x>EPA

  DOI
United States
Environmental Protection
Agency
Region 10
1200 Sixth Avenue
Seattle WA 98101
                                     910983111A
February 1984
Water
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

Volume II—Appendices
                                       Draft

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                           RED DOG MINE PROJECT
                         DRAFT ENVIRONMENTAL  IMACT
                                 STATEMENT

                          Volume II:  Appendices
1.   Reclamation Plan
2.   Spill, Prevention, Control and Countermeasure Plan
3.   Endangered Species Biological Assessment
4.   NPDES Draft Permit
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

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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 1 3 1984
                                            tNVIRONMENTU l\*\>j
                                                  P.-A.NCH

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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
         5.3,1  Open Pit Mine                                            24
         5.3.2  Mine Waste Dumps                                         29
                                                                         •30
         5.3.3  Tailings Impoundment
                                                                         00
         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.







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 cf Kotzebue, together with



associated transportation and shipping facilities.

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                              - 3 -
  PAC IFIC 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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Red Dog  Mine Site
          FIG. 3.1


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                                                                            -  8  -
Table 3.1:  Nature and Extent of Land Disturbance Associated with Red Dog Mine Project
            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
  	3£

  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
  2,070
III-A4, III-C3
    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



     in 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 differentecological  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, numbers 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
                           IU.TIA.      PROPOSED
                           INITIAL   '   OITCH/BERM
           FIG. 5.1     MINE PIT  LAYOUT

-------
                                                        - 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.

-------
                                                               -  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 phlebophyljji)
       and netleaf willow (S.  reticulata).   Dwarf arctic birch
       (Betula nana) and narrowleaf 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.   Diamond!eaf willow also
       appears as a co-dominant with  dwarf  arctic birch, narrow-
       leaf Labrador-tea and  Vaccinium  species in some  areas  of

-------
                                                        -  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

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

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

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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,

-------
                                                        -  35  -








and Friophorum angustifol ium.   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

-------
                                                        -  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

-------
                                                        - 37 -
is terminated, it is proposed that all  free standing super-
natant water will be treated and discharged to Red Dog
Creek, exposed 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
permafrost.  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 particulary 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  Water 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
       hydrological 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 8451
      MAX 848*
   SCALE
   1000
   ES_i
   FEET
2000
                        SYNTHETIC  LINER
SECTION
       DA M
     FIG. 5.3    WATER  STORAGE   POND    J

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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

-------
                      - 41 -
FIG 5.4   MILL SITE  PLAN

-------
                                                             - 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.

-------
      30
          IU
       FILL
      ORIGINAL GROUND"
TYPICAL ROAD SECTION
                                 - 43 -
    FIG.  5.5  LAND  TRANSPORT

-------
                                                        -  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 tne corridor.  Known peregrine falcon nesting  sites

-------
                 - 45 -
FIG.5.6  ROUTE  MAP

-------
                                                        - 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



and, 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

-------
                                                             -  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.

-------
                                                        - 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

       AMD 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)
                                                                        Paqe
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.
                                      in

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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 a 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-Ill)
Sulfuric acid, 93% (H_SC> )
Hydrated  lime ((CaOH) )*
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 the
            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%  HUSO.
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.

     In 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  (SiO_)  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 %                       -     O.'ll
            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

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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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0
                                                •a—
                                                                                                                                                                                        TIP O0« T .
           4-
                                                                 -t    !
                                                                                                                            v,
                                                                                                                            51

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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  3.3
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                              Krusenstern
                               National
                               Monument
Red Dog Port
  ( VABM 28)
                                                                               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 will  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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       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  tl-e  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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 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.
         o
    0  Ambient  conditions at location.
    0  Specific  material  and estimated quantity.
       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  Conl.ro!
            Mine  Site
       Size
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 Snowpiow 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
     Typical  Unit
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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     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
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
     Typical  Unit
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.

           HP Marine  -  HP  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  sulfuric  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  sulfuric  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 wAjch
        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.   Simply  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 well  as environmental  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).

Terres t ri a1 Spec i e s

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
kokrinensi s) 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.  si bin'cum,  Angelica  lucid a,  and
Senecio 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 (Mines 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 (Mines
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 1eg r u s t i 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 GCO 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.

Mines, 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.  Jn_ Wi 1 imovsky,  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 r obus tus) 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 Wrangel1 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.
                                  - 5 -

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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  (Eschrichtlus robustus)
    sightings in eastern Beaufort Sea.   Arctic  34(2): 186-187.

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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,
                                   ^VRegional  Director1
cc:   NAES
     LWRDP

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                                  UNITED STATES DEPARTMENT OF COMMERCE
                                  National Oceanic and Atmospheric Administration
                                  National Marine Fisheries Service
                                  P.O. Box 1668
                                  Juneau, Alaska  99802
                                                                     '....V^*
September 28, 1983
Mr. William M. Riley
Environmental Evaluation Branch (M/S 443)
Environmental Protection Agency                       %$•*•••   "$NV '
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

-------
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 arid 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,
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 north to the Chukchi Sea where the grey 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
(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 _al_., 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

-------
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, 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.

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.

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                     United States Department of the Interior
                                 FISH AND N\ II.DL I FT, SERVIC'E
IN REPLY REFER TO.                        101 1  E. TUDOR RD.
                                 ANCHORAGE, ALASKA 99503
         SE                              (907) 276-3800

         William M. Riley, EIS Project Officer                       ^     .  
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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,
                                    •3,,,, Regional Direct

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          U.S.  ENVIRONMENTAL  PROTECTION  AGENCY

 rtto Sri,.                         R E G ! O N  X
0^      $
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	Appendix A
NPDES Draft Permit

-------
                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 DRAFT  ENVIRONMENTAL  IMPACT  STATEMENT,  AND

                         NOTICE OF PUBLIC HEARING,  AND

                         NOTICE OF STATE CERTIFICATION
Public Notice No.:   AK-003865-2

Public Notice Issuance Date:  March 16, 1984
Public Notice Expiration Date:  May 14, 1984

1.    Applicant:

         Cominco Alaska Incorporated
         5660 "B" Street
         Anchorage, Alaska  99502

     a.  The applicant has applied for a National Pollutant Discharge
Elimination System (NPDES) permit to discharge pollutants to navigable waters
pursuant to the  provisions of the Clean Water Act (CWA).  The applicant
proposes to operate an open pit mining and mineral concentrating facility
north of Kotzebue in Northwest Alaska.  The treated wastewater discharges
resulting from the proposed facility will be discharged to Red Dog Creek,
which is being reclassified by the State for applicable Water Quality
Standards.

     b.  The National Environmental Policy Act (NEPA) requires that a detailed
statement be preparea for every major federal action with a potential for
significantly affecting the quality of the human environment.  This statement,
called an Environmental Impact Statement (EIS),  evaluates the potential
environmental effects of such federal actions in addition to identifying
alternatives to the proposal.  EPA's NPDES regulations state that the issuance
of an NPDES permit to a new source may be a major federal action and therefore
subject to the NEPA requirements.

An NPDES permit  is required for the proposed Red Dog mining and milling
facility.  This  facility has been determined to  be a new source under the
NPDES regulation definitions.  An environmental  review conducted for this
proposal shows that significant environmental impacts may occur.  Therefore,
the issuance of  an NPDES to the proposed Red Dog facility is a major federal
action requiring the preparation of an EIS.

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                                      -2-
     c.  The EIS has been prepared and is being released for concurrent public
review with the proposed NPDES permit.  The EIS considers the environmental
impacts of the proposal as well as project alternatives (such as the location
and design of the transportation corridor).  Environmental, cultural, social
and economic impacts on the NANA region in particular and State of Alaska in
general are discussed at some length.  A unique feature of the Red Dog project
is that the applicants preferred alternative would involve a transportation
corridor through Cape Krusenstern National Monument.  This would require
consideration of the specific requirements mandated by Title XI of ANILCA for
acquiring a right-of-way across the monument.

EPA and Dept. of Interior have been the lead agency in preparing the EIS, and
the U.S. Army Corps of Engineers is a cooperating agency.  Technical
assistance was provided by OTT Water Engineers.

     d.  On the basis of the information in the draft EIS, EPA has made a
preliminary determination to issue the NPDES permit to the applicant.

2.   Tent at i ve peterrni nati on

The Region 10 Office of the Environmental Protection Agency  (EPA) has
tentatively determined to issue a discharge permit which  incorporates effluent
limitations which must be complied with to satisfy the New Source Performance
requirements and State of Alaska water quality standards.

3.   Pub!i c Hear in gs

EPA will hold public hearings on the proposed NPDES permit and the draft EIS
at the following locations and times:

ANCHORAGE                    KOTZEBUE                WASHINGTON, D..C.

May 2, 1984                  May 3, 1984             April 24, 1984
Nat. Park Srv. Office        NANA Museum             Room  7000 B
Room 110                     7:30 P.M.               Main  Interior  Bldg.
2525 Gambel St.                                      18th  &  C St. N.W.
7:30 P.M.                                            1:00  P.M.

4.   Public Comments

The proposed issuance of the NPDES permit  and the  availability of the  draft
EIS will be announced in the Federal  Register on March  16,  1984.

This announcement will  initiate a 60  day  review period,  ending May  14,  1984.
EPA solicits comments from all  interested  persons  and will  consider  these
comments before any  final actions are  taken.  All  comments  should include  the
name and address of  the  commentator,  and  concise statements  of  the  relevant
background  documentation or facts which  the  comment  is  based upon.

Written  comments on  the  EIS should be  submitted to EPA  to the attention of
Bill Riley, Mail Stop 443, 1200 Sixth  Avenue, Seattle,  Washington   98101  by
May 14,  1984 or presented to EPA  at  the  public hearing.   Written  comments  on
the NPDES permit should  be submitted  to  EPA  to the attention of  Wally
Scarburgh,  Water Programs Coordinator  -  Alaska, 3200 Hospital  Drive, Juneau,
Alaska   99801  by May 14,  1984  or  presented to  EPA  at the public  hearing.

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                                      -3-
Oral comments will  be accepted at the public hearing.

Persons wishing to  comment on the State Certification should submit written
comments to the State of Alaska, Department of Environmental Conservation,
Central Office, Pouch C, Juneau, Alaska  99811, by May 14, 1984 or presented
at the public hearing.

5.   State Certifi c at ion

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.

6.   Adnri n i strati v e Re cord

The proposed NPDES  permit, draft EIS and other related documents are on file
and may be inspected at any time between 8:30 am and 4:00 pm Monday through
Friday at EPA in Room 11D, 1200 Sixth Avenue, Seattle, Washington.  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 cost is  less than 25 dollars.

Additional copies of the NPDES permit and fact sheet may  be obtained from
Terry Moan, Mail Stop 521, EPA, 1200 Sixth Avenue, Seattle, Washington  98101
or by calling (206) 442-1286.

Additional copies of the draft EIS may be obtained from Bill Riley, Mail  Stop
443, EPA, 1200 Sixth Avenue, Seattle, Washington  98101 or  by calling
(206) 442-1760.

7.   Avai1abi1i ty of Documents

EPA and DOI will announce the availability of this document in the Federal
Register on Friday, March 16, 1984,  initiating a 60-day review and comment
period.  Comments should be submitted by May  14, 1984 to:

                   Will iam Ni. Riley
                   EIS  Project Officer
                   Environmental Evaluation Branch M/S 443
                   Environmental Protection Agency
                   1200 Sixth Avenue
                   Seattle, WA  98101

                   Telephone:   (206) 442-1760

Please bring this information to the attention of other persons  who might be
interested in this matter.

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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
     0.  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
     J.  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  in 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
     L.  Severability
     M.  Transfers

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

     A.   Specific  Limitations and Honitoring_ 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
             Moni tori ng Requirements
   30.0       20.0
(see  paragraph 4. below)
    N/A        N/A
Frequency
   (During

Continuous
Weekly
Weekly
Weekly
Weekly
Weekly

Weekly
Daily
Daily
 Samp 1 e Jype
DiscVargej

  Recorded
  Grab
  Grab
  Grab
  Grab
  Grab
  24 hr.
  Composite
  Grab
  Grab
         2.   Discharges
         October.
  are  only  permitted during the months of May through
         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 hoore "Environmental Baseline Studies - Red Dog Project" as
follows:

         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 biomonitoring 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.

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                                                 Page 5 of 19
                                                 Permit Mo.:   AK-003865-2
     C.   B1pmonitori ng  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
cola-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  biominitoring 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
         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.

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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 of_ 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.
                                                         DRAFT

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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
                                            Permit 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.

G.   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.
                                                      DRAFT

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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
         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  noncornpliance 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.

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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
                                                 Permit No.:
                                                        19
                                                         AK-003865-2
IV.
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.

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:
             That  any activity  has  occurred  or  will  occur which would  result

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

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                                             Page  16  of  19
                                             Permit 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.

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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
                                            Permit 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.  Aval 1 abi 1 ity 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.
                                                    DRAFT

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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.

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                                  FACT SHEET

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


                                                    Date:  March 16,  1984

Application No:  AK-003865-5; Cominco Alaska Incorporated

PROPOSED ISSUANCE OF A NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES)
PERMIT TO DISCHARGE TO THE WATERS OF THE UNITED STATES PURSUANT TO THE
PROVISIONS OF THE CLEAN WATER ACT.

        Applicant:    Cominco Alaska Incorporated
                      5660 "B" Street
                      Anchorage,  Alaska  99502

has applied for a National Pollutant Discharge Elimination System (NPDES)
permit to discharge pollutants from an open pit lead and zinc mine pursuant to
the provisions of the Clean Water Act.  The facility will be located  82 miles
north of Kotzebue, Alaska at Latitude 68° 4'  17" N., Longitude 162° 52' 05" W.
The receiving waters will be Red  Dog Creek.   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, (c)
background information and a description of the proposed discharges,  (d) basis
for limitations and monitoring, and (e) other information.

The proposed NPDES permit and other related documents are on file, and may be
inspected and copied 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 also is available from the EPA Alaska
Operations Office, 3200 Hospital  Drive, Juneau, Alaska 99801, and EPA Alaska
Operations Office, Room E556, Federal Building, 701  C Street, Anchorage,
Alaska 99513.  A copying machine  is available in the Seattle and Juneau
offices for public use at a charge of 20 cents per copy sheet.  There is no
charge if the total cost is less  than $25.00.

A.  TENTATIVE DETERMINATION

    EPA has tentatively determined to issue an NPDES permit to discharge to
the above listed applicant subject to certain effluent limitation and
monitoring requirements.

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                                     -2-
B.  PUBLIC COMMENT

    Persons wishing  to comment  on  the  tentative  determination of the  proposed
permit may do so by  the expiration date  of  the  Public  Notice.  All comments
should be submitted  in writing  to  EPA  as described  in  the  Public Comments
section of the attached Public  Notice.

    After the expiration date of the Public Notice,  a  final  determination  will
be made with respect to the  permit.  The tentative  determinations  contained  in
the draft permit will become final conditions  if no substantive comments  are
received during the  Public  Notice  period.

    The permit will  become  effective 30  days after  the final determinations
are made, unless a request  for  an  evidentiary  hearing  is submitted within  this
30 day period.  An evidentiary  hearing will be  granted only  if it  meets  all
the requirements of  40 CFR  124.74.

C.  BACKGROUND INFORMATION

    Following a U.S. Bureau of  Mines study  in  the Red  Dog  area during the
early 1970's information was released  in 1975  indicating a zone of high  lead
and zinc mineralization.  Although Cominco  staked claims in  the years to
follow, the NANA Regional Coorporation obtained  selection  rights to  the  Red
Dog claims with the  passage of  ANILCA  in 1980.   Cominco was  soon selected  by
NANA to act as a partner and developer of the  deposit. An NPDES permit
application was submitted by Cominco Alaska Inc. on January  15,  1983.
Cominco is defined as a new source according to  the NPDES  regulation
definitions (40 CFR  122.2).

D.  PROPOSED PROJECT

    Proposed mining  methods are to consist  of waste rock removal followed by
drilling and blasting of ore benches  in  a open pit.  Waste rock  not  suitable
for processing will  be stockpiled.  During  the first stages  of preproduction
it is anticipated that 1,365,000 tons  of material will be  removed.  Production
mining will involve  an annual extraction of 1,057,000 tons of  ore  with
approximately 3400 tons of  ore  daily  being  sent to a concentrator  mill.   A
selective flotation  process will  be employed to concentrate  the  minerals.
Milling processes will include  size reduction through crushing and autogeneous
grinding, selective  mineral concentration and dewatering of  concentrates.

E.  DESCRIPTION OF DISCHARGE

    It is anticipated that during  the  first five years of  operation  the
lead/zinc concentrator will require approximately 2100 gallons  per minute of
water to process approximately 3000 tons of ore per day.   The  applicant
proposes maximum recovery of processed water utilizing recycling in  excess of
85 percent.  The remaining  "bleed" of  process water will  be  discharged into
the tailings impoundment and co-mingled  with mine-site drainage.   The tailing
pulp discharge into the  impoundment will be alkaline at a  pH of  9.0  to 9.5.   A
berm/ditch system is proposed by the  applicant which will  divert mine runoffs
to the tailings impoundment site.   This  runoff will typically be characterized
by high  heavy metals concentrations,  particularly zinc.

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                                     -3-


    Additional  discharges  to the  tailings  impoundment  will  include  sanitary
wastewater yielding a total  8005  input  to  the  impoundment  of  approximately
56.3 Ibs.  per day.

    All discharges  from the  tailings  impoundment  will  be treated  via a High
Density Sludge  (HDS)  wastewater treatment  plant.   This process  consists of the
addition of lime to neutralize acidity  and precipitate soluble  metals as
hydroxides followed by flocculent induced  clarification to remove sludge
solids.  The applicant has summarized the  treated effluent characteristics as
follows:

             Parameter                                 Concentration

             Flow,  mgd                                    3.9 (6.0 cfs)
             pH                                          10.5
             Suspended Solids, mg/1                        5.0
             Aluminum, mg/1                                0.15
             Arsenic, mg/1                                 .002
             Barium,  mg/1                                   .05
             Beryllium, mg/1                               .003
             Calcium, mg/1                              500
             Cadmium, mg/1                                 .02
             Chromium, mg/1                                 .03
             Cobalt,  mg/1                                   .02
             Copper,  mg/1                                   .015
             Lead,  mg/1                                    .02
             Mercury, mg/1                                 .00005
             Nickel,  mg/1                                   .025
             Zinc,  mg/1                                   1.5


F.  RECEIVING WATER CHARACTERISTICS

    The waters of Red Dog  Creek do not  support aquatic life typical of most
undeveloped arctic  streams due to high  concentrations  of metals which result
as the main stem flows through the highly  mineralized  exposed ore body.  The
primary pollutants, cadmium, lead and zinc stabilize at highest concentrations
near the confluence of the main stem and the South Fork.   At  this point
background values for these  three parameters all  exceed EPA effluent guidelines
(40 CFR § 440.104).  Although concentrations are  lower in  the North Fork, Red
Dog Creek below the confluence of these drainages still exhibits  elevated
concentrations of these parameters.   Typical concentrations of  selected
parameters on the main stem  just  prior  to  the  confluence with the South Fork
are as follows:

             Parameter                        Concentration

             Flow,  mgd                              7.8 (12 cfs)
             pH                                     6.0
             Suspended Solids, mg/1                 14.3
             Aluminum, mg/1                          0.65

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                                     -4-
             Arsenic,  mg/1
             Barium, mg/1
             Beryllium,  mg/1
             Calcium,  mg/1
             Chromium, mg/1
             Cobalt, mg/1
             Copper, mg/1
             Lead,  mg/1
             Mercury,  mg/1
             Nickel, mg/1
             Zinc,  mg/1
                          26
               .0002
             0.21
               .001
               5
               .01
               .027
               .02
             0.26
               .0002
               .051
             18.03
    The Red Dog Creek drainage, due to its natural toxic
productive biological resource with the exception of the
used as grayling habitat.  Fish migrating to this point,
to high stress and mortalities.
                                 conditions  is  not  a
                                 North  Fork  which  is
                                 however,  are  subject
    Ikalukrok Creek, below the confluence with Red Dog Creek is the primary
biological  resource of concern which could be impacted by discharges into Red
Dog Creek from the proposed project.  A mixing zone is evident downstream of
the confluence and benthos distribution corresponds accordingly.  Water
quality both upstream and downstream of this mixing zone represents a
typically unpolluted arctic stream with
concentrations.  It is anticipated that
receiving water monitoring program will
water quality.
                the  exception  of  some elevated metals
                the  following  effluent limitations and
                assure the maintenance of existing
G.  BASIS FOR NPDES PERMIT EFFLUENT LIMITATIONS

    Section 301 (a) of the Clean Water Act provides that the discharge of
pollutants to waters of the United States is unlawful except in accordance
with the terms of a National Pollutant Discharge Elimination System  (NPDES)
permit.  A violation of any condition of a permit constitutes a violation of
the Act and subjects the discharger to the penalties specified in  Section 309
of the Act.

    On December 3, 1982, the Environmental Protection Agency promulgated the
Ore Mining and Dressing Point Source Category Effluent  Limitations Guidelines
and New Source Performance Standards (40 CFR Part 440).  Cominco Alaska  Inc.
is subject to the New Source Performance Standards  (NSPS)  as specified  in
40 CFR 440.104 of these guidelines.  Following  is a summary of effluent
limitations and monitoring requirements as proposed in  the draft permit.
    Effluent
    Characteristics
    Flow   (mgd)
    Copper   (mg/1)
    Zinc   (mg/1)
    Lead   (mg/1)
    Mercury  (mg/1)
Effluent Limitations
Daily       30 day
Maximum     Average
           Monitoring Requirements
           Frequency      Sample type
  7.1
   .3
  1.5
   .6
  0.002
5.4
 .15
 .75
 .3
0.001
Continuous
  Weekly
  Weekly
  Weekly
  Weekly
Recording
   Grab
   Grab
   Grab
   Grab

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                                      -5-


    Cadmium  (mg/1)        .10         .05         Weekly          Grab
    Total  Suspended                                                24 hour
     Solids mg/1          30.0        20.0          Weekly          composite
    pH                   10.5    (minimum 6.0)     Daily           Grab
    Temperature           N/A         N/A          Daily           Grab

    It should be  noted that the NSPS does not permit the discharge of mill
process wastewater, only mine drainage.  Additionally, in areas where annual
precipitation exceeds annual  evaporation the permittee is allowed to discharge
the volume of water equivalent to the net precipitation falling on the
tailings impoundment plus the total  precipitation for the mine drainage
diversion  area.  [40 CFR 440.104 (b)(2)(i)]  Based on available precipitation
and evaporation data for the  area the total allowable annual discharge was
determined as follows:

    Precipitation     =   28"
    Evaporation       =    9"
    Net precipitation =   19"
    Tailings impoundment (1st five years)  =  200 Acres
    Drainage area     =   2.75 sq. miles @ 640 acres/sq. mile  =  1,760 acres

    Tai1i ngs Impoundment

[200 ac.]  x [(19/12)ft./year=(net precip.)] x [43,560 ft.2/ac.] x [7.5 gal/ft.3]

                                     365 days

                           =    283,438 gal/day

    Drainage Area

[1760 ac.] x [(28/12)ft./year=(total precip.)] x [43,560 ft.2/ac.] x [7.5 gal/ft.3]

                                     365 days

                               3,675,748 gal/day

    Total  allowable annual  discharge =  1.44 x 10^ gallons

    The applicant's NPDES permit application has specified a daily maximum
flow of 7,100,000 gallons per day and a daily average flow of 5,400,000
gallons.  The requested discharge is for a six month period for the months
of May through October.  Using the applicant's daily average discharge of
5,400,000  gallons the annual  projected discharge would be 972,000,000
gallons.  This would fall within the allowable criteria.  Consequently,
NPDES flow limitations will be those requested in the application.

    Effluent limitations for  total copper, zinc, lead, mercury, cadmium and
suspended  solids  are specified as daily maximums and 30 day averages and
reflect New Source Performance Standards as specified in 40 CFR § 440.104.

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                                    -6-
    The effluent limitation of  10.5  for  pH  exceeds  the  NSPS range of 6.0 to
9.0.  However,  40 CFR § 440.131  (d)  allows  for  a  pH adjustment to exceed 9.0
if the application of neutralization and sedimentation  technology to comply
with metals limitations results  in an inability to  comply with the  pH  range
of 6.0 - 9.0.   This elevated pH  value of 10.5 was identified  in  pilot  plant
testing as the  level needed to  obtain optimum cadmium control.   The
applicant has  estimated the net  effect at the point of  discharge in the
receiving water to be a slight  increase  in  pH from  6.1  to 6.2.

F.  RECEIVING WATER MONITORING  PROGRAM

    The major  in-stream use of  the Wulik drainage is the significant
subsistence, commercial and recreational fishing.  References cited in the
Draft EIS identify the lower 40 miles of the Wulik  River as  a major
anadromous and sport fishing stream.  This  segment  is  also  used  for arctic
char over-wintering, salmon spawning and as a drinking  water  source.
Ikalukrok Creek is used by arctic char,  arctic  grayling and  salmon  for
spawning, rearing and migration.

    An ideal ambient water quality monitoring program  to  identify  impacts  on
the aquatic community would include  annual  in-stream biological  surveys.
However, this type of program could  also prove  to be logistically  difficult
as well as expensive.  A more cost-effective plan is to establish  receiving
water monitoring stations where key  physical and  chemical  parameters  could
be measured.  This approach provides information  that  would  relate  directly
to Alaska water quality standards (18 AAC 70)  and reflect  water  quality
goals.

    Sampling performed at these stations should provide information needed
to evaluate immediate impacts from the proposed project.   Parameters
monitored will be used primarily for:

    1)  An analysis of pollutant loadings and  receiving water dilutions.

    2)  An analysis of compliance with state water quality standards  and
        beneficial use impacts.

    Data should be collected at a frequency which will  support the use of a
probability theory to evaluate statistically defensible exceedance curves.
For two parameters, flow and conductivity,  it is desirable to employ
continuous monitoring equipment.  This would identify the  representativeness
of  grab sample days with respect to conditions  on days not sampled.

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                                     -7-
    Two stations are proposed for ambient water quality monitoring in the
Wulik drainage.  Data collection would occur seasonally from break-up (mid
hay) to freeze-up (mid October).  Station identification codes correspond to
those identified in the Dames and hoore environmental baseline report as
follows:

    Site 73:   Ikalukrok Creek downstream from confluence with Red Dog Creek.

    Site  9:   Ikalukrok Creek above confluence with Red Dog Creek.

    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 biominitoring 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.

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    The following table identifies parameter and frequency of collection for
the receiving water and biomonitoring programs:
                                                           Flow-thru
                             Site 73        Site 9    Biomonitoring Facility

    Flow                       b              a                 a
    Conductivity               b              b                 a
    Suspended Solids           b              b                 c
    Turbidity                  b              b                 c
    Cadmium (total)            b              b                 a
    Iron                       b              b                 a
    Lead                       b              b                 a
    Zinc                       b              b                 a
    Aluminum                   b              b                 a
    Hardness                   b              b                 a
    Temperature                b              b                 a
    Dissolved Oxygen           b              b                 c
    pH                         b              b                 c

    Frequency Codes:    a)  continuous
                        b)  weekly
                        c)  daily

    Rationale for the above sampling program.

    The NPDES permit will be issued for a period of five years.  Since mine
operations will not begin until 1987/1988 and permit issuance is anticipated
in 1984, the first three years of the monitoring program will provide
additional baseline data.  Monitoring during mine operations will be for a
period of approximately two years during the effective dates of the proposed
permit.  Results of this monitoring program will be used to develop
subsequent permit conditions.

    Although the Alaska Department of Environmental Conservation has not
established a mixing zone for the proposed discharge, it is not anticipated
that ambient water quality conditions will be exceeded in Red Dog Creek.

G.  BEST MANAGEMENT PRACTICES

    Section 304(e) of the Clean Water Act requires EPA to include conditions
in the NPDES permit that require the permittee to develop a Best Management
Practices Plan to control the discharge of toxic or hazardous pollutants by
way of plant site runoff, spillage or leaks, sludge or waste disposal,  and
drainage from raw materials storage.

    The intent of the Best Management Practices  (BMP) Plan is to recognize
the hazardous nature of the various substances used and produced by the
facility and the ways that such substances may be accidently dispersed.
Facilities should be designed and built to contain and recover  such losses
or to neutralize them before any adverse  impacts can occur.  The BMP should
address methods to detect and control all leakages.  Specifically,  all  areas
where concentrated solutions of hazardous substances are handled should  have
closed-drain systems and collection sumps to confine leaked or  spilled
materials within the facility.

    The permittee  is required to submit the BMP  program to EPA  within eight
months of the  NPDES permit effective  date.

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References

1.  NPDES Permit Application (AK-003865-2), January 15, 1983

2.  Ore Mining and Dressing Point Source Category Effluent Limitations
    Guidelines and New Source Performance Standards (40 CFR Part 440).
    December 3, 1982

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

4.  Tailings Impoundment Preliminary Design - Red Dog Project, Cominco
    Engineering Services Ltd.,  March, 1983

5.  Red Dog Mine - Project Overview, Cominco Alaska Inc., January, 1983

6.  Application of the HDS Process in the Treatment of Red Dog Tailing Pond
    Water - A Study Conducted by:Chemical Process Research Group

7.  Environmental  Baseline Studies - Red Dog Project,  Cominco Alaska Inc.,
    Dames & Moore

8.  Final Development Document  for Ore Mining & Dressing. EPA 440/1-82/061,
    November,  1982

9.  February 25,  1983 letter from Walter Kuit,  Cominco to L.  W. Scarburgh,
    EPA concerning pH and zinc  variances.

10. May 12,  1983 memo from Robert Burd,  Director,  Water Division, to Steven
    Shotzow, Director, Office of Water Regulations and Standards, re:  New
    Source Performance Standards

11. May 10,  1983 letter from Richard Neve', Commissioner,  ADEC to Harry
    Noah, Cominco  Alaska, re:   Preliminary Water Quality Standards

12. May 19,  1983 response from  Effluent  Guidelines Division,  re:   pH and
    zinc variances

13. July 14, 1983  letter from W.  J.  Kuit, Cominco, to  L.  W. Scarburgh,  EPA,
    re:  Effluent  Guidelines Division response  to  pH and zinc variances

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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  Notice
                          of  Appl

                          for  Permit
                               PUBLIC  NOTICE DATE:   March 16,
                               REFERENCE NUMBER:  07l-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
preparing  an  Environmental  Impact  Statement
                                  Protection   Agency  (EPA)  is
                                  (EIS)  for  the  Red  Dog Mine
The Alaska District Corps  of Engineers  is a coorperating  agency in
A  permit  decision regarding the road and tailing dam  will  not be
   after  the  Final EIS  has  been  prepared.  This  public  notice
    applicant's  preferred alternative.  Other  alternatives  are
       in the  EIS process and  a  discussion of  these  alternatives
             III of the EIS.
 project.
 the EIS.
 made  until
 reflects  the
 being considered
 can be found in Chapter
 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  EJS.  The  dates  and
 locations of  these public hearings can  be found  in the Draft EI5.

 CULTURAL  RESOURCES:   The   applicant's  perferrea   alternative  may  affect
 cultural resources  located  within and adjacent to Cape Krjsentstern  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 Endangerea  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   De  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 tne  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-

-------
The  Notice  of  Application   for   State   Mater   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-

-------
                                                                                                              RE DJDOG
                                                                                                               N

                                                                                                             DEADLOCK
                                                                                                             MTN
Vicinity  Map
            LEGEND
              MONUMENT BOUNDARY

              TRANSPORTATION CORRIDOR
                               VABM  28
                               PORT SITE -
                                                        67°30N NATIONAL NONUMENT
                                                                                                  CHUKCHI SEA 11
                                                                                                  Cominco Alaska
                                                                                                  Red Dog Projecl

                                                                                                  Sheet 1 of 4
LOCATION MAP

-------
 CHUKCHI SEA 11
SITE PLAN
Cominco Alaska
Red Dog Project

-------
NOTE: MINE SITE ROADS TO REQUIRE 177.408
 CU. YDS. FILL. INITIAL PIT DEVELOPMENT TO//
 SUPPLY SUITABLE WASTE ROCK FOR USE //
 AS FILL MATERIAL.                  //
                                                                                                         AVG. 6' FILL
                                                                        ROAD SECTION-TYPICAL
                                                                            MfAif-  ni-r i * \ff\iIT   Commco Alaska
                                                                            MINE  PIT LAYOUT   Red Dog Pr0ject
                                                                                                   •Sheet a of 4  1/84

-------
                                                                    ORE
                                                                   BOt>Y
ACCOMMODATION
SEEPAGE/CONTINGENCY «r
       DIVERSION  DITCH
                            IMPOUNDMENT-PLAN
                                                HAUL ROAD
                         YEAR
                                                      LINER
 SEEPAGE CONTINGENCY
  0AM
                                                 	EL 950


                                           	EL 870
                                           HAUL ROAD

                                                 	EL 800
             NOTE: UPSTREAM a DOWNSTREAM SLOPES FOR
                 YEAR 1 ARE Z: 1
                           930
                                     310
                              DAM SECTION
FILL REQUIREMENTS ( cu. yds. )
   ( MINE WASTE MATERIAL )
                                            CHUKCHI SEA 11
                                      TAILING IMPOUNDMENT
      YEAR 1

      YEAR 5
  255.000

 2.800.000
Comlnco Alaska
Red Dog Project
Sheet 4 of  4  1/84

-------
                              Public
 sisssar               of
 Alaska District                  ^
Regulatory Functions  Branch    V4%B0
Pouch 898                     IWl
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
preparinganEnvironmental  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
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.

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.

-------
                            Public  Notice
                            of  Application
 Alaska District                  ^        •».      	   • m
Regulatory Functions Branch   Y^^IP  •M'^kl^W^lB
Pouch 898                     IVl   •  ^•••••»
Anchorage, Alaska  99506
                                PUBLIC NOTICE DATE:   March 16, 1981*

                                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  £eet
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.   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  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
preparinganEnvironmental  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
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.

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.

-------
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
ana 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

-------
                                                                                                             RED,DOG
                                                                                                                  SlTf
                                                                                                                A   :
                                                                                                            DEADLOCK
                                                                                                            MJLbl
Vicinity  Map
            LEGEND
                                           IPIAVIK
                                           LAGOON-

                                         VABM 28
                                         PORT SITE -
MONUMENT BOUNDARY

TRANSPORTATION CORRIDOR
                                                        67 50N NATIONAL NONUMENT
           LOCATION MAP
                                                                                    Cominco Alaska
                                                                                    Red Dog Project
                                                                                    Chukchi Sea 9
                                                                                    071-OYO-2-830359
                                                                                    Sheet 1  of 13  1/8'

-------
     BALLAST FOR TANKER
    APPRQX. 75,000 CU.  Y0S.
 4
              1 000'
                                                              DOCK OVER SHEET  PILES
                                                             VOR CONCRETE CAISSON    65' .
                                                              BARGE DOCK


                                                                   335'
                                              4" FUEL LINE ( NTS )
                              EARTH FILL
                             20.000 cu yds.
                          " .PROTECTIVE
                         CASING <  NTS)
      DREDGE
        CUT   Dredging &  backfill  of trench
            involve 12,000 cu. yds. of material
    SECTION ELEVATION (§)

          hor. 1"= 170*
          ver. 1"= 50'
o
o
o
PLAN  OF PORT FACILITIES
                                               1"  400'
                                              tu
                                              z
     DEEP  WATER DOCK      BARGE
  ( BALLASTED  TANKEp )
          ODD   O  D~
       ( See  sheet 10 for
        tanker section )
                  Approximate location of
                  undersea  fuel line

             1017'
              1000'
          700'


   BREAK REPRESENTS 2750'
GENERAL SITE DEVELOPMENT

 63.000  cu  yds. FILL
                      20' Dl A
                      FUEL STG£
                      TANK AND
                      DRUM STGE
                                                                                                                             BOWER
                                                                                                                           GENERATION
                                                             (PORT. LAGOON
        DREDGED  AREA.
                                      SEABED
     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'

              BREAK'REPRESENTS  500'
                 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 AMO WOULD 8UPP1Y
     ALL GRAVEL NEEDED

     EXPLORATION AREA IS THE
     TOTAL AREA WITHIN WHICH
     THE PIT MAY BE LOCATED
                                                                                                         Alaska
                                                                                                 Red Dog Project
                                                                                                 Chukchi S«« 0
                                                                                                 071-OYD-a-830359
                                                                                                 Sheet 9 ol t8 1/84
                    PORT SITE

-------
a:
o
K

I
                                                                                                            Comlnco Alaska
                                                                                                            R«d Doy P'<>i«ct

                                                                                                            Chukchi Sea  6

                                                                                                            071-OYD-2-830»59

                                                                                                            Sheet 4 «f 1» 1/84
                                                                                                                                00


                                                                                                                                UJ
                                                                                                                                a:
                                                                                                                                o

-------
MA TCH LINE  B
  MATCH LINE C

-------
MATCH LINE  C
 MATCH LINE D

-------
MATCH LINE

-------
                                           CENTRATC STORAGE BUILDING
                                            lFme
                                        AT MILE 2.5
                                         PORT SITE
                                LOCATION DETAIL
                            ACCESS       ROAD
                                      912'0"
                               SECTION ELEVATION
                                                  CONCENTRATE  STORAGE
FACILITY  BUILT ON BEDROCK OF

FORMER BARROW SITE AT PT. (
Cominco Alaska
Red Dog Project
Chukchi Sea 9
071-OYD-2-830359
Sheet 8 of 13   1/84

-------
  PORT SITE
( See sheet  Z. for detail )
ORIGINAL GROUND
                                                        PORT LAGOON
   SECTION  ELEVATION (B
                = 300' ( approx.)
   hot. 1"=68'   ver.  1"=40'
   ORIGINAL GROUND
                                        NATURAL BREACH

                                            DREDGE.SPOILS
     o        SHORELINE         570 FEET

       SECTION ELEVATION  (A

       hor. 1"=225'  ver. 1"=40'
  T
  *
  o
  co



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ac
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i-
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O
O







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KITCHEN /DINER /REC.








               BARGE LAYOUT
                     " = 50'
20'
NOTJE:




12'

20'
                                                  CONSTRUCTION FACILITIES
                  ELEVATION
                     1"=50
                     Comtnco Alaska
                     Red Dog Project
                     Chukchi Sea 9
                     071-OYD-2-830359
                     Sheet 9 of 13   1/84

-------
                                                                         I    DRY GOODS

                                                                         {   CONTAINERS i
                          BALLAST
                      100.000 CU. YDS.
                                                      SECTION ELEVATION
                                                               "= 120'
   190'j
SEABEDL
                 AVAILABLE STORAGE DEPTH-42'

35' ,
n

1-H
i /ZINC^f

.BALLAST
i n

T
_5'iL__ " '-


—4 t—





BALLAST ^
SEABED


X ||~Ft;Et~{


\1 OIL 7
\t / 	
n
H-


BUI K > 	 ^ BULK
                                                                                                DREDGED PAD TO PRODUCE
                                                                                                25,000 CU. YDS.  MATERIAL
                                                                                                TO  BE USED  AS BALLAST
                                                                                                ( vertical exaggerated )
(  vertical
exaggerated )
      1 50'

SECTION ELEVATION (A)
       1"= 120'
                                                                      154'9"
                                                                                CARRIER
                                                                                                    DEEP  WATER  DOCK
                                                                 SECTION ELEVATION
                                                                         1"= 120'
                                                                                                         Cominco Alaska
                                                                                                         Red Dog Project
                                                                                                         Chukchi Sea 9
                                                                                                         07 1-OYD-2-830359
                                                                                                         Sheet 10o» 13   1 /84

-------
                    2% DRAINAGE DITCH
                                                                                   SLOPE VARIABLE

                                                                                 DEPENDENT ON  MATERIAL
  TYPICAL CROSS SECTION of BORROW  PIT
                        _____
                                                CUT SLOPE  VARIABLE
                                                                                    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.
Cominc o Alaska
Red Dog Project
Chukchi Sea 9
071-0YD-2-830359
Sheet 11 of 13   1/84

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                                                  ESTIM. ANNUAL
                                                  HIGH WATER
                                                                       AVG. CROSSING 8000 cu.yds. Fill
                            TYPICAL  BRIDGE CROSS  SECTION
                              SCALE :HOR. 1'=20'VERT.1"=10'
                                   30'
                        r
GRADED ROCK
PROTECTION  AROUND
CULVERT AS REQUIRED
                                                  TYPICAL SIDE SLOPE

                                                       2
    NATURAL  STREAM SLOPE
                                   CORRUGATED STEEL CULVERT
TYPICAL ROAD CROSS SECTION SHOWING TYPICAL  CULVERT
—                             „	—,—.	
                                              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
  BRIDGE&ROAD
CROSS SECTIONS
                                                                                              Cominco Alaska
                                                                                              Red Dog Project
                                                                                              Chukchi sea 9
                                                                                              07 1-OYD-2-830359
                                                                                              Sheet12of13  1/84

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                                               SLOPE
       \  \   \   \
                                                    \  \  \

                                                   350'
                                                                        \ \ \
                                                 ROAD
                            /  / /
/   /   /
                                               SLOPE


                                       TYPICAL PLAN OF TURNOUT
                                               SCALE 1' 60'
                                   -20-
GRADED ROCK PROTECTION

    AROUND CULVERT
                                         NATURAL STREAM SLOPE

                           TYPICAL CROSS SECTION OF TURNOUT

                                                N.T.S.
                             20'
                                  \  \
                                                                                           30'
                                                                                   NOTE:
                                                                                        REFER TO SHEET 2 of 13
                                                                                  TYPICAL SIDE SLOPE
                              Commco Alaska
                              Red Dog Project
                              Chukchi Sea 9
     CROSS SECTION & PLAN 0/1-0x0-2-830359
     ^==^========^==^==_ Sheet13o(13   1/84
                                                                       TYPICAL TURNOUT

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         OFFICE OF TSB GOVERNOR

     DIVISION OF POLICY DEVELOPMENT AND PLANNING
              GOVERNMENTAL COORDINATION UNIT
                                              BILL SHEFFIELD, GOVERNOR
                                              POUCH AW (MS • 01651
                                              JL'!,'EA U.ALASKA SSS11
                                              FHOt.'B: IS0
            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 DSC  1456(c)(3)  requires  the applicant
for a Federal permit to conduct  an  activity affecting land
cr water u^es in the Alaska  ccastal  zone  to provide certifi
cation that.the activity will  comply  with the  Alaska
Coastal Management Program (ACMP).
The
is w
requ
Pub!
cat i
the
be f
Plan
info
cent
AK 9
    p ropos e
    ithin t
    i red  be
    ic Noti
    on, the
    ce rt i fi
    o rwa rde
    n i n g  f o
    r m a t i o n
    act the
    9811, o
d activity desc
he ACMP, and th
fore your appl i
ce.   Upon recei
 Public Kotice
cation s tatemen
d to the Divisi
r its co n cur re n
 on the Al es ka
 Office of Coas
r the Division
ribed in your permit application
e following certification  is
cation can be processed to
pt of the signed, dated cert if i-
will be issued and will include
t.-  The Public Notice will
on of Policy Development  and
ce or objection.  For additional
Coastal Management Program,
tal. Management,  Pouch AP,  Juneau,
at the above address.
             CERTIFICATION STATEMENT
I certify  that,  to  the  best of my knowledge and belief,
the proposed  activity described in Department of  the  Army
Application  No.  Q71-QYD-2-830359    complies with  the  approved
                                        will
Alaska  Coastal  Mana percent Program , and
in a manner  consistent with such programs
                                  be conducted
                                       Signature t>T  Applicant
                                      September 6, 1983
                                               Date
WW: jo

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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
                                     I
     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
AIMILCA Title XI Right-of-Way
                  Application

-------
          16 rof.'n r»«
  p,..c,i»,d br DOl/usDAyDOT  APPLICATION FOR TRANSPORTATION AND

  '•%££»?•-'>-"?         UTIl-'TY  SYSTEMS AND FACILITIES
                                      ON FEDERAL LANDS
                                                      FORM APPROVED
                                                     OMB NO. IOO4-0060
  NOTE:  Before (completing and flllntc the application, the applicant ihould completely review thll pack-
          ace and~schedulc a  prcapplicalion meet'nR with teprcienl alive* of the agency  responiible for
          processing the application.  Each agency may have >pecLfic and unique requircmenti to be met
          In preparinc and  processing the application. Many times, with the help of the agency represen-
          tative, the application caq be completed m the preapplication meeting.
                                                                                                    FOR AGENCY USE  ONLY
                                               Application Number
                                               Date filed

                                               'pv/icoH  HPT  iA
   1.  Name and address of applicant (include zip
      code)
  COMINCO  ALASKA
  DIVISION OF COMINCO  AMERICAN  INC.
   5660 B  St., Anchorage,  AK 99502
2.  Name, title, and address of authorized agent
    U different from Item 1 (include rip code)
  H.  M.  GIEGERICH,   PRESIDENT
  COMINCO  ALASKA
   5660 B  St.,  Anchorage,  AK  99502
                                              3.  TELEPHONE (a,,a cojf)
                                            Applicant
                                              907/563-3686
                                            Authorized Agent
                                             Same
   4.  As applicant are you? (check one)

      a. |  | Individual

      b. txx! Corporal ion *

      c. |  ] Partnership/Association *
      d. |  | State Government/State Agency

      e. I  I Local Government
      f. I  I Federal Agency

      * If ctteied. complete tupplrmentat page
5,
Specify what application is for:  (cheek one)

a. I   I New authorization
b. I   1 Renew existing authorization No..

c. I   I Amend existing authorization No..
   d. I   I Assign existing authorization No.	
   e. |   | Existing use for which no authorization has been received '
   f. 3f?TI Other'Supply additional  information

   * If cheeked, provide detail* under Item 7
  6. If aa individual, or partnership are you a citizen(s) of the United States?  jy"! Yes  |   | No

  7. Project description (detcribe in detail): (a) Type of system or facility, (e.g.. canal, pipeline. road):  (b) related structures and facili
     tics;  (c) physical specifications (length,  width. grading, tic.); (<0 term of years needed;  (e) time of year of use or operation;  (f) Vol-
     ume or amount of product to be transported; (g) duration and timing of construction; and (h) temporary work areas needed for construe-
     Uon.  (Attack additional ibtttt. if additional if/act it nttded.)



       SEE ATTACHMENT "A"
 8. Attach nap covering area and show location of project proposal
                                                                   SEE ATTACHMENT  "B"
•9. State or local government approval:  i  I Attached  I   ! Applied for •!•  J Not required    See Attachment "A"

10. Nonrctumable application fee:      I   ! Attached  j   j Not required

11. Does project cross international boundary or affect international waterways? 1  I Yes  KXl No  (I/ "yet." indicate on map)

12. Civ* ststcmcnt of your technical and financial capability to construct, operate, maintain, and terminate system for which authorizatic
    la being requested.

     SEE  ATTACHMENT "A"

-------
  134.  D« scribe, other r«« ton«ble •lt«rn«(iv« routes «admod«* con«ld«rcd.



      'SEE ATTACHMENT "A"
    b. Vhy wcr« thei* alternative! not lelecled?



       SEE ATTACHMENT "A"
   c. Give explanation aa to why it is necessary to crois Federal landi.
  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 authorizacions and pending applications filed for similar projects which may provide information to the authorizing agency. (Sfei
      i/y number. Jate. code, or name.)


       SEE ATTACHMENT "A"




 IS.   Provide statement of need Cor project, including the economic feaaibitity and items such aa:  (a) cost  of proposal (construction,  ope.
      ttion. and maintenance);  (b) estimated cost of next best alternative; and  (c) expected public benefits.


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


       SEE ATTACHMENT "A"
 17.   Describe likely environmental effects that the proposed project will have on:  (a) air quality: (b) visual impact; (c) surface and grouc
      water quality and quantity:  (d) the control or structural change on any stream or other body of water;  (e) existing noise levels; an
      (0 the surface of the land. Including vegetation, 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, mcludLi
      threatened and endangered species;.and (b) marine mammals, including hunting, capturing, collecting, or killing these  animals.


       SEE ATTACHMENT "A"
19.  Name all the Dcpartmcnt(a)/Ageacy(ic*) where this application is being filed.
       NATIONAL  PARK  SERVICE
       U.S. CORPS OF  ENGINEERS
       ENVIRONMENTAL  PROTECTION  AGENCY



I HCRCBY CCRTirY. That  I am of legal age and authorized to do business in the Stale and that I have personally examined the informatior
contained in the application and belie** that the information submitted is correct to the best of my knowledge.	
                                    „
Title 18. U.S.C. Section 1001. makes it a crime for any person knowingly and willfully to make to any department or agency of the  Unitec
States any false, fictitious, or fraudulent statements or representations as to any matter within its jurisdiction.	

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                                     APPLICATION FOR TRANSPORTATION AND UTILITY SYSTfcMS
                                                 AND FACILITIES ON FEDERAL LANDS
                                                                                                  8y
                      GENERAL INFORMATION
               ALASKA NATIONAL INTEREST LANDS
   'ransportation and utility systems  and facility uses  for which the
   .pplication may be used are:
    1.  Caoals,  ditches, flumes, laterals, pipes, pipelines, tunnels,
   ad other systems for the transportation of water.
    2.  Pipelines and other system* for the transportation of  liquids
   ther than water,  including oil, natural gas,  synthetic liquid and
   iseous  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
   nergy.

   S.  Systems   for  transmission or reception of radio,  television.
   elephone. telegraph, and other electronic signals, and other means
   •f communications.

   6.  Improved   rights-of-wsy   for  snow  machines,  air cushion
   chicles, and all-terrain vehicles.

   7. Roads,  highways,   railroads,  tunnels,  tramways,  airports,
   finding strips, docks, and other systems of general transportation.


  .Tus  application mutt be filed simultaneously with each Federal
   epartment  or  agency  requiring  authorization  to establish and
  •perate your proposal.
  n Alaska, the following agencies will help the  applicant file  an
  ipplication and identify  the  other agencies the  applicant should
  :ontact and possibly- file with:

    Deportment of Agriculture
    Regional Forester.  Forest  Service (USFS)
      Federal Office Building, P.O. Box 1628
      Juneau, Alaska 99802
      Telephone:  (907) 588-7247 for * local Fort it Service Officrl
    Department ef Interior
    Bureau of Indian Affairs (BIA)
      Juneau Area Office. P.O. Box 3-8000
      Juneau. Alaska  99802
      Telephone:  (907) 586-7209

    Bureau of Land Management (BLM)
      701 C Street. Box 13
      Anchorage. Alaska  99S13
      Telephone:  (907) 271-SOS5 for a local BLM Office)

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

    U.S. Fish b Wildlife Service (FWS)
    Office of the Regional Director
      1011 East Tudor Road
      Anchorage. Alaska  99503
      Telephone:  (907) 276-3800
 Note-Filings with any Interior acency may be filed with any office
 noted  above or with the:  Office of the Secretary of  the Interior.
 Regional  Environmental Officer. Box 120.  IC7S C Street.  Anchor-
 age. Alaska  99513.
                                                                                    of I f
                                                   ^^^^^^^^
    Federal Aviation Administration
       Alaaka Region AAL-4. P.O. 14
       Anchorage. Alaaka  99513

  NOTE ~ The Otpartment of Transportation has  established  the
  above central  filing point  for  agencies  within  that  Department.
  A/fected  agencies »re:   Federal Aviation  Administration (F^A).
  Coast Guard (USCG).  Federal  Highway  Administration  (FK'.VA).
  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 file-J
 at the  local agency office or at a  location specified by the  respon-
 sible Federal agency.
                    SPECIFIC  INSTRUCTIONS
              (Items not lilted are self-explanatory)
 Item
  7
     Attach preliminary site and facility construction plans.  The
     responsible agency will provide  instructions whenever speci-
     fic plans are required.

 8   Generally,  the nap mutt  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(iea) 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 analysts  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, it the project is not near
     a  stream  or other body of water,  Jo not address  this subject.
     The responsible agency will provide additional  instructions.

     Applicstion  must  be signed by the applicant  or applicant's
     authorized representative.
If additional space is  needed to complete any item, please put t!ie
information  on o separate sheat of paper end identify it as "Contin-
uation of Item".
'For supplemental, tee reverie)

-------
                                                         SUPPLEMENTAL
NOTE: The rtiponnble •«ency(ie>) will provide • dditional inilruclioni.
I _ PRIVATE CORPORATIONS
a. Articles of Incorporation
b. Corporation Bylaws
A certification from the State showing the corporation ia in good standing and it entitled to operate within the
• State.
d. Copy of reaolution 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 togetheivwith. in the case of an affiliate controlled by the
entity, the number of shares and 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 chares
and the percentage of any class of voting stock of that entity owned, directly or indirectly, by the affiliate.
f If application is for an oil or gaa 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
n
n
a
a
a
a
a
FILED •
£]
(3
13
C
a
a
D
                                                    a - PUBLIC CORPORATIONS
a. Copy of law forming corporation
b. Proof of organization
c. Copy of Bylawa
d. Copy of resolution authorizing filing
If application is for an oil or gas pipeline, provide information required
' by Item "M" and "I-g" above.
n
n
n
n
a
a
a
a
a
a
                                    in -  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 "W" and "It" abov*.
n
n
n
n
n
CD
n
n
 • If the required information is already filed with the agency processing this application and  is current,  check block entitled "Filed.
  Provide the file identification 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 application for so 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:   (1) Th« processing at the applicant's request
 for an  authorization.   (2)  Documentation for public information.
 W Transfer to  appropriate Federal  agencies when concurrence
 Is required prior to granting a right in public lands  or resources.
'(4X$) Information from lha> record and/or the record will  be trans*
 ferrcd (a appropriate  Federal.  Slate,  local  or foreign agencies.
 when relevant  to civil,  criminal or regulatory investigations or
 prosecutions.
EFFECT OF NOT PROVIDING INFORMATION:  Disclosure of the
Information is voluntary.  If all the information is not provided, the
application may be rejected.
               DATA COLLECTION STATEMENT

The  Federal  agencies collect this Information from applicants
requesting right-of-way, permit, license. Icaae.  or certification for
the use of Federal lands.
The  Federal  agencies use  this information to evaluate the  ap-
plicant's proposal.
The  public la obligated to respond to  this  information request if
they  wish to obtain permission to 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.

-------
                                                  Table I

                              PRELIMINARY  BORROW SITE  SPECIFICATIONS,
                                          SOUTHERN CORRIDOR
Borrow
Site
Number
1*
2
3
4
5
6
Exploration
Area
ha
85.5
49.2
57.0
98.4
77.7
163.2
ac
211.2
121.6
140.8
243.2
192.0
403.2
Average Access
Disturbed Approximate Excavation Road
Pit Area Volume Needed Depth Length
ha ac m3 yd3 m ft km mi
19.4 48.0 305,853 400,043 2.1 7.0 0.19 0.12
9.5 23.4 289,144 378,188 3.0 10.0 0.39 0.24
--
5.2 12.8 190,189 248,760 4.9 16.0 1.29 0.80
13.9 34.4 590,100 771,826 4.3 14.0 1.08 0.67
_ _ __ __ __ __ — - - - - -
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.

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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

     0  Route
     Option
     Suboption
Northern
Southern
                           Noatak
GCO Route
Western  Route
Omikviorok  Route
Kruz  Route
     0  Mode
Slurry Pipeline
Hovercraft
Railroad
Road
                                                     Winter only
                                                     "Year-Round"
                                    - 4 -'

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     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 Relative Level of Potential Impact1
Suboption Low
Transportation Route2
Northern Corridor
GCO Route

C
O
M
p
A
R
D Asikpak Route Cultural Resources
Regional Use




Southern Corridor
Western Route Krusenslern Impact




C Omikviorok Route
0
M
P
A
R
E
0
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

0






E
L
I
M
I
A
T
E
D


I
M
I
N
A
T
E
D

       Kruz  Route*
                                 Water Quality
                                 Vegetation
                                 Freshwater Biology
                                 Wildlife
                                 Subsistence
                                 Technical Feasibility
                                 Economic Feasibility
                                                             Fish
                                                  Cultural  Resouces
                                                  Krusenstern  Impact
 Transportation Mode
    Railroad
C
O
M
P
                                 Subsistence
                             Water Quality
                             Air Quality
                             Vegetation
                             Freshwater Biology
                             Fish
                             Wildlife
                             Cultural  Resources
                             Regional  Use
                             Krusenstern  Impact
                     Recreation
                     Technical Feasibility
                     Economic  Feasibility
                         E
                         L
                         I
                         M

                         N
                         A
                         T
                         E
                         D
E
D
    Road (year-round)1
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 are  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 car-
     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
0  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
           o
             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, yeai—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 -

-------
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
                                 IPUVIK
                                 LAGOON'
                                VABM 28
                                PORT SITE
	  MONUMENT  BOUNDARY
     TRANSPORTATION CORRIDOR
      CAPE KRUSENSTERN
|67*30NNATIONAL MONUMENT
DQCB  PROJECT

-------
   ATTACHMENT C

Corps of Engineers
     Permit $
 071-04D-2-830359
  Cnukchi Sea 9

  Section 10/404
 Background Data

-------
    VOMIWENT  BOUNDARY

    TRANSPORTATION CORRIDOR
LOCATION  MAP
Cominco  A la sK a
Red  Dog  Project
Chukchi Sea  9
071-OYD-2-830359
Sheet 1  of 13   1/84.

-------
£\
     BALLAST  FOR TANKER
    APPROX.  75.OOO  CU. YDS.
              1000'
     o
    - o
     eg
                     DOCK OVER SHEET  PILES
                     .OR CONCRETE  CAISSON
                                               4" FUEL LINE ( NTS )

                                                             SEABED
                                             HIGH TIDE LINE

                                          16'II ==!='=
                                                                                           65'
                                                                     BARGE  DOCK


                                                                           335'
                                                                             EARTH  FILL
                                                                            29,000 cu  yds.
                    " .PROTECTIVE
    7	rr^	T  CASING ( NTS )
DREDGE 1Z
  CUT   Dredging &  backfill  of  trench
      involve 12,000 cu.  yds.  of materiafX
                                                               SECTION  ELEVATION (§)

                                                                    hor.  1 " = 170'
                                                                    ver.  1"= 50'
o
o
o
     DEEP WATER DOCK
  ( BALLASTED TANKEP  )
          ODD   O C
       (  See sheet 10 for
         tanker  section )
      PLAN  OF PORT  FACILITIES
                  1"  400'
BARGE
                  Approximate location;of
                  undersea fuel line   j
             1017'
                700'


         BREAK REPRESENTS 2750'
                                         UJ
                                         z
                                                                                           GENERAL SITE DEVELOPMENT
                                                                                            63,000 cu yds. FILL
                                                                                                                 20' Dl A
                                                                                                                   -.^ STGE
                                                                                                                 TANK AND
                                                               200'        510'

                                                             BREAK^REPRESENTS  500'
              1000'
                                 L
                   AREA.
     SECTION  ELEVATION ®
                                       SEABED
                      NO TES-  Port facility location may be slightly
                               altered to reduce impact to  cultural
                               resource site.
 hor. 1"
 ver. 1 " = 40'
                                                                SEAPORT FACILITIES
                                                                          Cominc o Alaska
                                                                          Red Dog Project
                                                                          Chukchi Sea 9
                                                                          071-OYD-2-83035J
                                                                          Sheet2of13   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
                                                                                             vV^   '    '  \
                     PORT  SITE
                                                                                                    Comlnco Alaska
                                                                                           1  MILE    Red Dog Project
                                                                                                    ChuKchl Sea 9
                                                                                                    071-OYD-2-830359
                                                                                                    Sheet 3  of 13  1/84

-------
         Comlnco Alaska
1  MILE    Red Dog Project
         Chukchi S»a 6
         071-OYD-2-830359
         Sheet 4 of 13  1/84

-------
         Comlnco  Alaska
1  MILE    Red  Dog Project
         Chukchi Sea  G
         071-OYD-2-830359
         Sheet 5 of 13 1/84

-------
 ->   «     y,
/  V  /
                  -
          Comlnco  Alaska
 1  MILE    Red Dog Project
          Chukchi  Sea 6
          071-OYO-2-830359
          Sheet 6  °' 13  1/84

-------
               WU.  SITE
               -  _/    \
> \  o.
                      Comlnco Alaska
              1 MILE   Red Doy Protect
                      Chukchi Sea 0
                      071-OYD-2-830359
                      Sheet 7 of 13  1/84

-------
Page 3
                          Preliminary Barrow Area Locations Kruz Route
  Borrow
  Site #
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
               48.0
                 211.2       400,043       7.0
                                           0.12
                                           No
                23.4
                 121.6       378,188      10.0
                                           0.24
                                           No
                               140.8
                                                                       No
                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

-------
Page 4
                          Preliminary Barrow Area Locations Kruz Route
Borrow Disturbed
Site # Area (Pit)
(Acres)
7 6.0
8 12.4
9 13.8
10 15.5
11 7.3
12 7.3
13 16.1
14 11.5
Exploration
Area
(Acres)
166.4
147.2
217.6
51.2
51.2
41.6
89.6
38.4
Average
Volume
Req'd
(Cu. Yd.)
195,471
401,669
553,140
322,543
70,640
70,640
228,697
224,580
Average
Exc . Depth
(Ft. )
20
20
25
13
6
6
9
12
Access Rd. Within 100 yards
Length of stream
(miles )
0.30 No
0.66 No
2.46 No
0.15 Yes
0.10 No
0.10 No
0.10 No
0.05 No

-------
' -x
                                 LOCATION DETAIL
                             ACCESS        ROAD
                                       912'0"
                                SECTION ELEVATION
                                         1"=35'

                                                  CONCENTRATE STORAGE
  FACILITY BUILT  ON BEDROCK OF

  FORMER BARROW SITE  AT PT. (T
Cominco Alaska
Red Dog Project
Chukchi Sea 9
071-OYD-2-830359
Sheets of 13   1/84

-------
                                                    BARGE
                                                          PORT LAGOON
   PORT SITE
 (  See sheet 2 for detail )
 ORIGINAL GROUND

  15
    SECTION  ELEVATION (B
                                                              " = 300' ( approx.)
    hoc. 1 "- 68'   ver. \"- 40'
   ORIGINAL GROUND
        hor  1 " = 225'   ver. 1" =40'
                                         NATURAL BREACH
                                             DREDGE SPOILS
                     168'0"
  T
  p
  o>

tr
0
*-
2
(T
0










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o:
0
Q









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O
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o:
o
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^
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KITCHEN/DINER/REC












                BARGE LAYOUT
                                             WO TE:
20'
                  ELEVATION
                     1" = 50'
                                             1 2'
                                            20'
CONSTRUCTION FACILITIES
               Comlnco Alaska
               Red Dog Project
               Chukchi Sea 9
               07 1-OYD-2-830359
               Sheet 9 of 13  1/84

-------
                          BALLAST
                      1 00,000 CU. YDS.
SEABED
                 AVAILABLE STORAGE DEPTH-42'
                                   BALLAST
SECTION ELEVATION
        1" = 1 20'
             35'
                                                                                               ,  DREDGED PAD TO PRODUCE
                                                                                               \ 25,00 Q CU, YDS. MATERIAL
                                                                                                 TO BE USED AS BALLAST
                                                                                                 (  vertical exaggerated )
                                                      BALLAST
                                                                 X
  	^5-:i	.
(vertical        '      150'
exaggerated )
                                                 SEABED
               l>"g*-1
              (I  OIL  '
                                                                                   n
                                    BULK
                                 * CARRIER


                 SECTION ELEVATION ®
                1 54'9"
  BULK
CARRIER
                                             DEEP  WATER DOCK
                        1"= 1 20'
           SECTION  ELEVATION (§)
                  1" = 120'
                                                                                                        Comlnco Alaska
                                                                                                        Red Dog Project
                                                                                                        ChuKchl Sea  9
                                                                                                        071-OYD-2-830359
                                                                                                        Sheet 10 of 13   1/84

-------
                                                                                    SLOPE  VARIABLE

                                                                                  DEPENDENT ON MATERIAL
                 ^—  2%  DRAINAGE DITCH

   TYPICAL CROSS SECTION of  BORROW PIT

                        NT.S.
                                                CUT  SLOPE  VARIABLE
                                                                                    NOTE-

                                                                                    VOLUME  OF OVERBURDEN
                                                                                    NOT AVAILABLE

                                                                                    NO OVERBURDEN STOCKPILE
                                                                                    SHOWN AT THIS TIME
TYPICAL  PLAN  of BORROW PIT

               N.T S                 ~
  TYPICAL BORROW PI
CROSS SECTION&^LAt
           Cominco Alaska
           Red  Dog Project
           Chukchi Sea 9
           071-0 Y D-2-8303£
           S h e et 1 1 o f 13  1/t

-------
                                                                                              :zsrfr:.'.€ >;i ^
                                                      n i i a a
                                                    "^^//^('
                                TYPICAL BRIDGE CROSS  SECTION
                                 SCALE :HOR.  1'=20'  VERT. 1 "=1 0'
                                       30
 GRADED ROCK
 PROTECT 1C N  AROUND
 CULVERT AS REQUIRED
TYPICAL  SIDE SLOPE

      2
      NATURAL STREAM SLOPE/       CORRUGATED STEEL CULVERT

TYPICAL  ROAD CROSS  SECTION SHOWING TYPICAL CULVERT
                                                  AVG.  1 500 cu. yds. of fill
                         AVG. CROSSING 8000 cu.yds.  Fill
   EXPLANATION  of ROAD

•  56.7 MILES LONG,30' NOMINAL WIDTh
     W/GRAVELED SURFACE & AVG
     6' SUBBASE of GRANULAR FIL'_

•  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
                   C u min c o Alaska
                   Red Dog P r o j o c t
                   Chukcrii Sea  9
                   071-0 Y D-2-8303 5
                   Shoet12oM3   1/8<
                            BRIDGE&ROAD
                         CROSS SECTIONS

-------
                                                   SLOPE
                                                         \\\
        \  \   \   \
                                                        350'-
                               \  \
                                                      ROAD
                                                                                                    30'
                                                   s/op/
                                           TYPICAL PLAN OF TURNQU_T

                                                    SCALE  T 60'
                                                                                            NOTE:
                                                                                                 REFER TO SHEET 2 of 13
                                       -20-
                                                                                          TYPICAL SIDE SLOPE
GRADED ROCK PROTECTION


     AROUND CULVERT
                                             NATURAL STREAM SLOPE


                              TYPICAL CROSS SECTION  OF TURNOUT


                                                      N.T.S.
                            Commc o Alaska

                            Red D°9 Pro'ect
                            ChuKch, Sea 9

CROSS SECTION & PLAN 0/1-0x0-2-83035
 .                           Sheet13o(13   m
                                                                               TYPICAL  TURNOUT
                                                                               lYri^AL  IUHNVUI

-------
          ATTACHMENT D

Environmental Protection Agency
          NPDES Permit
          (Port Site)

-------
                                  i. AT 1C1-''-1, POLL'JTAK'T iJISCM-r'iGr C L l'.'.l\'M IOI.' S VSTEf.'.
                           STANDARD  FOFIfvi C  - ;.-,A.','UFACTU.RIf«G AND COMMERCIAL

                                     SECTIC'J I.  APPLICANT AN'D FACILITY  DESCRIPTION
   ADDITIONAL INSTRUCTION rO=» SCt-tCTEO ITCr.-.S
 ? BOOKLET er^ORE FILLIPS P-* THESE
                                                                IN SCPARATC INiT HUCTlO'c BOOKLCT Ai ir
-------
                                                                 (tt-tl (1-
            3»•. *4 ».*;•:*:
                                  03
Xrp jxl tt»ot|t< pwnnom

,<»p j»d tueiirS punnou:

<««p i»d tuaiitl 0wn»«ui

Xrp ,
Xfp »d tuotit* punnem

Xip j>d IWOM>* pwnoawi
                                                 i
                                          i   ":'i
                                            • to
 i*0

 • to

P«O

>IOI


4>Ot
                                                                        f >"»»»»•>• A

                                                                             ,>»V>O
                                                          MI u| Xt
                                                                                       •»

-------
         /..  ' .•:>•'. f



lytten-.

Surface imoounamcni wttr> no






Facility dltcnaro « and volume
•If there arc dltchargtt to 'other.*


"***•!

ic-kcl
io»al
10»el
ICJII
.to»gt
'>**" •"•
'•loiii'l
.toil
io»ji

•tout ';
Ofml<
. •_.,—
'•-. •:*.•• o*
" :'i. -.r*
: i

i

I





1



;



10X2
10*12

JOInZ
10IIZ
IOSIZ '
01K2 ';
ouz :•


-< -i- vs,iu-nt U'vc =
i
! 2.0
i
J







2.0
'

  1 O. rirmltt, LIceriMi an* Application*
      U'^"K*
. . - - .,?„•>;
•* " " 1


Type of Permit
• or LJcente
J^*S(!(cj ~"'.iif*..






ID Number
•:.-' ''Xdix -«:-:.






Date
Hied
VR/MO/OA'
•".. i<«) • '. ' •-'






Date
Iffuad
VR/MO/OA
.',<'*#) *vr:

V




Date
Denied
. VR/MO/OA
._*' •*(« .-• '.v






Cxplratlon
Dale
VR/MO/OA
••(M •"«•






1 I,  Mapt anrf Dr*wlnf»
     Attach all required map* »nd arawlotj* to the back of thU application.(ftc« ln«lrucf*on«)
tZ. AeltfllUnal lnfa>rmatl*li
'•1 tZ Item Number




Information





-------
                                                                                                               I-'OHM AI'l'KOVED
                                                                                                               OMB No. 1SS-R0100
FOR AGENCY USE







                         STANDARD  FORM C - MANUFACTURING  AND  COMMERCIAL
                                       SECTION II. BASIC DISCHARGE DESCRIPTION
  Complete Ihis section for cJch discharge indicated in Section I,  Item 0. that is to surface waters.  This includes dischar9es to municipal sewerage
  systems in whicli the wattcwalcr does not 90 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.
  I.   Discharge Serial No. and Name
      a.  Discharge Serial No.
         (see instructions)
     b. Discharge Name
        Give name of discharge, if any.
        (see instructions)

     c. Previous Discharge 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
        is planned for some future date,
        give (he 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.

 J.   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.

            State

            County

     (if applicable) City or  Town


S.   Discharge Point Description
     Discharge is into (check one);
     (see instructions)
     Stream (includes ditches, arroyos.
    and other  intermittent watercourses)

    Lake

    Ocean

    Municipal  Sanitary Wastewater
    Transport  System

    Municipal  Combined Sanitary and
    Storm Transport  System
 20U
                                          20tb
 ZOtc
 ZOZa
 ZOZb
Z02e
20}
204«

204b

204C
205a
          001
                                                    DOMESTIC WASTEWATER TREATMENT
          VR   MO
         YR  MO
        D
                                                                               Agency Use
                 Alaska
         NANA  region
                                                              Z04d

                                                              204«
DSTR
QLKE
SOCE

OMTS
 EPA Form 7550.23 (7-73)
                                                                                                     Thin section contains 9 pajjes.

-------
                                               DISCHARGE SERIAL NUMUER
       MtiMicip.il Storm Water Transport
       System

       well (Inaction)

       Other

       l( 'oihet' is checked, specify


  C.   Discharge Point — Lit/Long  Give
       the precise location of the point
       of dlschar9« to the nearest second.

        Latitude

        Longitude


  7.   Discharge Receiving Water Name
       Name the waterway at the point
       of discharge.(see instructions)
  If the discharge is through an out-
  tall that extendt beyond the shore-
  line or is below the mean low
  water line, complete Item 8.
      Offlhore Discharge

      a.  Discharge distance (rom shore

      b.  Discharge Depth Below Water
         Sur(ace
  9.   Discharge Type and Occurrence
      a.  Type o( Discharge  Check
         whether the discharge is con-
         tinuous or Intermittent.
         (lee 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 (or routine mainte-
         nance), check the months dur-
         ing the year when the discharge
         is operating, (see instructions)

 Complete Items 10 and UK "inter-
 mittent" is checked in Item 9.1.
 Otherwise, proceed to Item  12.
 10.  Intermittent Discharge Quantity
     State the average volume per dis-
     charge occurrence in thousands o(
     gallons.


 11.  Intermittent Discharge Duration
     and Frequency

     a.  Intermittent Discharge Duration
        Per Day  State the average
        number o( 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.
 EPA Form 7550-73 (7-73)
          DSTS

          QWEL

          DOTH
FOR AGENCY USE








ZOta

ZOCb



Z07a
 201*
 XOt I
 20*t>
 ZOtC
2111
211k
              JO  MIN


164  DFd    14	MIN
                                          -SEC

                                          -SEC
                                                      For Agency Use
Major

Minor

Sub

                                   207e
                                                                                        For Agency Use
                                                    303e
            500
                      -feel
             14
                                                                .feet
       3QC(con) Continuous

       D(int) Intermittent
         —days per week
       DJAN,   QFEB   OMAR   DAPR
                  OJUN   QJUL

        )QsEP   GOCT   fl NOV    DDEC
                       .thousand gallons per discharge occurrence.
            .hours per day
            .discharge occurrences per day
        F,..mJuly  ,0 Oct
              month    month
                      n-2

-------
                                        DISCHARGE SERIAL NUMBER
                                                                                            FORM APPROVED
                                                                                            OMB No. 158-ROIOO
FOR AGENCY USE








 13.  Activity Oeicrlpllon  Give a
     narrative description of activity
     producln9 this discharge.fsee
     instructions)
ZIJi
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,  5,

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
    jmount of either 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 production.(see
    Instructions)
    a. Raw Materials
Maximum Unit Shared Dischargee
SIC Code Name Amount/Day (See Table 1) (Serial Number)
(»)





-:. -.- (2) •;• -**;.- -





: ""X - 'fSJ^ • •" -





(4)





fS>





b. Products
Maximum Unit Shared Discharges
SIC Code Name Amount/Day (See Table 1) (Serial Number)
*I4* (1)




(2)




W>




(4)




(S)




EPA Form 7SSO-23 (7-73)
                                                    II-3

-------
                                        DISCHARGE SERIAL NUMBER
FOR AGENCY USE








 IS. Wnte Abjtemtnt
    a.  Wjftc Abatement Practices
       Describe the waste abatement
       practices used on this discharge
       with a brief narrative,  (see
       Instructions)
    b. Watte Abatement Cedes
      Using the codes listed In Table
      II of the Instruction Booklet.
      describe the waste abatement
      processes for this discharge In
      the order In which they occur
      If possible.
                                  2Kb
 „,„,„„,: WASTEHATER WILL BE COLLECTED  IN  A COMMON  SURGE

TANK AND TREATED  BY EXTENDED  AERATION.   THE  SOLIDS  WILL

BE  SETTLED IN  A CLARIFIER & AEROBICALLY DIGESTED PRIOR

TO  DISPOSAL.   THE CLARIFIER OVERFLOW WILL BE DISINFECTED

AND DISCHARGED TO THE  SEA.	
                                             PEQUAL
 (4)  PSEDTM

 (7) 	

(10) 	

(13) 	

(16) 	

(19) 	

(22) 	

(25) 	
 (2)

 (5)

 (8)

(11)

(M)

(17)

(20)

(23)
                         PAERAT
 (3)



 (9)

(12)

(IS)



(21) ,

(24)
                                                                                     BACTIV
                                             SAP-ROB
EPA Form 7550-23 (7-7J)
                                                   11-4

-------
                                                 DISCHARGE SERIAL NUMBER
FORM APPROVED
OMll No. 158-R0100
FOR AGENCY USE








  1C. Wistewater Characteristics


  Check the box beside each conilltuent which It present In the effluent (discharge water).  This determination Is to be based on actual analysis
  or best estlmate.ffee Instructions)
Parameter
216
Color
00080
Ammonia
00610
Organic nitrogen
00605
Nitrate
00620
Nitrite
00615
Phosphorus
00665
Sulfate
00945
Sulfide
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
c
«.
4
cu

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
C
Si
V
£



















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 Namet (or the Ingredient Statement on
                  Pettlcide Labels. 2nd Edition, Environmental Protection Agency, Washington. D.C. 20250, June 1972, at
                  required by Subsection 162.7(b) of the Regulations for the Enforcement of the Federal Insecticide,
                  Fungicide, and Rodenticide Act.
EPA Form 7550-23 (7-73)
                                                             II-5

-------
                                                            OISCHAHGE SERIAL NUMOEH
FOR AGENCY USE








       17.  Oeicrlption of Intike and Oltch«r?e

           For each o( trie parameters listed below, enter In the appropriate box the value or code letter answer called (or.(see Instructions)

           In addition, enter the parameter name and code and all required values lor any of the following parameters If they were checked In Item 16;
           ammonia, cyanide,  aluminum, arsenic, beryllium, cadmium, chromium, copper, lead, mercury, nickel, selenium, zinc, phenols, oil and grease
           and chlorine (residual).                                                                                                              '





Parameter and Code
*5 I'T".^*
-. . f"


Flow*
Gallons per day
00056
pH
Units
00400
Temperature (winter)
°F
74028
Temperature (summer)
•F
74027
Biochemical Oxygen Demand
(BOD 5-day)
mg/l
00310
Chemical Oxygen Demand (COD)
mg/l
00340
Total Suspended (nonfilterable)
Solids
mg/l
00530
Specific Conductance
micromhos/cm at 25* C
00095
Settleable Matter (residue)
ml/1
00545
Influent

^

00

•° >
<
»- X
*> ™
lie
CD

2,250


8.2


34


42


NA



NA


NA



NA

NA


•o ^
0 u

t> ej 2
r" ^ >
~ •*• *C
c c Q
(2)

1,500


7.0


55


60


Nil



NA


NA



NA

NA

Effluent




n

<
X
13
n
0
(3)

1,500

X'



70


80


30



NA


20





0.5


« 2
3 •-
•a 5
> SQ
E *o "o **
' 5i ••* ti i*
1 1 ^ « 1
S O W Q <
(4)

500


6.5


60


70


10



NA


10



NA

0.2

X
*> c1 ~



E r> "a **
3 \* o 2*
'x S 5. J{
S o u a
(S)

2,000


7.5


75


85


50



NA


45



NA

0.75




t__

J> -

3 X
£ <
(6)
































w-

u »
^> X
E -3
3 C
Z <
(7)
































a.

u
a.
n
CO
(8)




























     'Other discharges sharing intake flow (serial numbers).(see instructions)
EPA F«m 7550-23 (7-73)
                                                                     11-6

-------
                                                                                                                FORM APPROVED
                                                                                                                OMO No. 158-R0100
                                                   DISCHARGE SERIAL NUMBER
FOR AGENCY USE









 17.  (Confd.l
Parameter and Code
?««
Arnrnonia flflfilO
Qi 1 6 Gcease OQ550 	
rhlorinp 50060




Influent
Untreated Intake
3 Water
(Daily Average)
NA
NA
NA




In-Plant Treated
3 Intake Water
(Daily Average)
NA
NA
NA




Effluent
O
00
n
0
<
JK
*«
o
(3)
5.0
LT 5.0
2.0




Minimum Value
Observed or
3 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








' ~* Number of
*•*
| *•* Analyses








'<* Sample Type







II,  Plant Contrail  Check If the fol-
     lowing plant control! are available
     for thlt discharge.
     Alternate power source for major
     pumping facility.

     Alarm or emergency procedure for
     power or equipment failure

     Complete Item 19 If discharge Is
     from cooling and/tor tteam water
     generation and water treatment
     additives are used.
I*. Water Treatment Additives  If the
    discharge Is treated with any con-
    ditioner. Inhibitor, or algiclde,
    answer the following:

    a.  Name of Materlal(t)
       Name and address of manu-
       facturer
   c.  Quantity (pounds added per
       million gallons of water treated).
2t*«
                                         2Kb
        O APS



       Q ALM
  EPA F«m 7S50-2J (7-73)
                                                                 11-7

-------
                                                    DISCHARGE SERIAL NUMBER
FOR AGENCY USE









      d.  Chemical composition of these
          additives (tee Instructions).
                                            21»d
  Complete Items 20-25 I) there Is a thermal discharge
  (e.9.. associated with a steam and/or power generation
  plant, steel  mill, petroleum refinery, or any other
  manufacturing process) and the total discharge flow is
  1 0 million gallons per day or more,   (see Instructions)
  20. Thermal Discharge Source  Check
      the appropriate Item(s) Indicating
      the source of the discharge,  (see
      instructions)

      Boiler Slowdown

      Boiler Chemical Cleaning

      Ash Pond Overflow
      Boiler Water Treatment — Evapora-
      tor Slowdown

      Oil or Coal  Fired Wants — Effluent
      from Air Pollution Control Oevlcef
      Condense Cooling Water

      Cooling Tower Slowdown
      Manufacturing Process
      Other

 21.  Discharge/Receiving Water Temper-
      ature Difference
      Give the maximum temperature
      difference between the discharge
      and receiving waters for summer
      and winter operating conditions.
                    (see Instructions)
        Summer

        Winter

 22.  Discharge Temperature. Rate of
      Change Per Hour
      Give the maximum possible rate of
      temperature change per hour of
      discharge under operating con-
      ditions,  (see Instructions)

 23.  Water Temperature. Pereentlle
      Report (Frequency of Occurrence)
      In the table below, enter the
      temperature which Is exceeded 10%
      of the year. 5% of the year. 1% of
      the year and not at all (maximum
     yearly temperature), (see  Instructions)
     Frequency of occurrence

     a.  Intake Water Temperature
        (Subject to natural changes)
     b.  Discharge Water  Temperature

24.  Water 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, (see Instructions)
                                            220
tttt
2230
«*
         OBLBD
         DBCCL
         DAPOF
         DOCFP

         DCONO
         QCTBO
         OMFPR
         DOTHR
               _°F./nour
10%
°F
°F
s%
°F
OF
1%
OF
°F
Maximum
°F
°F
              _feet/sec.


              .minutes
Ef A Fe*m 7550-23 (7-73)
                                                                II-8

-------
                                                                                                               FORM APPROVED
                                                                                                                    No.  I58-RV100
                                                     DISCHARGE SERIAL NUMQER
FOR AGENCY USE








   26.  Additional Information


226          item
                                                                      Information
EPA Form 7550-23 (7-73)
                                                               II-9
                                                                                                                     CPO tO«.OI4

-------
           ATTACHMENT F

Supplemental Corporate Information
          Cominco Alaska

-------
r
                                        of Alaska
Bcpartttttnt
of
01
nrnmcrcE
anfc
IE
conomtc
Bcuelopmcnt
11 t


                                derttftcatE
              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
                                                                        o. 19
                                                                              85
                                                 RICHARD A LYON
                                                COMMISSIONER OF COMMERCE AND
                                                    ECONOMIC DEVELOPMENT

-------
                                 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
                                      -i-

-------
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
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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.
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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
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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 sh'all  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
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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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                                                 iAi AS TO FOR;.-. AND ?:LH
                                                       SEP 27 -,255
              RESTATED ARTICLES OP INCORPORATION  A uuiDLOW  .
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     (c)  To engage In the mercantile, merchandise,  ^eal
estate, brokerage, commission, consignment,  warehouse,
rr^ufacturins and transportation business, the conduct and
cpsration of irrigation works, the caneration 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,
ar.d 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,
deeds of trust, or the pledging of collateral or the giving of
other security and upon such terms as to priority and discount,

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or otherwise as shall be thought fit and to purchase or
i-sdeen (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 maintainance, in fully
or 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
•;he 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
tsove objects, and to establish and carry on any business  or
vr.iar taking permissable under the law which may seem calculated
•0 enhance the value of any of the property or rights of this
company or to facilitate the disposition thereof  and to
er.gc.3e in any and all kinds of business that a natural person
might or could engage In and to engage In such business as the
Hoard 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  ($35,000,030.00)
     divided into:
    «       (i)  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;

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     (ii)  Two million eight hundred thousand (2,800,000)
           shares of six percent (6£) non-voting r.on-
           cumulative redeemable participating preferred
           shares of the par value  of Ten Dollars ($10.00)
           each (hereinafter called the  "preferred shares")
           having attached thereto  the rights, restrictIor.s,
           conditions 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 (656) per annum on the amounts from time
 to time paid up thereon.  The board of  directors shall
 be entitled from time to time 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 par?
 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 sum
 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.

 k.  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.


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6.  in any case of redemption of preferred shares uncle:-
the provisions of clause 5 hereof, this corporation shc.il
at least twenty (20) days before the date specified for
redemption mall to each person who at the date of nailins
is a. registered holder of preferred shares to be redeemed
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 if
part only of the shares held by the person to whoa 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 such 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
this corporation.  From 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 nada
upon presentation of certificates in accordance with 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.
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     7.  The holders of the preferred shares shall i-.ot have
     any voting rights for the election of directors r.or,
     wlthour limiting generality, for any other purpoce; no.-
     shall they be entitled to attend shareholders' .T.ee-cinsc.

     8.  In the event of the liquidation or dissolution of
     t:ii3 corporation or any other distribution of ics c.~set=
     ar.ons the shareholders, the holders of the preferred
     shares shall.be entitled to receive the par value of
     their holdings in priority to any distribution so she
     holders of the common shares or any shares of any o'cher
     cl.-xss ranking Junior to the preferred shares, but the
     he-cars of the preferred shares shall not be entitled to
     share any further in th3 distribution of assets.

                              IV.

     The duration of this Corporation shall not be limited to

ar.y number of years, but shall be P2RP2TUAL.

                               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 cf meeting, and powers ar.d

du-ies of the Directors shall be such as are prescribed by the

Sy-laws of the corporation.  The names and addresses of the

^tractors in office at the time of the adoption of these

?;i5i;at5d Articles are.-

          R. Hendricks
          Room 3100
          630 Dorchester Boulevard West
          Montreal 2, Quebec, Canada

          P. 2. Burnet
          2ast 1224 - 2?th Avenue
          Spokane, Washington

          J. C. MacLean
          818 Riverside Avenue
          Spokane, Washington

          H. T. Fargey
          Room 3100
          630 Dorchester Boulevr.rd west
          Montreal 2, Quebec, Canada


                              -6-

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          A.  o.  woif-f
          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
be located at the city of Spokane, in the County of Spokane,
and state of Washington.
     IN WITNESS WHEREOF, we have set our hands and seals under
tl-.ese presents this   IH&   day of September, 1965.
                              T.'S^ Burnet;"' president
                           ATTEST :
                                  --- _
                                    {  25
                               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 tr.e date of the Restated Articles, and
     (c)  That tl-.3 Restated Articles supersede and take the
pl^cc of theretofore existing Articles of Incorporation and
;_T.er.d.T.ents thereto.
                                        F7E. Burnet
                                        J-. IX. Rae
SUBSCRIBED AKD SWORN to before  me this
    , 1965.
                                                       cay  of
                            Notary Public in and for the  stare
                            of Washington, residing at Spokane
                               -8-

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                   DEPARTMENT OF THE ARMY
                    ALASKA DISTRICT. CORPS OF ENGINEERS
                                POUCH 898
                           ANCHORAGE. ALASKA 99506

                            8 February 1984
      ATTBHTION OFl
Regulatory Functions Branch
Special Actions Section
Mr. Harry Noah
Cominco Alaska
5660 B Street
Anchorage, Alaska

Dear Mr. Noah:
99502
     This  letter  is   in  regards  to your  Title  XI
transportation   system  (Q71-OYD-2-830359,    Chukchi
Department of  the Army (DA)  permit  application for
the mine site (071-OYD-4-840012, Chukchi Sea 11).
                                    application for  the
                                    Sea   9)   ?.nd   your
                                  certain  activities at
     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 iH 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 00
                                                    EISJ404
                                                    IPMWIW

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            U.S.  ENVIRONMENTAL  PROTECTION  AGENCY

                                 REGION  X

          '•^                   1200  SIXTH AVENUE

s TOK^ 1              SEATTLE, WASHINGTON 98101
   ATTNY0°  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,
   Rogdr K. Mochnick, Chief
   Water Permits Section

   cc:  Ron Kreizenbeck, AOO (Juneau)
        Floyd Sharrock, NPS

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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

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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,
Re
Alaska Region

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	Appendix 7
Cultural Resources Protection

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  Advisory
  Council On
  Historic
  Preservation
  The Old Post Office Building
  1100 Pennsylvania Avenue, NW, #809
  Washington, DC 20004
  January 26,  1984
  Mr. Floyd Sharrock                                      '   7     -
  National Park Service                                   '   ;	—
  2525 Gambell                                            	:~~	
  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
            f''     /
                          ;
  '.Thomas F/ King,  Director
^-'Office of Cultural "Resource  Preservation

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DEPARTMENT OF NATITRAL

             DIVISION OF PARKS AND OUTDOOR RECREATION

     January  30,  1984

     File:  3130-1  (NPS)
                                                            BILL SHEFFIELD, GOVERNOR
                                                       225A CORDOVA STREET
                                                       ANCHORAGE ALASKA 99501
                                                       PHONE (907) 2762653
     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
Red Dog Mining Project.
                                Environmental  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~^1^0 if there are  any questions.

     Sincerely,

     Nei1 C.  Johannsen
     Director
                 i Hi plane
          State Historic Preservation Officer

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