
P
A
R
E
D
                                 Subsistence
                                                         Water Quality
                                                         Air Quality
                                                         Vegetation
                                                         Freshwater Biology
                                                         Fish
                                                         Wildlife
                                                         Cultural Resources
                                                         Regional Use
                                                         Krusenstern Impact
                                                  Recreation
                                                  Technical Feasibility
                                                  Economic Feasibility
                                              I
                                              M
                                              I
                                              N
                                              A
                                              T
                                              E
                                              D
Road  (year-round)'
Recreation
Regional Use
Technical Feasibility
Economic  Feasibility

Vegetation
Freshwater  Biology
Fish
Wildlife
Subsistence
Cultural Resouces
Krusenstern Impact
Water Quality
Air Quality
     Disciplines  having the same level of potential impact for all options arc not shown.
     Suboptions  arc compared only with other(s) for same corridor (i.e.,  CCO and Asikpak routes for
     northern  corridor; western,  Omikviorok and  Kruz routes for southern corridor.)

     Proposed  alternative.

                                                     -  8  -

-------
     Following  the  options  screening process,  the best option for mode of
     transport  was  relatively  easy to identify.   However,  the route location
     had two options each  which appropriately addressed one  or  more of the
     scoping issues.  These options, shown in the following table,  were cai—
     ried through the comprehensive  environmental impact assessment process.
   TRANSPORTATION  OPTIONS ELIMINATED DURING  SCREENING PROCESS

         OR RETAINED FOR COMPREHENSIVE IMPACT ASSESSMENT
                          Retained
Transportation

0  Route
 Option
  Suboption
                                      Eliminated
 Option
Suboption
Northern    Asikpak Route   Northern    GCO Route
                 Southern
            Kruz Route
                 Southern   Western  Route
                            Omikviorok  Route
0  Mode
Road
Year-Round
Railroad
B.   Identify Why Alternatives Were Eliminated

     Each option and suboptions for the transportation route and  mode iden-
     tified  during the  scoping process was individually reviewed  from envi-
     ronmental  and  technical perspectives.   If an option (or suboption)  was
     environmentally  and technically  reasonable,  it was retained for further
     detailed analysis.    If,   however,  the  option  (or  suboption) was  deter-
     mined  to  be unreasonable  or infeasible  on  environmental  or  technical
     grounds,  and if other  options retained adequately addressed the scoping
     issues, it  was eliminated.  The following table presents those options  and
     suboptions eliminated during  the initial review  process and outlines  the
     major  reasons why each was eliminated.
                                    -  9  -

-------
  MAJOR  REASONS  FOR  ELIMINATION  OF TRANSPORTATION  OPTIONS AND

              SUBOPTIONS DURING INITIAL  REVIEW PROCESS
Transportation
0  Route
     Option
Noatak Corridor
   Mode
Slurry Pipeline
                    Hovercraft
                   Winter  Road
 Major Reasons for  Elimination

Road would cross many lowlands
with substantial  permafrost and
wetlands problems
Many stream crossings with asso-
ciated  impacts  on water quality
and  fish

Cold weather slurry lines not yet
feasible
High spill  hazard
Slurry water disposal problems
Wasteheat from  power generation
couldn't  be used to dry concen-
trates

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
erosion  problems
Greater spill hazards at river
crossings
Increased disturbance to wintering
caribou
Less flexibility for other regional
uses
     Each  of  the  remaining options  (or suboptions)  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,  or specific  set of "options screening criteria"  was
     developed   against  which  each option  (or  suboption)  was screened to
     identify potential  impacts upon that discipline.
                                    - 10--

-------
For  each discipline, once  each  option  for  the transportation  route and
mode had been  evaluated against all screening  criteria,  each option was
then  compared  to other  related options  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  (i.e.,  route and  mode).   The  relative  levels  of potential
impact were low, moderate  and high.

It should be  noted  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  11  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 alternatives for  formal  public  review in the  draft EIS.

In the  next step  of the process,  the levels  of potential  impact for all
disciplines  were grouped  for  each  option.   This  provided a combined
picture of the individual  levels of potential  impact.

The  final step  of  the option  screening process  was to  select the best
option for  the   route  and  mode of transportation.   This  was done  by
determining the  option which showed  the lowest overall 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 more  favorably  addressed one or  more of  the  scoping  issues.

In the  case of the  transportation  route,  two options   (one for each
corridor) appropriately addressed one or more)  of the scoping  issues and
therefore, both  were retained.   The Asikpak  route  to Tugak Lagoon was
selected  as  the  best suboption  for the  northern corridor  as was the Kruz
route to VABM  28 for the southern corridor.

For  the  mode of transportation,  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.

The  evaluation  criteria were applied separately to the two  route  options
to determine a  "relative  total impact value" (low, moderate or high) for
each.   It is  important  to  note that  the  relative  total  impact  value
assigned  to each option was derived  only  by  evaluation  of that option
                                -  11  -

-------
     relative to the other for each  criterion, and thus  does not  necessarily
     represent  the absolute  impact.   The  northern  Asikpak  route was  not
     selected  because it  would present a relatively higher level of total impact
     than  the  southern   Kruz  route.   An  accounting  of  the  relative  total
     impact follows.
                RELATIVE  TOTAL  IMPACT VALUES  ASSIGNED

              TO  THE  TWO TRANSPORTATION ROUTE  OPTIONS1
       Evaluation  Criteria
1.  Risk of Water Quality
    Deterioration

2.  Impact to Fish and Fish
    Habitat

3.  impacts to Wildlife  and
    Wildlife Habitat

4.  Impact to Traditional Sub-
    sistence  Harvest Activities

5.  Impact on Cape Krusenstern
    National  Monument

6.  Technical Complexity

7.  Cost
  Southern
 Kruz  Route     Northern Asikpak Route
Higher Impact
                 Higher Risk


                 Higher Impact


                 Higher Impact


                 Higher Impact
                 Higher Complexity

                 Higher Cost
    Potential impact to other  resources  (i.e., coastal geologic processes;
    marine life and marine habitat;  cultural resources; and  local  social,
    cultural and  economic conditions) would be  similar  for both options.
     The  southern  Kruz route  rated  inferior to the northern  route only for
     impacts to the Monument, while the northern  route rated  inferior to the
     southern  route for water quality, fish, wildlife,   subsistence,  technical
     complexity and  cost.  Based on these,  relative  impacts, and considering
     the southern  route would not  significantly  impact  the  Monument,  it  was
     determined that  the northern  transportation  route  would  not  present a
     prudent  option  for the development  of an access  route to  the  Red  Dog
     Project.
                                    - 12 -

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QUESTION 14:

List Required Authorizations to Allow Construction of the Project

Before construction and operation of the Red  Dog Project  can  begin,  Cominco
must  obtain  several federal  and state approvals.   The  major permits or other
approvals include:

     Federal Government*

     U.S.  Environmental Protection Agency  (EPA)

          0  National Pollutant  Discharge  Elimination System Permit  (NPDES)

     U.S.  Army Corps  of  Engineers  (COE)

          0  Section 404 Permit (wetlands)
          0  U.S.  COE Section  10  (port site)

     U.S.  National  Park Service (NPS)

          0  Right-of-Way for Transportation System

     Other  permits which  are needed for  construction but  fall outside Title 11
     jurisdiction:

          0  U.S.  EPA  NPDES Water Quality Permit (mine)
          0  U.S.  COE Section  404 (mine  site)

     U.S.  Fish and Wildlife (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)

     State  of  Alaska

     Department of Environmental Conservation (DEC)

          0  Air Quality Permit to  Operate
          0  Certificate of Reasonable Assurance (Water  Quality)
          0  Wastewater Disposal Permit

          0  Solid Waste Disposal  Permit

     Department of Fish and Game (ADF&G)

          0  Title 16  Anadramous Fish Stream Permit

* There are State of Alaska approvals which must be obtained as part of the
  federal permit decisions.
                                    - 13  -

-------
     Department of  Natural Resources  (DNR)

          0  Right-of-Way Permit
          0  Water Rights Permit
          0  Tidelands Use Permit

          0  Tidelands Lease
          0  Materials Sale Contract

     State Historic Preservation Office (SHPO)

          0  Archaeological Clearance

     Governor's Office of Management and Budget, Division of Governmental
     Coordination

          0  Coastal  Zone Management  Consistency Determination

     Local Government

     North Slope Borough (NSB)

          0  Land Use Permit


QUESTION 15:

Statement of Need

The  proposed  route represents the most logical  siting of the transportation
corridor to provide  access  to the Red Dog  Project.   The mine represents  a
significant economic  stimulus to the NANA region and  individual shareholders
of the NANA  Regional Corporation.  Congress clearly encouraged the  develop-
ment  of this mine when the land was withdrawn  from the Noatak Preserve and
made  available to the  Regional Corporation for selection.

The  proposed  route  would  have the least potential environmental  impact of all
the routes considered along with  the  least potential to adversely  effect exist-
ing subsistence activities in the project area.

The  proposed  route  would cost  approximately   $74.7  million  for the  entire
corridor from  Red  Dog to the  sea.   The next  most acceptable  route which
would  avoid  the National  Monument would cost  approximately $125.7 million.
In addition,  the  more  expensive  corridor  would  have  significantly  greater
impacts to  wildlife,  fisheries  and subsistence  values.   The  project would
provide jobs for an  economically depressed area of Alaska.  However, without
a  prudent  and cost-effective  route  to  the  coast,  development  of  the mine
would not occur in the foreseeable  future.

The  benefits to the  public would  be  represented  through the construction of
an environmentally  acceptable  route  which could serve the  Red Dog Project
and  other potential  mining operations  in the  district.   The  Red  Dog area


                                    - 14  -

-------
represents  one of the  most significant undeveloped mineralized  areas  in  the
United  States.   The  proposed route will  provide access to this  district  in  a
manner compatible with  the existing  lifestyle in  the  region and  the  aims of
Congress  in the protection  of  resources  as outlined in the Alaska Lands  bill.


QUESTION 16:

Effect on  the Population of the Area

The  potential  effect on  existing  socio-economic  characteristics of  the NANA
region can only be predicted based on  the  total  Red Dog  Project.

The  Red  Dog  mine  would  provide  permanent,  year-round  employment  in  a
developing  region  with substantial  unemployment.   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  region that seem
likely  to  improve economic or job conditions  to  a significant extent.  At  final
capacity,  the project would  contribute about 547 jobs and an  annual payroll of
$8.4  million  to NANA  region  residents.  For  comparison, the Alaska Depart-
ment  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  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  undetermined  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.

It is  estimated that the mining  project would  eventually add  about 354 persons
to the  total  population  of the  region above the  baseline forecast  without  the
mine.   Much  of this  growth would  occur at  the early stages of  the project.
This  would  include an estimated  118 new  resident  workers, plus  their  house-
holds.  It is assumed that Kotzebue's more  developed commerce,  transporta-
tion  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.

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
mine  project on population movements within  the  region are, at  best,  specula-
tive.   On  the one hand,  Kotzebue's more developed  cash economy  and com-
munity  services may  prompt some migration there of village residents working
                                    - 15 -

-------
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 is  that  the project would  not have  much  net  effect
on intraregional population movement.


QUESTION 17:

Information  provided for  item 17  will focus on likely  environmental  effects of
only those  components  of the project (i.e.,  transportation  route and  mode)
directly  associated  with  Cape   Krusenstern  National  Monument.   Potential
environmental  impacts  associated  with  the project in its  entirety have  been
fully  assessed in  the  project  Environmental  Impact  Statement (EIS).   Please
refer  to this  document  for a discussion of potential  impacts  other than those
directly associated with the Monument:

A.   Air Quality

     Vehicle traffic on  the road  would be  the  only  source of  pollutant emmis-
     sions  within  the  Monument.   Pollutant emmissions  from these  vehicles
     would  not reach  significant  levels even under  the worst of atmospheric
     conditions.   Dust generation, however,  could effect directly  surrounding
     vegetation.

B.   Visual

     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  of this  portion of the Monument is  very  low (i.e., less than
     five  visitors  per  year from  outside the region), the road port  site  and
     the transfer facility would be obvious to  viewers from most  parts  of the
     western  portion of the Monument.

     The  proposed port site  and  transfer facilities would  be  located in partial
     retention VQO  areas,  although port  site facilities  would  be located on
     private  land, and the  VRM  Program is not applicable   to private land.
     The  layout  and colors of the port facility could however  be made to con-
     form with the VQO to mitigate much of the visual impact.  The  visual im-
     pact of  the  large  ballasted  tanker  would  be  high,   but not  significant
     considering  the purposes for which the Monument  was established.   The
     partial retention VQO could  also  be achieved  here if appropriate  visual
     quality considerations were made during facility design.

C.   Surface  and  Groundwater Quality and  Quantity

     Potential  groundwater impacts  associated  with  the  road  would primarily
     involve  the  risk  of  groundwater  contamination from fuel  and  chemical
     spills.    Soils  containing  groundwater might  then act  as conduits  for con-
     taminant migration  to nearby streams.  Travel  time  between a spill  site
     and a  nearby stream would  depend on the  location of the spill, the sub-
     stance spilled and  the nature of intervening soil  materials.   Spillage con-
     trol  plans and  rapid response  to spills would  be  the primary  mitigative


                                     -  16  -

-------
     measures.   The  SPCC  Plan  outlines  the proposed draft plan for  spill
     reaction.

     Within  the Monument, the road  would  have only  one major  bridge  cross-
     ing the  Omikviorok  River and  20  minor  bridge or  culvert  crossings.
     Assuming proper  methods of  construction  and drainage control are fol-
     lowed,  environmental impacts would be insignificant.  The road  construc-
     tion  and  maintenance  guidelines  described  below and elsewhere  in the
     application would largely protect  against water quality  degradation  due  to
     sediment.  The Red  Dog mine  project would  follow acceptable guidelines
     for road  construction in the Arctic.

     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
     specifications  would  prevent  permafrost thawing  and resulting   severe
     erosion  problems.  Borrow areas would  be  situated  to  minimize potential
     water quality impacts on local  drainages.  Buffer strips  and  sedimenta-
     tion  ponds would  be used at rock quarry areas to protect water quality.
     Haul roads for construction materials would receive special  attention due
     to  their  temporary nature and  potential for tundra and permafrost dam-
     age.

D.   Control or Structural Change on  any Stream or other  Body of Water

     Information  pertinent to this  item  has  been  included under item (c)
     above.    However, the  possibility of  development of  a port  facility has
     raised  questions  concerning  potential   impact  upon  the  historic  beach
     ridges  at Cape Krusenstern,  although no project related  facility actually
     within  the Monument would  affect  the  transport  of  coastal  sediments.
     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
     transport,  and  no   significant  effect on the  Cape  Krusenstern  beach
     ridges.   (See  Woodward/Clyde,  October 1983  "Coastal Transport Cape
     Krusenstern to Cape  Thompson".)

E.   Noise

     The road would be used consistently for nine to twelve 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.  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 discernible  to the
     human ear  up to 8 km (5 mi) from the  road.

     Noise  disturbance to  visitors   at Cape   Krusenstern  National  Monument
     would be unavoidable  within  8  km (5  mi) of the  road.   The relative
     briefness 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.
                                    - 17 -

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F.   Surface of the  Land (Vegetation,  Permafrost,  Soil & Soil  Stability)

     Much  information pertinent to this  item  has been included in  the discus-
     sion  under  item (c) above.   Other effects  include  direct loss of vegeta-
     tion  and  potential  changes  in  the  ground  cover due to  human activity,
     dust  and  compaction.   Road  construction  through the  Monument  would
     destroy approximately  77  ha  (190  ac)  of vegetation;  generally avoiding
     the more  valuable wetland areas.  Any off-road  foot or vehicle traffic on
     snow  covered  ground  might  result  in  compaction and  late  melting or
     impeded  drainage and  increased erosion.   Direct  damage  to uncovered
     vegetation  might  include  breakage  of  plant parts,  depression  of the
     ground  surface, ponding and increased erosion.


QUESTION 18:

A.   Populations of Fish,  Plant, Wildlife, and  Marine Life
     (Threatened &  Endangered Species)

     The  road  would cross the Omikviorok River at least once on  three of its
     five forks and  once on  the upper part of the main stem.   The lower por-
     tion  of  the  river  provides  spawning  and  rearing   habitat  for  char.
     Tributaries  to  the Omikviorok River  would  also  be crossed,  but none of
     these tributaries  is known  to contain  fish  in the vicinity of the road
     crossings.   New Heart Creek would also  be  crossed and is known to con-
     tain  Arctic char.  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  protection of proper crossing site selection,
     crossing design and  construction timing.

     The  road  would cross approximatley 38 km  (24 mi)  of the Monument,  and
     approximately  77 ha (190 ac)  of vegetation  would be destroyed by  actual
     road  construction.  A large percentage of the vegetation destroyed  would
     consist  of tussock tundra,  low shrublands  and complexes  of  both.   The
     more  valuable  wetlands  (e.g.  waterfowl   habitat) would  generally  be
     avoided.  Three candidate  threatened or  endangered  plant  species  had
     the potential for  occurrence in the  project  area,  but none  were  found
     during extensive field surveys from  1981 to  1983.  Impacts are not con-
     sidered  regionally significant as the  loss would  be small,  relative  to the
     total  of similar resources in  the area.  Maximum  dust fall  might occur to
     a  distance of  approximately 300  m  (984  ft) from the  road, impacting
     roadside vegetation.  Mosses and  lichens would  be most  susceptible and
     might,  with  other heath  and  herbaceous  plants,  experience a loss of
     vitality  along  the road.  Other taxa,  for  example cottongrasses,  might
     increase  in  relative abundance in the roadside environment (Brown  et. al
     1980).

     Construction  of the  road  could cause a significant  loss  of  habitat for
     song bird and  small mammal  species,  but it 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.  In-
     direct habitat  loss, however,  would  be of significance on  a greater than


                                    - 18 -

-------
     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  dif-
     fering degrees by avoiding the area.

     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  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 south-
     east.   Road  activity  would  cause avoidance of the corridor, and  hence
     displacement, thereby  limiting  to  some extent the use of otherwise avail-
     able  winter  habitat.  There would also likely  be some  mortality  due to
     vehicle  collisions  or  added  stress from  winter  traffic.   (It  should be
     noted that any  route chosen within the  project area  would have at least
     the same  level of impact or greater.)

     The  Cominco/NANA  agreement  specifically  recognizes the possibility of
     major caribou migration interruptions.   NAN A  has retained the  authority
     to suspend operation of the project during  periods when  caribou  move-
     ments are imminent to minimize  the  possibility  of such  interruptions.

     Two  nest  sites  of the  endangered peregrine falcon have  been reported
     along  the corridor  in  the  Monument.  The  road alignment has  been
     altered to provide a buffer  of at  least 3.2 km (2 mi) around the pere-
     grine nests.   Aside  from  road  construction disturbance that might cause
     nest  abandonment  during  the  first two  years of  project  development,
     long-term  raptor breeding  would  likely not  be  seriously affected by road
     activity because of the distances  from the nests.

     Limited  waterfowl  habitat  exists along  the  southern corridor.  The road
     would  cause  no  significant  direct  habitat  loss,  and  relatively little in
     direct habitat loss.   The major impact would be from long-term increased
     human access to the area, particularly by hunters  or other  visitors  who
     might disturb molting or staging Canada geese.

B.   Marine Mammals

     Not applicable.
                                     -  19  -

-------
    ATTACHMENT B
Access corridor map

-------
          LEGEND
             MONUMENT BOUNDARY

             TRANSPORTATION CORRIDOR
          KRUSENSTERN
cy O i/\ ij *
r^-3^ NATIONAL MONUMENT
RED  DOB  PROJECT

-------
   ATTACHMENT C

Corps of Engineers
     Permit #
 071-04D-2-830359
  Cnukchi Sea 9

  Section 10/404
 Background Data

-------
                         RED 'DOG PROJECT
                    SUPPORTIVE INFORMATION FOR
                404/SECTION 10 PERMIT APPLICATION

                  Reference No. 071-04D-2-830359

                    Waterway No. Chukchi Sea 9


Applicant:     H. M. Giegerich, President,  Cominco Alaska,
               5660 "B" Street, Anchorage,  AK  99502


LOCATION

Work

The proposed project will  include  the construction of a road  and
port site for the Red Dog Mine.  The  road  will  be 56.7 miles  long
vith a  total  of  28 turnouts  (4,000 cubic  yards average fill  per
turnout).   The  turnouts will  be 50 feet  wide and 350 feet  long.
See attached sheets for additional information.   Specific  permits
will be sought later in the permit  process  for the barrow sites.

The average depth of the road  will be  30 feet wide with  6  feet of
aggregate subbase  (3,866,000 cubic yards)   the  exact location of
the barrow  sites  have  not as  yet  been determined.  However,  the
general locations of the barrow sites  are presented on  the  attach-
ed plans. Please refer  to pages 3 and  4 for more specific informa-
tion on barrow sites.

There are a total  of   175  culvert crossings  with each crossing
requiring 1,500 cubic  yards of  material.   There  are  two  bridge
crossings with an  average  fill requirement of  8,000 cubic  yards.
The one major stream crossing  is the Omikviorok River with  a  mul-
tiple bridge span of greater than  100 feet.   See the road  plans
for additional information.
The port will consist of the construction  of  concentrate transfer
facility, dock,  upland  port facility,  and a concentrate  storage
building.

The concentrate  transfer facility will consist  of  ballasting  a
large ship  on the  sea floor  approximately  4,000 feet  offshore.
The ship will be  ballasted in 35 feet  of water and will be  used to
transfer lead and  zinc  concentrate from the  dock to ocean  going
ships.   The  area  dredged for such an action would  be  1,000  feet by
150 feet by  5 feet deep, with the dredged material pumped into the
ship's  wing  tanks to act as ballast (total  of 25,000  cubic  yards).
In  addition,  1,000 feet  to  the  north,   an  area  1,000 feet by
200 feet by  10 feet deep will be dredged to supply ballast  for the
tanker  (total of 75,000 cubic  yards).   There would be no  onshore
storage of dredged material.   (See attached plans for additional
information.)

-------
The dock will be 400 feet long and extend  to  12  feet  of water off-
shore.   Twenty-nine thousand (29,000)  cubic yards  of  fill would  be
needed for  the  dock,  including armor rock located at  the toe  of
the structure.

The upland  port  site  will be  used  as  a  staging area for  concen-
trate  shipping,   the  movement  of  mine   supplies,   and   building
materials.  The pad will be 510 feet by 265 feet and  10 feet deep.
The total fill required is 63,000 cubic yards.

The concentrate storage building will be located on  the excavated
barrow site approximately 2.5 miles from the shore side facility.
The building will be 912 feet  by  180 feet  by  80 feet  tall.    No
fill will be required.

The opening  of  the port lagoon would  require  the dredging of  an
opening which would be 60 feet by 370 feet by 12 feet.  A-total  of
15,000 cubic yards of material would be moved.   This  would  be done
to allow  access to the  lagoon for the construction barge to  be
used :.n ths initia.l development of the road aid port.

Purpose

The purpose  of  the permit request  is  to  develop  a  road and port
for the building and operation of the Red  Dog Mine.   The road will
be an  industrial  use road  constructed  to  carry 150 ton  trucks
which will move  lead/zinc  concentrate  from the mine to the port.
The  road  would  carry up  to  12 truck trips  per  day  plus other
assorted mine related vehicle trips.

The port  would  function  approximately 4  months of  the  year and
would act as the  incoming and  outgoing point for  all material for
the Red Dog  Mine.   Please refer to the Preliminary  Draft  EIS for
additional details.

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Page 3
                          Preliminary Barrow Area Locations Kruz Route
  Borrow
  Site if
Disturbed
Area (Pit)
 (Acres)
Exploration
   Area
  (Acres)
 Average
 Volume
  Req'd
(Cu.  Yd.)
 Average
Exc. Depth
  (Pt. )
Access Rd.   Within 100 yards
 Length       of stream
 (miles)
               48.0
                 211.2       400,043       7.0
                                           0.12
                                           No
               23.4
                 121.6       378,188
                            10.0
                             0.24
                              No
                              140.8
               12.8
                 243.2       248,760      16.0
                                           0.80
                                           No
               34.4
                 192.0
               771,826      14.0
                             0.67
                              No
                               403.2
                                                                       Yes

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Page 4
                          Preliminary Barrow Area Locations Kruz Route
  Borrow
  Site It
Disturbed
Area (Pit)
 (Acres)
 Exploration
   Area
	(Acres)
 Average
 Volume
  Req'd
(Cu.  Yd.)
 Average
Exc. Depth
  (Ft. )
Access Rd.
 Length
 (miles)
Within 100 yards
  of stream
                6.0
                 166.4       195,471
                              20
                             0.30
               12.4
                 147.2       401,669
                              20
                             0.66
                                                                                    No
               13.8
                 217.6       553,140
                              25
                             2.46
                                                                                    No
    10
  15.5
     51.2        322,543
               13
                0.15
                                                                                    Yes
    11
   7.3
     51.2
  70,640
                0.10
                 No
    12
   7.3
     41.6
  70,640
                0.10
                 No
    13
  16.1
     89.6        228,697
                             0.10
                              No
    14
  11.5
     38.4        224,580
               12
                0.05
                 No

-------
                                                                                                       ""' "  R'ED DOG'
                                                                                                           .MINE^SlTE
                                                                                                           DEADLOCK
                                                                                                           MTN_
Vicinity Map
           LEGEND
                                          IPIAV1K
                                          LAGOON'
                                        VARM 28
                                             SITE -
    WONUMEN1 BOUNDARY
    TRANSPORTATION CORRIDOR
                                                                                                Comlnco Alaska
                                                                                                Red Dog Project
                                                                                                Chukchi Sea  0
                                                                                                071-OYO-2-830359
                                                                                                Sheet 1  of 13   1 /
LOCATION MAP

-------
     BALLAST FOR TANKER
    APPROX. 75,000 CU, YQS.
             1 000'
                                                                                               BARGE DOCK

                                                                                                    335'
                                             4" FUEL LINE (NTS)

                                                           SEABED
                                DOCK OVER SHEET  PILES
                                                             OR CONCRETE  CAISSON
                                                                                      EARTH FILL
                                                                                    29,000 cu yds.
                               " .PROTECTIVE
                              CASING (  NTS)
           DREDGE
             CUT  Dredging &  backfill  of trench to
                 involve 12,000 cu. yds. of materia
                                       SECTION ELEVATION (§)

                                            hor. 1" = 170'
                                            ver. 1"= 50'
o
o
o
     PLAN  OF  PORT  FACILITIES
     DEEP WATER DOCK
  •( BALLASTED TANKEp )
BARGE
         ODD   Q LT
       ( See  sheet 10(or
        tanker section )

                  Approximate location
                  undersea fuel line
             1017'
                                                        GENERAL SITE DEVELOPMENT
                                                         63,000  cu yds. FILL
               700'


         BREAK REPRESENTS 2750'
1
550'

•.•_
I
400' '
                                                                  [PORT..LAGOON
                                                   200'       510'

                                                 BREAK~REPRESENTS 500'
              1000'
                   AREA
                                     SEABED
       U8'
     SECTION ELEVATION (A)
 hor.  1"-400'
 ver.  1 " = 40'
NOTES: Port facility location may be slightly
        altered to reduce impact to cultural
        resource site.
SEAPORT FACILITIES
         Cominco Alaska
         Red Dog  Project
         Chukchi Sea 9
         071-OYD-2-83035S
         Sheet 2 of 13   1/8

-------
     CHUKCHI  SEA
NOTE:
     DARK AREA REPRESENTS
     ACTUAL PIT AND WOULD SUPPLY
     ALL GRAVEL NEEDED
     EXPLORATION AREA IS THE
     TOTAL AREA WITHIN WHICH
     THE PIT MAY BE LOCATED

                     PORT SITE  Q±
                                                                                                     Comlnc o Alaska
                                                                                              MILE   Red Dog Project
                                                                                                     Chukchi Sea 9
                                                                                                     071-OYD-2-830359
                                                                                                     Sheet 3  of 13  1/84

-------
             \   v   >x  '"'
             X1..'  '<\  •
grayet pj'1  .. \   .-'    ^
                        Comlnco Alaska

               1 MILE   Red Dog Project

                        Chukchi Sea  9

                        071-OYD-2-830359

                        Sheet 4 at 13 1/84

-------
                  Comlnc o A la s K e      j
0       1  MILE  .  Red  Dog  PrOjec'     j
                  C.luKchiSeaG       (
                  07 1 -0 YD  2- 800.3 f. -  !
                  S h e e t  5  o f 1 3   1 / 8•;   i

-------
                                           gravel pii
                                       Expl/ora/fio
>TgraV^K,
      it
                                       Comlnco Alaska
                              1 MILE    Red  Dog Project
                                       Chukchi Sea 9
                                       07 1-OYD-2-830359
                                       Sheet 6 of 13  1/84

-------
            MILL 5/re
rOA^r
                    Cominco Alaska
           1 MILE    Red  Dog Project
                    ChuKcht See. Q
                    07 1-0 YD-2-83035
                    Sheet 7 oi 13 1/84

-------
                                                       LOCATION
                                  LOCATION DETAIL
                              ACCESS        ROAD
                                         912'0"
                                SECTION ELEVATION
                                          1"=35
FACILITY BUILT ON BEDROCK  OF

FORMER BARROW SITE  AT  PT. (7)'
CONCENTRATE STORAGE

           Cominco Alaska
           Red Dog Project
           Chukchi Sea 9
           071 -U Y U-2-830359
           Sheets  o(13   1/R4

-------
                                                    BARGE
                                                          PORT LAGOON
   PORT SITE
 ( See sheet 2 for detail )
 ORIGINAL GROUND
    SECTION  ELEVATION (B
                                                              " = 300' ( approx.
          = 68'  ver.  1= 40
   ORIGINAL GROUND
ver. 1"=40'
                                          NATURAL BREACH
                                             DREDGE SPOILS
                                              15,000 CU. YDS.
 -15
     o         SHORELINE         570 FEET

       SECTION ELEVATION  (A
       hor.*1" =
1


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3


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                BARGE LAYOUT
                                                                          -b.
                                             NOTE:
20'i
                  ELEVATION
                     1"=50'
                                             12'
                                             20'
                               CONSTRUCTION FACILITIES
                                             Comlnco Alaska
                                             Red Dog Project
                                             Chukchi Sea  9
                                             071-OYD-2-830359
                                             Sheet 9 of 13  1/84

-------
                                           BULK CARRIER
                                                                      {   DRY GOODS  |

                                                                         CONTAINERS  I
    BALLAST
100.000 CU. YDS.
                                                                                                     DELIVERY BARGE
                                                       	I
SEABED,
                 AVAILABLE STORAGE DEPTH-42'
                                                    SECTION ELEVATION
                                                           1"= 120'
n


i~7VL
oc' /ZINC\l
f \
_5' . I

/

*




/

if
i


BALLA
n

— » *—


Rill K
s






T


BALLAST ^

SEABED
J


.
X


t



L-
VF
v
\




UE
OIL

	



Zl

i/
	 „_






— v






f

n

— i t-j—


BULK
                                                                      \ DREDGED PAD TO PRODUCE
                                                                       \25.000 CU. YDS. MATERIAL
                                                                        TO BE  USED AS BALLAST
                                                                        ( vertical exaggerated )
  ( vertical
  exaggerated )
 1 50'
          ' CARRIER
                                                                   1 54'9"
CARRIER
                                                                           DEEP WATER DOCK
                 SECTION ELEVATION (X)
                       1"= 120'
                                         SECTION ELEVATION ®
                                                1"= 120'
                        Comlnco Alaska
                        Red  Dog Project
                        Chukchi Sea 8
                        071-OYD-2-830359
                        Sheet10of 13  1/84

-------
                                                0*00*1
                —  2% DRAINAGE DITCH
  TYPICAL  CROSS  SECTION of BORROW PIT
                       __
                                                                                SLOPE  VARIABLE
                                                                              DEPENDENT ON MATERIAL
                                              CUT SLOPE  VARIABLE
                                                                                 NOTE:
                                                                                 VOLUME  OF OVERBURDEN
                                                                                 NOT AVAILABLE

                                                                                 NO OVERBURDEN STOCKPILE
                                                                                 SHOWN AT THIS TIME
                                                                                TYPICAL BORROW PI
                                                                                       SEC/0 N & PLA
TYPICAL PLAN of BORROW PIT
Commco Alaska
Red Dog Project
C h u K c f- 1 Sea 9
07 1-OYO-2-83GJf

-------
                                                                                                     •fi^r" vj-f^
                                                                                                           I'/ X
                                                                             AVG. CROSSING  8000 cu.yds. Fill
 GRADED ROCK
 PROTECTION  AROUND
 CULVERTAS REQUIRED
                               TYPICAL  BRIDGE  CROSS SECTION
                                 SCALE :HOR. 1 '=20'   VERT. 1 "=1 0'
                                      30
      NATURAL STREAM SLOPE
               TYPICAL SIDE  SLOPE

                     2
CORRUGATED GTEEL  CULVERT
TYPICAL  ROAD CROSS SECTION SHOWING  TYPICAL  CULVERT
                                             ^15   AVG  1500  cu. yds of fill
EXPLANATION  of  ROAD

56.7 MILES  LONG,30' NOMINAL WIDTh
  W/GRAVELED SURFACE & AVG.
  6' SUBBASE of GRANULAR FILL

TOTAL FILL .  3.866.000  cu. yds
TOTAL CULVERTS : 175

TOTAL TURNOUTS : 28
 - 4000 cu.  yds. FILL
 - DIM. 50'  WIDE X 350'LONG
  PER TURNOUT
MAJOR BRIDGES  ONE

CROSSING  of RIVERS  &  STREAMS :
 -OMIKVIOROK RIVER
                Co m i(ic u Alaska
                Rod Hog P r 0 | (i c !
                Chukchi So ii 9
                S h f o t 1 2 ^ ' 1 3  1 / 8 '
                                           BRIDGE&ROAD
                                        CROSS SECTIONS

-------
                                               SLOPE
                                                            \x\\\\\\ J
       \  \   \   \
                                                   350'-
                                                 ROAD
                                                                                        \  \
                                                                                           30'
/  /////////   ////////  /  /   /
                                       SL
                                               SLOPE
                                                                         s  /  /  /  //  ///  //
                                       TYPICAL PLAN OF  TURNOUT
                                               SCALE 1' 60'
                                                                                   NOTE:
                                                                                       REFER TO SHEET 2 of 13
GRADED ROCK PROTECTION
    AROUND CULVERT
                                   -20-
                                                                                  TYPICAL SIDE SLOPE
                                        NATURAL STREAM SLOPE

                           TYPICAL CROSS  SECTION OF TURNOUT
                                                N.T.S.
                                                                                    Commco Alaska
                                                                                    Red Dog Project
                                                                                    Chukchi Sea 9
                                                           CROSS SECTION & PLAN 0/1-0x0-2-330359
                                                                       TYPICAL TURNOUT

-------
         ATTACHMENT D
Environmental Protection Agency
   NPDES Permit Application
          (Port Site)

-------
                                  i. A7/CV.-L POLL'JTAU'T DlKCHifVC.r  £ : L IV.IVM I OK SVSTEM
                                   . ": _.:.-T;C.-. .-!-.-. "-LF.V TC- r.'T ."•-••- -:::f r. AST £ •.•:;* TSR

                            STANDARD  FGFNVi C -  .V.A.'v'UFACTURUvG  AND COMMERCIAL
                                     ScCTlC'J I.  APPLICANT AfCD ?ACIUTY DESCRIPTION

          Unfrli otfie/**>tt« to*:***tS C* "Ml iCkfT' 'II items *»t if. t>* € c.T*.3»»»«C H *•• tlttr. «» no:  4DDl*c*D«t inaicite *ICA«.*

                                                               IN SC^AHATC IMJT nuCTiO'v- BOOKLET AS i«O«CAT£o.
              I(MST«UCTIO:»'S TO5* SfLECTEO irre.-.S
eOOKLET BEFORE FILI-IN'C Oi.'" THESE ITEK'.S.
                                                                                                                           TO
     t.
            *l N»»T*€ ol
            in(trucc« Intiructioml
          Number t Street

          City

          Stale

          Zip Cod*

   9.  AppllcantH Authorize* A tent
       (Me Inctrwetlorx)
         Name and TKU
         Number t. $tr«*t Addrcii

         City

         State

         Zip Cod*

        Telephone

  4.  rVerl»u« AppllcatUn
      If • prevlouc appl>caer*on Slgnlnf
/ ' -
-— i/^y -* -{

I0i.


1OSI

Title

YR MO DAY

           Slf nature of
                          cant or Authorized
                                                                                    Date Application Slf ned
 IS U.S.C Section JOOJ providet thit:
 Whoever, in iny miner within the ivritdietion ofiny defurtment or ifrney of the United Stitet lno*-in[ly ind wilfully ftltifiet. eonccelt or
eooert up by iny trick, ffheme. vr device » miterttl/iel. ormekei inyfilte. ftetitiaui or fraudulent tlitement or repreuntition, or mikei or
me* inyfilte writing or document knowing time loeontiin iny filte. fictitiout or fraudulent ttilemenl or entry, tkittte fined not more thin
110.000 or imp/ironed not more thin five yetn. or both.
         YP  MO
                                                        AGENCY USE
                                                         1-1
                                                                                    OFFICE- 	Cf*> *ef.o« Uu-

                                                                                             	Stait

                                                                                     TVif* tfdion r/v.umi .> p*(

-------
          Bom Public *ni- Pxxtc)

          Crteck block •:  Fcdcfat facility
          *c»a pivr GS£>  mwrntory Control
         Location
          &«««( & Numocf


          CISy

          County


          State


  C.   Mature •» Bu
      tlor»|  Indicate water Intake volume
      per day by touree*. Ertlmate
      aver*fe volume pe* day In thoutand
      gallon* per day.

       Municipal or private water >y*tem

       Surface water

       Ground water

       Oliver*
      Total Item 7

   *lf there l< Intake water from
    •other.* apeclfy the fource.


i.   raclllty Water tta*  Cttlmate
    averafc volume per day In thouund
    f allonf per day for the fotlowlnf
    type* of water uca** al the facility.
    (uc Initructloni)
  •—  Noncontact coollnf water

      Boiler feed water

     Proccti water (Includlnf contact
     coollnf water)

    Sanitary water

    Other*

    Total Item •

  •It Iher* a«* dl»char*et to
  •other/ ipeclfy.

  if tne•' wale' UM. f
-------
no
             /.. ' .-:•• :r r—:-'-  - •-
                  w,*ir» iti-t »;••". t v !'. f
                            r»p r*s **'it^ no
           cffft/ent
          Wctt Injection
         Other*

         Facility titicnc?e«* xnd
         ToUl J*em 9,
             *H «xl
I
j

tOitl
icst:

S;'h,:-

• to*}', :
•tO*k» J
.-loin "j
.;<••;- -4
: i
'
,

;





i

\ T5ar
I 	
i

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— —
;-•.•••"•'•:<*>' ---'.\






• for Apency U«*
-^ ,-S(b> -^«f^
-i'!:-: .::;tSl
v™r-';.-y^«|

' t*' . *
d


Type of l»*fmlt
• of LJctnM
^^K
-------
                                                                                                               I-'OKM APPROVED
                                                                                                               OMB No. 158-R0100
FOR AGENCY USE









                         STANDARD  FORM C - MANUFACTURING AND COMMERCIAL
                                       SECTION II.  BASIC DISCHARGE DESCRIPTION



  Complete this section lot each discharge indicated in Section I. Item 9. Hut is lo surface waters.  This includes discharges to municipal sewerage
  systems in which Hie waslcwalcr does not go through a treatment works prior to being discharged to surface waters.  Discharges to wells must
  be described where there are also discharges to surface waters from this facility.  SEPARATE DESCRIPTIONS OF EACH DISCHARGE ARE
  REQUIRED EVEN IF SEVERAL DISCHARGES ORIGINATE IN THE SAME FACILITY. All values for an existing discharge should be repre-
  sentative of the twelve previous months of operation.  If this is a proposed discharge, values should reflect best engineering estimates.
  ADDITIONAL INSTRUCTIONS FOR SELECTED ITEMS APPEAR IN SEPARATE INSTRUCTION BOOKLET AS INDICATED. REFER
  TO BOOKLET BEFORE FILLING OUT THESE itEMS.
  1.   Discharge Serial No. and Name

      a.  Discharge Serial No.
         (see instructions)
      b.  Discharge Name
         Give name of discharge, if any.
         (see instructions)

      c.  Previous Discharfe Serial  No.
         If previous permit application
         was made for this discharge (see
         Item 4. Section I), provide previ-
         ous discharge serial number.

 2.   Discharge Operating Dates

      a.  Discharge Began Date  If the
         discharge described below is in
         operation, give the date (within
         best estimate) the discharge
         began.


     b.  Discharge to Begin Date  If the
        discharge has never occurred but
        it planned for tome future date.
        give the date (within best  esti-
        mate) the discharge will begin.

     C.  Discharge to End Date  If dis-
        charge ft scheduled to be discon-
        tinued within the next S years,
        give the date (within best esti-
        mate) the discharge will end.

 3.   Engineering Report Available
     Check if an engineering report Is
     available to reviewing agency upon
     request, (see instructions)

 4.   Discharge Location   Name the
     political boundaries within which
     the point of discharge is located.

             Slate

             County

     (if applicable) City or Town


S.    Discharge Point Description
     Discharge is into (check one):
    (see  instructions)

    Stream (includes ditches, arroyot,
    and other intermittent watercourses)

    Lake

    Ocean

    Municipal Sanitary Wattewater
    Transport System

    Municipai Combined Sanitary and
    Storm Transport System
 EPA Form 7550-23 (7-73)
  20ta
                                          lOlb
 ZOIC
 2021
 lOZfc
 Z02C
 201
204a

204b

204C
lOSa
           001
                                                    DOMESTIC WASTEWATER TREATMENT
 88   6
  VR  MO
          VR  MO
          YR  MO
                                                                               Agency Use
                 Alaska
         NAMft  yonion
Z044

204*

204f
QSTR

DLKE

SflOCE


DMTS
                                                               II-I
                                                                                                    T/ii« feel ion contains 9

-------
                                             DISCHARGE SERIAL NUMUER
     Municipal Storm Water Transport
     System

     Well (Inicction)

     Other

     If 'other' is checked, specify


 G.   Discharge Point — Cat/Long  Give
     the precise location of the point
     of discharge to the nearest second.

       Latitude

       Longitude


 7.   Discharge Receiving Water Name
     Name the waterway at the point
     of discfiarge.fsee instructions)
If the discharge is through an out-
fall (hat extends beyond the shore-
line or is below the mean low
water line, complete Item 8.


• .  Offshore Discharge
    a. Discharge distance from Shore

    b. Discharge Depth Below Water
       Surface
9.  Discharge Type and Oc
     a.  Type of Discharge  Check
        whether the discharge Is con-
        tinuous or intermittent.
        (see Instructions)

     b.  Discharge Occurrence Days per
        Week  Enter the average num-
        ber of days per week  (during
        periods of discharge)  this dis-
        charge  occurs.

     C.  Discharge Occurrence —Months
        If this discharge normally
        operates (either intermittently,
        or continuously) on less than
        a year-around basis (excluding
        shutdowns for routine mainte-
        nance), check the months dur-
        ing the  year when the discharge
        is operating, (see instructions)

 Complete Items 10 and  11 if "inter-
 mittent" is checked in item 9 .a.
 Otherwise, proceed to Item 12.


 10.  Intermittent  Discharge Quantity
     State the average volume per dis-
     charge occurrence In thousands of
     gallons.

 II.  Intermittent  Discharge Duration
     and Frequency
     a. Intermittent Discharge Duration
       Per Day  State the average
       number of hours per day the
       discharge  Is operating.

     b. Intermittent Discharge
       Frequency  State the average
       number of discharge occur-
       rences per day during  days
       when discharging.


12.  Maximum Flow Period Give the
     time period in which the maximum
     flow of this discharge occurs.
        DSTS

        QWEL

        DOTH
FOR ACENCV USE








20SP
ZOCa
ZOCb
207*
207b
20la
                                         20«b
                                         201*
                                         20»b
                                         io»e
                                         219
                                         2111
                                        2 ltfc
                                        lit
           67  PF«    1$_MIN
         164
               PEG
                                                                                   -SEC

                                                                                   -SEC

For Agency Use
Mai or

Minor

Sub


20TC
For Agency Use

303*


           500
                     .feet
            14
                                                              .feet
       JQC(con) Continuous

       D (int) Intermittent


       	days per week
        OJAN,  QFEB   OMAR    CD APR
        OMAV* XD-iuN   QJUL     SAUG
                QOCT   ONOV    Ooec
                                                               .thousand gallons per discharge occurrence.
                                                    .hours per day
                                                    -discharge occurrences per day
       f—July .„ Oct
             month    month

-------
                                        DISCHARGE SERIAL NUMBER
                                                                                             FORM A PPRO VED
                                                                                            OMB No. 158-ROIOO
FOR AGENCY USE








 13. Activity Oetcrlplion  Give a
    narrative description of activity
    producing this discharge.(see
    instructions)
UP TO  20  PEOPLE  (NORMALLY 14)  WILL BE  ACCOMMODATED

AT THE PORT  SITE DURING THE  SHIPPING SEASON.   DOMESTIC

WASTEWATER WILL BE GENERATED IN  THE KITCHEN,  SHOWER,  &

SANITARY  FACILITIES WHICH WILL  BE  A PART OF THE  CAMP

ACCOMMODATIONS.   THESE WASTEWATERS WILL BE COMBINED &

TREATED PRIOR TO DISCHARGE.
14. Activity Causing Discharge For
   each SIC Code which describes
   the activity causing this discharge,
   supply the type and maximum
   amount of cither the raw material
   consumed (Item Ma) or the product
   produced (Item 14b) In the units
   specified In Table I of the Instruc-
   tion Booklet. For SIC Codes not
   listed In Table I. use raw material
   or production units normally used
   for measuring productlon.(iee
   Instructions)
a. Raw Materials
Maximum Unit Shared Discharges
SIC Code Name Amount/Day (See Table 1) (Serial Number)
tt4a - - |1) ., . .-. •;. •..- „;





*t£.'->.>'/fe' 'fM'iS^^S&Sfe,





> - • - - .'3»>XCx«i £f J|<* ' •?*!





• f4»'^.- -.-•.=





, .(Sf.' - -. " :.,-•.'*





b. Products
Maximum Unit Shared Discharges
SIC Code Name Amount/Day (See Table 1) (Serial Number)
*I4» (1)




121




'•• '•• - ' „<*»




14)




'S)





-------
                                         DISCHARGE
FOR AGENCY USE









 IS.  Wjitc Abatement
     a. Waite Abatement Praclicei
       Describe the waste abatement
       practices used on this discharge
       with a brief narrative, (see
       Instructions)
    b. Waste Abatement Codes
      Using the codes listed In Table
      M of the Instruction Booklet.
      describe the waste abatement
      processes for this discharge In
      the order In which they occur
      If possible.
lisa
                                   ItSb
 Narrative: WASTEWATER WILL  BE COLLECTED IN A  COMMON  SURGE

TANK  AND  TREATED  BY  EXTENDED AERATION.   THE SOLIDS WILL

BE  SETTLED IN A CLARIFIER 6  AEROBICALLY DIGESTED PRIOR

TO  DISPOSAL.   THE CLARIFIER  OVERFLOW WILL BE  DISINFECTED

AND DISCHARGED TO THE SEA.	
       (1)
       (4)  PSRDTM

       (7) 	

      (10) 	

      (13) 	

      (16) 	

      (19)	

      (22) 	

      (25) 	
 (2)



 (8) .

(11)

<1<)

(17) .

(20) .

(23).
                                                                   PAERAT
                                                  ,BACTiy
                                          (3)1

                                          (6) RAPRfm

                                          (9) 	

                                         (12) 	

                                         (15) 	

                                         (18) 	

                                         (21) 	

                                         (24) 	
EPA Form 7550-23 (7-73)
                                                    II-4

-------
                                               DISCHARGE SERIAL NUMBER
FOKAf APPROVED
OMU No. 158—ROIOO
FOR AGENCY USE









1C. Wattewater Characteristics


Check the box beside each conttltuenl which it present In the effluent (discharge water).  This determination Is to be based on actual analysis
or best estimate.(iee Instructions)
Parameter
216
Color
00080
Ammonia
00610
Organic nitrogen
0060S
Nitrate
00620
Nitrite
00615
Phosphorus
00665
Sulfate
00945
Sulfidc
00745
Sulfite
00740
Bromide
71870
Chloride
00940
Cyanide
00720
Fluoride
00951
Aluminum
01105
Antimony
01097
Arsenic
01002
Beryllium
01012
Barium
01007
Boron
01022
Cadmium
01027
Calcium
00916
Cobalt
01037
Chromium
01034
Fecal coliform bacteria
74055
X
w
oT

X

X
X
X

















X
Parameter
216
Copper
01042
Iron
01045
Lead
01051
Magnesium
00927
Manganese
01055
Mercury
71900
Molybdenum
01062
Nickel
01067
Selenium
01147
Silver
01077
Potassium
00937
Sodium
00929
Thallium
01059
Titanium
01152
Tin
01102
Zinc
01092
Algicides*
74051
Chlorinated organic compounds*
74052
Pesticides*
74053
Oil and grease
00550
Phenols
32730
Surfactants
38260
Chlorine
50060
Radioactivity*
74050
Present



















X


X

                  •Specify substances, compounds and/or elements in Item 26.

                  Pesticides (insecticides, fungicides, and rodenticides) must be reported in terms of the acceptable common
                  names specified in Acceptable Common Namet and Chemical Nemet for the /ngredient Statement on
                  Petticide Labflt. 2nd Edition. Environmental Protection Agency. Washington. D.C. 20250. June 1972. as
                  required by Subsection 162.7(b) of the Regulations for the Enforcement of the Federal Insecticide,
                  Fungicide, and Rodenticide Act.
                                                              II-5

-------
                                                           DISCHAHGE StRIAU NUMBER
FOR AGENCY USE









      17.  Description of Intake and Oltcharge
          For each of the parameters listed below, enter In the appropriate box the value or code letter answer called for.-• Analysis










|,_ Number of
•— Analyses









3 Sample Type









     'Other discharges sharing intake (low (serial numbers).(see instructions)
EPA F~m 7550-23 (7.73)
                                                                     II-6

-------
                                                                                                                FORM APPROVED
                                                                                                                OMB No.  tSS-ftOIOO
                                                   DISCHARGE SERIAL NUMBER
FOR AGENCY USE

'* '.
.;






 17.  (Conl'd.)
Parameter and Code
JJ&
Ammonia flnfilf) 	
Oil s Grease 00550
rhlnrine 5Q06Q




Influent
Untreated Intake
3 Watel
(Daily Average)
NA
NA
NA




In-Plant Treated
2 Intake Water
(Daily Average)
NA
NA
NA




Effluent
1
O
>
<
JK
"«
a
(3)
5.0
LT 5.0
2.0




Minimum Value
Observed or
2 Expected During
Discharge
Activity
3.0
LT 5.0
1.0




Maximum Value
^ Observed or
-" Expected During
Discharge Activity
10.0
5.0
3.0




^ Frequency of
•^ Analysis







9^ Number of
— i
— Analyses







w Sample Type







1*. Plant CenlroU  Check If trie fol-
    lowing plant controlt are available
    for thlc discharge.
    Alternate power source for ma|or
    pumping facility.

    Alarm or emergency procedure for
    power or equipment failure

    Complete Item 19 If discharge Is
    from cooling and/of steam water
    generation and water treatment
    additives are used.
If. Water Treatment Additives If the
    discharge Is treated with any con-
    ditioner. Inhibitor, or alglclde.
    answer the following:
    a.  Name of Materlal(s)
    b.  Name and address of manu-
       facturer
       Quantity (pounds added per
       million gallons of water treated).

-------
                                                      DISCHARGE SERIAL NUMBER
FOR AGENCY USE









       d.  Chemical composition of these
          additives (see Instructions).
  Complete Items 2O-25 If there Is a thermal discharge
  (e.g.. associated with a steam and/or power generation
  p!ant. steel mill, petroleum refinery, or any other
  manufacturing process) and the total discharge ftow is
  10 million gallons per day or more,   (see Instructions)
  20.  Thermjl Discharge Source  Check
       the appropriate item(s) Indicating
       the source of the CUcharg*.  jsee
       instructions!

       Sotler Slowdown

       Boiler Chemical Cleaning

       Ash Pond CK'erfiow

       Bo!!c' Water Treatment — Evapora-
       tor Slowdown

       O'l or Coai K!fe?tweei* the discharge
      and itxelvlnjf waters for summer
      t^-t winter opef»t!r*g cor«dtHor*s.
                    (sea Instructloncj
        Winter


 22*  Discharge TcmpcrJiurft^ Aa*e of
      Chang* Per Hour

      Civs tha maximum possible rate oi
      tt^ip«ratur« charts* P«r hour ot
      discharge under operating con-
      ditions.  (se« Instructions)


 23.  Wa*«;p' Temperature. ^erccntiJe
      Report (Frequency of Occurrence)
      Ir. th« ! »Dlc below, ir-tcr the
      iemperj!tur« which U «x£e«ded 10%
      of th« y«ar. S% o» th« year, 1% of
      trve year and not at all (maximum
      yearly Ump«fMur«!.  (M« Instructions)
     Frequency of occurrence

     «.   Intake W«t*i Tamp«rature
        (£ut>)ect to natural change*)
     b.  Discharge Water Temperature


24.  Wattr Intake Velocity
     (see Instructions)

2S.  Retention Time  Give the length of
     time. In minutes, from start of
     water temperature rise to discharge
     of cooling water. («*• Instructions)
                                            221«
          QBLBO
          DBCCL
          OAPOF
          OEPBO

          QOCFP

         OCONO
         DOTHR
 222
224


221
                 °F./hour
10%
°F
°F
5%
°F
°F
1%
°F
°F
Maximum
°F
°F
_feetAec.

.minutes
EPA Perm 75SO-23 (7-73)
                                                                 II-8

-------
                                                                                                               FORM APPROVED
                                                                                                               OMO No. 1S8-K010O
                                                     DISCHARGE SERIAL NUMBER
FOR AGENCY USE








   2C. Additional Information

226:         Item
                                                                      Information
                                                                                                                     CPO mam.at A

-------
       ATTACHMENT E
 An Economic Evaluation of
Alternative Road Routes from
RED DOG to a Road/Marine
     Transhipment Site

-------
                     TABLE   OF   CONTENTS

                                                                  Page No.

LIST OF FIGURES 	    1
  I.   INTRODUCTION
          Purpose and Outline of Report
 II.   DESCRIPTION OF PROPOSED ROAD ALTERNATIVES
       0  Identification of Alternatives Considered
       0  Description of Selection Procedure
       0  Derivation and Definition of Design Parameters
       0  Discussion of Engineering Constraints

III.   COST ESTIMATES	   18
       0  Basis of Estimate
       0  Audit
          Estimate for Asikpak Route
       0  Estimate for *ruz Route Using Borrow Sources
          Inside the National Monument
       0  Estimate for Kruz Route Using Borrow Obtained
          Outside the National Monument

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                              LIST OF FIGURES

                                                                 Page Mo.

Figure  1   °    Preliminary Selected Route Options                  4
        2   °    Engineering Constraints                             5
        3   °    Hunting  and Trapping Constraints                    6
        4   °    Fish  and Game Constraints                           7
        5   °    EIS Selected Route Options                         9
        6   °    Design Vehicle (Concentrate Truck)  and
                 Module Transporter                                 11
        7   °    Road Cross Sections                                13
        8   °    Proposed Borrow Pit Locations                       14
        9   °    Typical  Bridge Details                              16
       10   °    Typical  Culvert Details                             17

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I.   INTRODUCTION

     The purpose of this  report is to provide  route selection and  engi-
     neering data sufficient to permit a detailed  independent  review.

     The report  outlines  the cost  of constructing  and  operating a  road
     from Red Dog to a  port  on  the Chukchi Sea.   The alternative routes
     investigated are  identified  and the  selection procedure  described.
     In addition, the report defines the environmental constraints,  basic
     engineering design parameters and basis of estimate.

     Throughout this report geographical identification  is  based  on  phys-
     ical features  and  settlements named  on  the  U.S.  Geological Survey
     1:63360 scale mapping.

-------
II.   DESCRIPTION OF PROPOSED ROAD ALTERNATIVES
      The Red Dog deposit is  located  in  northwest Alaska approximately 90
      miles north of Kotzebue and 70 miles east  of Kivalina.   The deposit
      is  on  the west  side   of  Deadlock Mountain  and straddling  Red  Dog
      Creek.   A suitable mill site has been identified on a low hill 1-1/2
      miles west of the deposit at an elevation of 1050 feet.   This is the
      designated inland terminus  for  all  the alternative  road  routes  in-
      vestigated.

      Four possible  port  sites on  the  Chukchi  Sea have  been identified,
      together with two road vehicle  to barge transshipment  sites on  the
      Noatak River.  These are located as follows (see Figure 1):
        Port Site 1
        Port Site 2
        Port Site 3
28 miles  northwest of  Kivalina village,
between Singoalik and Pusigrak lagoons.

16 miles  northwest  of Kivalina  village
and immediately south of Tugak lagoon.

Located 10  miles  southeast  of  Kivalina
village at  VABM 17, between  Imikruk  and
Ipiavik lagoons.
        Port Site 4
Located  16
village  at
mouths   of
Creeks.
miles  southeast  of  Kivalina
VABM  28,  midway  between  the
 New  Heart   and  Umagatsiak
        Transshipment Site 1 —  On the Noatak River at Noatak village.
        Transshipment Site 2 —
At the Fish hatchery on the Noatak River,
19 miles  south  of Noatak  village and 10
miles   above  the   confluence   of   the
Agashashok River.

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II.   DESCRIPTION OF PROPOSED ROAD ALTERNATIVES (continued)

      Engineering and environmental  constraint maps were  prepared incor-
      porating existing data and  the  results  of field work carried out by
      Cominco's consultants.  (For much simplified versions of these maps,
      see Figures 2, 3,  and 4).   Using these maps along with U.S. Geologi-
      cal Survey 1:63360 scale mapping  numerous possible routes and route
      segments were defined (see Figure 1).

      For each of these routes,  the  alignment has been  plotted on 1:63360
      scale mapping or enlargement of this mapping and for the majority of
      routes profiles were also prepared.

      A  preliminary  engineering  evaluation  was  carried  out  for   each
      route.   This  evaluation  included  an  estimation  of  route length,
      determination  of  terrain  characteristics by segment, calculation of
      approximate fill quantities, preliminary  sizing of major bridges and
      an  estimation  of  minor bridge  and  culvert  requirements.   From  this
      data,  preliminary cost  estimates  were  prepared.   A  preliminary
      selection  was  made   using  these cost estimates  in conjunction  with
      the constraint mapping and additional field reconnaisance.

      All of  these  routes  were  reviewed by  the  Environmental  Protection
      Agency  and the Department  of   the  Interior.   The KRUZ and ASIKPAK
      route  options  were  selected by  these  agencies   for  more   detailed
      study  (Figure  5).    The  Environmental  Impact Statement  should be
      referred to for a detailed  description  of this selection procedure.
      In  addition,  further  studies  were  carried  out by  Cominco and  the
      Environmental Protection Agency's E.I.S.  contractor  of the  logistics
      and  costs  of  the   road/barge/bulk  carrier  transshipment  via  the
      Noatak River.

-------
                                    L'^i^^?!0-;^ -is ^^--l^ -Jl',"'"-'
                                    »»• .  x~%^ "" %  ('' —^="i"5-   i1—""" -~ ^
                                     f*\~~"^ -N' •4r--i** . .^jfitfnOCLL— -.-
             MAJOR  BRIDGES  —


             MINOR  BRIDGES  	  •
PRELIMINARY  SELECTED  ROUTE  OPTIONS
 PORT 3V

VABM 28
                                                                                                                                    NOATAK

                                                                                                                                    VILLAGE

-------
                                            STEEP
                                        Q  WETLANDS
                                        D  *UFEIS  ZONE
                                            VISIBLE PERMAFROST
                                                  CONDITIONS
TRANSPORTATION   ROUTES
       ENGINEERING   CONSTRAINTS
HOODPLAIN
BORROW PITS
MINOR STREAM CROSSING
MAJOR STREAM CROSSING
                                                              FIGURE   2

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                                         6
TRANSPORTATION  ROUTES
HUNTING &  TRAPPING CONSTRAINTS
                               tr i /^ 11 «•»

-------
TRANSPORTATION  ROUTES
   FISH ft GAME CONSTRAINTS
                         FIGURE 4

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II.   DESCRIPTION OF PROPOSED ROAD ALTERNATIVES (continued)

      At  this  point,  engineering  design  parameters  were  reviewed  and
      refined  to  form  a  basis  for more  detailed evaluation  of the  two
      selected routes.  These parameters are as follows:

      0  Road design speed - 30 mph.
      0  Road width - 30 feet.
      0  Design vehicle is  the  proposed concentrate haul truck/a tractor/
         double trailer, side dump  vehicle of  443,000 Ibs GVW  and maximum
         tandem axle loads of 109,500 Ibs.  (Figure 6).
      0  Crossfall 3% either side of center  line.
      0  Side slopes 2:1 minimum.
      0  Maximum grade 4%.
      0  Maximum grade change 4%.
      0  Minimum radius of horizontal curvature 400 feet.
      0  Minimum radius of vertical curvature  1500 feet.
      0  Thaw settlement of subgrade 6  inches  maximum.
      0  Passing turnouts (50 feet  total  road  width)  at 2 mile  intervals.
      The  road must  also  be capable  of handling  the  movement of  plant
      modules  of  up  to  1500 tons weight  during the construction  period.
      These  modules  will be  moved on  multi-wheeled,  hydraulic  levelled,
      purpose  made  transport vehicles  (Figure  6).    Maximum  speed  when
      loaded  will  be  approximately  5 mph.    Side  clearances  must  be
      sufficient  to  permit movement  of  modules  up to  70  feet wide.

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ROUTE  OPTIONS

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                                                                                1(
II.   DESCRIPTION OF PROPOSED ROAD ALTERNATIVES  (continued)

      At stream  and river  crossings,  two  approaches  to  module  movement
      have  been  considered.    Modules  may  be  transported  through  the
      streams at  low  water using  temporary diversion  roads  and  fords  or
      alternatively,  bridges  would  be  strengthened  to  sustain  module
      loads.  Either of the approaches would be  viable  for  the Kruz  Route,
      however, on  the  Asikpak  Route, fording  the  major rivers may  not be
      practicable and strengthening of the  longer span  bridges will  result
      in significantly increased costs.
      The maximum grade of 4% was adopted to accommodate movement  of  plant
      modules and to permit possible future reuse  of  the grade  for a  rail-
      road.  In general,  grades will  be easier than the maximum,  particu-
      larly on the Kruz  route  where maximum grades only exceed  1-1/2% for
      short distances.   The maximum 4% grade will  be  adopted in  areas  of
      more  difficult terrain  on  the  Asikpak  route  and  on  both  routes
      locally at stream crossings.
      The use of  4% grades for  a  railroad will  generate  operating  diffi-
      culties and high operating costs.   Industry practice for a  railroad
      of this type  would  be  to  limit grades to 1-1/2% which  will  signifi-
      cantly  reduce  operating  costs  but  at  the  expense  of   increased
      capital  cost.   Studies   indicate   that  1-1/2%  grades  will   offer
      economic  benefit where  profile  improvements are  required  in  the
      vicinity  of  stream  crossings only.    The  easier  terrain of  the Kruz
      route option would permit cheaper conversion  to a railroad.
      Both  routes  lie within  the zone  of continuous  permafrost and  all
      soils and bedrock  are  expected  to be permanently frozen.   Available
      thermistor data shows temperatures  from 32°F  to  27°F indicating  a
      relatively warm permafrost.   The active  layer  is  expected  to  range
      from 1-2 feet thick on poorly drained soils  to  a maximum  of 4-5 feet
      on well-drained upper slopes.

-------
                                                                11
  19,900 LBS
98.600LBS
109.500LBS   105.500LBS
601'
4
1
, ]
18011
»
I '
180"
192 "
/
i l 11 :
I T t f '
V
63"
f
109.500LBS
               CONCENTRATE   HAULER - 150 tons
TRACTOR
                      20 WHEEL  AXLES  AT s'-O1' CENTERS
          158,733 LBS
            (TYP.)
                       MODULE    TRANSPORTER
                                                   FIGURE  6

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II.   DESCRIPTION OF PROPOSED ROAD ALTERNATIVES  (continued)

      From  an  engineering  point  of  view,  the  most  acceptable  thermal
      regime is  expected to occur  on well  drained,  gently sloping  north
      facing slopes.

      Preliminary thermal  analyses  have  been  carried  out  which  indicate
      that a minimum fill depth of from 5 feet to 6.5  feet  will  be requir-
      ed to limit thaw  settlement to 6 inches.   Determination of  minimum
      fill  depth for detailed  road  design will  be based on  the  results  of
      the Geotechnical  Investigation which will  define  terrain,  underlying
      soils, ground  thermal  regime  and  micro-climate  variations.    It  is
      anticipated that  minimum fill   depth  will  vary  along  the length  of
      the road.

      The estimates  have been based  on  a minimum fill  depth  of 6.5  feet
      with  an alternative  composite  construction  comprising  2  inches  of
      rigid insulation  with  a 2  feet minimum thickness  of granular  fill
      topping.    Thermal  characteristics   of  both  Asikpak and  Kruz routes
      are expected  to  be similar and  so  these  sections have  been  adopted
      for both  routes (Figure 7).  The composite  section will  be  utilized
      only  where haul distances from borrow sources are long enough for  it
      to offer  a cost advantage.

      On the Asikpak and Kruz  routes  it  is anticipated  that cut and  fill
      construction  will  only  be  possible  within   the  final  8   miles
      approaching Red Dog.

      Proposed  borrow pit  locations  have  been determined by reference  to
      U.S.  Geological Survey  mapping, aerial photography  at 1:12000, re-
      ports  and terrain  unit mapping  based on field work carried out for
      Cominco  by  Dames  and  Moore and  supported by  field   reconnaissance
      (Figure 8).

-------
                                       13
                  £>''." 5'' Klisl'i
                  i=-luU
   FILL  CROSS SECTION
COMPOSITE  CROSS  SECTION
   TYPICAL  ROAD SECTIONS
                             FIGURE 7

-------

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                                 ^.^•"*  "*-v-c[r-~--r-5---"-"-r---"-*-" -r-_."'
                                          Vf~ ••=•-:----ii -.-•--"--•-.--
PROPOSED  BORROW PIT  LOCATIONS
 >N^
-v
                                                                                                               
-------
                                                                                15
II.   DESCRIPTION OF PROPOSED ROAD ALTERNATIVES  (continued)

      All water courses  crossed by the selected routes  have been  identi-
      fied, their drainage  basins  defined  and areas measured.  Peak  flows
      at  each   crossing  were   calculated  using  peak  unit  flows  of  80
      cfs/sq. mile  for drainage basins  smaller than  10  sq. miles and  55
      cfs/sq. mile for drainage basins exceeding 10 sq. miles.  Lengths  of
      bridges were  calculated   using  a  peak  flow of  5 fps and an  average
      water depth of  4 to 5 feet.   Bridges  have been used wherever  peak
      flow exceeds 800 cfs.  Culvert  sizes are based  on capacities  ranging
      from 10 cfs for 24-inch diameter to 710 cfs for  120-inch  diameter.

      Bridges are designed  using standardized decks suitable for spans  of
      50 to  60  feet with  a width  of 30 feet  face  to face  of  guardrails.
      These units would be utilized wherever possible.  Construction  would
      consist of  steel beams  supporting  composite  precast concrete  deck
      slab units  with abutments and piers  of  steel   adfreeze  piles  into
      permafrost  (Figure  9).   Pier  design  would be  modified  wherever  a
      significant thaw bulb exists.

      Culverts  would  be  galvanized corrugated steel  pipe  with  rip-rap  or
      similar protection  to side  slopes  adjacent to  the  crossing.   Cul-
      verts (48-inch  diameter)  would be provided at  all  well-defined  dry
      swales  and  in addition 24 and 30-inch  diameter  culverts  are  allowed
      for at a  nominal spacing  to handle sheet flow and roadway runoff
      (Figure 10).

      Preliminary engineering studies and all engineering  for the Southern
      Route options were carried  out for Cominco  by R&M Consultants  of
      Anchorage.   Engineering   for  the  Northern  and  Noatak Route  options
      has been  carried out by Cominco Engineering Services  Ltd.  A  consis-
      tent methodology has been used  throughout.

-------
 BRIDGE  SECTION
                               16
                           d)

                           5
                           fl

                           
-------
                                                17
p 2,0 r E^:-p
     D  e- L!
                  CROSS  SECTION
                    ELEVATIONS
                 TYPICAL CULVERTS
                                       FIGURE 10

-------
III.   COST ESTIMATES

       Estimated road  costs  are developed  as "Direct  Costs"  to which  are
       added "Indirect Costs"  to  obtain a "Net Total Cost".   A contingency
       allowance is added  to  this  Net Total  Cost  to give the  "Total  Esti-
       mated Capital Cost" for road construction.

       Direct costs are developed under five  headings:

                          0  Road Fill
                          0  Turnouts
                          0  Culverts
                          0  Bridges
                          0  Royalty on Fill

       Road fill cost  is  generated  as  two elements:  first,  the fill  which
       includes all extraction and placement  costs  and,  second,  the haulage
       cost. The base  costs  used  in  this estimate  are  $9.20  per cubic yard
       for fill and $1.30 per cubic yard mile for  haulage.   These  prices
       also allow  for  all costs associated with  cut and  fill  construction
       and insulation costs where composite construction is  utilized.

       Turnout cost is generated in a similar manner to  road  fill  cost.

       Culverts are  estimated assuming all culverts are of the  average 80
       feet  length and are  priced according to  size.   Prices  used  range
       from $6,400 for a  24-inch  diameter up  to $61,200  for a  120-inch di-
       ameter  culvert.  These costs  include  all installation  costs,  provi-
       sion  for  the side slope protection  and allowance  for  mitered end
       treatment on culverts  of 66-inch  diameter or larger.

       Bridge  costs  are based on  nominal  deck area  which  is  defined as net
       width times  span.   The base cost  used in  this estimate  is  $400 per
       sq.  foot  of nominal  deck  area.    This price  includes  allowance for
       deck, substructures,  piling,  watercourse training work,  side  slope
       protection  and  provides for all  field construction and  deck  place-
       ment.  Actual costs for major  bridges  on the Asikpak  route  may well
       be  higher  than  the base case,  if  hydraulic  or  other  considerations
       dictate longer  spans  than those  provided  for with the  standard deck.

-------
                                                                                 19
III.   COST ESTIMATES (continued)

       Royalty on fill  is  estimated at a  rate  of $0.45  per  cubic yard  of
       fill  extracted.  This item also includes a provision for  reclamation
       work  at the borrow sites.

       Indirect costs  are  estimated  as  7.3% of  direct costs.    Indirect
       costs cover the costs of engineering design and  project management.

       The Contingency  allowance  is estimated  at 5.7%  of  net total  costs
       and is an  allowance  to  cover a portion  of the  anticipated risk  in
       carrying out the road construction element of  the  project.

       All direct costs  included  in the  estimate  include an allowance  for
       construction support, construction supervision,  taxes and  insurance.

       Costs for the Kruz route option have been developed on two  bases:

       0  Alternative 1 assumes that fill will be drawn  from borrow sources
          dispersed throughout the route as defined (Figure 8).

       0  Alternative 2  assumes  that fill  will  be drawn only  from  borrow
          sources  located outside the Krusenstern  National  Monument.   This
          alternative  includes  the  cost  of constructing an  ice  road from
          close to the port to  borrow sources 7 and 8.   This  ice  road will
          permit  construction   equipment  access  to  these borrow sources
          which  would provide fill  for construction in  the northern part  of
          the monument.   (Figure 8).

          Another approach  to  constructing this  alternative  has  also been
          estimated.   This  approach  allows  for flying  construction  equip-
          ment into  the  Red Dog  airstrip  and  building  the  road from  two
          fronts  only.   There  was  no significant difference  between esti-
          mated costs for  these  two approaches.  The estimate for the  ice
          road approach  is  used in  this  report.

       Costs for  the Asikpak route option have  been  developed on  the basis
       that  fill  will  be  drawn  from borrow sources dispersed throughout  the
       route.

-------
m-   COST ESTIMATES (continued)

       A control  has been applied to ensure a uniform approach  to  road  fill
       costs for both route  options.   This involves making  direct compari-
       son of costs for Asikpak  route  segments  with those for a route  seg-
       ment with  similar terrain characteristics  estimated  for one  of  the
       Southern routes.

       For  instance,  Asikpak route  segment A5  is compared with  Southern
       route segment M5.   Both   segments  are  on gently graded  lower  slopes
       on the fringe of wetland  areas and have average borrow availability.

       Operating costs consist  of  all  items for which  costs will   vary  de-
       pendent on  road  route mileage.   These  include concentrate haulage,
       personnel  movement,  haulage of  inbound  supplies  and road  mainten-
       ance.

       Cominco,  as  part of  their  normal  estimating  procedure,  frequently
       make use of a suitably experienced third party to  carry  out an audit
       of their estimates.  If  a reasonable correlation  is achieved,  confi-
       dence  in  the  validity  of  the  estimate  is enhanced  and  estimate
       credability improved.

       The estimate for the Kruz route option has  been audited  by  Morrison-
       Knudsen of  Boise, Idaho.   This  company is a large and  reputable
       civil engineering  contractor  with extensive experience  of  construc-
       tion in remote areas.  They have  been  involved in Alaskan  construc-
       tion for 40 years.

       This audit  was  completed in May  1984  and   the road element took  the
       form  of an  independent  estimate  carried   out  in  accordance  with
       Morrison-Knudsen's usual  in-house  methods for  preparing  construction
       bids.   Their estimate  is based on  a  reduced nominal  fill  thickness
       of  5  feet compared with the  6-1/2 feet designed depth  used  in  the
       Cominco estimate.

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                                                                                 21
III.   COST ESTIMATES  (continued)

       Morrison-Knudsen's  estimate  of total  net  cost is  $68.2 million  to
       which they  added  a contingency allowance of $4.4 million  for  an es-
       timated  total  cost  of  $72.6 million.   This  provides  an  unusually
       close correlation with  Cominco's estimate  of $74.7 million.   For
       construction work  of this  type  at a  remote site,  it is  very unusual
       for independent estimates  to agree so  closely.
RD15/d

-------
ASIKPAK ROUTE

QUANTITIES  AND COSTS — FILL
   A!
A3

65
          FILL
112.1858


\68Z7\0
         1917731
 KAUL
                        \ 5474^2
244 533 1
                         HAUL
                         c^st
                         C$)
                                 117 O 5^
 NEf
TOTAL
                1 3375600
                i i 302545
                               20S22055
                                        7222593
                                           -70
         £1,55
                          7,47

-------
ASIKPAK  ROUTE

CONSTRUCTION COST ESTIMATE-CULVERTS


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-------
ASIKPAK  ROUTE
CONSTRUCTION  COST  ESTIMATE-BRIDGES
                                               H !
  A
30

50
        A-S.
        re i
45
30
  A2.
                     ICIVALII^A
                                               10 .

-------
ASIKPAK  ROUTE
CONSTRUCTION  COST  SUMMARY
                                                                  25
                      FILL
   Al
         I3.7S
                                         18.34-
                      17-7^
                                                 31. la
   A3
12.5
II.
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                                         7.91
                      72.3
                                       -26,7
                                         MDI
                                                     FILL
                                                   4-.CP
                                                              5,93

-------
KRUZ  ROUTE

(USING  BORROW  SOURCES  THROUGHOUT  ROUTE )

CONSTRUCTION  COST   ESTIMATE - FILL
          pnuu
         OJAKITITY
  FILL
 coe
                                MlLt)
  HAUL
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                                    C^M)
  M
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2773173
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                  7352364
47H
 294 250
                             74^44
                           7222333
          2,12
                   7-4-7
                                                       54.47

-------
KRUZ ROUTE
CONSTRUCTION   COST  ESTIMATE - CULVERT
 3
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-------
KRUZ  ROUTE
CONSTRUCTION  COST  ESTIMATE - BRIDGES
S6SMEMT
                                     -TFEET)
                                           &OOO0O

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                                                     1,72.
                                                    4,90

-------
                                                                 29
KRUZ  ROUTE
(USING BORROW SOURCES  THROUGHOUT ROUTE )
CONSTRUCTION  COST  SUMMARY
            MILES-,)
                      FILL
                  (4
M I
   M 1
&.&0
                                         £7-77
                                                15.
             1. 95
          2-22,
   H2.
                              . 13
            II. 50
          \\.76
 -72
   M7
                   0.02.
             7.44
          7-47
         7.37
            5<2>.<2»5
         54.4-7
                                                              4.3
                                                            7^-7
                                                            74-7

-------
KRUZ  ROUTE

(NOT USING  BORROW SOURCES  INSIDE KRUSENSTERN  NATIONAL  MONUMENT)

CONSTRUCTION  COST  ESTIMATE -  FILL
          FILL
             . YD)
FILL
               MILE
MAUL
  C40
   M
          13556(263
                              14-324942
                    19493425
           14-9 ISO
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           ATTACHMENT F

Supplemental Corporate Information
          Cominco Alaska

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                              of Alaska
         3§EparttnEnt of (Enmmcrce anu iEcnnomtc
                       dErttficatc
     The  undersigned,  as  Commissioner of Commerce and Economic Develop-
ment of the State of Alaska, and custodian of corporation records for
said State, hereby certifies that

                    COMINCO AMERICAN INCORPORATED

a corporation organized under the laws of Washington            did,
on the 26thday of  December 1973 , qualify as a foreign corporation
authorized to do business in the State of Alaska; and

     I FURTHER CERTIFY that  the said corporation has not withdrawn
since qualifying herein,  and that all required corporate reports have
been filed to date and all corporate taxes and fees due this office are
paid to date.  •	——	——
                                 IN TESTIMONY WHEREOF. I execute this certificate and
                                 affix the Great Seal of the State of Alaska this

                                   2nd   day of   September     A. D. 19  85
                                        RICHARD A LYON
                                       COMMISSIONER OF COMMERCE AND
                                           ECONOMIC DEVELOPMENT

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                                  BY-LAWS
                                       of
                          COMINCO AMERICAN INCORPORATED

                                   ARTICLE I
                                  Shareholders

      Section 1.   Place  of Meetings:   Any meetings  of  the  shareholders,  including
 the annual  meeting, may be held  at such  places and at such  times, within  or
 without the State of Washington,  as  may  be designated and as set forth  in
 the Notice  of Meeting.
      Section 2.   Annual  Meeting:   The annual meeting  of the shareholders  of
 the corporation  shall be held once in each calendar year  and at such date and
 time as the Board of Directors may designate,  at which time the shareholders
 shall elect a Board of  Directors  for  the  ensuing year and transact any  and
 all  other business that may come  before  the meeting.
      Section  3.   Special Meetings:  Special meetings  of the shareholders  of
 the corporation may be  called by  the  Chairman  of the  Company, Chairman  of the
 Executive Committee of  the Board  of Directors,  if one is  so designated, the
 President or  by a quorum of the directors, or  by the  holder or holders  of
 not  less than one-tenth  (1/10) of  the  shares of common stock outstanding  and
 entitled to vote  at the meeting.
     Section 4.  Notice of Meetings:  Written  notice  for  the holding of the
 annual meeting of the shareholders or of a special  meeting of the shareholders
 shall be given by the Secretary of the corporation  or by the person or persons
 authorized to call the meeting.  The notice,  shall  state  the  place,  day,  and
hour of the  meeting and, in the  case of a special meeting  of the shareholders,
the purpose  of the special  meeting.  The  notice shall  be mailed to  each holder

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of  shares of common stock of the corporation outstanding and entitled to vote
at  the meeting by first class United States mail not less than ten (10) days
nor more than fifty (50) days before the date designated for the annual meeting
and not less than two (2) days before the date designated for holding a special
shareholders meeting. The address to which the notice is mailed shall be that
designated by the shareholder.
     Section 5.  Quorum:  The presence, in person or by proxy, of the holders
of  a majority of the shares of common stock entitled to vote shall constitute
a quorum at all meetings of the shareholders and the majority vote of such
shares shall be the acts of the meeting, unless otherwise required by law
or  these By-Laws.
     Section 6.  Meeting by Consent and Waiver of Notice:  When the share-
holders entitled to vote are present at any meeting, except the annual meet-
ing, and sign a written consent thereto on the record of such meeting, then
the holding of that meeting and the acts of that meeting are valid, regardless
of  how called, noticed,  or where held.
     Section 7.  Informal Action of Shareholders:  The shareholders, in lieu
of  their meeting together, may act by a resolution in writing approved, con-
sented to and signed by all of the shareholders entitled to vote on the action
taken and said act or acts shall be as valid and effective as if same had been
passed at any other meeting of the shareholders.  Such resolution shall be
filed by the Secretary of the corporation in the corporate records as the
minutes of a shareholders meeting.
     Section 8.  Voting  Rights:   Bona fide common shareholders, having stock
in their names on the stock books of the corporation at least ten (10) days
prior to any meeting at  which a vote shall  be taken, are entitled to one vote
for each share of stock  so held; provided,  however,  that when voting for directors,

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 each shareholder shall  be entitled to accumulate his vote by  giving  one  candidate
 for director as many votes as  the number of such directors to be  elected multiplied
 by the number of his shares shall  equal, or by distributing such  votes on  the
 same principal  among any number of such candidates.
      Section 9.  Proxies:   A Shareholder entitled to vote may do  so  either
 in person or by proxy in writing.   A proxy shall  not be  valid after  eleven
 (11)  months  from the date of its execution unless a  longer period is expressly
 stated in the proxy.  A  proxy  may  be revoked by a writing of  a later date
 or by attendance of  the  shareholder at the meeting and so declaring.
      Section 10.  Adjournments:  Any meeting of the shareholders may adjourn
 from day  to  day or from  time to time.   Prior to adjournment,  the  time and
 place of  the continuation  of the meeting shall  be announced and,  unless  the
 adjournment  is  for more  than fourteen  (14)  days,  no  other notice  of  the  adjourned
 meeting or of the business  to  be transacted shall  be necessary. Matters  pertaining
 to the adjournment shall  be set forth  in the minutes of  the meeting.  Upon
 reconvening  pursuant  to  the adjournment,  if a quorum is  present any  business
 may  be transacted which  could  have  been  transacted at the meeting originally
 called.
      In case  of any meeting involving  the  election of directors,  the  adjournment
 must  be for  a time no later than the next  day and those who attend the adjourned
 meeting although less than  a quorum  as provided in these By-Laws  shall never-
 theless constitute a quorum for  the purpose  of electing directors.

                                  ARTICLE  II
                              Board of Directors

     Section 1.  Number and Term of Office;  The business, property and  affairs
of the corporation shall  be managed by the Board of Directors  which shall
                                      -3-

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 be comprised of never less than three (3)  persons,  but which  by  resolution
 duly passed by the Board of Directors may  at any time  be  increased  to  any
 number not exceeding  fifteen (15)  or, having once been increased, may  be reduced
 to any number not less  than three  (3).  The directors shall  be elected  annually
 by the shareholders at  their annual  meeting and  shall  hold  their office for
 one (1) year or until their successors  are elected  and qualified.
      Section 2.   Committees:  The  Board of Directors,  by  resolution adopted
 by a majority of the  full  Board of Directors, may designate from among its
 members an Executive  Committee  and one  or  more other committees  including,
 without limitation, a Compensation Committee, and such committees shall have
 the powers granted to them by the  Board of Directors,  the By-Laws or by Law,
 but no committee shall  have the authority  of the  Board of Directors  in reference
 to amending the  articles of incorporation,  adopting a  plan  of merger or consoli-
 dation, recommending  to  the shareholders the sale, lease, exchange  or  other
 disposition of  all  or substantially  all  the  property and  assets  of  the corporation
 otherwise  than  in  the usual  and regular course of its  business,  recommending
 to the  shareholders a voluntary dissolution  of the corporation or a revocation
 thereof, or amending the By-Laws of  the corporation.
     Section 3.  Vacancies:  Upon  the death,  resignation  or removal of a director
 from office, the Board of Directors may elect a director  to hold office until
 the next annual election and a  successor is  elected and qualified. Any directorship
to be filled by the Board of Directors  by reason of an increase  in their number
may be filled by the Board of Directors for  a term of office continuing only
until the  next annual  election of the directors by the shareholders.
     Section 4.  Compensation:  Directors shall  receive such compensation
and expenses for their services  as Directors as the Board of Directors may
designate.

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      Section 5.   Removal:  At  a  meeting  called  expressly for that purpose
 any or all  of the Directors  may  be  removed with or without cause by a vote
 of the holders of a majority of  the  shares then entitled to vote at an election
 of directors.
      Section 6.   Place of Meetings:  Meetings of the Board of Directors may
 be held at  such  time and at  such places, either within or without the state,
 as designated in  a Notice of Meeting.
      Section 7.   Annual Meeting:  The Board of  Directors shall  meet each year
 immediately after the conclusion of the  annual  meeting of the shareholders
 and shall elect officers and consider such other business as may come before
 it.
      Section 8.   Special Meeting:  A special  meeting of the Board of Directors
 may  be  called at  any time by the Chairman of the Company, Chairman of the
 Executive Committee, the President or a Vice President if a member of the
 Board of Directors, or by a quorum of the directors whenever he or they may
 deem it expedient.
     Section 9.  Notice of Meetings;  Written notice for the holding of the
 annual meeting of the Board of Directors shall be given not less than ten
 (10) days in  advance of the meeting, nor not  less than two  (2)  days in advance
 of the meeting in the case of a special  meeting of the Board of Directors,
 by notice issued by the Secretary after having first been authorized so to
 do.
     Section 10.   Quorum:   Until  changed by resolution of the Board of Directors
three (3) directors is  a sufficient  number to form the Board for the transaction
of business  of the corporation  and every decision of a majority of those directors
present at a meeting  in which a quorum is present shall  be  the  act of the
Board of Directors.

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     Section 11.  Meeting by Consent and Waiver of Notice: When all directors
 are present at any meeting and sign a Waiver of Notice and a consent to the
 holding of such meeting, and such Waiver and consent is made a part of the
 record of such meeting the holding of such meeting and the acts of that meeting
 are valid regardless of how called, noticed or where held.
     Section 12.  Informal Action of the Board of Directors:  The directors,
 in lieu of their meeting together, may act by a resolution in writing approved,
 consented to and signed by all of the directors and said act or acts shall
 be as valid and effective as if same had been passed at any other meeting of
 the directors.  Such resolution shall be filed by the Secretary of the corpo-
 ration in the corporate records as the minutes of a directors meeting.
     Section 13.  Attendance by Conference Communication: Members of the Board
 of Directors or any committee designated by these By-Laws or appointed by
 the Board of Directors may participate in a meeting of such Board or Committee
 by means of a conference telephone or similar communications equipment by
 means of which all persons participating in the meeting can hear each other
 at the same time and participation by such means shall  constitute the presence
 in person at the meeting of all persons so participating in the meeting.
     Section 14.  Adjournment:  Any meeting of the Board of Directors may
 adjourn from day to day or from time to time. Prior to adjournment the time
 and place of the continuation of the meeting shall be announced and, unless
 the adjournment is for more than fourteen (14)  days,  no other notice of the
 adjourned meeting or of the business to be transacted shall be necessary.
Matters pertaining to the adjournment shall  be set forth in the minutes of
 the meeting.   Upon reconvening pursuant to the adjournment if a quorum is
present any business may be transacted which could have been transacted at
the meeting originally called.

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     Section 15.  Other Capacity:  A director may serve the corporation in the
capacity other than a director and may receive such compensation for services
rendered in the other capacity as the Board of Directors may designate.
     A director may be or become a director or officer of any company promoted
by this corporation or in which it may be interested as a shareholder or otherwise.
     No director shall be disqualified in respect of his office by reason
of his holding any office or place of profit in this corporation or in any
company in which this corporation is a shareholder or in any company holding
shares in this corporation; nor shall any contract or arrangement entered
into by or on behalf of this corporation in which any director is in any way
interested (whether by reason of being a shareholder of or otherwise interested
in any other company for that reason) be void and every director so interested
and having declared his interest shall have the right to vote respecting any
such contract or arrangement; nor shall any director be liable to account
to this corporation for any profit realized from any such office or place
of profit or realize by any such contract or arrangement by reason only of
such director holding that office or place of profit or fiduciary relation
thereby established.
                                  ARTICLE III
                    Officers, Managers, or Representatives

     Section 1.  Officers:  The officers of the corporation shall consist
of a President, one or more Vice Presidents, a Secretary, a Treasurer, and
such other officers or assistant officers as the Board of Directors shall
designate,  or as are designated in these By-Laws. Any two or more offices
may be held by the same person except the office of Chairman, if one is so
elected,  or President and Secretary.
                                      -7-

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      Section 2.  Election and Term of Office: The officers of the corporation
 shall  be elected annually by the Board of Directors at their annual meeting
 at which time  they may,  in their discretion, elect a Chairman of the Company,
 who may also be President and,  in the absence of any agreement to the contrary
 shall  hold office until  their successors are elected and qualified.
      Section 3.  Vacancies;  Upon the death, resignation, or removal of an
 officer from office, the Board  of Directors may elect or appoint a replacement
 to hold office until the next annual election and a successor is elected and
 qualified.
      Section 4.  Other Officers. Managers or Representatives: The Board of
 Directors may  appoint or elect  such other officers, managers or representatives
 as, in its discretion, it deems necessary to serve at the will of the Board.
      Section 5.  Chief Executive Officer:  The Board of Directors may designate
 the Chairman of the Company, if one is so elected, or the President to be the
 Chief Executive Officer, who shall be the general executive head of the company
 and who shall exercise the general supervision, management and control of all
 business and affairs of the company.  In the absence of such a designation the
 President shall be the Chief Executive Officer of the company.
     Section 6.  Duties of the Chairman;   The Chairman of the Company shall
 preside at all  meetings of the directors or shareholders and shall  perform
 other duties as are prescribed by these By-Laws and as the directors may,
 from time to time,  require.
     Section 7.  Duties of the President:  The President shall have such duties
 as may be assigned  to him,  from time to time,  by the Board of Directors or as
 are prescribed by the By-Laws of the company.
     Section 8.  Duties of Vice Presidents:   The Vice President,  or if more
than  one,  the Vice  Presidents in order of seniority (as determined by the
                                      -8-

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directors) shall be vested with all  the powers and shall perform all the duties
of the President in the absence or disability or refusal to act of the President,
save that no Vice-President shall preside at a meeting of the Directors who
is not a member of the Board of Directors.  The Vice President, or if more
than one, the Vice-Presidents, shall also have such other powers and duties
as may, from time to time, be assigned to him or them, respectively, by the
directors.
     Section 9. Secretary: It shall  be the duty of the Secretary to keep alpha-
betically the names and addresses of all shareholders; he shall, along with
the President, sign all of the stock certificates of the company and keep
the records thereof; the seal of this corporation shall be in his custody;
he shall give or cause to be given all notices of all meetings of the directors
or shareholders; and shall record all proceedings of the meetings of shareholders
and directors; and shall perform such other duties as may be required by laws,
these By-Laws or as the directors may require of him.
     Section 10. Treasurer: It shall be the duty of the Treasurer to keep
safely all moneys and securities of this corporation, and he shall deposit,
disburse or deliver the same under the direction of the directors; he shall
submit a statement of his accounts when called for by the President or directors,
and shall  perform such other duties as may be required by laws, these By-Laws
or as the Board of Directors may require from time to.time and to give such
bonds as the directors may require.

                                  ARTICLE IV
                                Shares of Stock

     Section 1.   Capital  Stock:   The capital  stock of the corporation shall
be as set  forth  in the Articles  of Incorporation.   Issuance of stock shall

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 be subject to the  provisions  of  the  Articles  of  Incorporation  and  the By-Laws.
 All  certificates of  stock  shall  be  signed  by  the President or  such other officers
 designated by the  Board  of Directors and countersigned  by the  Secretary or
 any  Assistant Secretary, and  shall  be impressed  with  the corporate seal.
 Signatures and the corporate  seal may be imprinted  thereon as  facsimilies thereof
 if authorized by the Board of Directors.
      Section  2.  Treasury  Stock:  Stock of the corporation held by the corpora-
 tion shall  be treasury stock, and shall neither  vote  nor participate in dividends,
 and  its  disposition  shall  be  determined by the Board  of Directors.
      Section  3.  Transfers:   Transfers of  stock  shall be subject to these
 By-Laws  and applicable law of the State of Washington.  Transfers  of stock
 shall be made only on the  books  of the corporation.   The old certificate,
 properly endorsed, shall be surrendered to the Secretary and cancelled before
 a  new certificate  is issued.
     Section  4.  Close of  Stock  Book:  The  stock book of the corporation shall
 be closed  against tranfers for a period of  ten days before payment of dividends
 and  for a  period of  ten days  before  each meeting of the shareholders.
     Section  5.  Loss of Certificate;  In  case of loss  or destruction of a
 certificate of stock, a new certificate shall be issued in lieu thereof after
 satisfactory proof has been made to  the Board of Directors of the  loss or
 destruction and, in addition,  upon the giving of satisfactory security, by
 bond or otherwise,  as the Board of Directors shall  require,  against any loss
 to the corporation by reason of the  issuance of a duplicate.  A replacement
certificate shall  have the word "DUPLICATE" marked on its face.
     Section 6.  Mailing  Address Required;   At the time of issuance of stock,
the Secretary  of the  corporation shall obtain from the recipient shareholder
his mailing address which shall  be entered  in the stock ledger and shall  become

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a part of the permanent records of the corporation. It shall thereafter be
the obligation of each shareholder to advise the Secretary of any change of
such address and the Secretary shall promptly enter such a change in the stock
ledger.  First Class mail, whether regular, airmail, registered, or certified,
addressed to such address shall be sufficient for all  corporate notices and
for all official communications between the shareholders pertaining to corporate
business, except where specifically set forth otherwise in these By-Laws.

                                   ARTICLE V
                                     Seal
     Section 1.  Seal:  The seal of this corporation shall bear the following
inscription in the words "COMINCO AMERICAN INCORPORATED - Washington" in the
form of a circle, and with the words "CORPORATE SEAL" in the center of the
circle.

                                  ARTICLE VI
                         Miscellaneous Corporate Acts
     Section 1.  Corporate Funds:  All funds of the corporation shall be deposited
in the bank or banks designated by the Board of Directors. All checks, drafts
or orders for the payment of money and all notes and acceptances and bills
of exchange shall be signed by such officer or officers or designated persons
of the corporation as the Board of Directors shall designate.
     Section 2.  Execution of Written Instruments;  All written instruments
requiring formal execution on behalf of the corporation shall be executed
by the President or a Vice President and attested by the Secretary and impressed
with the seal  of the corporation; provided, however, that the Board of Directors
may in any particular instance designate another procedure for execution.

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     Section 3.  Dividends:  Dividends shall be paid from the surplus earnings
 of  the corporation  as the Board of Directors shall from time to time designate,
 but no dividend  shall be paid that will  impair the capital structure of the
 corporation.
     Section 4.  Sale. Merger, Dissolution or Mortgage of all Corporate Property:
 At  a meeting of  all the shareholders called, among other things, for that
 purpose,  the shareholders representing two-thirds of the stock entitled to
 vote may  dissolve and distribute the assets of the corporation, direct the
 sale, merger, or mortgaging of all or substantially all of the corporate proper-
 ties, and in such case, the directors shall cause such conveyances, documents,
 or  mortgages to  be made accordingly.

                                  ARTICLE VII
                                   Indemnity

     Section 1.   Indemnity:  Any person made a party to any action, suit or
 proceedings, by  reason of the fact that he is or was a director, officer,
 employee, trustee or representative of the corporation, or of any corporation,
 partnership, trust or joint venture in which he served as such at the request
 of  the corporation, shall be indemnified by the corporation against the reasonable
 expenses, including attorney's fees, judgments, fines or amounts actually
 and  necessarily  incurred by him in connection with the defense of such action,
 suit or proceedings, or in connection with any appeal  therein, if he acted in
 good faith and in a manner he reasonably believed to be in or not opposed to
 the best  interests of the corporation,  and, with respect to any criminal action
 or proceeding,  had no reasonable cause to believe his conduct was unlawful.
 The termination of any action,  suit or proceeding by judgment, order, settle-
ment, conviction, or upon a plea of nolo contendere or its equivalent, shall
                                     -12-

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 not,  of itself,  create  a presumption  that the person  did  not  act  in  good  faith
 and in a manner  which he reasonably believed to be  in or  not  opposed to the
 to the best interests of the  corporation,  and,  with respect to  any criminal
 action or proceeding, had reasonable  cause to believe that his  conduct was
 unlawful.
      The foregoing  right of indemnification shall not be  deemed exclusive of
 any other rights to which any officer,  director, employee, trustee or repre-
 sentative may be entitled apart  from  the  provisions of this section.
      The amount  of  indemnity  to  which any  officer or  any  director may be entitled
 shall  be fixed by the Board of Directors,  except that in  any  case where there
 is no disinterested majority  of  the Board  available,  the  amount shall be fixed
 by -either  independent legal counsel in  a written opinion  or by  the shareholders.
      The corporation shall have  power to purchase and maintain  insurance on
 behalf of  any person who  is or was a  director,  trustee, officer, employee,
 or representative of the  corporation, or is  or  was  serving at the request
 of the  corporation, partnership, joint  venture, trust or  other  enterprise
 against any liability asserted against  him  and  incurred by him  in any such
 capacity or arising out of his status as such,  whether or not the corporation
 would  have the power to indemnify him against such  liability under the provisions
 of  this  section.

                                 ARTICLE VIII
                                  Amendments

     Section 1.   Repeal. Amendment. Adoption of By-Laws:  The By-Laws of the
corporation may  be changed or amended at any time by the Board of Directors
subject, however, at all times to the power of the shareholders to change,
alter, repeal  or  to adopt new  By-Laws.

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                                                  M  t? i? (a (D ^ IE
                                                  LoiAS TO FO.U-. AN3 rlLH.
                                                       SEP  27 -.855
               RESTATED ARTICLES OF INCORPORATION  A_  LUDLOW KRA.V.E
                  Cominco American Incorporated   BY...'i.2™...'.	_.....'.-....:...
                                                  AttlbTANT «U*CMVI&OA 3* COfcFOAATI

     V.'e,  the  undersigned, H.  W. BOETZK2S, a resident and
 citizen of the State of Washington, United States of America,
 ar.d H.  C.  LAKE,  a resident and citizen of the State of Oregon,
 United  states of America, do hereby associate ourselves
 together  for  the purpose of forming a corporation ur.der and
 pursuant  to the laws" of the state of Washington, ancl to that
 end do  hereby make,  execute and enter into Articles of incor-
 poration,  in  triplicate, certifying as follows, to-wit;
                                I.
     The  none of the corporation shall be "Cominco American
 Incorporated."
                               II.
     The  objects for which this corporation is formed are  as
 follows:
     (a)   To  locate,  purchase, acquire, trade, own, use,
 cavelop,  improve,  operate,  sell, deal and trade in, encumber,
 and alienate  deposits,  claims prospects, necessary or desirable
 machinery,  tools,  equipment,  and adjuncts thereto,  and to  use,
 sell, dispose of,  and encumber the products thereof.
     (b)  To  purchase,  lease,  exchange, acquire by foreclosure
 or otherwise,  real,  personal,  mixed,  tangible and intangible
 property, assets,  rights,  claims, equities, franchises,
 business concerns  and undertakings of every kind, and character,
 and to sell,  assign,  convey,  deal in,  lease, pledge,  mortgage
 ar.i dispose of all or any part thereof,  and to use, operate,
 continue, develop. Improve  and manage  or otherwise  turn to
 account all or any of the properties  or rights of this corpora-
tion.

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     (c)  To engage In the icsrcantile, merchandise, .^eal
estate, brokerage, commission, consignment, warehouse,
r-i^iufacturing and transportation business, the conduct and
c-paration of irrigation works, the caneratlon and distribution
cf electrical energy, the conduct of public utilities and the
rendering of public service in any of the phases or branches
thereof, and to acquire, own, use and dispose of the necessary
tools, machinery, equipment, stocks, buildings, stores, wharves,
warehouses, real estate, vehicles, boats, vessels, aeroplanes,
and other property, real and personal, necessary therefor and
to dispose of the products thereof, and to assess and collect
compensation for services rendered, goods, wares and merchan-
dise sold and delivered, and benefits conferred, and to exercise
the right of eminent domain.
      (d)  To establish, form and subsidize or. otherwise assist
in the promotion or foundation of other companies or the
prosecution of any other undertaking or enterprise of any
description which may advance directly or Indirectly the objects
of this corporation, and to secure by purchase, trade, sub-
scription,- or otherwise acquire and to deal and trade in, the
stock, certificates of interest, debentures,  bonds or other
securities of other companies, trusts or  other organizations.
      (e)  To loan money and grant credits; to Incur Indebted-
      i
r.sss, borrow or raise money with or without security, to evidence
the same by proper Instruments, and to secure the payment of
money borrowed or raised when deemed expedient by the issue of
debentures, bonds, chattel mortgages, real estate mortgages,
ceeds of trust, or the pledging of collateral or the giving of
other security and upon such terms as to  priority and discount,

                              -2-

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or otherwise as shall be thought fit and to purchase or
i-adeeta  £at a premium If deemed expedient) any notes, deben-
tures, bonds, mortgages or securities of this corporation.
      (f)  To pay for any rights or property acquired by or
services rendered 'to this corporation in connection with its
promotion, organization, operation or malntalnance, in fully
cr partly paid shares of stock, debentures, bonds, other
securities of this corporation, cash, privileges or anything
of value.
      (g)  To pay any commission or brokerage, for the purpose
of securing the subscription or sale of all or any part of
•che stock of this corporation.
      (h)  To procure this corporation to be legalized,
domiciled, or recognized In any foreign country, state or
colony and to transact any business there.
      (i)  To do all such acts and things as are incidental,
conducive, necessary or permissable to or under the above
objects in their broadest sense or which will aid any of the
above objects, and to establish and carry on any business or
undertaking permissable under the law which may seem calculated
-o enhance the value of any of the property or rights of this
company or to facilitate the disposition thereof and to
engage in any and all kinds of business that a natural person
might or could engage in and to engage in such business as the
2oard of Trustees may deem to the advantage of this corporation.
                             III.
     1.   The authorized capital stock of this Corporation
     shall be Thirty-Five Million Dollars ($35,000,000.00)
     divided into:
          (1)  Seven hundred thousand (700,000)  shares of
               common stock with a par value of Ten Dollars
               ($10.00) each with full and equal voting
               privileges;

                               -3-

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     (il)  Two million eight hundred thousand (2,800,000)
          shares of six percerv; (6-i) non-voting r.on-
          curaulative redeemable participating preferred
          shares of the par value of Ten Dollars ($10.00)
          "each (hereinafter called the "preferred shares")
          having attached thereto the rights, restrictions,
          cor.dltlon.3 and- limitations hereinafter set out.

2.  The holders of the preferred shares shall be entitled
to receive and this corporation shall pay thereon, quarterly,
semi-annually or annually, as and when declared by the
board of directors out of the moneys of this corporation
properly applicable to the payment of dividends fixed
preferential non-cumulative cash dividends at the rate
of six percent (6$S) per annum on the amounts from tine
to time paid up thereon.  The board of directors shall
be entitled from time to tlir.e to declare part of the
said preferential dividend for any fiscal year notwith-
standing that the dividend for that fiscal year shall
not be declared In full,  if, within four months after
the expiration of any fiscal year of this corporation,
the board of directors In its discretion shall not have
declared the said fixed preferential dividend or any
part thereof on the preferred shares for that fiscal
year, then the rights of the holders of the preferred
shares to such dividend or to any undeclared part
thereof for such fiscal year shall be forever extinguished.
No dividend shall at any time be declared or paid or set
aside for the common shares or any part thereof for any
fiscal year unless the fixed preferential dividend for
such fiscal year on all the preferred shares then
outstanding shall have been declared and paid or a sura
set aside for payment thereof.

3.  Whenever in any calendar year a dividend or dividends
aggregating sixty cents a share have "been paid or declared
on the common shares outstanding any and all further
dividends (not being the preferential dividends on the
preferred shares) declared and payable in such calendar
year shall be declared and paid in equal amounts per share
on all the preferred shares and common shares at the time
outstanding without preference or distinction as between
preferred shares and common shares.

4.  This corporation may at any time or times purchase
for cancellation the whole or any part of the preferred
shares outstanding from time to time by-such means and
at such price or prices as the board of directors may
authorize.

5.  This corporation may redeem at any time all or from
time to time any part of the outstanding preferred shares
on payment to the holders thereof of the amount paid up
thereon, together with all declared and unpaid preferential
non-cumulative cash dividends thereon, but such right to
redeem may not be exercised in any case prior to the end of
five years from the date of issuance of the preferred share
or shares to the holder thereof.


                         -1-

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6.  In any case of redemption of preferred shares under
the provisions of clause 5 hereof, this corporation snail
at least twenty (20) days before the date specified for
redemption mail to each person who at the date of nailins
is a registered holder of preferred shares to be redee.r.cd
a notice in writing of the intention of this corporation
to redeem such preferred shares,  such notice shall be
mailed in a prepaid letter addressed to each such share-
holder at his address, as it appears on the books of this
corporation or In the event of the address' of any such
shareholder not so appearing then to the last knov:n address
of such shareholder; provided, however, that accidental
failure to give any such notice to one (1) or more of
such shareholders shall not affect the validity of such
redemption.  Such notice shall set out the redemption price
and the date on which redemption is to take place and :.:"
part only of the shares held by the person to whom it is
addressed is to be redeemed the number thereof so to be-
redeemed.  On or after the date so specified for redemp-
tion this corporation shall pay or cause to be paid to or
to the order of the registered holders of the preferred
shares to be redeemed the redemption price thereof on
presentation and surrender at the head office of this
corporation or any other place designated in sucl-. notice
of the certificates representing the preferred shares
called for redemption.  If a part only of the shares
represented by any certificate be redeemed a new certifi-
cate for the balance shall be issued at the expense of
ohis corporation.  Prom and after the date specified for
redemption in any such notice the preferred shares called
for redemption shall cease to be entitled to dividends
and the holders thereof shall not be entitled to exercise
any of the rights of shareholders in respect thereof
unless payment of the redemption price shall not be made
upon presentation of certificates in accordance v;ith the
foregoing provisions, in which case the rights of the
shareholders shall remain unaffected.  This corporation
shall have the right' at any time after the mailing of
notice of its intention to redeem any preferred shares
as aforesaid to deposit the redemption price of the shares
so called for redemption or of such of the said shares
represented by certificates which have not at the date of
such deposit been surrendered by the holders thereof in
connection with such redemption to a special account in
any bank named in such notice to be paid without Interest
to or to the order of the respective holders of such
preferred shares called for redemption upon presentation
and surrender to such bank of the certificates representing
the same and upon such deposit being made or upon the date
specified for redemption in such notice, whichever is the
later, the preferred shares in respect whereof such deposit
shall have been made shall be redeemed and the rights of
the holders thereof after such deposit or such redemption
date, as the case may be, shall be limited to receiving
without interest their proportionate part of the total
redemption price so deposited against presentation and
surrender of the said certificates held by them respectively.
                         -5-

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     7.  The holders of the preferred shai-es shall r.ot i-.ave
     any voting rights for the election of directors r.or,
     without limiting generality, for any. other purpose; r.o.-
     shall they be entitled to attend shareholders' .T.ee-cinsa.

     8.  In the event of the liquidation or dissolution of
     this corporation or any other distribution of ics resets
     arr.ons the shareholders, the holders of the preferred
     shares shall.be entitled to receive the par value G.
     their holdings in priority to any distribution to she
     holders of the common shares or any shares of any oshei-
     d:\s3 ranking junior to the preferred shares, but the
     hc—clers of the preferred shares shall not be entitled to
     share any further in the distribution of assets.

                              IV.

     The duration of this Corporation shall not be limited to

any number of years, but shall be P2RPSTUAL.

                               V.

     The management of the Corporation shall be vested in a

Board of Directors which shall consist of not less than three

(3) persons and the number, qualification, terms of office,

r.anr.er of election., time and place of meeting, and powers ar.d

duties of the Directors shall be such as are prescribed by the

3y-laws of the Corporation.  The nanes and addresses of the

Directors in office at the time of the adoption of these

Sedated Articles are :

          R. Hendricks
          Room 3100
          630 Dorchester Boulevard West
          Montreal 2, Quebec, Canada

          P. 2. Burnet
          East 1224 - 27th Avenue
          Spokane, Washington

          J. C. MacLean
          8l8 Riverside Avenue
          Spokane, Washington

          H. T. Pargey
          Room 3100
          630 Dorchester Boulevr.rd West
          Montreal 2, Quebec, Canada


                              -6-

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          A. 0. Wolff
          Room 3100
          630 Dorchester Boulevard West
          Montreal 2, Quebec, Canada
          R. D. Perry
          Room 3100
          630 Dorchester Boulevard West
          Montreal 2, Quebec, Canada
          D. D. Morris
          Room 3100
          630 Dorchester Boulevard West
          Montreal 2, Quebec, Canada
                              VI.
     The principal place of business of this Corporation shall
'zi located at the city of Spokane, in the County of Spokane,
and state of Washington.
     IN WITNESS WHEREO?, we have set our hands and seals under
vl-.ese presents this   /y-&   day of September, 1965.
                               FTa. Burnet, president

                           ATTEST:
                               J. D/ Rae, secretary-Treasurer

STATE 0? WASHINGTON )
                    : ss.
County of Spokane   )
     P. E. Burnet and J. D. Rae, being first duly sworn on
cath, depose and say:
     (a)  That they have been authorized to execute the within
Restated Articles by resolution of the Board of Directors
adopted on the 8th day of September, 1965.
     (b)  That the Restated Articles correctly set forth the

                              -7-

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text of the Articles of Incorporation as amended and supple-
r.or.ted to the date of the Restated  Articles,  and
     (c)  That tl-.3 Restated Articles  supersede and take the
pl^ca 01" theretofore existing  Articles of Incorporation and
;_-er.dxent3 thereto.
                                              7Q.-.X.
                                        J-. D'. Rae
SUBSCRIBED AND SWORN to before  me  this
    , 1965.
                                                       day of
                            Notary PuDl.lc in ana for the state
                            of Washington, residing at Spokane
                               -8-

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 ATTACHMENT G






Correspondence

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         U.S.  ENVIRONMENTAL  PROTECTION  AGENCY

    ^                        REGION  X

       'f0                   1200  SIXTH AVENUE

       |              SEATTLE, WASHINGTON 98101
    •-•  M/S 443


February 6, 1984


Mr. H.M. Giegerich, President
Cominco Alaska
5660 "B" Street
Anchorage, Alaska  99502

Dear Mr. Giegerich:

The EPA has reviewed the revised consolidated ANILCA Title XI  application
submitted by your company December 14, 1983, for Federal  permits necessary
to construct a transportation system across Cape Krusenstern National
Monument.  With regard to the proposed wastewater discharge from the port
facility, the information submitted is adequate for EPA to begin processing
your application.

Sincerely,
Roggr K. Mochnick, Chief
Water Permits Section

cc:  Ron Kreizenbeck, AGO (Juneau)
     Floyd Sharrock, NPS

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                   DEPARTMENT OF THE ARMY

                    ALASKA DISTRICT. CORPS OF ENGINEERS

                                 POUCH 898

                           ANCHORAGE. ALASKA 99506
                            8 February  1984
      ATTENTION OFi
Regulatory Functions Branch
Special Actions Section
Mr. Harry Noah
Cominco Alaska
5660 B Street
Anchorage, Alaska  99502

Dear Mr. Noah:

     This  letter  is  in  regards  to  your Title  XI  application  for  the
transportation   system  (0?l-OYD-2-830359,   Chukchi   Sea   9)   and  your
Department of  the Army (DA)  permit application for certain activities  at
the mine site (071-OYD-4-840012, Chukchi Sea 11).

     These applications  are  complete and  soon a  public notice  for each
permit  application  will  be published  as an appendix  in the  Red  Dog Mine
Environmental Impact Statement (EIS).   The public  notices  are required  to
solicit  comments regarding your  project.   Any  comments received  will   be
evaluated  and considered  in  our  permit  decision.   We  expect to make  a
permit  decision  approximately 30 days after the publication of the  notice
of availability  of the Final EIS.

                                       Sincerely,
Copy Furnished:
                                       Larry  IX Reeder
                                       Chief, Special Actions  Section
                                       Regulatory  Functions  Branch
Mr. Bill Riley
Environmental Evaluations Branch  {M/S 443)
Environmental Protection Agency
1200 6th Avenue
Seattle, Washington  98101
                                                   FEB 0 3  '

                                                    EE8J404 RH1BH

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                 United States Department of the Interior
                             NATIONAL PARK SERVICE
                                Alaska  Regional Office
                            2525 Gambell  Street, Room 107
 IN REPLY REFER TO:                Anchorage,  Alaska  99503-2892
L76 (ARO-P)
                                                       FEB 10  1984
Mr. Harry A.  Noah
Environmental Coordinator
Cominco Alaska
5660 B Street
Anchorage, Alaska  99502

Dear Mr.  Noah:

We have reviewed the revised  Title  XI  application submitted by Cominco
January 31, 1984.  It is our  understanding  that the application has been
submitted to  the Corps of Engineers (Corps) and the Environmental Protection
Agency (EPA)  and that it will  be  published  in this form in the Red Dog Mining
Project Draft Environmental Impact  Statement (DEIS) along with our review
comments  and  those of the Corps and the  EPA.

We have no objection to the application  appearing in this form in the DEIS.
However,  it does not contain  all  information required by Title XI of the
Alaska Natural Interest Lands Conservation  Act and applicable laws insofar as
the National  Park Service is  concerned.  The following corrections must be
made and  the  indicated additional information (earlier requested in our letter
dated January 6, 1984) must be provided.

Item 4.  Because Cominco Alaska is  a private corporation, items (d) and (e) of
the supplemental data sheet are to  be  completed.

Item 7.  You  have indicated that  the concentrate storage structure is a related
facility  (to  the use system),  as  is the  borrow area in which it is to be
constructed.   The borrow area (and  structure) are to be situated on lands
selected  and  tentatively approved for  conveyance to NANA.  Therefore at such
time as you provide the information requested in Item 15, it will be necessary
to anticipate the possibility that  title conveyance may not occur and that the
facility  would therefore remain on  Cape  Krusenstern Monument lands adminis-
tered by  the  National  Park Service.  Because title to these lands has not been
conveyed, the acreage (211 acres) will be figured in the application fee to be
provided  as part of the Title XI  application.

Your response (attachment A,  page 1, paragraph 6) to our request for a descrip-
tion and  explanation of why related structures and facilities (identified by
Cominco)  are  minimally necessary  for construction, operation, and/or maintenance

-------
of the system, is inadequate.  The National Park Service must have sufficient
fiscal data to make an independent evaluation of your conclusion as indicated
in attachment A.

We appreciate that the information in the detail requested in our January 6
letter item 7(e)(f) is not now available.  But we will require it to be
provided at such time as engineering studies are completed that are adequate
to realistically identify and evaluate the system in relation to the natural
and cultural landscape.

Item 9.  We repeat the request of our January 6 letter, that the status of
required applications for state and local governmental permits indicated in
item 9 be consistent with the information provided in item 14.

Item 10.  If we understand your application correctly, the lineal right-of-way
through Cape Krusenstern National Monument is 24 miles.  Based on 36 CFR
14.22(a)(3), there will be a nonrefundable fee of $500.00 for each 20 miles or
fraction thereof for a total of $1,000.  For each 40 non-linear acres or
fraction thereof, there is authorized a charge of $250.  Since there has been
no determination concerning borrow as a related structure or facility, we will
defer the acre charge until such time as borrow might be authorized.

Item 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 trans-
     portation 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.

Sincerely,
Regional
Alaska Region

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                                        Tpommco Alaska
•Mr. Floyd Sharrock
U.S. National Park Service
2525 Gambell, Room 107
Anchorage, AK 99503
August 20, 1984
Dear Floyd:

As  per  our conversation  of  August 16,  1984,  this letter
confirms  Cominco's completion of  the  summer geotechnical
program  within Cape  Krusenstern  National Monument.   Our
investigations  have  indicated  the need for  one  small
realignment of the road and the adding of one borrow site.
(Please  refer  to  the  enclosed map.)  This modification is
suggested  because of  the poor soil conditions  which were
identified on  the more northerly segment of  the road.  Due
to  the   generally poor soil  conditions found  along this
segment  of the road,  the alignment modification will not
change Cominco's  initial  cost estimates.  Maintaining the
road  route along  its original route would have  increased
the cost of the  road.   (Cost estimates  were outlined in
"An  Economic  Evaluation  of  Alternative  Road  Routes from
Red Dog  to Transhipment  Site, June 1984".)   In the review
of  the  proposed  change, no  adverse environmental impacts
have been  identified  by Cominco.

Other than the one suggested change,  no other major modi-
fications  are anticipated in the   road  alignment at this
time.

The enclosed  information should complete  the data request-
ed  of Cominco to complete  the Title  XI  application.   If
this  is  not the  case, please  notify us  as  soon  as possi-
ble.

Sincerely,
   vironmenral  Coordinator
 aw
 Enclosu/e

 cc:  Mr. William Riley,  EPA

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                    ITBRN
          PARK BOUNDARY
                   RED DOG
                    MINE
RED DOG ROAD

MUD L.AKB

ROAD ALTERNATIVES

-------
Cominco Alaska/5660 "B" Street/Anchorage, Alaska 99502/Tel. (907) 563-3686
 Roger Contor
 Regional Director
 National Park Service
 2525  Gamble
 Anchorage,  Alaska  99501
 August 27,  1984
                                                   Alaska Region Offira
                                                     I
                                                  	I ™ \\	II.
                                          TComir Gq ftl|efy-
FO f|   ||
'* 'I   I!
WP
 Dear  Roger:

 Cominco  would like to clarify it's Title XI Application  in
 regards  to the  status of  road  alignment and  Barrow site
 location.   It is our understanding that the final detailed
 road  alignment will not be determined until after Congress
 makes their  decision  on  the  Title  XI  permit.    Final
 alignment  would be  determined in the  field  in conjection
 with  the final  design of  the road  and  bridge crossings.
 We  would like to  request  that Title XI decision  be based
 on  a  3/4 mile corridor and that  the  road  would be located
 within this corridor.

 In  regards  to the  final Barrow  site locations, it  is our
 understanding that Congress will make the determination as
 to  whether  Barrow can  be  taken  from within  the monument.
 Once  that decision is  made the final identification of the
 Barrow sites  can be accomplished.  However,  to clarify our
 position,  enclosed is  a map  showing our  current  thinking
 on  Barrow site  location.

 We  would like to  request  that this  letter be  included as
 part  of  our  Title  XI  Permit  Application.     If  our
 understandings  are not correct,  please contact  us  as soon
 as  possible.

 Sincerely,
  rry A. Noah
  visonmental Coordinator
HAM/jlh

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     CHUKCHI
NOTE:
   - DARK AREA REPRESENTS
     ACTUAL SITE AND WOULD
     SUPPLY ALL GRAVEL  NEEDED

   - EXPLORATION AREA 13 THE
     TOTAL AREA WITHIN WHICH
     THE SITE MAY BE LOCATED
                                                                                                           t       .
                                                                                                   Comlnco  Alaska
                                                                                          1  MILE    Red Doo  Project
                                                                                                   Chukchi S«fl 0
                                                                                                   071-OYD-2-830359
                                                                                                   Sheet 1 o» $   8/S4
                     PORT SITE

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      -   Comlnco  Alatka
1 MILE    Rtd Ooo Project
         Chukchi Saa 9
         Sheet i of a   »/«4

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              United States Department of the Interior
                           NATIONAL PARK SERVICE
IN REPLY REFER TO:
    L76(ARO-CTS)
      ALASKA REGIONAL OFFICE
     2525 Gambell Street, Room 107

     Anchorage, Alaska 99503 - 2892
                                                      AUG 6 1
    Mr.  Harry  Noah
    Environmental Coordinator
    Cominco  Alaska
    5660 B Street
    Anchorage,  Alaska  99502

    Dear Mr. Noah:

    In our letter of  February 10, 1984, we itemized the deficiencies

    in the "Title XI" permit application by Cominco Alaska for a

    right-of-way across Cape Krusenstern National Monument.  The

    additional  information provided in the report, An Economic

    Evaluation  of Alternative Road Routes from RED DOG to a

    Road/Marine Transhipment Site, and in your letter dated August

    27,  1984,  appears to complete the information required by Title

    XI and necessary  for National Park Service purposes.

    Sincerely,
ActingRegional  Director
    Alaska  Region

    cc:
    Joe Williamson,  COE
    Bill RTley,  EPA
    Paul Gates,  DOI
                  i rr-" -
     UJIS1

iu
          SEP

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L76(ARO-CTS)

                                                  31 AUG 1984
Mr. Barry Morehead
Department of Transportation
Division of Administration
P.O. Box 1648
Juneau, Alaska  99802

Dear Mr. Morehead:

As we discussed a few weeks ago, and again today, we are
forwarding a copy of the report, An Economic Evaluation of
Alternative Road Routes from RED DOG to a Road/Marine
Transhipment Site.                             ~   ~~~

In the opinion of the Chief, Division of Facility Design and
Maintenance, Alaska Region, National Park Service, the report  is
suitable for an independent evaluation of the proposed
construction.  A copy of that opinion is attached.  As indicated
in the introduction to the report, the intent was to provide
route selection and engineering data sufficient to permit a
detailed independent review.

The issues that we would like the Department of Transportation
to address are:  appropriateness of the engineering design for
the area, and for the purposes of the construction; accuracy of
the cost estimates based on engineering design; and evaluation
of the comparative costs for the alternative routes.

The applicant company has advised us that its engineers will be
available upon request to discuss these data with you.  Contact
person is Harry Noah, Environmental Coordinator, Cominco Alaska
(907/563-3686) .

Sincerely,
          6HARROCK
Floyd W. Sharrock
Chief, Office of Consulting
  and Technical Services

Enclosure

FWShar rock :le: 8/3 0/84

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              United States Department of the Interior
IN REPLY REFER TO:
    L76(ARO-CTS)
NATIONAL PARK SERVICE

 ALASKA REGIONAL OFFICE
 2525 GambelI Street, Room 107
 Anchorage, Alaska 99503 - 2892
10 SEP 1984
    Mr. Harry Noah
    Environmental Coordinator
    Cominco Alaska
    5660 B Street
    Anchorage, Alaska  99502

    Dear Mr. Noah:

    In your letter of August 27, you  indicate  certain
    clarifications, or modifications,  in Cominco's  Title XI
    right-of-way application.  We understand these  to  be:   1)  the
    addition of a proposed borrow site approximately one-half mile
    south of Mud Lake, 2) a rerouting  of the proposed  road between
    Bear Lake and the Omikviorok River along the  west  shore of Mud
    Lake, and 3) the addition to the  previously requested
    right-of-way  of a three-fourths  mile  wide corridor  within which
    the road right-of-way will be located.

    We note these changes without comment.  They  will  be forwarded
    for incorporation in the final environmental  impact  statement as
    part of the Title XI application.
    Sincer
             Director
           Region
    cc:
    B. Koula, DOI
    R. Stenmark, WASO-650
    Wm. RiLev, EPA
       Shaver, Superintendent, NWA

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US. Department
of Transportation
Federal Highway
Administration
September  26,  1984
                                  AlasKa Division
                                ocrs^l
Floyd W.  Sharrock,  Chief
Office of  Consulting and Technical Services
National  Park  Service, Alaska  Regional Office
2525 Gambell  Street, Room  107
Anchorage,  Alaska  99503-2892
Dear Mr.  Sharrock:

As requested  by  your August  31,
the report,
f
                                  1984 letter, we  have reviewed
Based on  the  information provided in the report,  the roadway
design is  appropriate for  the  intended purpose.   The cost
estimates  are  reasonable and  compare favorably  with  bid prices
for roadway work performed  by  the State of Alaska in the northwest
part of the state.   Computation  of costs for  the  alternative
routes is  consistent with  good  engineering practice  and should
provide a  good basis for comparative evaluation.

If additional  information  and/or evaluation of  particular design
details is  desired, we suggest  you contact the  Nome  District
of the State  of Alaska, Department of Transportation and Public
Facilities.
                          By:
                                Sincerely yours,

                                Barry F. Morehead
                                Division Administrator
                                Robert E.
                                Assistant
Ruby
Division Administrator

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	Appendix 7
Cultural Resources Protection

-------
  Advisory
  Council On
  Historic
  Preservation
  The Old Post Office Building
  1100 Pennsylvania Avenue, NW, #809
  Washington, DC 20004
  January 26,  1984
  Mr. Floyd Sharrock                                      "   :   	-'-—-.
  National Park Service                                      ;         —'
  2525 Gambell                                            —' ;T— 	-, 	.'
  Anchorage, Alaska  99503                               		'

  Dear Floyd,

  This is with regard to our telephone conversation today concerning the
  draft environmental impact statement on the granting of rights-of-way
  for facilities connected with the Red Dog Mine,  and with regard  to our
  earlier meeting on the same subject.

  As you know, NPS has not yet requested the comments of the Council on
  this undertaking pursuant to Section 106 of the  National Historic Pres-
  ervation Act and our regulations, 36 CFR Part 800.   This is appropriate,
  however, as you are at the draft EIS stage; we do not discourage  earlier
  consultation, but many agencies find it convenient to provide the draft
  EIS as the Preliminary Case Report required by our regulations, and
  obtain our comments in time for inclusion in the final EIS, and we
  encourage this sort of integration of Section 106 and NEPA responsibilities.

  The approach you have described to me verbally,  in which Section  106
  consultation with the State Historic Preservation Officer and Council
  will lead to either protection in place of, or data recovery  from,
  National Register-eligible archeological sites already identified through
  intensive survey of the areas to be affected by  the undertaking,_seems
  to be a reasonable way to proceed.  We will look forward to receiving
  your formal request for comments, and to bringing our review  to a prompt
  conclusion.

  Sincerely,  ,,."  //f ^

    /
  '.Thomas F.*"King,  Director
//'Office of Cultural "Resource Preservation

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I>E1»ARTME.YT OF A'AirRAE RESOURCES

             DIVISION OF PARKS AND OUTDOOR RECREATION

     January  30,  198A

     File:  3130-1  (NFS)
                                                            BILL SHEFFIELD, GOVERNOR
                                                  225A CORDOVA STREET
                                                  ANCHORAGE. ALASKA 99501
                                                  PHONE (907) 276-2653
     Mr.  Roger  Contor,  Regional  Director
     Alaska  Regional  Office
     National Park Service
     2525  Gambell, Rm.  107
     Anchorage,  AK  99503

     Dear  Mr. Contor:

     We  have reviewed  the Draft  Environmental
     Red  Dog Mining Project.
                                     Impact Statement  for  the
     In  general,  we  feel  that  it  is  a  well-done document that responds
     to  the  critical  issues.   As  for heritage resources, there is little
     specific  information  presented  beyond  the number  of sites to be im-
     pacted.   However,  more complete data  is  readily available in the cited
     reports by Hall.   It  appears  that the  level  of  archaeological  survey
     has  been  adequately  intensive to  identify most, if not  all,  of the sites
     in  the  project  area  (except  those,  if  any, that are deeply buried and
     cannot  be discovered  by normal  survey  techniques).

     The  general  procedure for dealing with impacts  to heritage resources
     is  adequately presented.   We  concur with avoidance of sites  if feasible
     and  this  appears to  be the best alternative in  the majority  of cases.
     Some  sites,  of  course, will  require mitigation  by data  collection.   We
     look  forward to working with  the  Advisory Council  for Historic Preservation
     and  involved federal  agencies in  developing a Memorandum of  Understanding
     on mitigation of National  Register  eligible sites and emergency procedures
     for  sites discovered  during  construction (if any).

     In  conclusion,  we  concur  that the project will  have no  significant
     adverse impact  on  cultural resources with appropriate mitigation efforts.

     Please  contact  us  at  265-^lAO if  there are any  questions.

     Sincerely,

     Nei1  C. Johannsen
     Di rector
    By:
T^J^illiplane    /\
State Historic Preservation Officer

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             United States Department of the Inte
                       NATIONAL PARK SERVICE
                         Alaska  Regional Office
                     2525 Gambell Street, Room 107
MFLY KKPKR TO:            Anchorage,  Alaska  99503-2892

                                                            NTAL EVALUATE
     H24(ARO-CTS)                                  ;        BRANCH

                                               7 JUff 1984
     Mr.  Robert  Fink,  Acting  Director
     Advisory  Council  on  Historic Preservation
     730  Sirams,  Room 450
     Golden, Colorado  30401

     Dear  ttr.  Fink:

     Pursuant  to Title XI  of  the Alaska National Interest Lands
     Conservation Act,  Cominco  Alaska has filed a joint
     application with  the  Corps of Engineers, Environmental
     Protection  Agsncy, and  the National Park Service for permits
     necessary for  the project.  Operating under proposed rules
     for  implementation of Title XI,  the National Par.< Service
      (t.'PS)  is  tha agreed  upon "lead agency" for the consolidated
     application.   In  the  capacity of lead agency, the NPS is
     requesting  Advisory  Council review and comment on the
     proposed  federal  action.

     Earlier,  you were provided with  copies of the draft
     environmental  impact  statement (DEIS)  for the project.  In
     that  document  a route that, in part, transects C^.pe
     Krusenstern is  identified  as the preferred route for a
     transportation  and utility system that d-xten^s frc~ th? min =
     site  to the port.    w'hile  the permit application to the tiPS
     is only for a  right-of-way across Cape Krusenstern Motional
     Monument,  as the  designated lead agency, we are soliciting
     Advisory  Council  comments  for the entire project.

     As indicated in the  DEI£>  most of the project area is within
     the  Cape  Krusenstern  Archeologic«l District, a K-. tionsl
     Historic  Landmark.   Field  archeological survey along ths
     proposed  transportation  corridor (rr.im; to port) has
     occurred.   Prehistoric  and historic sites were identified as
     indicated  in the  DEIS.   Level of intensity v:as adequate to
     determine with  reasonable  certainty tne presence or absence
     of sites,  but  was not sufficiently intensive for
     construction clearance.   There was no subsurface testing.
     As ~.  condition  of the parmit, should one be granted,
     intensive "project clearance level" survey of ths area of
     project impact  will  be  conuuctc-d.

     Pursuant  to Section  106  of the National Historic
     Pr-i-sarveticn Act,  as  amines.::, and 35 JFR o03 .;G r.av* applied

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the Criteria of effect and have determined that the proposed
action covered by the DEIS will have no adverse effect by
virtue of facilities design to avoid identified cultural
sites, or by scientific data recovery in accordance with the
Advisory Council's "Recommendations for Archeologi£P"D3ta
Recovery," and in conformance with "Archeology and Historic
Preservation; Secretary of the Interior's Standards and
Guidelines."  The cited standards for data recovery will
apply to the two sites that cannot reasonably be avoided,
and to any sites discovered in emergency situations.

Sincerely,
         Director
Alaska Region

cc:
State Historic Preservation Office
H. Noah, Cominco Alaska
W. Riley, EPA
P. Gates, DOI
J. V7illiamson, CCE
J. Richter, Ott VJater Engineers
J. Estus, NPS/ARO
K. Schoenberg, NPS/ARO

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                                                      '  3  AUG 1984
                                                    BILL SHEFFIELD, GOVERNOR
      Piuch 7001
ALASKA mm 99510
DEPARTMENT OF NATURAL RESOURCES

            DIVISION OF PARKS AND OUTDOOR RECREATION


  July 3O,  1984

  File:  3440  (NPS)
  Dr. Floyd Sharrock
  Chief, Consulting  & Technical Services
  ftlaska Regional  Office,  NPS
  £5£5 Bambell  Street,  Room 107
  ftnchorage,  ftK 995®3-£89£

  Dear Floyd:

  Thank you for your letter of June 6,  1984  concerning the  Red  Dog

  Project  in  and near Cape Krusenstern  National  Monument.



  We  have  reviewed  the project documents and   concur  with  your

  determination of "No ftdverse Effect"  with the  conditions outlined

  in your  June  7th letter (file no.   H24  (flRO-CTS))  to the ftdvisory

  Counci1.
  Please contact  us  at  £65—4140 if there  are any questions.

  Sincerely,

  Neil C. Johannsen
  Director
                                                 !'p\\
                                                 ' -
  By:  Judith E.  Bittner
       State Historic Preservation Officer

  TftS:tls
                                                      AUG

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Advisory
Council On
Historic
Preservation
The Old Post Office Building                  Reply to:   730 Simms Street, Room 450
1100 Pennsylvania Avenue, NW, #809                     Golden, Colorado 80401
Washington, DC 20004

September 6, 1984

Mr.  Roger Contor
Regional Director
National Park Service
Alaska Regional Office
2525 Gambell Street, Room  107
Anchorage, AK  99503-2892

REF:  Red Dog Mining Project affecting Cape Krusentern National
      Monument, and Cape Krusentern Archeological  District

Dear Mr. Contor:

On August 20, 1984, the Council's Western Division of Project
Review received your determination as project  lead agency that
the referenced undertaking would have no adverse effect on the
above properties which are listed on the National  Register of
Historic Places.  We have reviewed your supporting documentation,
but  we cannot agree with your finding for the  following reasons:

    Your no adverse effect determination is based  on  either
    avoidance or by negation of adverse effects by means of data
    recovery.  As yet, a data recovery plan (or plans) and the
    requisite intensive survey and subsurface  testing have not
    been accomplished.  Therefore, its adequacy as a  means to
    negate adverse effects cannot be assessed.

Therefore, the Executive Director objects to your  determination.

Under Section 800.6(a)(2) of the Council's regulations, your
acceptance of the following condition will eliminate  the basis
for our objection:

    Data recovery plans as referenced in your  letter  dated
    June 7,  1984, shall be developed in consultation  with the
    Alaska State Historic Preservation Officer  (SHPO).  Data
    recovery plans shall be submitted, together with  pertinent
    SHPO comments to Council staff for review.  The Executive
    Director or his staff shall have  15-days in which to object
    to the plans.  Should the Executive Director object to the
    provisions of a data recovery plan, the Executive Director
    shall either:

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         a)  refer  the matter  to the Chairman  pursuant  to 36 CFR
            Section  800.6(b)(7);  or

         b)  provide  NFS with  recommendations,  which shall be taken
            into account in developing final  data  recovery plans.

 If you agree  to implement  this condition,  please  sign on the
 concurrence line  below, return this letter to us,  and also send a
 copy to the Alaska  State Historic  Preservation Officer.  This
 will then be  incorporated  into your determination  and compliance
 with Section  106  and the Council's regulations will be complete.

 Thank you for your  continued cooperation.

 Sincerely,
     •t  Fink
 Chief,  Western Division
  of  Project Review
 I  concur: *
                                 e)
* Concurrence is with the further understanding that activities
within the boundaries of Cape Krusenstern National Monument will
be directed according to the guidelines of the current NPS-28
which is the basis for a Programmatic Memorandum of Agreement
among the Advisory Council on Historic Preservation, the
National Park Service, and the National Council of State
Historic Preservation Officers.

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	Appendix 8
            Coastal Zone
Management Consistency

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          OFFICE OF THE GOVEISKOB.

      DIVISION OF POLICY DEVELOPMENT AND PLANNING
              GOVERNMENTAL COORDINATION UNIT
                                               BILL SHEFFIELD, GOVERNOR
                                              POUCH AW (MS • 01BSi
                                              JL'tJSAU. ALASKA S$811
                                              P.-iOt.'E: 1507) 465-3SG2
             Certification of Consistency with the
             Alaska  Coastal  Management Program
                      Re:  Department of the Army Permit
                          Application No. 071-OYD-2-830359
                          Appl icant .•Cominco Alaska
                                                       o-f
Section 307(c)(3) of the'  Coastal  Zone Management Act
1972 as amended  by 16  USC 1456(c)(3) requires the applicant
for a Federal permit to conduct an activity affecting land
cr water ui.es in.the Alaska  ccastal  .zone to provide certifi.
cation that .the  activity  will  comply with the Alaska
Coastal Management Program {ACMP).
'The  propose
is within't
requi red  be
Public  Noti
cation,  the
the  certifi
be forwarde
 Manning  fo
  nf orrnati on
  ontact  the
  ' 99811,  o
           d activity  described  in you
           he ACMP,  and  the  following
           fore your application can b
           ce.  Upon receipt  of  the si
            Public  Notice  will  be issu
           cation statement.-   The Pub!
           d to the  Division  of  Policy
           r its concurrence  or  object
            on the  Alaska  Coastal Mana
            Office  of  Coastal. Manageme
           r the Division  at  the above

            CERTIFICATION  STATEMENT
r permit application
certification is
e processed to
gned,  "dated certifi-
ed and wi11 include
i c Noti ce will .  •
 Development end
ion.  For additional
cement Program,
nt, Pouch AP, Juneau,
 address.
    ertify  that,  to the best of my knowledge  and  belief,
     proposed activity described in Department  of the Army
     ication  No.   Q71-OYD-2-830359   complies  with the approved
     
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             OFFICE OF THE GOVERNOR

             OFFICE OF MANAGEMENT AND BUDGET
         DIVISION OF GOVERNMENTAL COORDINATION
SOUTHEAST REGIONAL OFFICE
431 North Franklin
Pouch AW, Suite 101
Juncau, AK 99811-0165
Phone:  (907) 465-3562
SOUTHCENTRAL REGIONAL OFF 1CE
2600 Denali Street
Suite 700
Anchorage, AK 99503-2798
Phone: (907) 274-1581
                                                    BILL SHEFFIELD, GOVERNOR
                           CENTRAL OFFICE

                           POUCH-AW
                           JUNEAU, ALASKA 99811 -0165
                           PHONE. (907) 465-3562
NORTHERN REGIONAL OFFICE
675 Seventh Avenue
Station H
Fairbanks, AK 99701-4596
Phone:  (907) 456-3084
  Registered Mail                  August 6, 1984
  Return Receipt
  Requested
 Mr.  Harry Noah
 Cominco Alaska
 5660 "B" Street
 Anchorage, AK  99502
  Dear Mr. Stoech;
  SUBJECT:  RED DOG MINE TITLE  11  PERMIT PACKAGE
            STATE  I.D.  NUMBER AK840525-20C

  The Division of  Governmental  Coordination  (DGC)  has complete
  review of Red Dog mining project against the  standards of  tJ
  Alaska Coastal Management Program.   The project proposal co
  of an inland open pit lead/zinc  mine, mineral concentrator,
  coastal shipping facility, and an interconnecting transporj
  system.

  This conclusive  consistency determination  applies to the
  consistency requirements for  your project  and the followi
  and/or federal authorizations as per 6 AAC 50:

       1.   U.S. Army Corps of  Engineers  (COE)  permits COF
            071-OYD-4-840012 and COE 071-OYD-2-830359.

       2.   Environmental Protection Agency  (EPA)  Nation?
            lution Discharge Elimination System (NPDES)
            AK-003865-2 and AK-004064-9.

       3.   Alaska Department of Environmental  Conserva
            Certificates of Reasonable Assurance (401)
            permits named above.
  Based on our  review, the Division concurs  that the j

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Mr. Noah
             - 2 -
                     August 6, 1984
consistent with the Alaska Coastal Management Program provided
the following stipulations are added to the NPDES permit
AK-004064-9 issued by the EPA:
Page 3 I.E. Effluent Characteristics (outfall 002).
following monitoring requirements:
                                    Add the
Effluent
Characteristics
Zinc (mg/1)
Lead (mg/1)
Mercury (mg/1)
Cadmium (mg/1)
Effluent
Daily
Maximum

1.0
 .6
0.002
0.10
Limitations
30 day
Average

 .5
 .3
0.001
0.05
Monitoring Requirements
Frequency Sample Types
Monthly
Monthly
Monthly
Monthly
Grab
Grab
Grab
Grab
Page 6, II, Add the Following:

E.   Monitoring Program Revisions

     1.   The type and frequency of sampling may be changed
          depending on the above effluent and field monitoring
          program results.

     2.   EPA may require additional monitoring, including
          biomonitoring if mercury, lead, zinc, cadmium, or oil
          and grease concentrations exceed effluent limits.

These stipulations are necessary to insure that the parameters
included in the water quality monitoring program at the Port Site
include sampling for heavy metals as per 6 AAC 80.140 AIR, LAND,
AND WATER QUALITY.  The text of this standard is provided as an
enclosure to this letter.

The National Park Service Right-of-Way permit to construct the
transportation system through the Cape Krusenstern National
Monument has also been under consideration during this project
consistency review of the Title 11 related approvals.  The State
continues to support the southern corridor through Cape
Krusenstern, and finds the COE permit description of the road
grade and fill placement through that corridor acceptable at this
time.  However, we reserve comment on the final recommended terms
and conditions applicable to the National Park Service
Right-of-Way permit until such time that the State's Department
of Natural Resources, NANA-Cominco, and the National Park Service
are prepared to jointly develop and implement terms and con-
ditions which will effectively address the concerns and respon-
sibilities of these land management groups.  Our postponement of
the final consistency review comments on the Right-of-Way is not

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Mr. Noah                      - 3 -             August 6,  1984
intended iri any way to hinder progress on the Alaska National
Interest Lands Conservation Act, Title 11 permit processing.

By a copy of this letter we are informing the EPA,  COE,  and the
National Park Service of our consistency finding.

Thank you for your cooperation with the Alaska Coastal Management
Program.
                                 Lncerel
                                Robert L. Grogan
                                Associate Director
Enclosure
cc:  Esther Wunnicke, Commissioner, DNR, Juneau
     Dick Neve1,  Commissioner, DEC, Juneau
  \  Don Collinsworth, Commissioner, DFG, Juneau
     Jerry Brossia, District Manager, DNR, Juneau
     Douglas Lowery, Regional Supervisor, DEC, Juneau
     Al Ott, Regional Supervisor, DFG, Juneau
     Fred Wemark, NANA CRSA, Kotzebue
     Bill Riley,  EPA, Seattle
     Joe Williamson, COE, Anchorage
     Floyd Sharrock, NFS, Anchorage

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                         STATE OF ALASKA

              DIVISION OF GOVERNMENTAL COORDINATION

                        STANDARDS OF THE

                ALASKA COASTAL MANAGEMENT PROGRAM
Standard(s):   6 AAC 80.140.  AIR, LAND, AND WATER QUALITY.
Notwithstanding any other provision of this chapter, the stat-
utes pertaining to and the regulations and procedures of the
Alaska Department of Environmental Conservation with respect to
the protection of air, land, and water quality are incorporated
into the Alaska coastal management program and, as administered
by that agency, constitute the components of the coastal manage-
ment program with respect to those purposes.

                             Authority: AS 44.19.893
                                        AS 46.40.040
                           - 1 -

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